Questions on AHERA

Questions on AHERA
NOTE: This document was scanned from the
original and has been carefully checked for
errors. Formatting was changed slightly to
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Therefore there are some blank pages that are
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This is a collection of questions commonly asked about the new Asbestos-Containing
materials in Schools rule, promulgated by the U.S. Environmental Protection Agency in October
1987 under the Asbestos Hazard Emergency Response Act (AHERA) of 1986.
Many questions are answered directly and completely, as they are clearly addressed by
provisions of the rule. Other questions, however, must be answered more generally, for the
Agency's response to the question may change depending upon the specific circumstances in a
particular school. Schools, of course, may also be subject to State or local asbestos management
and abatement requirements, not reflected in this document.
This "100 Commonly Asked Questions" document is offered as a guide to help school
officials, training providers and accredited persons better understand the new AHERA schools
rule. If you have further questions, please contact the EPA Regional Asbestos Coordinator who
serves your area or call the EPA Toxics Hotline in Washington, D.C., at 202/554-1404.
Office of Toxic Substances
Office of Pesticides and Toxic Substances
U.S. Environmental Protection Agency
Washington, D.C. 20460
May 1988
100 Commonly Asked Questions About the New
AHERA Asbestos-in-Schools Rule
Table of Contents
Effective Dates
Buildings Covered by the Rule
General LEA Responsibilities
Inspections, Reinspections, and Periodic Surveillance
Response Actions
Operations and Maintenance (O&M)
Custodial and Maintenance Worker Training
Management Plans
TEM, PCM, Sampling and Analysis
Warning Labels
XIV. Transport and Disposal
State Waivers
XVI. Miscellaneous
Asbestos-containing Building Materials
Asbestos-containing Materials
Asbestos Hazard Emergency Response Act
Local Education Agency
NESHAP National Emission Standards for Hazardous Air Pollutants
Operations and Maintenance
Phase Contrast Microscopy
Transmission Electron Microscopy
Questions 1-7
On what date does each of the following requirements become
the management plan
specific O&M work practices
O & M training
periodic surveillance
warning labels
selection of an LEA's Designated Person
management plan availability for public review
The Management Plan--The effective date of the
management plan is the date on which the LEA begins to
implement its plan. According to AHERA § 203(i), this can be no
later than July 9, 1989.
O&M Work Practices--After December 14, 1987,
LEAs must abide by the operations and maintenance requirements
in § 763.91, whenever any of these activities need to be performed.
O &M Training--(i) The 14-hour training requirement (see
section 763.92(a)(2)) is for specific members of the custodial and
maintenance staff who conduct activities that may disturb ACBM.
After December 14, 1987, only custodial and maintenance staff
who have had the 14-hour training are permitted to conduct such
(ii)--The effective date for the 2-hour general awareness training is
defined in the rule. Section 763.92 (a)(1) states that the LEA shall
ensure, prior to the implementation of the operations and
maintenance provisions of the management plan_(emphasis
added), that all members of its maintenance and custodial staff
who may work in a building that contains ACBM receive
awareness training of at least 2 hours." As outlined in the rule,
therefore, all members of the custodial and maintenance staff must
have awareness training on or before July 9, 1989.
Periodic Surveillance--In § 763.92(b)(1), the rule states that
"... at least once every 6 months-after a management plan is in
effect, each LEA shall conduct periodic surveillance…” in its
buildings. Thus if a management plan was put into effect on July
9, 1989, for example, the LEA would have to conduct its first
periodic surveillance by January 9, 1990.
Warning Labels--Section 763.95(a) states that the LEA "...
shall attach a warning label immediately adjacent to any friable
and nonfriable ..." ACBM found in routine maintenance areas. As
a result, if ACBM is identified in routine maintenance areas, the
material must be labeled as soon as possible thereafter. (For
material identified under the 1982 rule, these materials should have
been labeled as of December 14, 1987.) After the results of the
inspections conducted pursuant to the 1987 schools rule are
known, all ACBM identified in routine maintenance areas must be
Selection of an LEA's Designated Person--Section763.84
requires that LEAs designate a person to ensure that the actions of
persons who conduct a variety of activities, including O&M,
inspections and response actions, are carried out in accordance
with the rule. As a result, LEAs must select a Designated Person
as soon as possible to ensure these activities are done properly.
Management Plan Availability for Public Review--
Section 763.93(g)(1) states that "... upon submission of a
management plan to the Governor for review, a local education
agency shall keep a copy of the plan in its administrative office."
This means that the LEA must have the plan available for public
review (including parents and staff) in its administrative office on
the day on which it is submitted. Each individual school shall have
a copy of the school’s plan available on the same day.
Question 8:
When must LEAs take certain response actions for areas of
significantly damaged surfacing ACM and damaged or
significantly damaged thermal system insulation ACM?
Several conditions listed in § 763.90 necessitate a quick response.
For example, a room with significantly damaged friable surfacing
ACM must be immediately isolated and access to it restricted, if
these measures are needed to protect human health and the
environment. In addition, damaged or significantly damaged
thermal system insulation must be at least repaired and then
maintained by the LEA in an intact state and undamaged condition.
As a result, as soon as a management planner and LEA determine
that these conditions exist, the LEA must initiate steps to take
action. The LEA cannot wait until July 9, 1989 to address these
Question 9:
The AHERA statute requires schools to begin implementing the
management plan by July 9, 1989. Exactly what must be begun by
this date?
July 9, 1989, is the latest date on which any LEA can begin to
implement its management plan. The formal operations and
maintenance plan designed for a particular school (for example, a
routine cleaning schedule for that school), and the response action
schedule with completion dates, must be implemented no later than
July 9, 1989. A schedule for an abatement project, for example,
will become effective on July 9, 1989, even though the project is
not scheduled until later. In addition, the July 9, 1989, date is the
latest date on which schools can begin their periodic surveillance
and reinspection intervals. In other words, periodic surveillance
must be performed within 6 months of July 9 if a school
to implement its management plan on this date.
Question 10:
A school district leases space from a nonschool group (corporation,
YMCA, etc.). Who is responsible, the school district or the
landlord for complying with the AHERA rule?
The LEA is responsible for complying with the rule. There are
several references to school buildings under the authority of an
LEA in AHERA (see sections 203(b),(c),(d), (e),(f) and (i)). This
phrase clearly covers buildings owned by the LEA. It also
includes buildings leased by LEAS since LEAS control access to
these buildings, how these buildings are used by occupants (e.g.,
classes in certain rooms, administrative offices in others), the
furnishings within the buildings, and the scheduling of schoolrelated activities. As a result, an LEA which leases a school
building exercises authority with respect to the use of the building
as a school. Section 763.85(a) of the rule states that leased school
buildings are covered and that the LEA is responsible.
Question 11:
If an LEA owns a building but does not currently use it as a school,
must it be inspected by October 12, 1988? (For example, what if
changes in school population have forced a school district to close
a school and to rent the building out to a religious group for
The LEA doesn't have to inspect such a building by October 12,
1988. However, § 763.85(a)(1) indicates that LEAs shall inspect
each school building that they lease, own, or otherwise use. As a
result, before an LEA decides to use a building already leased or
owned as a school building, the LEA must first inspect the
In addition, § 763.93(a)(3) states, "If a local education
agency begins to use a building as a school after October 12, 1988,
the local education agency shall submit a management plan for the
school [to the State] prior to its use as a school."
Question 12:
If an LEA obtains a building in April of 1990, for example, how
soon must the LEA inspect it?
Section 763.85(a)(2) addresses this issue. "Any building leased or
acquired on or after October 12, 1988, that is to be used as a school
building, shall be inspected as described in (a)(3) and (4) of this
section prior to its use as a school building."
Question 13:
A school building burns down. An LEA wants to use a local
community center for 6 months due to the emergency. Does this
temporary school building have to be inspected?
Section 763.85(a)(2) states that, "In the event that emergency use
of an uninspected building as a school building is necessitated,
such buildings shall be inspected within 30 days after
commencement of such use."
Question 14:
Will for profit schools be required to comply with the EPA rule?
No. Section 202(7) of AHERA specifically refers only to nonprofit schools. As a result, schools operated on a for profit basis
are not covered.
Question 15:
Are State-run schools (e.g., prison schools, schools for the
handicapped, etc.) covered by AHERA?
That usually depends on State law. AHERA section 202 states that
"... the term 'school' means any elementary or secondary school as
defined in section 198 of the Elementary and Secondary Education
Act of 1965 (20 U.S.C. 2854)." The definition to which this refers
states: "the term 'elementary school' means a day or residential
school which provides elementary education, as determined under
State law, and the term secondary school means a day or
residential school which provides secondary education, as
determined under State law, except that it does not include any
education provided beyond grade 12..." (20 U.S.C. 2854) Thus,
individual State law addresses whether a State-run school is
covered as an elementary or secondary school.
Question 16:
Several high school students take advanced placement classes with
college freshmen at the State University. Does a classroom or
building that these students frequent have to be inspected?
No. AHERA § 203 refers to school buildings under the authority of
an LEA. These classrooms are not under an LEA’s authority, and
therefore are not covered.
Question 17:
Each year the local high school has its annual play at a local
Community center. Rehearsals and the actual shows run for over 2
months. Is this building covered?
If the local community center is not under the authority of the
LEA, This building is not covered.
Question 18:
Are churches or sanctuaries that are under the LEA’s authority,
which are attended by students for religious purposes during
normal school hours, required to be inspected?
No. However, if a church is under the authority of an LEA and is
used for other school instruction (e.g., math, spelling, etc.) as part
of the school’s curriculum, then it must be inspected and included
in the management plan.
Question 19:
Are the school district's administrative offices (such as the Board
of Education or the Superintendent's Office) covered by AHERA,
even if students never attend classes in these buildings?
Yes. Among the structures covered in the definition of "school
building" in AHERA (section 202) and the rule (section 763.83)
would be any other facility used for the instruction or housing of
students or for the administration of educational or research
programs (emphasis added)."
Question 20;
Are the school system's maintenance or storage facilities (e.g., bus
garage or warehouse) covered by the rule?
In general, the answer is yes. Section 202 of AHERA and section
763.83 of the rule define "school building" to include "... any
maintenance, storage, or utility facility, including any hallway,
essential to the operation of any facility described in this definition
of school building under paragraphs (1), (2), or (3)." Paragraphs
(1), (2), and (3) cover classrooms, libraries, gymnasiums, and
administrative offices. For purposes of the rule, the facility is
deemed essential if the LEA uses the facility. Vacant facilities of
this type (i.e., empty storage facilities, empty warehouses, etc.) are
not deemed essential, and therefore are exempt, because they are
not used. Once the LEA begins to use these facilities, however,
they become essential and must be addressed as required by the
Question 21:
An LEA has a school building which is no longer
being used and is scheduled for demolition. Is the LEA required to
have an accredited contractor and workers do the abatement work
which is required under NESHAPS?
Not under AHERA, although individual States or localities may
have other statutes. A building that is abandoned and scheduled
for demolition is not covered by AHERA since the building is no
longer being used as a school.
Question 22:
Several LEAs bus students to bowling alleys or YMCA swimming
pools and gymnasiums for physical education classes. Must LEAs
inspect these buildings?
No. These buildings are not covered by the rule.
Question 23:
A school uses a single room in a nonschool building on a regular
basis as a classroom for elementary and secondary education
purposes during regular school hours. Is the room covered by the
rule? Is the entire building also covered?
The single room used by the school on a regular basis as a
classroom is covered by the rule. The rest of the building is not
Question 24:
Sections 763.84(g)(2) and 763.93(e)(3)(4) refer to,
The"... trained person designated by the LEA to implement the
management plan…” The Rule does not indicate what specific
training course is required to qualify the person(s) responsible for
implementing the management plan. Should this person be
"accredited" and would it be as a management planner or
contractor/supervisor or project designer? What would constitute
adequate training?
The LEA's designated person is not required to be accredited;
however, he or she must have some minimal training. Section
763.84(g)(2) lists the training requirements. No specific hours of
training were required since a designated person in a small LEA
with only nonfriable ACBM may not need to have as much
training as the designated person for a large city school system.
Section 763.93(e)(4) requires, however, that the LEA list the
course name, dates, and hours of training undertaken by the
designated person.
Question 25:
Can an LEA designate a committee instead of one
person to coordinate asbestos programs for an LEA?
No. Section 763.84(g)(1) requires each LEA to designate "a
person". This person or the LEA, however, may choose to appoint
an advisory committee.
Question 26:
Can a group of LEAs share a Designated Person?
Question 27:
Must an LEA's Designated Person be an employee of the LEA, or
can this person be an outside consultant, available on a part-time
basis? Does the Designated Person have to be "on-site" at the
LEA, or can he/she be located at another location?
The Designated Person does not have to be an LEA employee.
Section 763.80(a) allows LEAs to delegate the duties of their
Designated Person under the rule, but the LEAs remain responsible
for the proper performance of those duties. The Designated Person
does not have to be on-site at the LEA.
Question 28:
Many LEAs intend to select certain person(s) who
are permanent employees of the district to become accredited
inspectors, management planners, project designers,
contractor/supervisors and abatement workers. Does EPA foresee
any problems with this approach, since S 763.84(h) cautions
against "conflict of interest" among accredited personnel?
The conflict of interest provision in the rule pertains to outside
contractors who serve in two or more capacities. (see rule preamble
discussion, p. 41836. LEAs have the option to use their own
employees to carry out all tasks.
Question 29:
What is the definition of school as contained in Section 198 of the
Elementary and Secondary Education Act of 1965 (20 U.S.C.
The following excerpts include key terms from the 1965 Act.
LEAs should contact their appropriate State agency for specifics
on State law.
20 U.S.C. 3381, Elementary and Secondary Education Act
of 1965 (c) The term "elementary school" means a day or
residential school which provides elementary education, as
determined under State law.
The term "local educational agency" means a public
board of education or other public authority legally
constituted within a State for either administrative control
or direction of, or to perform a service function for, public
elementary or secondary schools in a city, county,
township, school district, or other political subdivision of a
State, or such combination of school districts or counties as
are recognized in a State as an administrative agency for its
public elementary or secondary schools. The term also
includes any other public institution or agency having
administrative control and direction of a public elementary
or secondary school.
The term "secondary school" means a day or
residential school which provides secondary education, as
determined under State law, except that it does not include
any education provided beyond grade 12.
20 U.S.C. 2854
(7) The term "elementary school" means a day or
residential school which provides elementary education, as
determined under State law, and the term "secondary
school" means a day or residential school which provides
secondary education, as determined under State law, except
that it does not include any education provided beyond
grade 12.
Question 30:
What specifically must be inspected, and what need not be
inspected? Where do you draw the line? Determining the location
of every material that may contain asbestos may be impossible.
Should an inspector tear up the school building (e.g., knock down
walls) to find asbestos?
EPA will require LEAs to ensure that accredited inspectors
conduct a thorough and complete inspection. However, in most
cases, EPA does not intend that the accredited inspector undertake
destructive steps (e.g., tearing down a wall) in an attempt to locate
An accredited inspector is expected to take reasonable
steps to locate ACBM. Specifically, an accredited inspector is
expected to conduct a thorough visual inspection, examine all
concealed accessible areas (e.g., above drop ceilings, inside
ventilation shafts, etc.) and carefully review building plans and use
his or her own knowledge to determine if ACBM was used in areas
that are inaccessible. Building plans may provide some helpful
information about where to look for ACBM, but they are not a
substitute for a thorough inspection.
An accredited inspector must answer two questions with
respect to inaccessible areas:
Is there reason to suspect that ACBM is present?
Is there reason to believe fibers could be released from
ACBM and carried from the area?
If the answer to both questions is ‘yes”, the inaccessible area must
be examined. If the answer to question number one is “no”, no
further action is needed. If the answer to question number one is
“yes”, but question number two is answered “no”, the LEA should
inventory the material as assumed ACBM and keep track of the
material during periodic surveillance and reinspection.
The second question above is important. A key aspect of
most inspector training courses is understanding how the air
circulates inside a building. If air circulates through an area that
contains asbestos, asbestos fibers could be carried to the rest of
the building.
Question 31:
Does nonfriable surfacing and miscellaneous ACM
have to be assessed? What about thermal system
Nonfriable miscellaneous and nonfriable surfacing ACBM do not
have to be assessed. However, thermal system insulation with no
damage must be assessed if it has potential for damage or
potential for significant damage. The definitions of potential
damage and potential significant damage in § 763.83
include circumstances under which there is a “ reasonable
likelihood that the material or its covering (emphasis added)" will
become damaged or significantly damaged. The term "covering"
applies to thermal system insulation. Thus, thermal system
insulation can be characterized as having potential for damage or
potential for significant damage.
In addition, § 763.90(a) states that the LEA “ shall select
and implement in a timely manner the appropriate response actions
in this section consistent with the assessment conducted in §
763.88 (emphasis added)." Therefore, the areas requiring response
actions under § 763.90 must be assessed under § 763.88. Section
763.90(e) states that "... if any friable surfacing ACM, thermal
system insulation ACM, or friable miscellaneous ACM that has
potential for damage is present in a building, the local education
agency shall at least implement an operations and maintenance
program (emphasis added)." Similarly, thermal system insulation
ACM with the potential for significant damage also has response
action requirements. Since both § 763.90(e) and (f) list response
actions for thermal system insulation with the potential for damage
and significant damage, such material must be assessed under §
Question 32:
Can unaccredited persons under the supervision of
an accredited inspector collect samples, and look in crawlspaces
and other areas to locate ACBM?
No. Sections 763.85, 763.86, and 763.88 all specifically require an
accredited inspector to conduct the necessary tasks in order to
fulfill the inspection and reinspection requirements.
Question 33:
Must encapsulated ACBM be reassessed every 3 years?
During a reinspection, in addition to checking friability,
encapsulated ACBM must be closely examined to determine
whether the response action has failed. If the response action has
failed, the area must be reassessed.
Question 34:
A school building includes a "covered exterior hallway or
walkway". Does this include both the underside and roof of these
Only the underside of the hallway or walkway is included.
Question 35:
By what date must the reinspection be finished? Is it October 12,
1991, July 9, 1992, or 3 years from the original inspection?
Section 763.85(b)(1) states that "At least once every 3 years after a
management plan is in effect, each local education agency shall
conduct a reinspection ..."of each school building. If a management
plan became effective on July 9, 1989, a reinspection must occur
no later than July 9, 1992
Question 36:
Can a building inspector use his/her own lab to analyze the bulk
samples taken?
Yes, if the lab has interim EPA or NBS accreditation.
Question 37:
Can an LEA just assume that some or all friable and nonfriable
suspect material contains ACM rather than taking samples?
Yes, Sections 763.86(a), (b), (c), and (d) explicitly permit suspect
ACBM to be assumed to be ACM.
Question 38:
What is “suspect” ACM? Can EPA provide a completed list?
EPA-approved training courses address what type of materials
might contain asbestos. In addition, these courses provide guidance
on where thee materials are typically located in buildings.
A complete list of all suspected ACBM would b difficult to
compile. However, the following is a partial list of materials that
are classified as either suspected ACBM for purposes of the rule,
or as materials not covered by the rule. Within the latter category,
some materials may contain asbestos, but they are not building
materials under the rule and therefore are not included in the
AHERA rule. Other materials would not contain any asbestos, or
enough asbestos to be defined as ACM under the rule.
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Suspected ACBM
Not CoveredBy
Cinder block
Surfacing materials (e.g., spray applied
on trawled-on materials on walls and ceilings)
Wall board (material could be
gypsum, transit, or other product)
Pressed wood
Thermal system insulation
Corrugated-like paper
product used for thermal
system insulation
Wall or ceiling carpet
Gaskets in heating and air
conditioning equipment
Floor tile (includes adhesives)
Ceiling tile and panels
Exterior roofing shingles
x, could
Auditorium curtains
x, could
Cement asbestos water pipe
Chemical lab table and desk tops
x, could
Suspected ACBM
Fire doors
Fire brick for boilers
Suspected ACBM stored in school
ACBM cloth adjoining air ducts
Not Covered
x, could
Chemical lab gloves
x, could
Fire blanket
x, could
Sheeting in fume hood
Brake shoes
x, could
Kiln bricks and cement
Bunsen burner pad
x, could
Question 39:
Please define what is meant by the phrase, "any
change in condition", as it refers to surveillance?
A maintenance person conducting periodic surveillance would
notice water damage, major delamination, a major fiber release, or
even minor damage. For surfacing material, damage might also
include separation of ACM from the substrate; flaking, blistering,
or crumbling of the ACM surface; and scrapes, gouges,, mars, or
other signs of physical injury. Asbestos debris may also indicate
damage. For thermal system insulation, damage may include
gouges, punctures, water damage, crushed areas and torn or
missing coverings. The person conducting periodic surveillance
will have to be aware of the materials previous condition,
documented in the management plan, in order to determine if any
changes in the material's condition has occurred.
Question 40:
Should the management planner exercise a quality
control function over the inspector's report?
Section 763.88(d) requires the accredited management planner "to
review the results" of inspections, assessments, and reinspections.
Question 41:
Can an inspector who received accreditation in 1988 grant an
inspection exclusion for all or part of a school he inspected in
Yes. The accredited inspector would essentially state that all or
part of his previous inspection has met the requirements of the new
Rule (see § 763.99). In general, the accredited inspector is the
person Who can determine that the LEA is eligible for an
exclusion (see? Sections 763.99(a)(1), (2), (3), (5), (6), and (7).
However, under § 763.99(a)(7), an architect or engineer can sign a
statement that no ACBM was specified for use in the construction
of a school built After October 12, 1988.
Under § 763.99 (a)(4), the lead agency in a State that has
Received a waiver from V 763.859a) can grant an exclusion.
Question 42:
Is the removal of nonfriable asbestos containing
Floor tile considered a response action that requires the use of
accredited personnel? If more than 3,000 square feet is removed
this summer, must TEM be used for clearance?
If the floor tile or its adhesive material does not become friable
during the removal process, it is not a response action, since the
definition of response action refers to a method "that protects
human health and the environment from friable ACBM." If the
material becomes friable during removal, however, the job is then
a response action requiring both accredited personnel and the use
of TEM if the area exceeds 3,000 square feet.
Typically, vinyl asbestos floor tile is tightly bound and asbestos is
generally not released under normal use. However, during a
removal operation, the tile could be rendered friable. In addition,
any sanding operations conducted to remove the adhesive beneath
the tiles would render the adhesive material friable.
Question 43:
Is the installation of carpet over damaged A/V
Floor tiles an enclosure?
No. An enclosure is defined in § 763.83 as "an airtight,
impermeable, permanent barrier around ACBM to prevent the
release of asbestos fibers into the air." Carpeting is not
impermeable, permanent, or airtight.
Question 44:
What does the term "timely fashion" mean? How will
EPA enforces this?
On page 41839 of the preamble EPA addresses the "timely
fashion" issue:
However, LEAs should be advised that in providing a
schedule for beginning and completing each response
action as required in § 763.93(e)(6), the LEA is specifying
what constitutes implementation of preventive measures
and response actions in a timely fashion for that LEA
(emphasis added). EPA and State enforcement officials
will be monitoring LEA adherence to these schedules to
determine whether enforcement actions are warranted
against those schools which fail to meet their own
deadlines for completing preventive measures and response
actions. In reviewing management plans, States may reject
plans if the schedule for response actions is not reasonable
and timely (AHERA § 205(c)(1)).
Question 45:
If, during a periodic surveillance check, a custodian finds damaged
thermal system insulation, what must be done?
Section 763.90(b) states that "... if damaged or significantly
damaged thermal system insulation ACM is present in a building,
the local education agency shall:
At least repair the damaged area.
Remove the damaged material if it is not feasible, due to
technological factors, to repair the damage.
Maintain all thermal system insulation ACM and its
covering in an intact state and undamaged condition."
As a result, the LEA must at least repair the damaged area and
make sure that the thermal system insulation is constantly
maintained in an intact state and undamaged condition.
Question 46:
Is ceiling tile friable or nonfriable? If it is friable, must accredited
persons and TEM be used to remove 3,600 square feet of ceiling
tile in a cafeteria?
Like all other materials, the friability of ceiling tile must be
determined by hand pressure. If the ceiling tile is friable, and the
inspector either assumes ceiling tile is ACM or sampling confirms
the presence of ACM, accredited persons and TEM must be used
in the example outlined above.
Question 47:
Please define the phrase, "... materials that are about to become
If a workman is about to sand nonfriable floor tile that was
assumed to be ACBM, this material would shortly become friable.
The material would immediately be subject to the O&M
requirements found in §763.91.
Question 48:
Are there circumstances under which initial cleaning requires the
use of an accredited supervisor?
No. Section 763.91(c)(1) does not require accredited personnel for
this task.
Question 49:
Must an accredited person develop the O&M plan?
No. AHERA stipulates that only certain activities
require an accredited person. Section 206(a)(3) does not require an
accredited person to develop the O&M plan. However, EPA
strongly recommends that schools use an accredited management
planner to develop the O&M plan to ensure that the plan is
consistent with the regulations.
Question 50:
O&M covers friable material only. What about
nonfriable ACBM with the potential for damage? Does this type of
material need to be addressed in an O&M plan?
Nonfriable surfacing and miscellaneous materials need not be
covered by an O&M plan, even if they have potential for damage
or significant damage.
However, as stated in § 763.90(e) and (f), thermal system
insulation with the potential for damage or significant damage
must be covered in an O&M program as described in § 763.91.
Question 51:
What is the difference between § 763.91, which addresses
operations and maintenance activities, and the O&M plan required
in § 763.93?
The operations and maintenance requirements listed in S 763.91
are in effect for all LEAs whenever specific maintenance activities
are conducted or accidents occur. The O&M plan as part of the
management plan is a particular control program tailored to each
individual school. Section 763.91 describes the procedures which
LEAs must carry out for certain O&M activities, such as cleaning,
in their buildings after December 14, 1987. An O&M plan in §
763.93 is a specific control program for a particular school
building. For example, the O&M plan for a certain school may
include a monthly schedule for routine cleaning, and may also
include specific requirements of how to prevent fiber release from
ACBM within the school building. (The procedures for such a plan
are provided in § 763.91.) The O&M plan for a particular school
may also include a permit system to exercise control over work
conducted in the school that could disturb ACBM. The O&M plan
must be implemented as part of the school's management plan no
later than July 9, 1989.
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Question 52:
a) Will any of the custodial and maintenance worker personnel
who have received previous training be "grandfathered" in?
b) If so, what criteria will these workers have to meet, and what
will be the process for making the determination?
a) Custodial and maintenance personnel may be “grandfathered".
Section 763.92(a)(3) states that “...local education agency
maintenance and custodial staff who have attended EPA-approved
asbestos training or who received equivalent training for O&M and
periodic surveillance activities involving asbestos shall be
considered trained for purposes of this section."
b)In making this determination, LEAs will need to determine if
previous training adequately covered the topics required in §§
763.92(a)(1) and (2). Equivalent training in this case means
comparable training; it need not be exactly the same. Obviously a
training course taken in 1985 could not have covered the AHERA
statute or regulation, or the OSHA standard. Previous instruction,
however, must have covered the following key items: information
on health effects; how to recognize ACBM and damaged ACBM;
and, for staff who may disturb ACBM, information on handling
ACBM, use of respirators and hands-on training. Additionally,
EPA recommends that individuals who have received equivalent
training in the past receive information on AHERA.
Question 53:
What are the qualifications or exact training needed by an
individual who conducts the 2-hour awareness training and the 14hour additional training for the maintenance and/or custodial
The regulation does not require specific qualifications for
instructors who perform O&M training. LEAs should, however,
select instructors with a professional or educational background in
the asbestos field.
Question 54:
Does EPA plan to develop a "canned" training
program for the 2-hour training course required for custodial and
maintenance workers under § 763.92?
With EPA funding, the National Asbestos Council and the
American Association of School Administrators (AASA) have
worked jointly to develop a videotape and instructor's manual that
generally cover the requirements for the 2-hour awareness training
for custodial and maintenance staff. One of EPA's funded training
centers, Temple University, is also developing an awareness video.
As required by the rule, custodial and maintenance staff must also
receive site-specific training (e.g., location of ACBM in their
building). LEAs interested in the AASA videotape should contact
AASA at (703) 875-0723 for details.
Question 55:
Sections 763.92(a)(1) and (2) refer to 2-hour training and 14-hour
training. If an LEA's workers have not taken the 3-day course to
become "accredited" abatement workers, and the LEA decides to
have workers receive the 2-hour and 14-hour training, where
should the workers go for the abbreviated training? How is this
training documented?
EPA anticipates that LEAs will use a variety of resources to train
custodial staff. Private consultants, LEA staff, local colleges and
labor groups are potential sources of instructors for O&M training.
Section 763.94(c) requires LEAs to keep specific information on
O&M training, including the location of the training and the
number of hours of training.
Question 56:
Under what circumstances can a State disapprove a
management plan? Is an LEA required to accept changes
recommended by the State?
Section 205(c)(1) of AHERA states
… the Governor may disapprove a management
plan within 90 days after the date of receipt of the
plan if the plan:
does not conform with the regulations under
§ 203 (i) (or with § 204(d) if there are no regulations),
does not assure that contractors who are accredited
pursuant to this title will be used to carry out the plan, or
does not contain a response action schedule which
is reasonable and timely, taking into account circumstances
relevant to the speed at which the friable ACM in the
school buildings under the local education agency authority
should be responded to, including human exposure to the
asbestos while the friable ACM remains in the school
building, and the ability of the local education agency to
continue to provide educational services to the community.
According to § 205(c)(2) of AHERA, "if the State
Governor disapproves a plan, the State Governor
shall explain in writing to the LEA the reasons why
the plan was disapproved and the changes that need to be made in
the plan. Within 30 days after the date on which notice is received
of disapproval of its plan, the LEA shall revise the plan to conform
with the State Governor's suggested changes (emphasis added).
The Governor may extend the 30 day period for not more than 90
The LEA, therefore, must revise its plan to conform with
changes specified by the State in conformance with § 205(c)(1). If
the LEA's plan does not conform with the State's modified plan,
the school is in violation of AHERA.
Question 57:
An LEA has to develop an asbestos management plan
for each school. Does this mean an LEA has to have a separate
management plan for each of its schools, or can it have one large
plan that covers all of its schools?
LEAs must have a separate management plan for each
school, according to § 763.93(a)(1). In addition, § 763.93(g)(3)
states, "Each school (emphasis added) shall maintain in its
administrative office a complete, updated copy of the management
plan for that school." To clarify further, this does not mean that
each building on a school's campus needs the management plan,
just the administrative office for that school.
Question 58:
After October 12, 1988, under what circumstances
will LEAs have to submit a revised management plan to the State
for review?
Sections 763.93(a)(2) and (3) require LEAs to submit management
plans to their States for school buildings leased, otherwise
acquired, or used as school buildings after October 12, 1988. This
requirement is for buildings added to the plan.
Question 59:
Must LEAs notify their State when they update their
management plans after a reinspection?
No. The rule does not require LEAs to notify their State when they
update the management plan as a result of a reinspection. This
pertains to buildings already in the management plan. However,
through their own regulations, States may require LEAs to notify
the appropriate State agency when plans are updated as a result of
a reinspection.
Question 60:
When must the LEA initially notify parent, teacher,
and employee groups in writing about the
availability of the management plan?
Section 763.93(g)(4) requires LEAs to notify in writing parent,
teacher, and employee organizations of the availability of the
management plan when the management plan is submitted to the
Governor (State designee) and at least once each school year.
Question 61:
If the LEAs have been inspected by an accredited inspector,
samples have been taken and analyzed, and no asbestos-containing
material has been found, must the district still develop a
management plan? At what point is it not necessary to develop a
The answer to the first part of this question is yes. Section
763.93(e) requires the results of the inspection to be reported in the
management plan. With respect to the second part of the question,
all LEAS, even a school built after October 12, 1988, with an
exclusion based on an architect's statement that no ACBM was
used in construction (see § 763.99(a)(7)), must have a management
plan. In this case, the management plan would simply include the
architect's statement and the notification to parents, teachers, and
employees regarding the availability of the plan.
Question 62:
If, in 5 years, an LEA has all ACM removed from a school
building, does the annual written notification requirement
regarding the management plan availability and asbestos-related
activities still apply?
The annual written notification to parents, teachers, and other
school employees remains in effect even if a school indicates it has
removed all ACM. The purpose of the availability of the
management plan is to enable the public to determine if the LEA
has implemented the management plan satisfactorily.
Question 63:
Are the LEAs required to keep and/or maintain their
management plan for any specified length of time?
The rule does not specify a date after which LEAs no longer need a
management plan. As a result, LEAs should plan to keep their
management plans indefinitely. Certain records, however, can be
discarded within a certain period of time after the ACBM has been
removed (see § 763.94).
Question 64:
Section 763.93(f) states that the LEA "may" require
a statement signed by an accredited management planner that the
plan is in compliance with the Rule, but that this statement may not
be signed by the person responsible for implementing the plan
(even though he/she may be an accredited management planner).
Why is the plan implementor prohibited from signing this
Section 763.93(f) comes directly from the statute § 203(i)).
However, as noted in the actual language, such a statement is not
required. The purpose of this prohibition is to discourage conflict
of interest between the management plan preparer and an
abatement contractor. For LEAs with a concern about conflict of
interest between the management planner and the abatement
contractor, or about the adequacy of the plan, such a statement
should be considered.
Question 65:
What forms of written public notifications are acceptable? If no
specific organizations exist for the LEA to address, what
constitutes acceptable written notification?
LEAs have a great deal of flexibility with respect to methods of
notifying parents, teachers, and employees. However, §
763.93(g)(4) requires LEAs to keep a copy of the notification. A
letter to the PTA and the employees' union is acceptable.
In the absence of such formal organizations, the LEA must still
notify parents, teachers, and employees in writing. As stated on
page 41841 of the rule's preamble, in some instances this
notification could take the form of a newspaper advertisement, an
article in an LEA newsletter, or some other form. The Agency will
further examine these methods of notification on a case-by-case
basis. LEAs unsure about how to properly notify these groups
should contact their Regional Asbestos Coordinator.
Please note, under S 763-93(g)(4), LEAs must include in
the management plan a description of the steps taken to notify such
organizations, and maintain a dated copy of the notification.
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Question 66:
How should the periodic surveillance results be
documented? How detailed does the information have to be and
what constitutes adequate records?
Section 763.94(d) requires LEAs to "... record the name of each
person performing periodic surveillance, the date of the
surveillance, and any changes in the conditions of the materials."
A one-page checklist (i.e., change/no change) with sufficient room
for comments by the person conducting the surveillance would be
adequate. if changes are noticed, the comments must describe each
change clearly.
Question 67:
Does a person have to take the training course and
exam from the same sponsor for accreditation?
AHERA sections 206(b)(1) and (c)(1) indicate that persons seeking
accreditation need to take a training course and pass an
examination. For full accreditation through an EPA-approved
course, persons must take the course and exam from the same
training course sponsor. States that have accreditation programs
may require persons seeking accreditation to pass a Stateadministered exam. Section 206(c)(1) of AHERA states that "...
the Administrator shall ensure that any EPA-approved training
course is consistent with the model plan (including testing
requirements) developed under subsection (b). A contractor may
be accredited by taking and passing such a course."
Question 68:
If an individual took a course at an EPA training
center after January 1, 1985, and was
"grandfathered in" as having taken an approved course, when does
this person have to take a course to become fully accredited?
When is the first refresher course required?
Persons who are "grandfathered in" after January 1, 1985, do not
have to take a course to become fully accredited until one year
after their State has or was required to have an accreditation plan
approved by EPA, and do not have to take the first refresher
course until 2 years after their State has or was required to
have an accreditation plan approved by EPA. For example, a State
legislature convenes in January 1988. By July 1988, the State must
have developed an accreditation program that meets the Model
Plan. Contractors, inspectors, management planners, workers,
supervisors and abatement project designers in that State have one
year to become fully accredited (i.e., July 1989). The first refresher
training would be required by July 1990. These dates are still in
effect for individuals even if the State fails to act, in which event,
they would complete EPA-approved courses at the specified
Question 69:
What is the time frame for accredited individuals
to take the required refresher training course? For example, are
they required to take the refresher course prior to the expiration of
their accreditation, or 60 days after? If they do not take the
refresher course prior to expiration or some subsequent date
including a grace period, will they be required to take another full
training course and pass the required examination before they can
be reaccredited?
Individuals must take an annual refresher course to maintain their
accreditation, as specified in the answer to Question 68. In the
example cited above, if a person fails to take the refresher course
within the 1-year prescribed period, their accreditation ceases. As
a result, those persons cannot conduct AHERA work in their
pertinent discipline. They will have 12 more months to take the
refresher course in order to resume conducting AHERA work. If a
refresher course is not taken during that period (i.e., within 24
months after accreditation), the entire training course (e.g., 4 days
for supervisors) must be repeated and the exam passed.
Question 70:
When would a conflict of interest exist among accredited
A conflict of interest with respect to accredited personnel would
exist if, for example, the management planner and abatement
contractor worked for the same firm. The planner might
recommend to the LEA more expensive response actions than are
necessary in the management plan.
Question 71:
May a person serve as an accredited inspector and
management planner on the same school project?
Yes. EPA anticipates that many LEAs will have the same person
conduct both tasks. However, LEAs must still evaluate whether
that person has a conflict of interest (see section 763.84(h)).
Question 72:
Can an LEA hire one abatement firm both to conduct
a response action and to carry out the TEM
clearance air monitoring on that project?
No. In Appendix A on page 41858 of the rule under "Sampling", it
states that TEM "... sampling operations must be performed by
qualified individuals completely independent of the abatement
contractor to avoid possible conflict of interest." The LEA would
have to select another person or firm "completely independent" of
the abatement contractor to do this work. The abatement firm
would not be allowed to subcontract this work since the
subcontractor is not "completely independent" of the contractor.
Question 73:
Can an LEA itself become approved as a training center?
Question 74:
How can an LEA find accredited personnel to perform
inspections, develop management plans, and conduct response
In States with EPA-approved programs, the LEA should contact
the appropriate State agency responsible for accreditation. In
States without approved programs, LEAs may communicate with
the contacts from EPA-approved courses and request a list of
accredited individuals. LEAs also have the option of hiring
accredited personnel from a State with an EPA-approved program.
of course, LEAs may also choose to solicit proposals to conduct
inspections, management plans and response actions in
newspapers, professional or trade journals. The requirement that
persons must be accredited should be emphasized in the LEA's
description of the project. Two national organizations, the
National Asbestos Council and the National Insulation Contractors
Association, have or are in the process of developing lists of their
members who have accreditation credentials. Finally, LEAs may
have their own personnel trained and accredited through EPAapproved courses or State programs.
Question 75:
Must an individual respirator fit test be given to
each and every training course participant? Many training
providers are concerned about their liability. Shouldn't the student
be required to furnish a doctor's statement that indicates the student
can safely wear a respirator?
Training entities must provide students with the opportunity for
respirator fit testing. If a student declines to be fit-tested, that is
his or her prerogative. In addition, a training entity may require
the student to furnish medical evidence that he or she is capable of
wearing a respirator. Therefore, if a student has a medical
statement from a physician indicating that he or she can be fittested, and the student wants to be fit-tested, the training entity
must fit-test the student.
Question 76:
Must an accredited designer be used to design a
response action?
Section 763.90(g) requires that "Response actions including
removal, encapsulation, enclosure or repair, other than small-scale,
short-duration repairs, shall be designed and conducted by persons
accredited to design and conduct response actions (emphasis
added)." An accredited designer, then, must develop the job
specifications for a response action.
Question 77:
If an abatement designer takes the course for contractors and
supervisors, and his/her certificate says "contractor/supervisor",
how can the individual prove that he/she is qualified to design
abatement projects?
The designer should show the LEA the relevant section of the
Model Accreditation Plan that enables a person who has
successfully completed the contractor/supervisor course to be
accredited as a designer (see plan page 15878, "Abatement Project
Question 78:
Where does it say in the AHERA rule that LEAs must use
accredited workers and supervisors to conduct asbestos abatement
work after December 14, 1987?
Section 763.90(g) requires response actions to be designed and
conducted by persons accredited to design and conduct response
actions. on page 41826, under the heading "Dates", it states that ...
rule shall be effective on December 14, 1987 the "... rule shall be
effective on December 14, 1987." As a result, the requirement to
use accredited personnel under AHERA is in effect as of
December 14, 1987. Any asbestos-related work requiring
accreditation conducted after that date or must use accredited
Question 79:
With respect to TEM, what does the term "contiguous
portions" mean?
The intent of S 763.90(i)(8) is to prevent an LEA from artificially
dividing up a large project so as to avoid the TEM requirement.
For example, an LEA that has a 3,300 square foot gymnasium
cannot artificially divide the gym into 3 separate areas of 1,100
square feet, and then conduct separate abatement in each area,
clearing each area by PCM. These areas are obviously contiguous,
thus TEM is required.
However, an abatement job in wing A of a building that
totals 1,700 square feet and a job in a separate, non-contiguous
wing that totals 1,500 square feet are not contiguous portions of
Question 80:
If an LEA plans to remove 3,500 square feet of ACBM
from six adjacent classrooms joined by a hallway, does TEM have
to be used for clearance of the entire area or can the LEA choose to
remove the ACBM from each classroom separately and use PCM
to clear each separate room?
TEM must be used unless clear engineering reasons exist for
dividing such a project into smaller areas. A primary reason EPA
permitted the use of PCM for the 3-year phase-in period was to
enable an LEA to minimize its total abatement expenses for a
small project (e.g., less than 3,000 square feet). For one small
project, EPA believes the additional cost of TEM analysis at
current prices could greatly increase the total cost of the project.
However, permitting an LEA to subdivide what would normally be
one large project into several smaller projects defeats the purpose
of the TEM requirement. As necessary, EPA will review such
situations on a case-by-case basis.
Question 81:
What is meant by the phase "at approximately the
same time" (in § 763.90(i)(8)) as it relates to TEM clearance?
The intent of §763.90(i)(8) is to prevent an LEA from avoiding the
TEM requirement by either artificially dividing up a larger project,
or by removing ACBM in stages over the course of a relatively
short period of time from what normally would have been one
large Project if the TEM phase in did not exist. For example, if an
LEA removed 1,600 square feet of surfacing ACBM in June 1988,
and 1,600 square feet of adjacent surfacing ACBM a few weeks
later, EPA would consider this to be removing contiguous portions
of ACBM at approximately the same time". As necessary, EPA
will review such situations on a case-by-case basis.
Question 82:
Would surfacing ACBM on ceilings of two classrooms
on two separate floors be viewed as contiguous areas?
No. Even if one classroom was directly beneath the otherclassroom, these would not be contiguous areas under the rule.
Each floor would normally have its own containment barrier.
Question 83:
With regard to TEM, is there a plan to establish a
certain number of air samples to be collected for abatement project
clearance based on square footage/area or cubic footage/ volume?
No. As stated in Appendix A, the minimum number of TEM
samples that need to be collected for each test site is 13 samples.
These break down as follows:
— 5 samples per abatement area
— 5 samples per ambient area positioned at locations
representative of the air entering the abatement site
— two field blanks
— one sealed blank
Not all of these samples will have to be analyzed, in certain cases.
Question 84:
Are there criteria for doing aggressive air monitoring?
Yes. Unit III.B.7.d. of Appendix A in the rule provides criteria for
aggressive air monitoring.
Question 85:
Please define the term "nonfriable suspected ACBM." Also, what
does the term "manner sufficient to determine" mean with respect
to sampling such material?
Nonfriable suspected ACBM could be wallboard or floor tile.
"Manner sufficient to determine" means the accredited inspector
must take an appropriate number of samples for that material. For
example, a number of training courses recommend that an
inspector take the same number of samples for materials like floor
and ceiling tiles as the inspector would for surfacing material.
Other training courses suggest that three samples should be taken
from homogeneous areas of such material.
Question 86:
Please clarify the use of the term, "homogeneous
area", which has a regulatory definition of being uniform in color
or texture, when applied to thermal system insulation having pipe
lagging that has either been discolored or applied differently to
give the appearance of possessing a different texture.
The accredited inspector must make a judgment on whether pipe
lagging is indeed uniform in color and texture. If the suspect
material looks darker due to water damage, it is appropriate for the
inspector to consider this as part of the same homogeneous area. If
the suspect material has been applied differently, however, it
probably would not be uniform in color and texture since there
would be a noticeable difference in the suspect materials
Question 87:
If PCM is being used for clearance, does the sampling volume
table in the mandatory TEM method have to be followed to
determine the sampling volume for the PCM samples?
No. The table is required only for samples which will be analyzed
by TEM. The table was set up to maintain an analytical sensitivity
of 0.005 fibers per cubic centimeter (f/cm3) for the TEM analysis.
The table does not apply to the PCM analysis.
Question 88:
How does one determine the amount of air to sample for the PCM
analysis to maintain a limit of quantification of 0.01 f/cm3?
Follow the procedure in the EPA Silver Book, specifically outlined
on pages 4-5. The volume required to reliably quantify fibers
down to 0.01 f/cm3 may be calculated using the first formula on
these pages. Note that for NIOSH 7400, the minimum fiber loading
is specified. Also, alert labs that the area of viewing for a field will
vary between microscopes and that they must determine this value
from their microscopes.
Question 89:
Can dual-headed pumps be used at abatement sites when taking the
five samples?
This avoids the intent of the directions given in the nonmandatory
appendix for TEM. The method states: "Position ambient samples
at locations representative of the air entering the abatement site." A
dual-headed pump will not sample air at two different locations.
Question 90:
Can someone collect more than five samples inside the abatement
site and pick the best of the results for the clearance test?
No. An equal number of samples should be taken inside and
outside the abatement site for clearance. The minimum number is
five inside and five outside. The rule does not prohibit the
collection of more than five samples inside and an equal number
outside; however, collection of a higher number inside and then
selecting only five of those values is not appropriate.
Question 91:
How can the public get copies of the listing of
accredited laboratories?
Contact a Regional Asbestos Coordinator or call the TSCA Hotline
at (202) 554-1404.
Question 92:
Do you have to label enclosed or encapsulated ACBM
in routine maintenance areas?
Yes. Section 763.95(a) states that "... the local education agency
shall attach a warning label immediately adjacent to any friable
and nonfriable ACBM and suspected ACBM assumed to be ACM
located in routine maintenance areas (such as boiler rooms) at each
school building. This shall include:
Friable ACBM that was responded to by a means other than
Question 93:
ACBM for which no response action was carried out."
What are some examples of routine maintenance areas
that would require labeling? What does routine mean?
Examples are boiler rooms, equipment rooms, pipe tunnels, fan
rooms, air handling rooms, or any other area that serves primarily
as a maintenance area.
"Routine" means that a maintenance or custodial person
frequents an area (see above) on a regularly scheduled or
predictable basis to perform maintenance activities.
Question 94:
In general, will school employees other than custodial and
maintenance workers have to stay out of routine maintenance
The rule does not prohibit other school employees from entering
routine maintenance areas.
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Question 95:
In Appendix D of the rule, dealing with the
transport and disposal of asbestos waste, should the "shoulds" be
interpreted as "shalls"? In other words, are these recommendations
now requirements?
The recommendations in the transport and disposal guidance
document-have not become requirements. LEAs have to comply
with applicable DOT and NESHAP regulations governing
transport and disposal, not with the recommendations found in
Appendix D. Enforcement of Appendix D will be based on the
current DOT and NESHAP regulations cited in the Appendix, not
on the recommendations suggested therein.
Question 96:
Can EPA delegate the AHERA regulatory program to
government agencies such as county and city governments?
Several county and city governments have programs which are
more stringent.
With respect to § 763.98 which addresses State waivers, these
waivers apply only to States.
Question 97:
Who will review the management plans submitted by the
Department of Defense (DOD)?
Section 203 (1) of AHERA requires the Secretary of Defense to
carry out “ any function, duty, or other responsibility imposed on
a Governor of a State [for any school] operated under the defense
dependents’ education system provided for under the Defense
Dependents’ Education Act of 1978 (20 U.S.C. 921 et seq.).”
Question 98:
Does the regulation explicitly prohibit any conflict of interest?
Yes. In Appendix A to the rule, the regulation states that TEM
“…sampling operations must be performed by qualified
individuals completely independent of the abatement contractor...”
Question 99:
What are EPA’s plans for developing standardized or model forms
for inspections and/or management plans?
The EPA-funded model training course materials for trainers,
available for purchase by calling 301/468-1916, and the LEA
Guide to assist LEAs in complying with the new rule, mailed to
LEAs in February, include model forms and formats for
inspections and management plans, respectively.
Question 100:
In a high school vocational-tech class dealing with
automobile brake repairs, or in a school maintenance facility that
repairs brakes on school buses, is the asbestos hazard from brake
dust covered by AHERA?
No. AHERA covers asbestos-containing building materials only,
and brake shoes are not building materials under AHERA.
However, EPA believes it is advisable to establish a program to
contain brake dust and prevent its release (see also OSHA's
Appendix F to its rule). EPA has proposed a rule to phase out the
use of asbestos in brakes and other products. Information on
establishing a program to control brake dust can be found in the
publication, Guidance for Preventing Asbestos Disease Among
Auto Mechanics.
This publication is available from:
Superintendent of Documents
U.S. Government Printing Office
Washington, DC 20402
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