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The documents from the FOAA show that, if one understands the widespread presence of asbestos as a kind of industrial disaster which overextends the state’s economic resources, then the state’s handling of asbestos risk assessment and remediation is very much a kind of lazy triage, in which looming problems are neglected until they rise to the rank of emergency.

This approach operates at the expense of the building’s permanent workers, its maintenance workers, and the public. What follows is a set of examples which substantiate the claim that the approach to asbestos maintenance in the Cultural Building has been on a problem-specific and emergency basis-level.

(1)(a): In May of 2001, an abatement project was undertaken in the basement custodial closet because debris from spray-on asbestos fireproofing had “fallen onto custodial supplies and equipment.”21

(1)(b): In April of 2002, a BGS staff member was sent to the cultural building to replace steam valves on the 5th floor. His activities caused asbestos containing debris to dislodge from the ceiling of an administrative office on the 4th floor and fall near to where two women were working. During BGS maintenance work a water leak also spouted from a 4th floor office ceiling which was traced back to room 515 — a room which had undergone extensive asbestos abatement within the last couple of months.22

(1)(c): In May of 2004, it was reported that asbestos containing mudded fittings had been “dislodged by a mechanical contractor performing work on one of the coils in the air handling unit located in the mechanical room of the Cultural Building.” Air conveyance systems had to be shut down to ensure that fibers didn’t get picked up into circulation around the building. The event was considered a “major fiber release episode.”23

(2)(a): On July 7th, 2003, an emergency abatement was undertaken because a leak was discovered from a water line under the Cultural Building’s 4th floor laboratory fume hood and a panel of asbestos-containing transite was preventing the plumber from accessing it.24

(2)(b): On May 1st, 2007, it was found necessary to abate asbestos-containing fireproofing from the 2nd floor archives in order to grant a plumber access to a drain pipe for removal.25

In Early June of 2001, abatement began on the second floor of the Cultural Building (the library), which purpose was twofold to “eliminate the potential release of airborne fibers that may be occurring as the result of supply air flow eroding asbestos decorative ceiling paint”26 and also because the cement blocks of the honeycomb ceiling hosting the paint appeared to be badly cracked.27 28

In examples (1)(a)-(c), abatement occurred because the asbestos in the building had already gotten out of control and posed an immediate threat to workers, be they (a) administrative (b) custodial or (c) maintenance workers. The workers who discovered or dislodged the asbestos faced a serious risk of exposure; it is only a combination of their good judgement and sheer luck that the situation could be promptly contained and that the exposure was, hopefully, not acute. Needless to say, no employee should be put in a high-risk situation without proper training and consent; the physical and psychological traumas linked to asbestos exposure are too severe to take chances.29 These examples speak to the need for a more proactive approach, one which does not assume that freak incidents will have mild consequences.

In examples (2)(a)-(b), an urgent need for building maintenance brought about the asbestos removal. There are a few separate concerns here. The first is that a maintenance worker might be the one that discovers an asbestos-containing obstacle to the assignment at hand, and there is the issue of whether that worker consents to the risk and, if so, is properly equipped to recognize and safely avoid it. Certainly this should not be taken for granted, as seen in (1)(a).

Another issue embodied in examples (1)-(2) is that these are problem-specific, ad-hoc emergency abatements, and as such they often do not address the root of the problem or are not intentionally designed. As in (3)(b), where the 2nd floor archives have featured asbestos hazards repeatedly over the years, these band-aid fixes keep exhaust financial and attention resources and keep the building’s asbestos illness always in limbo between remission and paroxysm.

Building deterioration necessitated the abatement in example (3). The potential consequences of asbestos entering the airstream through paint erosion and ceiling fracture are of concern not just to workers but also the general public who visit the Cultural Building’s state library and museum. The approach of waiting to abate until visible signs of structural damage manifest is an invitation to danger.


20 E.g. a May 13, 2015 memo from Larry Mare to BGS Director Edward Dahl and Special Projects Director Jill Instasi on the subject of the asbestos in the Cultural Building Archives.

21 NTC Job #5415-2001, Project Report

22 NTC Job #5886-2002, Field Notes, Project Report, Floor Plan

23 Bates Environmental Health & Safety, Inc., “Re: Response Action due to Asbestos Pipe Fitting Insulation Damage in the Cultural Building,” May 25, 2004; AmeriSci Job No. 504051159

24 NTC Job #7309-2003. Project Report and Asbestos Project Notification, Form N

25 Form 30 Construction Proposal and Contract. Project: Asbestos Abatement of Sprayed on Fireproofing; Department, Agency: B.G.S.; Location: 2nd Level Archives, Cultural Building; Appropriation No.: MGFA 2005 B.8

26 NTC Job #4993-2001, Project Report

27 NTC Job #4993-2001, Visual inspection of Asbestos Abatement Work Area, 06/02/01

28 According to a notice of demolition and renovation from the FOAA between the BGS, Abatement Professionals (contact: Robert W. Rickett, Jr.), and Northeast Test Consultants (contact: Jim Guzelian), Another large-scale independent emergency asbestos renovation on the third floor was also wrapping up on 06/15/03

29 Bonafede, M, Ghelli, M, Corfiati, M, et al. The psychological distress and care needs of mesothelioma patients and asbestos-exposed subjects: A systematic review of published studies. Am J Ind Med. 2018; 61: 400– 412.