The Three Schools: Who Was Exposed

ACCEL Schools Ohio LLC ran three public charter schools in northeastern Ohio inside buildings old enough to be riddled with pre-ban lead paint and asbestos construction materials. The children attending these schools ranged from kindergarten age to 14.

• Youngstown Academy of Excellence at 1408 Rigby Street, Youngstown, Ohio 44506: approximately 212 students, kindergarten through 8th grade. The building is owned by GSP Rigby Street LLC. The school is operated by ACCEL Schools Akron FB LLC, a subsidiary of ACCEL Schools Ohio LLC.
• STEAM Academy of Warren at 261 Elm Road, Warren, Ohio 44483: approximately 342 students, early kindergarten through 8th grade. Building owned by GSP Elm Road LLC. Operated directly by ACCEL Schools Ohio LLC.
• Niles Preparatory Academy at 45 S. Chestnut Avenue, Niles, Ohio 44446: approximately 146 students, early kindergarten through 8th grade. Building owned by GSP Chestnut Street LLC. Operated directly by ACCEL Schools Ohio LLC.
• All three buildings were constructed prior to 1978. This is the legal threshold that triggers federal lead paint rules precisely because pre-1978 construction routinely used lead-based paint. Any responsible school operator inherits the obligation to inspect, document, and manage these hazards.
• Total student population across the three schools: approximately 700 children, the youngest of whom were in early kindergarten programs.

What the EPA Found Room by Room

Federal inspectors visited all three schools in April 2024. What they documented across two days is a systematic pattern of hazardous conditions inside spaces where children and staff were present daily.

Youngstown Academy of Excellence

• Peeling lead paint on walls and ceilings, particularly concentrated near windows in storage rooms and classrooms. The paint was actively deteriorating, not a theoretical future risk.
• Suspected asbestos-containing material observed on walls and on the back of a whiteboard used to store school supplies. This is a contact surface in a school setting.
• Deteriorating ceiling tiles potentially containing friable asbestos. Friable asbestos is material that can be crumbled by hand pressure; when that happens, microscopic fibers become airborne.
• Evidence of prior repair attempts on ceiling tiles that appeared to involve asbestos-containing material. These repairs were conducted on a floor used for storage, apparently without proper procedures.
• Damaged suspect pipe thermal system insulation (TSI) and prior repair attempts to that insulation. Disturbing asbestos pipe insulation without containment and proper abatement procedures releases fibers.

STEAM Academy of Warren

• Peeling suspected lead paint on the ceiling in hallways adjacent to the gymnasium, areas students actively use and walk through every school day.
• Deteriorating ceiling material potentially containing asbestos in those same hallways.
• Peeling lead paint from walls and ceilings in storage rooms, with lead paint chips and dust visibly accumulating on the floor and on furniture stored there.
• Lead paint debris collecting on desks, tables, and chairs stored in accessible rooms that were described as furniture that “eventually may be used in active classrooms.” This furniture was contaminated with lead dust and was being cycled back into use.
• Suspected lead paint collected in a bucket in a storage room accessible to staff. Someone gathered this material; the question is whether they understood what it was and what proper disposal requires.
• Ceiling material potentially containing asbestos collected on a table in a storage room accessible to staff.
• Peeling suspected lead paint from walls and ceilings near windows in a classroom currently in use by students and staff. This is the most direct exposure point.
• Damaged pipe TSI and prior repair attempts on that insulation, same pattern as Youngstown.
• Two older boiler casings and a suspect asbestos gasket removed from the boiler system. One gasket was damaged. The other was described as “significantly damaged.”

Niles Preparatory Academy

• Inspected on April 3, 2024. EPA inspectors evaluated the building for both suspected lead-based paint and suspected asbestos-containing material under the same criteria applied at Youngstown and Warren.
• North American Environmental Services, Inc. was separately retained by ACCEL to conduct AHERA inspections at Warren and Niles following the initial Youngstown inspection during which they were already on-site.

The Missing Records: The Violation That Preceded All Others

• During inspections, EPA inspectors requested asbestos management plans, inspection reports, and other records required to be maintained under the Asbestos Hazard Emergency Response Act (AHERA). ACCEL could not provide this documentation on-site.
• Upon follow-up, ACCEL confirmed that no asbestos management plans, inspection reports, or other records required by AHERA existed for any of the three schools. These are not discretionary records. AHERA has required them for schools since 1987.
• The absence of these records means ACCEL either never had the buildings properly inspected at the time it assumed operations, or the records were lost and never replaced. Neither scenario is acceptable for a school operator.

The Anatomy of Asbestos at These Schools

The third-party AHERA inspection at Youngstown conducted by North American Environmental Services, Inc. on April 3, 2024, identified asbestos in six specific material categories throughout the school building.

The Non-Financial Ledger

There is a desk somewhere in the Warren school. Maybe two desks. Tables. Chairs. They were in a storage room, pulled out of classrooms at some point for some reason, stacked against a wall while teachers reorganized or the room got a new coat of paint or somebody decided the layout needed to change. While those desks sat in storage, peeling paint from the ceiling and walls drifted down. Lead paint. The kind that was everywhere in schools built before 1978. It settled on the surfaces. On the places where kids put their arms. Their hands. Their faces when they get tired in the afternoon and lean forward and rest their head on the desk.

EPA inspectors saw this. They documented it. They wrote in federal legal language that suspected lead-based paint was “collecting on desks, tables, and chairs stored there that eventually may be used in active classrooms.” That phrase, “eventually may be used in active classrooms,” is bureaucratic. What it means is: someone was going to move those desks back. Maybe next semester. Maybe next year. When the class grew, or a new teacher needed furniture, those contaminated surfaces were going back into rooms full of children.

This is the thing that gets lost in the regulatory documents. Lead does not look like anything. It does not smell. A child who presses their hands on a contaminated desk and then rubs their eyes, or chews a pencil, or eats a snack without washing their hands first, has been poisoned. They will not know it. Their parents will not know it. Their teacher will not know it. The exposure is invisible and cumulative. The damage shows up later, in ways that get misread as something else: difficulty concentrating, behavior problems, a slower reading pace, a lower test score. Things that in low-income school districts get explained away by a hundred other factors. Nobody draws a line back to the desk.

The children in these three schools in Youngstown, Warren, and Niles are not wealthy children. These are public charter schools in northeastern Ohio cities that have been economically dismantled for decades. The families who send their kids to these schools are not choosing between this school and a well-funded suburban school with updated buildings. They are making the best of what is available. They trusted that the people operating the school, the company paid to run it, had done the basic legal minimum to make the building safe.

ACCEL had not done that minimum. No asbestos management plan. No AHERA inspection records. No documentation of any kind. Not for Youngstown. Not for Warren. Not for Niles. For a company operating schools in pre-1978 buildings, this is not a paperwork lapse. The whole point of the AHERA recordkeeping requirement is to ensure that someone has actually looked, has actually measured, has actually documented where the asbestos is and what condition it is in. Without that documentation, nobody knows. Without that knowledge, a maintenance worker replaces a ceiling tile without knowing it contains amosite asbestos. A janitor sweeps up debris from a damaged pipe without knowing it is thermal system insulation. Every act of ordinary building maintenance becomes a potential exposure event.

A citizen filed a complaint on March 8, 2024. One person, in Youngstown, picking up the phone or filling out a form because they saw something that scared them. That complaint is the reason EPA showed up. Without that citizen, those buildings would still be running without management plans. The system did not catch this. A person did.

Legal Receipts: What the Order Actually Says

These are verbatim quotes from the EPA’s Administrative Order on Consent, Docket No. RCRA-05-2024-0019, signed June 28, 2024. The document is a federal enforcement order.

“At Warren, EPA inspectors observed suspected lead-based paint peeling from the walls and ceiling and collecting on the floor of storage rooms accessible to staff, as well as collecting on desks, tables, and chairs stored there that eventually may be used in active classrooms.”

• This proves contaminated furniture was in the pipeline to re-enter classrooms. The exposure was not hypothetical or confined to a sealed-off zone; it was one logistics decision away from direct daily student contact.
• The phrase “accessible to staff” confirms these were not locked, restricted hazmat areas. People were moving through these rooms regularly.

“At the Schools, EPA inspectors requested asbestos management plans, inspection reports, or other records required to be maintained under AHERA, but ACCEL could not provide this documentation… ACCEL’s representative confirmed that no asbestos management plans, inspection reports, or other records required to be maintained under AHERA exist for the Schools.”

• This is a direct admission from ACCEL’s own representative. Not a contested allegation. ACCEL confirmed in its own words that no AHERA-required records existed for any of the three schools.
• AHERA has been federal law since 1987. Any company that takes over operations of a pre-1978 school building is legally obligated to have these inspections conducted and records maintained. This violation predates any specific peeling paint or damaged pipe observed in April 2024.

“At Youngstown, EPA inspectors observed repairs which appeared to be an attempt to replace suspected asbestos-containing ceiling tile from a classroom on a floor of the building used for storage.”

• This documents that someone attempted to repair or replace ceiling tiles that contained or were suspected of containing asbestos, without following proper abatement procedures. Disturbing asbestos-containing material without containment releases fibers into the air.
• Combined with the absence of any AHERA records, this suggests the person doing the repair may not have known they were dealing with asbestos, precisely because no management plan existed to tell them.

“Based on the information described above, EPA has determined that present conditions at the Schools may present an imminent and substantial endangerment to health or the environment within the meaning of Section 7003(a) of RCRA.”

• “Imminent and substantial endangerment” is the legal standard EPA must meet to use Section 7003 of RCRA. This is a high bar. EPA does not deploy this authority casually; it triggers significant enforcement machinery including the right to sue in federal district court.
• This determination means EPA’s professional inspectors looked at what was in these school buildings and concluded children and staff faced a real, present risk of harm, serious enough to justify emergency legal action.

“Exposure to asbestos can cause various lung diseases, including lung cancer, mesothelioma, and asbestosis… Lead has been classified as a probable human carcinogen by the United States Environmental Protection Agency and a possible human carcinogen by the International Agency for Research on Cancer.”

• EPA included these health effects directly in the legal order as factual findings. These are not background statistics; they are the documented consequences of the conditions the order was issued to address.
• Mesothelioma is a cancer with no known cure and a median survival time after diagnosis measured in months. It can take 20 to 50 years to develop after exposure. A kindergartener exposed in 2023 may not see a diagnosis until 2043 to 2073. The harm from these conditions will be invisible for decades.

“Exposure to lead in children can cause learning disabilities, reduced intelligence, behavioral problems, growth impairment, permanent hearing and visual impairment, and other damage to the brain and nervous system… Children’s heightened risk level is due not only to children’s normal hand-to-mouth behavior which increases their exposure to lead by ingestion, but also children’s increased physiological ability to ingest lead into their bodies.”

• Federal regulators are explicitly saying, inside a legal order about these specific schools, that the lead hazards found here can cause permanent cognitive damage to children. This is not a study cited in passing; it is a factual finding incorporated into an enforceable federal order.
• The hand-to-mouth behavior referenced is not carelessness; it is developmentally normal behavior for young children. Kindergarteners and early elementary students touch everything and frequently put their hands near their mouths. Placing these children in buildings with deteriorating lead paint is placing them in a biochemical trap designed exactly for their developmental stage.

How the Timeline Unfolded: From Complaint to Federal Order

The sequence of events from the first citizen complaint to the signed federal order took less than four months. What the timeline reveals is how long these buildings may have operated without proper compliance, and how quickly the situation escalated once a single person spoke up.

What ACCEL Was Supposed to Do vs. What It Did

Federal law under AHERA has required asbestos inspections and management plans for pre-1978 school buildings since 1987. The gap between what ACCEL was legally required to do and what it actually did is the foundation of this entire enforcement action.

Societal Impact Mapping

Public Health: Who Bears the Damage

The health consequences documented in the EPA order fall hardest on the youngest and most physiologically vulnerable population: children in early childhood education. The order itself enumerates these harms as factual findings, not background context.

• Lead exposure in children causes learning disabilities, reduced intelligence, behavioral problems, growth impairment, and permanent hearing and visual impairment. The EPA’s own factual findings in this order state that these outcomes result specifically from exposure at the developmental stage of the children attending these schools.
• Children under the age of six face the highest lead exposure risk. Early kindergarten programs at STEAM Academy of Warren and Niles Preparatory Academy were enrolling children at exactly this age threshold into buildings with deteriorating lead paint in active classrooms.
• Children’s normal hand-to-mouth behavior is specifically cited in the order as a mechanism of ingestion. Lead paint chips and dust on desks, floors, and furniture are ingestion hazards for this age group. This is not speculative; it is the documented pathway by which young children are poisoned by lead dust.
• The CDC has identified lead dust as a major exposure pathway, particularly for young children. Peeling paint on hallway ceilings and classroom walls is a continuous source of lead dust as paint chips fall and fragment.
• Lead exposure in adults causes memory and concentration problems, hypertension, cardiovascular disease, and damage to the male reproductive system. Staff members, including teachers and maintenance workers, were exposed alongside students in these buildings.
• Asbestos exposure causes lung cancer, mesothelioma, and asbestosis. Mesothelioma has a latency period of 20 to 50 years. Children exposed in these schools during the 2023-2024 school year may not develop symptoms until the 2040s through 2070s, a health debt that will not appear in any current tally of harm.
• Attempts to repair asbestos-containing pipe insulation and ceiling tiles without proper procedures created acute airborne fiber release events. Anyone in the building during these uncontrolled disturbances faced immediate inhalation exposure.

Economic Inequality: The Geography of Harm

These three schools are in Youngstown, Warren, and Niles, Ohio, cities in the northeastern corner of the state that have been systematically economically stripped by deindustrialization. The families whose children attend public charter schools in these communities face specific and compounded vulnerabilities.

• Charter school families in economically disadvantaged communities have fewer educational alternatives. The power to choose a different school, to withdraw a child from a hazardous building and enroll them somewhere safer, is not equally distributed. Families with means can act on information. Families without means often cannot.
• Lead poisoning produces cognitive effects that disproportionately suppress academic outcomes in children who are already navigating under-resourced school environments. The harm compounds existing disadvantage; it does not occur in isolation from it.
• ACCEL Schools Ohio LLC is a private company operating public charter schools. This structure extracts public education funding into a private management layer. The company collected per-pupil public funding for each of the approximately 700 students in these three schools while those students sat in buildings with no AHERA compliance records and deteriorating toxic materials on the walls and ceilings around them.
• Families were not notified of the hazards before EPA compelled it. The order required ACCEL to notify parents by email and through each school’s public website within 24 hours of receiving assessment reports; this notification structure did not exist before federal enforcement created it.
• The stipulated penalty for non-compliance with this order is $2,000 per day per violation. Maximum civil penalty for outright non-compliance is $18,139 per day. These figures are enforcement tools, but they are also a measure of how far corporate cost-benefit calculations had run before a federal order intervened.
• ACCEL waived its right to judicial review of the order as part of the consent process. This is standard procedure, but it means the company agreed to every finding in this document: the conditions, the hazards, the failure to maintain required records, and the determination of imminent and substantial endangerment.

The “Cost of a Life” Metric

Relationship Map: Who Operates What and Who Owns What

The corporate structure between ACCEL and the building owners is worth examining. The schools are operated by ACCEL entities, but the buildings are owned by separate LLCs with GSP in their names. The EPA order binds ACCEL and its subsidiaries, not the building-owning LLCs.

What Now?: Who to Contact and How to Push Back

The EPA order requires ACCEL to complete abatement and submit to ongoing inspections through 2029. The order does not require financial penalties paid to affected families. The regulatory process is underway; community pressure and organized oversight are what keep it honest.

Key Named Figures in the Order

• Ronald J. Packard, Chief Executive Officer of ACCEL Schools Ohio LLC. He co-signed the consent order on June 28, 2024.
• Michael D. Harris, Division Director, Enforcement and Compliance Assurance Division, EPA Region 5. Signed the order for EPA.

Watchlist: Regulatory Bodies with Jurisdiction

• U.S. EPA Region 5: Primary enforcement authority. The order is active through at least 2029 with annual lead inspections required. Contact Michael Todd, Enforcement Officer, at todd.michael@epa.gov or (312) 886-4843.
• Ohio EPA: Received the original citizen complaint on March 8, 2024, and notified federal EPA on March 11. Ohio EPA has concurrent oversight authority for asbestos in schools under Ohio state regulations.
• Ohio Department of Health: The abatement plans under this order must be submitted to the Ohio Department of Health for approval alongside EPA. Lead abatement results must also be submitted there.
• EPA Office of Inspector General: If you believe ACCEL is not complying with the terms of this order, a complaint can be submitted to the EPA OIG directly.

What You Can Do

• Request the AOC and all inspection reports. Under the terms of this order, ACCEL must make the AOC available to parents and staff upon request. Ask for it in writing from each school’s administrative office. The order also requires ACCEL to make Asbestos Management Plans available without cost or restriction once they are completed.
• Check the EPA’s administrative record. The full record is publicly available at https://www.epa.gov/oh/accel-charter-schools. This includes all submissions ACCEL makes under this order, including abatement plans, clearance sampling results, and weekly progress reports.
• Organize with other parents at these schools. The community relations section of this order requires ACCEL to cooperate with EPA in providing information to the public and to participate in public meetings EPA may convene. Request a public meeting through EPA Region 5. Collective requests carry more weight than individual ones.
• Connect with local environmental justice organizations working in Youngstown, Warren, and the Mahoning Valley. Environmental justice groups have experience tracking corporate compliance with EPA orders and applying public pressure when companies drag their feet.
• If your child attended any of these schools during the 2023-2024 school year or earlier, speak with a pediatrician about blood lead level testing. The CDC has guidance on when testing is warranted for children in environments with identified lead hazards.
• Contact your Ohio state legislators about charter school accountability and building safety standards. Charter school operators in Ohio receive public per-pupil funding. Public funding must carry public accountability, including mandatory, publicly reported AHERA compliance records before a company is permitted to operate a school in a pre-1978 building.