Asbestos Coordinator Self Study Guide  ()

Asbestos Coordinator Self Study Guide  ()
TABLE OF CONTENTS
Pre-course Quiz . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii
Chapter
1
Using the Self-Study Guide . . . . . . . . . . . . . . . . . . . . . . . . . 1
Chapter
2
An Introduction to Asbestos . . . . . . . . . . . . . . . . . . . . . . . . . 5
Chapter
3
Asbestos Health Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Chapter
4
What is Required of the LEA? . . . . . . . . . . . . . . . . . . . . . . 14
Chapter
5
The AHERA Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Chapter
6
The Management Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
Chapter
7
Reinspections and Periodic Surveillance . . . . . . . . . . . . . . .
Chapter
8
The Operations and Maintenance Program . . . . . . . . . . . . . . . 55
Chapter
9
Training and Accreditation . . . . . . . . . . . . . . . . . . . . . . . . 70
Chapter
10
Recordkeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76
Chapter
11
Related Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80
52
FIGURES
Figure 5-1: Decision Tree to Determine Physical Assessment Categories . . . . . . . . . 26
Figure 6-1: Flow Charts of Possible Response Actions . . . . . . . . . . . . . . . . . . . . 42
TABLES
Table 5-1:
Table 5-2:
Table 6-1:
Table 6-2:
Table 6-3:
Table 6-4:
Table 9-1:
Table 9-2:
Bulk Sampling Requirements . . . . . . . . . . . . . . . . . .
Inspection Report Compliance Checklist . . . . . . . . . . .
Contents of the Management Plan . . . . . . . . . . . . . . .
Implementation Requirements with the Management Plan
Frequent Problems with Management Plans . . . . . . . . .
Management Plan Compliance Checklist . . . . . . . . . .
LEA Employee Training Requirements . . . . . . . . . . .
Accredited Worker Training Requirements . . . . . . . . .
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22
35
36
45
47
49
73
74
LISTS
Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88
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Acronyms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93
PRE-COURSE QUIZ
The questions in this pre-course quiz are related to the information found in this guide. The
quiz will serve as an immediate self-assessment of your knowledge of some of the basic
principles of the Asbestos Hazard Emergency Response Act (AHERA). Please answer all
of the following questions. The answers to the questions immediately follow the quiz.
1. Asbestos that is easily crumbled into a powder by hand pressure when dry is:
A. Friable
B. Non-friable
C. Decomposable
D. Asbestos powder
E. None of the above
2. Exposure to asbestos may result in:
A. Asbestosis (a disease characterized by lung scarring)
B. Lung cancer
C. Mesothelioma (a cancer arising in the chest cavity or abdominal cavity)
D. All of the above
E. None of the Above
3. Asbestos-related diseases are ___________________ and have a latency period of
_____.
A. dosed related, 15 to 30 years
B. fatal, 30 days
C. non-existent, 60 years
D. dangerous, 1 hour
E. serious, 10 years
4. The three main federal government agencies that regulate asbestos are:
A. Food and Drug Administration, Department of Transportation, Environmental
Protection Agency
B. Department of Transportation, Environmental Protection Agency, Occupational Safety
and Health Administration
C. Department of Health and Human Services, Environmental Protection Agency,
Occupational Safety and Health Administration
D. General Services Administration, Department of Health and Human Services,
Occupational Safety and Health Administration
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Pre-Course Quiz
E. No federal government agencies regulate asbestos
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Pre-Course Quiz
5. Which of the following are not the responsibility of the Local Education Agency?
A. must conduct periodic surveillance in each building under its authority at least once
every six months and use an accredited inspector to conduct the reinspections every
three years
B. must attach a warning label immediately adjacent to any friable and nonfriable
asbestos-containing building material (ACBM) and suspected ACBM located in routine
maintenance areas, such as boiler rooms, at each school building
C. must send all notification, inspection, and periodic surveillance records to EPA on an
annual basis
D. ensure that complete and up-to-date records of inspections, reinspections, response
activities, periodic surveillances, and operations and maintenance activities are
maintained
E. must comply with the notification requirements to workers, students, building
occupants, parents, and short-term workers
6. Which activities must be conducted by an accredited inspector?
A. Identify all homogeneous areas of material that are suspected to contain asbestos
B. Gather information on the uses and functions of the spaces within the homogeneous
areas
C. Collect samples of material suspected to be ACBM and send them to the lab for
analysis
D. Perform a physical assessment of the material and document the results in an
inspection report
E. All of the above activities
7. Some of the most common uses of asbestos-containing building materials found
include:
A. Fireproofing on structural members
B. Plaster, pipe and boiler insulation
C. Acoustical or sound proofing material
D. Flooring and ceiling tiles
E. All of the above
8. In addition to imposing other requirements, the Asbestos Hazard Emergency
Response Act requires that a Local Education Agency:
A. Close buildings in which asbestos is found
B. Perform inspections to identify asbestos-containing building materials in its buildings
C. Notify the Environmental Protection Agency on the locations of asbestos-containing
building materials in the schools of the district
D. Remove all asbestos-containing building materials from its buildings
E. B and D
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Pre-Course Quiz
9. A management plan must contain appropriate response actions. Which of the
following is not an appropriate response action:
A. Replace damaged asbestos-containing building materials with new undamaged
asbestos-containing building materials
B. Repair damaged asbestos-containing building materials to an undamaged or intact
condition
C. Encapsulate asbestos-containing building materials with a material that surrounds or
embeds asbestos fibers
D. Enclose asbestos-containing building materials in an airtight, impenetrable permanent
barrier
E. None, all of these are appropriate response actions
10. At least once every
months, the Local Education Agency must conduct a visual
inspection of all areas identified in the management plan as asbestos-containing
building materials (ACBM) or assumed to contain asbestos-containing building
materials to determine whether the condition of the ACBM or assumed ACBM has
changed. This is called a(n)
.
A. 12, periodic surveillance
B. 12, inspection
C. 6, periodic surveillance
D. 6, inspection
E. 24, reinspection
11. Final air clearance of a functional space after a response action to remove,
encapsulate, or enclose ACBM involves the following:
A. visual inspection
B. collection of air samples
C. analysis of samples by PLM
D. analysis of samples by TEM, unless the project involves less than 160 square feet or
260 linear feet, in which PCM may be used
E. A, B, D
12. How can the Local Education Agency best minimize accidental disturbances of
ACBM during maintenance and renovations activities?
A. establish a permit system that calls for all work orders and requests to be processed
through the AHERA designated person
B. require the AHERA designated person to maintain AHERA inspector and management
planner accreditations
C. require the principals of all schools to attend asbestos awareness training
D. require all periodic surveillance inspections to be conducted by accredited inspectors
E. assure that all AHERA management plans are updated on an annual basis
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Pre-Course Quiz
13. A designated person must:
A. Receive training that provides basic knowledge of a number of asbestos-related
subjects, as listed in EPA's asbestos regulations
B. Complete EPA-or State-approved inspector course and become accredited
C. Have a college degree
D. Pass an EPA test on Designated Person roles and responsibilities
E. Complete no training
14. An asbestos management program is subject to which EPA statutes and regulations:
A. Asbestos Hazard Emergency Response Act
B. Asbestos Hazard Emergency Response Act, National Emissions Standards for
Hazardous Air Pollutants
C. Asbestos Hazard Emergency Response Act, National Emissions Standards for
Hazardous Air Pollutants, EPA Worker Protection Rule
D. Asbestos Hazard Emergency Response Act, National Emissions Standards for
Hazardous Air Pollutants, EPA Worker Protection Rule and Asbestos School Hazard
Abatement Reauthorization Act
E. None of these
15. Local Education Agencies must conduct the following notifications:
A. annually to parents, teachers, and employee organizations on the availability of the
asbestos management plan
B. annually to workers, building occupants and their guardians on recent or planned
asbestos activities (such as inspections, response action, etc.)
C. to short-term workers (e.g. telephone repair workers, utility workers, or
exterminators) who may come into contact with asbestos on the locations of asbestoscontaining building materials (or assumed ACBM)
D. annually to EPA or state agencies on updates to the management plan.
E. A, B, C
16. The management plan must:
A. be kept in the Local Education Agency's administrative office
B. be kept in the administrative office of each school building
C. be available to persons for inspection without cost or restriction
D. be complete and up-to-date
E. all of the above
(1) A (2) D (3) A (4) B (5) C (6) E (7) E (8) B (9) A (10) C (11) E (12) A (13) A
(14) D (15) E (16) E
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Pre-Course Quiz
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1
USING THE SELFSTUDY GUIDE
Aim of the Guide
EPA requires schools to appoint an asbestos management coordinator, called the "AHERA
designated person" to be responsible for a number of asbestos-related activities, including
the implementation of the plan for managing asbestos-containing building materials
(ACBM) in the school buildings and compliance with the federal asbestos regulations.
Even though the AHERA requirements have been in place for some time, EPA inspectors
have found misunderstanding and confusion on how to implement the requirements, as well
as how to best manage asbestos in school buildings. EPA has designed this self-study
guide to help the designated person understand his or her responsibilities and comply
with the federal asbestos requirements. This manual is recommended for persons recently
appointed to the position of AHERA Designated Person, as well as persons who have held
the position for some time.
Background
On October 22, 1986, Congress promulgated the Asbestos Hazard Emergency Response
Act (AHERA), Public Law 99-519. AHERA mandated that EPA develop regulations to
respond to asbestos in schools. On October 30, 1987, EPA promulgated the AsbestosContaining Materials in Schools Rule (hereinafter referred to as the AHERA Rule), 40
CFR Part 763, Subpart E. This rule requires that all of the nation's nonprofit elementary
and secondary schools, both public and private, inspect their school buildings for asbestoscontaining building materials (ACBM), develop a plan to manage the asbestos for each
school building, notify parents and staff regarding management plan availability, provide
asbestos awareness training to school maintenance and custodial workers, and other
requirements described in detail in this manual. A list of key responsibilities for school
districts is located on page 18. (Note that certain States consider pre-schools the first step
of the elementary education process and therefore have included pre-schools under their
State AHERA regulations.)
The governing authority responsible for AHERA compliance is the Local Education
Agency (LEA). "Local Education Agency" means either any local educational agency as
defined in Section 198 of the Elementary and Secondary Education Act of 1965 (often
called school district), the owner of any private, non-profit elementary or secondary school
building, or the governing authority of any school operated under the Defense
Department's education system.
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CHAPTER 1
Using the Self-Study Guide
In July 1991, EPA released the results of an evaluation of AHERA implementation. The
results showed that certain elements of school asbestos programs were not being
effectively implemented. The agency concluded that schools needed better guidance on
how to run their asbestos programs. Shortly after, EPA hired a contractor to develop the
Designated Person Self-Study Guide. Due to the shortage of funding, this project was
abandoned in 1992.
Over the past seven years, EPA staff have observed that the quality of school asbestos
programs depend heavily on the dedication and work of the AHERA Designated Person
(DP). Schools without a competent DP tend to have more AHERA violations. Common
violations are listed on the table "Frequent Problems with the Management Plan" on
page 47. Schools with DPs who know the AHERA requirements can effectively prevent
the release of asbestos fibers through their own actions, as well as their ability to hire and
oversee the work of personnel conducting asbestos-related activities at their school
buildings.
The AHERA Designated Person Self Study Guide is an important tool to improve LEA's
compliance with AHERA and to protect the health of school building occupants through
preventing the release of asbestos fibers. With the support from EPA HQ and all the other
EPA regional offices, the Seattle office of EPA undertook the task of updating and
finalizing this manual on August 1995.
Responsibilities of the AHERA Designated Person
The responsibilities of the AHERA Designated Person include:
! ensure that all activities of anyone who conducts the following are carried out in
accordance with the AHERA requirements: conduct inspections, reinspections,
periodic surveillance; develops, implements and updates management plans; and plans
and implements asbestos-related activities (such as maintenance or removal);
! ensure that all custodial and maintenance employees are properly trained;
! ensure that all workers, building occupants, students, and their parents are notified
annually about management plan availability and recent and upcoming asbestos-related
activities;
! ensure that short-term workers who may come into contact with asbestos are provided
information regarding the location of this asbestos;
! ensure that all warning labels are posted; and
! consider any conflicts of interest that may arise when selecting accredited personnel
to conduct asbestos-related activities.
AHERA Designated Person Required Training
AHERA requires that the DP be adequately trained to carry out his or her responsibilities.
Due to the differing needs of school districts based on the size of the district and the
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CHAPTER 1
Using the Self-Study Guide
amount and condition of the ACBM, AHERA does not list a specific training course or
specific number of hours of training for the DP. Further, AHERA does not require the DP
to be accredited. Specifically, the regulations note the training must include the following
topics:
! health effects of asbestos;
! detection, identification and assessment of asbestos-containing building materials
(ACBM);
! options for controlling asbestos-containing building materials; and
! asbestos management programs.
! relevant Federal and State regulations concerning asbestos, including AHERA and
its implementing regulations and the regulations of the Occupational Safety and
Health Administration, the U.S. Department of Transportation, and the U.S.
Environmental Protection Agency (See Chapter 11 for further information on
regulations related to AHERA.)
To determine whether reviewing this document would satisfy the training requirements
for the DP, school personnel should consult with the regional asbestos coordinator in
the EPA Regional Office serving their state.
Instructions for Using this Guide
To use this guide effectively:
! Assemble all documents that appear in the list entitled "Documents Required for
Completion of Self-Study Guide."
! Make copies of the tables, figures and supplemental materials that appear in this
guide to use as working copies.
! Review the chapter summaries and supplemental materials at the end of each
chapter as you proceed through the guide.
! Take the Quiz before and after you have completed this Self-Study Guide.
Documents Required for Completion of Self-Study Guide
A designated person using this guide should have copies of the following documents for
reference:
! Environmental Protection Agency
40 CFR Part 763; Asbestos-Containing Materials in Schools; Final Rule
(October 30, 1987), the Model Accreditation Plan, Interim Final Rule (February
3, 1994), and Asbestos Abatement Projects; Worker Protection; Final Rule
(February 25, 1987; note: this rule must undergo revision to conform to the
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CHAPTER 1
Using the Self-Study Guide
OSHA Worker Protection Rule, 29 CFR 1926.1101, 8/10/94).
100 Commonly Asked Questions About the New Asbestos-in-Schools Rule
(May 1988).
! Your School Asbestos Inspection Report/Management Plan
Choose a document that is representative of your school buildings if you have
multiple schools.
! Occupational Safety and Health Administration
29 CFR §1910.1001: General Industry Standard on Asbestos and 29 CFR
§1926.1101: Construction Industry Standard (August 10, 1994).
Useful References
A designated person may also wish to refer to one or more of the following EPA
documents in completing this guide:
! Environmental Protection Agency
40 CFR Part 61; National Emission Standards for Hazardous Air Pollutants;
Asbestos NESHAP Revision; Final Rule (November 20, 1990);
Guidance for Controlling Asbestos-Containing Materials in Buildings (Purple
Book): (June, 1985; 560/5-85-024);
Managing Asbestos in Place: A Building Owners Guide to Operations and
Maintenance Programs for Asbestos-Containing Materials (Green Book) (July,
1990; 20T-2003);
Asbestos in Buildings; Guidance for Service and Maintenance Personnel
(June 1985; 560/5-85-018);
A Guide to Performing Reinspections Under the Asbestos Hazard Emergency
Response Act (AHERA) (Yellow Book) (February 1992);
Answers to the Most Frequently Asked Questions About Reinspections Under
AHERA (May 1991);
Environmental Hazards in Your School: A Resource Handbook (October 1990).
Policy Clarification for the Asbestos Hazard Emergency Response Act: Under
What Circumstances is Removal of Vinyl Asbestos Tile or Similar Materials a
Response Action under AHERA? (EPA, July 1992).
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To obtain any of the documents listed above, contact the EPA Toxic Substances
Control Act (TSCA) Hotline at (202) 554-1404 or the U.S. Government Printing
Office.
2
AN INTRODUCTION
TO ASBESTOS
The History of Asbestos
The word "asbestos" is derived from the Greek language. The Greeks admired the
"miracle mineral" because of its softness and flexibility and its ability to withstand heat.
The Greeks used asbestos much like cotton, spinning and weaving it into cloth.
Asbestos was not widely available anywhere in the world until the late 1800s, when
major deposits were found in Canada. Thereafter, asbestos was used to make thermal
insulation for boilers, pipes, and other high temperature applications, and was also used
as a fireproofing and reinforcement material. During World Wars I and II, the military
used asbestos extensively in ships and other applications. Commercial usages of
asbestos in buildings increased greatly thereafter, but growing concerns about the health
risks associated with asbestos exposure resulted in a voluntary reduction in the use of
asbestos beginning in the 1970s.
Characteristics of Asbestos
Asbestos is comprised of a group of natural minerals. Unlike other minerals, however,
the crystals of asbestos form long, thin fibers. Asbestos deposits are found throughout
the world, but the primary sites of commercial asbestos production are Canada, Russia,
and South Africa. Commercial mining of asbestos in the United States was halted in
the 1980s.
Once extracted from the earth, asbestos-containing rock is crushed, milled (or ground),
and graded. This produces long, thread-like fibers of material. What appears to the
naked eye as a single fiber is actually a bundle of hundreds or thousands of fibers, each
of which can be divided even further into tiny fibers (fibrils), invisible without the aid
of a microscope.
Asbestos materials are divided into two groups -- serpentine and amphibole. All
asbestos in the serpentine group is called Chrysotile. This is the most common type of
asbestos found in buildings in the United States, accounting for approximately 95
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CHAPTER 2
An Introduction to Asbestos
percent of the asbestos found in the nation's buildings. It is commonly known as "white
asbestos" because of its natural color.
The amphibole group contains five types of asbestos. Amosite, the second most
common type of asbestos found in buildings in the United States, is often referred to
as "brown asbestos" for the color of the natural mineral. Crocidolite, or "blue
asbestos" has been used in high-temperature insulation products and on chemical
resistant surfaces, such as laboratory tables for chemistry and biology classes (upon
occasion, the custodial staff will drill holes in table tops for new fixtures without
realizing that the material may contain crocidolite. The remaining three types of
asbestos in the amphibole group -- Anthophyllite, Tremolite, and Actinolite -- are rare
and have little commercial value. They are occasionally found as contaminants or
minor constituents in asbestos-containing materials.
Uses of Asbestos
Asbestos has been used in thousands of products, largely because it is plentiful, readily
available, cheap, strong, does not burn, conducts heat and electricity poorly, and is
resistant to chemical corrosion. Products made with asbestos are often referred to as
asbestos-containing materials (ACM).
Asbestos proved particularly useful in the construction industry. Building materials that
contain asbestos are referred to as asbestos-containing building materials (ACBM).
Commercial usage of asbestos products in the construction industry was most common
from about 1945 to 1980. Some of the most common uses of ACBM include:
! Fireproofing material -- Usually spray-applied to steel beams used in
construction of multi-story buildings to prevent structural members from
warping or collapsing in the event of fire.
! Insulation material -- Usually spray-applied, trowel-applied, or manually
installed after being preformed to fit surfaces such as pipes for thermal insulation
and condensation control.
! Acoustical or soundproofing material -- Trowel- or spray-applied. May also
be used for decoration. Asbestos was mixed with other materials and sprayed
onto ceilings and walls to produce a soft, textured look.
! Miscellaneous materials -- Asbestos has been added to asphalt, vinyl, cement
and other materials to make products like roofing felts, exterior siding and
roofing shingles, wallboard, pipes for water supply, combustion vents, and flues
for waste gases and heat. Fibers in asbestos cement, asphalt, and vinyl materials
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CHAPTER 2
An Introduction to Asbestos
are usually firmly bound into materials in good condition and typically will be
released only if the material is damaged mechanically -- for example through
drilling, cutting, grinding, or sanding. In addition, asbestos in roofing shingles
and siding exposed to weathering may slowly deteriorate and has the potential
to release fibers.
Examples of the more common ACBM found in schools are flooring, vinyl base,
mastic, roofing materials, gaskets in heating and air-conditioning equipment, ceiling
panels and tiles, wallboard, joint compound, plaster, pipe and boiler insulation, ductwrap insulation, duct joint tape, duct vibration dampening cloth, fireproofing on
structural members, fire brick for boilers, fire doors, acoustical spray-on, cement pipes,
and panels.
Friable vs. Nonfriable ACBM
Friable ACBM will release fibers into the air more readily than nonfriable ACBM.
Therefore, the AHERA Rule differentiates between friable and nonfriable ACBM. The
regulations define friable ACBM as material that may be crumbled, pulverized, or
reduced to powder by hand pressure when dry. Friable ACBM also includes previously
nonfriable material when it becomes damaged to the extent that when dry it may it may
be crumbled, pulverized, or reduced to powder by hand pressure. Undamaged nonfriable ACBM should be treated as friable if any action performed on the material will
make them friable.
Categories of Asbestos-Containing Building Materials
EPA identifies three categories of ACBM (See the definitions appearing in § 763.83 of
the AHERA Rule):
! Surfacing Materials -- Interior ACBM that has been sprayed on, troweled on,
or otherwise applied to surfaces (structural members, walls, ceilings, etc.) for
acoustical, decorative, fireproofing, or other purposes. This includes acoustical
plaster, hard plasters (wall or ceiling), fireproofing insulation, spray-applied or
blown-in thermal material, joint or patching compound (wall or ceiling), and
textured paints or plasters.
! Thermal System Insulation -- Insulation used to control heat transfer or prevent
condensation on pipes and pipe fittings, boilers, breeching, tanks, ducts, and
other parts of hot and cold water systems; heating, ventilation, and air
conditioning (HVAC) systems; or other mechanical systems. These insulation
materials include pipe lagging, pipe wrap, HVAC duct insulation, block
insulation, cements and muds, and a variety of other products such as gaskets
and ropes.
! Miscellaneous Materials -- Other, mostly nonfriable products and materials
found on structural components, structural members or fixtures, such as floor
tile, ceiling tile, construction mastic for floor and ceiling materials, sheet
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CHAPTER 2
An Introduction to Asbestos
flooring, fire doors, asbestos cement pipe and board, wallboard, acoustical wall
tile, and vibration damping cloth. "Miscellaneous materials" do not include
thermal system insulation or surfacing materials.
Please note that batt, blanket, and blown-in insulation should be placed in one of the
above categories according to use.
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CHAPTER 2
An Introduction to Asbestos
Chapter 2 Summary
Key Points About Asbestos
This chapter introduces some important terms used in the AHERA Rule. The
designated person should be especially familiar with the following:
Asbestos-Containing Material (ACM) -- Any material or product that contains
more than one percent asbestos.
Asbestos-Containing Building Material (ACBM) -- Surfacing ACM, thermal
system insulation ACM, or miscellaneous ACM that is found in or on interior
structural members or other parts of a school building.
Friable ACBM -- Material that may be crumbled, pulverized, or reduced to powder
by hand pressure when dry. Friable ACBM also includes previously nonfriable
material when it becomes damaged to the extent that when dry it may it may be
crumbled, pulverized, or reduced to powder by hand pressure.
Nonfriable ACBM -- Material that, when dry, may not be crumbled, pulverized, or
reduced to powder by hand pressure.
Surfacing ACM -- Interior ACM that has been sprayed on, troweled on, or
otherwise applied to surfaces (structural members, walls, ceilings, etc.) for
acoustical, decorative, fireproofing, or other purposes.
Thermal System ACM -- Insulation used to control heat transfer or prevent
condensation on pipes and pipe fittings, boilers, breeching, tanks, ducts, and other
parts of hot and cold water systems; heating, ventilation, and air-conditioning
(HVAC) systems; or other mechanical systems.
Miscellaneous ACM -- Other, mostly nonfriable, products and materials (found on
structural components, structural members or fixtures) such as floor tile, ceiling tile,
construction mastic for floor and ceiling materials, sheet flooring, fire doors,
asbestos cement pipe and board, wallboard, acoustical wall tile, and vibration
damping cloth.
Undamaged non-friable ACBM should be treated as friable if any action performed
would render these materials friable. When previously non-friable ACBM becomes
damaged to the extent that when dry it may it may be crumbled, pulverized, or
reduced to powder by hand pressure, it should be treated as friable.
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3
ASBESTOS HEALTH
RISKS
Health Effects Associated with Asbestos Exposure
The health effects associated with asbestos exposure have been studied for many years.
Results of these studies show that inhalation (breathing in) of asbestos fibers leads to
increased risk of developing several diseases. Exactly why some people develop these
diseases remains a mystery, but it has been well demonstrated that most asbestos-related
illnesses are dose-response related (i.e., the greater the exposure to airborne asbestos
fibers, the greater the risk of developing an illness).
Relative Hazards of Asbestos Exposure
Almost daily, we are exposed to some prevailing level of asbestos fibers in buildings
or experience some existing level in the outdoor air. Some fibers that are inhaled
remain in the lungs. Brief "bursts" of exposure, when added to the background level,
increase the potential to cause or trigger the development of an asbestos related disease.
These brief bursts of exposure occur in many ways. For example, when a carpenter
drills a hole in an asbestos fire door without taking any precautions, an increased
amount of asbestos may be released into the air. The more often these bursts of
exposure occur, the greater the risk of breathing asbestos fibers.
People most at risk for this additional exposure are maintenance and construction
workers who work on and disturb asbestos in buildings. This clearly demonstrates the
need for an active asbestos policy and an ongoing operations and maintenance (O&M)
plan for buildings that contain ACBM.
It is important to recognize that the majority of people who have developed diseases
because of asbestos exposures are former asbestos workers. These workers were
frequently exposed to high levels of asbestos fibers each working day, with little or no
protection. Today's asbestos maintenance workers and AHERA-trained asbestos
abatement workers are trained to follow specific work practices and wear appropriate
protection, including respirators, to minimize the risk of exposure. However, increased
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CHAPTER 3
Asbestos Health Risks
risk may occur when a worker who does not use a respirator or follow specific work
practices disturbs any ACBM.
The Respiratory System
The effects of asbestos exposure most often involve the lungs. Air breathed into the
body passes through the mouth and nose, continuing into the windpipe. The windpipe
divides into smaller and smaller tubes that end up in the lungs as air sacs called alveoli.
It is in these air sacs that respiration occurs. Oxygen is absorbed into tiny blood vessels
(or capillaries), and waste gases, such as carbon dioxide, pass out of the blood and are
exhaled.
The body has several mechanisms to "filter" the air it breathes. First, large particles
are removed in the nose and mouth. Many smaller particles are caught on the mucuscoated walls of the airway tubes. These airways have "hairy" linings (ciliate cells) that
constantly propel mucus upward. Particles caught in the mucus are swept up into the
back of the mouth. From here they are swallowed or expelled (spit out).
Unfortunately, cigarette smoking temporarily paralyzes these hair-like cells, disabling
one of the body's natural defenses against unwanted dust or fibers.
Despite natural bodily defenses, some dust particles inevitably reach the tiny air sacs
in the lungs. When this occurs the human immune system dispatches large cells called
macrophages to engulf the particles and "digest" them. These cells deposit a coating
on the particles and may begin forming scar tissue around them. This is just another
natural defense mechanism the body uses against unwanted debris in the lungs.
Asbestos-Related Diseases
If the body's defenses fail to control or remove asbestos fibers that enter the lungs, the
risk of developing an asbestos-related disease increases. Asbestos-related diseases
include asbestosis, lung cancer, mesothelioma, and other cancers.
! Asbestosis -- Asbestosis is a disease characterized by lung scarring. It reduces
lung elasticity -- the ability to inhale and exhale in response to muscular
contractions of the diaphragm -- and makes breathing very difficult. Asbestosis
is most common among workers who have been exposed to large amounts of
asbestos fibers over a period of time. It is a serious disease and, in those
persons exposed to high levels of asbestos, can eventually lead to disability or
death. All forms of asbestos are suspected to have the potential to cause
asbestosis. Like all diseases associated with asbestos exposure, it may take
many years for the disease to show up. The typical latency period for asbestosis
is 15 to 30 years. Available data indicate that the frequency of occurrence of
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CHAPTER 3
Asbestos Health Risks
asbestosis rises and the disease worsens with increasing dust exposure. The
Occupational Safety and Health Administration (OSHA) Asbestos Standards
were developed to minimize the incidence of asbestosis among asbestos workers
by reducing their exposure to asbestos.
! Lung Cancer -- As with asbestosis, there appears to be a dose-response
relationship between asbestos exposure and lung cancer. In addition, lung
cancer arising from asbestos exposure also has a latency period before
development -- typically 30 years or longer. The risk of contracting lung cancer
as a result of exposure to asbestos increases if the worker is a cigarette smoker.
Cigarette smokers who are exposed to asbestos are over 50 times more likely to
develop lung cancer than the normal, non-smoking population. As a result, a
program to help workers stop smoking and an asbestos operations and
maintenance program will help reduce the risk of lung cancer among asbestos
maintenance workers.
! Mesothelioma -- Mesothelioma is a cancer that occurs in the chest cavity lining
or in the lining of the abdominal (stomach) lining. This type of cancer spreads
rapidly and is always fatal. Cases of mesothelioma have been found in people
who have had a limited exposure to asbestos. The onset of this disease appears
to be independent of smoking behavior but related to dose and to time from first
known asbestos exposure. Mesothelioma tends to have a long latency period -usually 30 to 40 years.
! Other Diseases -- Several other diseases seem to occur more frequently among
people who have been exposed to asbestos. These include cancer of the
esophagus, stomach, colon, and pancreas; pleural (fibrous) plaques; pleural
thickening; and pleural effusion.
The risks of contracting any of these diseases make it extremely important that asbestos
maintenance workers utilize proper work practices and respiratory protection.
Risks Associated with Low Exposure
While studies of asbestos workers and laboratory animals clearly reveal that asbestos
is hazardous, the risks associated with low-level, non-occupational exposure (i.e., an
occupant of a building who is not actually disturbing the asbestos) have not been
directly demonstrated. Estimating low-level risks from exposure data is not a
straightforward process, and the validity of current methodologies is questionable.
Based on a thorough review of the literature available on the health effects of asbestos,
the National Institute for Occupational Safety and Health (NIOSH) has concluded that
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Asbestos Health Risks
there is no level below which the risks of contracting an asbestos-related disease are
zero. This means that there is no established safe level of exposure to asbestos.
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CHAPTER 3
Asbestos Health Risks
EPA Policy for Asbestos Control in Schools
EPA bases its policy for asbestos control in schools on the following premises:
! Although asbestos is hazardous, the risk of asbestos-related disease depends upon
exposure to airborne asbestos fibers.
! Based upon available data, the average airborne asbestos levels in buildings
seem to be very low. Accordingly, the health risk to most building occupants
also appears to be very low.
! Removal is often not a building owner's best course of action to reduce asbestos
exposure. In fact, an improper removal can create a dangerous situation where
none previously existed.
! EPA only requires asbestos removal to prevent significant public exposure to
airborne asbestos fibers during building demolition or renovation activities.
! Asbestos that has been identified will pose little risk if it is well maintained
under an operations and maintenance program. Improper operations and
maintenance also can cause dangerous situations. Therefore, EPA requires a
pro-active, in-place management program whenever ACBM is discovered and
is not removed.
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Asbestos Health Risks
Chapter 3 Summary
Key Points About Asbestos Health Risks
Asbestos-related diseases are dose-response related (the greater the exposure to
airborne fibers, the greater the risk of developing an illness) and have a latency
period (typically 15 to 30 years).
Exposure to asbestos may result in asbestosis (a disease characterized by lung
scarring, which reduces the lungs' ability to function), lung cancer, mesothelioma
(always-fatal cancer arising in the chest or abdominal cavity), and other diseases.
Risks associated with low-level, non-occupational exposure (e.g., a building occupant
who is not actually disturbing the asbestos) are not well established. The National
Institute for Occupational Safety and Health (NIOSH) has determined, however, that
there is no established safe level of exposure.
Asbestos that has been identified will pose little risk if it is well maintained under an
operations and maintenance program. EPA only requires asbestos removal to prevent
significant public exposure to airborne asbestos fibers during building demolition or
renovation activities.
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4
WHAT IS REQUIRED
OF THE LEA?
Scope and Purpose of AHERA
Broadly stated, AHERA requires that each Local Education Agency (LEA) perform
inspections to identify asbestos-containing materials in each of the public and private
elementary and secondary schools under its authority; develop, implement and update
asbestos management plans; take appropriate response actions; safely maintain asbestoscontaining building materials (ACBM); and comply with AHERA's recordkeeping
requirements.
The AHERA Rule outlines the general responsibilities of a LEA in § 763.84 and the
specific duties of the LEA in the succeeding sections of the rule.
General LEA Responsibilities
Under § 763.84 of the AHERA Rule, the LEA has the following general
responsibilities:
! Ensure that the activities of any persons who perform inspections, reinspections,
and periodic surveillance, develop and update management plans, develop and
implement response actions, and conduct operations and maintenance activities
are in compliance with all of the AHERA requirements.
! Ensure that all custodial and maintenance workers are properly trained.
! Ensure that workers and building occupants or their legal guardians are notified
at least annually about activities relating to ACBM.
! Ensure that short-term workers who may come in contact with asbestos in a
school are provided the locations of ACBM and suspected ACBM assumed to
be ACBM.
! Ensure that warning labels are properly posted.
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What is Required of the LEA?
! Ensure that management plans are available for inspection.
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CHAPTER 4
What is Required of the LEA?
! Appoint a "designated person" to ensure proper implementation of the AHERA
requirements.
! Ensure that the designated person receives adequate training to perform duties
assigned.
! Consider whether any conflict of interest may arise among personnel undertaking
activities related to the ACBM in a school or schools.
(See the Checklist of LEA General Responsibilities Under AHERA at the end of this
chapter.)
Conflicts of Interest
The AHERA Designated Person (school asbestos coordinator) should take into
consideration any conflict of interest and determine whether it should influence their
selection of contractors to accomplish asbestos related work in their schools. The
AHERA Rule identifies several situations where a conflict of interest may arise. For
example, the abatement contractor is not allowed to conduct final air sampling for
clearance by TEM analysis (See 40 CFR Part 763, Appendix A to Subpart E ((II)(B)(2)).
The group that determines whether an abatement site is acceptable for re-occupancy
should not be the same (or a related group) that is conducting the abatement work.
Similarly, if the LEA requires a management planner to sign a statement certifying that
the management plan is in compliance with AHERA, then the LEA may not want the
planner signing the statement to be the one who implements or will implement the plan.
The LEA may have unique concerns regarding potential conflicts that should be
discussed with and addressed by the designated person.
Specific Responsibilities of the LEA
Sections 763.85-763.99 of the AHERA Rule detail the specific responsibilities of the
LEA. These responsibilities are listed below, followed by brief descriptions. The
responsibilities are discussed in greater detail in subsequent chapters of this guide.
! Inspections -- An accredited inspector must conduct inspections of each school
building under the authority of the LEA. This involves visually inspecting
buildings for friable and nonfriable ACBM, sampling such materials unless they
are assumed to be ACBM, and having samples analyzed in accordance with the
AHERA regulations. Only accredited laboratories may be used to perform bulk
material sampling analyses.
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CHAPTER 4
What is Required of the LEA?
! Reinspections -- An accredited inspector must conduct a reinspection of all
friable and nonfriable known or assumed ACBM in each school building at least
once every three years that a management plan is in effect. A management
planner must review all three year inspection reports.
! Assessment -- For each inspection and reinspection, an accredited inspector
must provide a written assessment of all friable known or assumed ACBM in the
school building.
! Management Plans -- Each LEA must complete an asbestos management plan
for each school under its authority. An accredited management planner must
prepare the management plan based on the results of the inspection. In the
management plan, the management planner recommends appropriate response
actions, prepares cost estimates on the response actions, and schedules the
response actions. The management plan must be updated on a timely basis.
! Response Actions -- Based on the recommendations of the management planner,
the LEA must select the appropriate response actions consistent with the
assessment of the ACBM. The designated person must see to it that the response
actions are carried out in a timely manner and in compliance with the AHERA
requirements. "Timely manner" is not defined in the regulations but involves
the joint development of a schedule for plan implementation by the management
planner and the designated person. Only accredited laboratories may be used to
perform final clearance air sample analyses.
! Operations and Maintenance -- The LEA must implement an operations and
maintenance (O&M) program whenever any friable ACBM is present or
assumed to be present in a building under its authority. Where material
identified as nonfriable ACBM or nonfriable assumed ACBM is about to become
friable as a result of activities performed in the building, it must be treated as
friable and thus must also be subject to an O&M program. EPA recommends
that the LEA also manage nonfriable ACBM in their school buildings under an
O&M program.
! Training -- AHERA requires that building inspectors, management planners,
project designers, contractors/supervisors, and asbestos workers be accredited
before they can perform asbestos-related activities. The AHERA regulations
details specific training requirements for the designated person and for custodial
and maintenance workers, although these individuals are not required to
complete any EPA-approved courses or receive accreditation.
! Notification -- The LEA must issue the following notifications regarding
asbestos identified in its schools:
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What is Required of the LEA?
-- An annual notice to all workers and building occupants, or their legal
guardians, of all inspections, reinspections, and activities being
conducted to control asbestos exposure, including periodic
surveillance and asbestos removal, that are planned or in progress.
This notification should be documented in the management plan.
-- An annual written notice informing parent, teacher, and employee
organizations of the availability of the management plan for their
review. A dated copy of this notice must be maintained as part of
the management plan.
-- A notice to short-term workers (e.g., telephone repair workers,
utility workers, or exterminators) who may come into contact with
asbestos in a school identifying the location of ACBM or assumed
ACBM in the building. This notification should be documented in
the management plan.
A description of all notification processes must be maintained as part of the
management plan. The Parent Teacher Association (PTA) or school newsletter
may be used as a means to distribute the notifications to the students and their
families.
! Periodic Surveillance -- The LEA must conduct periodic surveillance in each
building under its authority at least once every six months after a management
plan is in effect. The periodic surveillance inspection report must be kept in the
management plan.
! Recordkeeping -- Records involving the inspection of and response to ACBM
must be kept in a centralized location in the administrative office of both the
school and the LEA. EPA recommends keeping these records in the
management plan for each school building and the overall management plan for
all school buildings. Recordkeeping is the responsibility of the designated
person. The following records must be kept:
-- Descriptions of preventive measures and response actions taken for
friable and nonfriable ACBM and suspected ACBM
-- Sampling information
-- Training information
-- Periodic surveillance information
-- Information on initial and additional cleaning performed
-- Information on operations and maintenance activities, including
information on any maintenance activities disturbing friable ACBM
-- Notifications to parents, building occupants, and short-term workers
-- Information on any fiber-release episodes
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CHAPTER 4
What is Required of the LEA?
! Warning Labels -- The LEA must attach a warning label immediately adjacent
to any friable and nonfriable ACBM and suspected ACBM assumed to be
ACBM located in routine maintenance areas (such as boiler rooms) at each
school building.
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CHAPTER 4
What is Required of the LEA?
Chapter 4 Summary
Key Points About LEA Responsibilities
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CHAPTER 4
What is Required of the LEA?
The LEA must have an accredited inspector conduct inspections of each school
building under its authority. A reinspection of all friable and nonfriable known or
assumed ACBM in each school building must be conducted at least once every three
years that a management plan is in effect. A management planner must review all
three year inspection reports.
For each inspection and reinspection, an accredited inspector must provide a written
assessment of all friable known or assumed ACBM in the school building.
The LEA must have an accredited management planner review the results of the
inspection/reinspection and the assessment and make written recommendations on
appropriate response actions. The accredited management planner also prepares the
asbestos management plan for each school under its authority.
The LEA must select the appropriate response actions consistent with the assessment
of the ACBM and the recommendations of the management planner.
The LEA must implement an operations and maintenance (O&M) program
whenever any friable ACBM is present or assumed to be present in a building under
its authority.
Building inspectors, management planners, project designers, contractors/
supervisors, and asbestos workers must complete EPA- or State-approved courses and
receive accreditation before they can perform any asbestos-related activities. The
AHERA Rule also specifies training requirements for LEA designated persons and
custodial and maintenance workers, although these individuals are not required to
complete any EPA-approved courses or receive accreditation.
The LEA must conduct periodic surveillance in each building under its authority at
least once every six months after a management plan is in effect.
The LEA must comply with the requirements to provide notification about asbestos
activities to workers, students, parents, teachers, and short-term workers.
The LEA must maintain records in accordance with the AHERA regulations.
The LEA must attach a warning label immediately adjacent to any friable and
nonfriable ACBM and assumed ACBM located in routine maintenance areas (such as
boiler rooms) at each school building.
Checklist of the Local Education Agency's
General Responsibilities Under AHERA
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CHAPTER 4
What is Required of the LEA?
The AHERA Designated Person must complete and sign a statement that the Local Education
Agency has met (or will meet) the responsibilities listed below. All references are to specific
provisions to the AHERA regulations (under § 763.84). The AHERA Designated Person should
be able to answer "yes" to each statement below.
1. The activities of any persons who perform inspections, reinspections, and
periodic surveillance, develop and update management plans, and develop and
implement response actions, including operations and maintenance, are carried
out in accordance with 40 CFR Part 763, Subpart E.
2. All custodial and maintenance employees are properly trained as required in 40
CFR Part 763, Subpart E and all other applicable federal and/or state regulations
(e.g., the Occupational Safety and Health Administration Asbestos Standard for
Construction, the EPA Worker Protection Rule, or applicable state regulations).
3. All workers and building occupants, or their legal guardians, are informed at least
once each school year about inspections, response actions, post-response action
activities, including periodic reinspections and surveillance activities, that are
planned or in progress.
4. All short-term workers (e.g., telephone repair workers, utility workers, or
exterminators) who may come in contact with asbestos in school are provided
information regarding the locations of ACBM and assumed ACBM.
5. All warning labels are posted in accordance with § 763.95.
6. All management plans are available for inspection, and notification of this
availability has been provided in accordance with § 763.93(g).
7. The undersigned person designated by the LEA according to § 763.84(g)(1) has
received adequate training as required by § 763.84(g)(2).
8. The LEA has and will consider whether any conflict of interest may arise from
the interrelationship between accredited personnel, and whether this potential
conflict should influence the selection of accredited personnel to perform
activities under 40 CFR Part 763, Subpart E.
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5
THE AHERA
INSPECTION
Introduction
An AHERA inspection must be conducted by an "accredited inspector," i.e., one who
has attended and successfully completed a course approved by EPA or an EPAapproved State program, passed an exam and received an accreditation number and
certificate. This accreditation must be updated annually. Once an AHERA inspection
is complete, the inspector must submit the results to the LEA in an inspection report.
There are two elements to an AHERA inspection: identification and physical
assessment.
Identification of ACBM
The initial inspection to identify all the ACBM in a building begins with locating and
listing all "homogeneous areas" of material that are suspected to contain asbestos. A
"homogeneous area" is an area of surfacing material, thermal system insulation, or
miscellaneous material that is uniform in color and texture. Suspected ACBM in a
homogeneous area or functional space must then be treated as ACBM unless samples
are taken and the sample analyses show the material to be non-asbestos. "Functional
space" means a room, group of rooms, or homogeneous area designated by a person
accredited to prepare management plans, design abatement projects, or conduct response
actions.
Homogeneous Areas
As was discussed in Chapter 2, interior materials suspected of containing asbestos must
be categorized as one of the following three types:
Surfacing Materials
Thermal System Insulation (TSI)
Miscellaneous Materials
Once a material is classified as a particular type, the inspector should identify areas
where the materials are all of one type.
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The AHERA Inspection
Note, EPA suggests that wings or additions added to a building should not be
considered homogeneous with the original structure. Building materials used in
different buildings should not be considered homogeneous. If there is any reason to
suspect that materials might be different, even if they appear similar, they should be
assigned to separate homogeneous areas, and if it is determined that sampling is needed,
such materials should be sampled separately. It is important that the inspector correctly
identify all homogeneous areas in the inspection report.
(See Example Form 1 at the end of this chapter for an example of how to record
information about the homogeneous areas in a school building.)
Functional Spaces
Once the inspector has identified the homogeneous areas in a building, he or she must
gather information that will tie each area to the uses or functions occurring within it.
The management planner will use the information gathered by the inspector to
determine functional spaces. Under the AHERA Rule, a functional space is essentially
a room, group of rooms, or space in a building that has an identified use. Examples
of functional spaces are classrooms, hallways, offices, mechanical rooms, ceiling
plenums, tunnels, and crawl spaces.
(See Example Form 2 at the end of this chapter for an example of how to record
information relating each homogeneous area to a functional space.)
Bulk Sampling
Under the AHERA Rule, all material suspected to be ACBM must be assumed to be
ACBM unless:
The homogeneous area is sampled as required by § 763.86 of the AHERA
Rule, and the samples are analyzed as required by § 763.87 of the
AHERA Rule and found to be non-asbestos; or
The suspect or assumed ACBM is in a building built after October 12,
1988, that is certified by an architect or developer as being asbestos-free.
Where sampling and analysis is performed on suspected ACBM, the procedures must
be properly documented and the sample's asbestos content must be below the EPA
definition of ACM (See Glossary in Appendices) in order for any of the suspect material
to be treated as asbestos-free.
Section 763.86 of the AHERA Rule sets forth requirements for bulk sampling based on
the type of material involved. Table 5-1 shows the number of samples required to be
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The AHERA Inspection
collected from each type of homogeneous area to meet the regulation requirements.
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The AHERA Inspection
Table 5-1
Bulk Sampling Requirements
Type of Material
Samples Required
Friable Surfacing Material
Area # 1,000 sq. ft.
3
Area > 1,000 sq. ft. but # 5,000 sq. ft.
5
Area > 5,000 sq. ft.
7
Thermal System Insulation (TSI)
TSI not assumed to be ACBM
3
Patched TSI not assumed to be ACBM (if patched
section < 6 linear or sq. ft.)
1
Each insulated mechanical system not assumed to
be ACBM where cement or plaster is used on
fittings such as tees, elbows, or valves
Samples in a manner sufficient to
determine if material is or is not
ACBM*
Friable Miscellaneous Material not Assumed to Be
ACBM
Samples in a manner sufficient to
determine if material is or is not
ACBM*
Nonfriable Suspected ACBM not Assumed to Be
ACBM
Samples in a manner sufficient to
determine if material is or is not
ACBM*
* EPA recommends that three samples be taken to meet this requirement
Note:
The designation of ACM for a homogeneous area based on one positive bulk
sample result is acceptable.
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The AHERA Inspection
The regulations do not indicate how many samples are required to meet the "in a
manner sufficient to determine." However, the EPA policy statement in the document
100 Commonly Asked Questions About the New AHERA Asbestos-in-Schools Rule
recommends that a minimum of three samples be taken from any homogeneous area to
prove that a material does not contain asbestos. However, the designation of ACM for
a homogeneous area based on one positive bulk sample result is acceptable.
Bulk samples are not required to be collected from any homogeneous area where the
accredited inspector has determined that the thermal system insulation is fiberglass,
foam glass, rubber, or other non-ACBM.
It is recommended that all samples taken always be analyzed, since one sample analysis
is rarely representative of a homogeneous area. EPA recommends the use of an
improved test method entitled "Method for the Determination of Asbestos in Bulk
Building Materials" in place of the 1982 procedures as found in 40 CFR Part 763,
Appendix E to Subpart E. Further EPA recommends that LEAs which have Polarized
Light Microscopy (PLM) laboratory results indicating floor tiles to be non-asbestos
containing may want to retest these materials using this new method. This method
should be considered for the following: 1) floor tiles which may contain thin fibers and
which were analyzed under the 1982 method and found not be contain asbestos, and 2)
materials such as hard wall and acoustical plaster, stucco or other similar multi-layered
materials or systems which were not analyzed and reported by layers.
(See Example Form 3 at the end of this chapter for a form that is representative of a
bulk sampling log that should appear in your inspection report.)
Exclusions to the AHERA Inspection Requirements
Under the AHERA Rule, all ACM that are used as interior building materials in a
school must be identified by ACBM category so that they may be properly sampled and
assessed for appropriate response action. However, identification of ACM at schools
is not required for ACM that is not installed (stored on site) or for consumer products
at the school (auditorium curtains, electrical wiring stored on-site, fire blankets, etc.).
ACM installed outside of the building (such as roofing materials and siding) is also
excluded from inspection under AHERA. However, this exemption does not extend to
the underside of any portico or covered exterior hallway or walkway or to any exterior
portion of a mechanical system.
Section 763.99 of the AHERA Rule also excludes from the inspection requirements any
sampling area or homogeneous area of a school building where:
! An accredited inspector has determined that, based on sampling records, friable
ACBM was identified in the area during an inspection conducted before
December 14, 1987. However, such ACBM must still be physically assessed
by the accredited inspector.
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! An accredited inspector has determined that, based on sampling records, nonfriable
ACBM was identified in the area during an inspection conducted before December 14,
1987. In such a case, the accredited inspector must identify whether material that was
nonfriable has become friable since the previous inspection and must assess the newly
friable ACBM.
! Based on sampling records and inspection records, an accredited inspector has
determined that no ACBM is present in the area and the records show that the area was
sampled before December 14, 1987, in substantial compliance with the AHERA Rule.
! The lead agency responsible for asbestos inspection in a State that has been granted a
waiver from the inspection requirements of the AHERA Rule has determined that,
based on sampling records and inspection records, no ACBM is present in the area.
The records must show that the area was sampled before December 14, 1987, in
compliance with the AHERA Rule.
! An accredited inspector has determined that, based on records of an inspection
conducted before December 14, 1987, suspected ACBM identified in the area is
assumed to be ACBM. In such a case, the inspector must identify whether material
that was nonfriable suspected ACBM assumed to be ACBM has become friable since
the previous inspection and must assess any newly friable material and previously
identified friable suspected ACBM assumed to be ACBM.
! Based on inspection records and contractor and clearance records, an accredited
inspector has determined that all ACBM was previously removed from the area.
! An architect or project engineer responsible for the construction of a new school
building built after October 12, 1988, or an accredited inspector signs a statement that
no ACBM was specified as a building material in any construction document for the
building or no ACBM was used as a building material in the building.
Physical Assessment
Once the inspector has identified all of the ACBM in a building, he or she must perform a
physical assessment of all TSI and friable material. Under § 763.88 of the AHERA Rule,
the physical assessment of ACBM involves classifying the material into one of the
following seven Physical Assessment Categories:
1.
2.
3.
4.
5.
Damaged or significantly damaged thermal system insulation (TSI) ACBM
Damaged friable surfacing ACBM
Significantly damaged friable surfacing ACBM
Damaged or significantly damaged friable miscellaneous ACBM
ACBM with potential for damage
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The AHERA Inspection
6. ACBM with potential for significant damage
7. Any remaining friable ACBM or friable suspected ACBM
The physical assessment may include the following considerations:
! Location and amount of the material
! Condition of the material, specifying:
-- Type of damage or significant damage
-- Severity of damage
-- Extent or spread of damage
!
!
!
!
Whether the material is accessible
Material's potential for disturbance
Known or suspected causes of damage or significant damage
Preventive measures that might eliminate the reasonable likelihood of undamaged
ACBM from becoming significantly damaged
To determine which of the seven Physical Assessment Categories a material should be
placed into, several terms must be defined. The preamble to the AHERA Rule, Federal
Register, October 30, 1987, p. 41830, examines the difference between "damaged
material" and "significantly damaged" material. According to the preamble, significant
damage exists where damage is evenly distributed across 10 percent or more of a functional
space or is localized over 25 percent of a functional space.
(See Example Form 4 at the end of this chapter for a form that may be used to show why
ACBM was assigned to a particular category.)
The preamble goes on to state that material has potential for significant damage, as
opposed to only potential for damage, if it is subject to major or continuing disturbance
due to factors such as accessibility or, under certain circumstances, vibration or air
erosion. If the accredited inspector determines that there is a high or strong likelihood of
major disturbance due to accessibility, vibration, or air erosion, there is a potential for
significant damage. If the likelihood of any of these factors occurring is moderate, there is
only a potential for damage. If the likelihood of any of these factors occurring is low, the
inspector should assign Physical Assessment Category No. 7 (any remaining friable ACBM
or friable suspected ACBM) to the material.
Because the physical assessment is used to determine which response actions will be chosen
to manage the asbestos, proper identification and assessment of ACBM are vital to the
effective implementation of the AHERA program. The decision tree that follows can help
determine the correct assessment category for material in a functional space (See the
Exercise at the end of this chapter for a brief exercise for determining the correct Physical
Assessment Category for a functional space).
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The AHERA Inspection
The Inspection Report
The results of an AHERA inspection or reinspection must be documented in an inspection
report. All decisions regarding ACBM in the LEA's buildings will be based on the
information found in this report, so it is vital that the report information be correct. If
materials are incorrectly identified as containing asbestos, the LEA will take on needless
expense for preventive measures, while if materials are incorrectly identified as not
containing asbestos, the LEA may expose building occupants to increased health risks and
itself to legal liability.
Contents of the Inspection Report
Section 763.85 of the AHERA Rule lists the required elements of the inspection report:
General Inspection Information
! Date of the inspection
! Signature of each accredited person who conducts inspection-related activities
! Ideally, a copy of the accreditation certificate for each accredited person making the
inspection; at minimum, the state of accreditation and accreditation number of each
accredited person who conducts inspection-related activities.
Information on Sampling/Assumed ACBM
!
!
!
!
!
!
!
!
!
Inventory of the locations of the homogeneous areas where samples are collected
Exact location where each bulk sample is collected
Dates that samples are collected
Homogeneous areas where friable suspected ACBM is assumed to be ACBM
Homogeneous areas where nonfriable suspected ACBM is assumed to be ACBM
Description of the manner used to determine sampling locations
Name and signature of each accredited inspector who collected the samples
State of accreditation of each accredited inspector who collected the samples
Accreditation number of each accredited inspector who collected the samples, if
applicable
Identification and Assessment Information
! List of whether the homogeneous areas identified in the report are surfacing
material, thermal system insulation, or miscellaneous material
! Assessments made of friable material and reasons for these assessments
! Name and signature of each accredited inspector making the assessment
! State of accreditation of each accredited inspector making the assessment
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! Accreditation number of each accredited inspector making the assessment, if
applicable
The inspection report should list the required elements in the order in which they are listed
above to promote uniformity and ease of comprehension. The inspection report should
also contain an introductory summary that briefly explains what will be found in the report.
Documentation such as field data sheets and optional photographs should appear in
appendices to the report.
(See the Inspection Report Compliance Checklist at the end of this chapter.)
Common Inspection Report Problems and Deficiencies
The designated person should ensure that the inspection report is complete. Asbestos in
Schools: Evaluation of the Asbestos Hazard Emergency Response Act: A Summary Report
identifies several areas in which inspection reports are often deficient. Examples include:
! Many inspection reports failed either to indicate areas where ACBM were present
or did so incompletely.
! Vibration dampening cloth, duct insulation, fire doors and linoleum were not
regularly identified as suspect ACBM.
! Eighty-two percent of school buildings had at least one ACBM unidentified in the
original AHERA inspection.
The best time to review the inspection report for completeness is during a building walkthrough, which is usually performed during the 6 month periodic surveillance inspection.
Such problems as missing or confusing warning labels, improper identification of
homogeneous areas, incomplete lists of suspect materials, and inaccurate or unclear sample
locations may be identified during the walk-through. Correction of problems identified
should be started immediately.
The designated person should be aware that an adequate number of samples must be
collected in order to determine whether an area is considered asbestos-containing (See
Table 5-1 above). If an adequate number of samples was not collected, the area must be
considered to be ACBM regardless of the results of the analyses. In such a situation, the
management planner, who reviewed the inspection/reinspection report, may advise the
LEA to either collect additional samples or may update the management plan to assume
that the areas in question are ACBM.
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Chapter 5 Summary
Key Points About the AHERA Inspection
An AHERA inspection must be conducted by an accredited inspector.
The inspector must identify all homogeneous areas of material that are suspected to
contain asbestos. Homogeneous areas contain asbestos that is uniform (alike) in
color and texture.
All material suspected to be ACBM must be assumed to be ACBM unless the
homogeneous area is sampled, and the analysis of the samples shows them to be nonasbestos. Adequate number of samples must be taken or the area will be considered
to be ACBM regardless of the results of the analyses.
Once the inspector has identified all ACBM in a building, he or she must perform a
physical assessment of all TSI and friable ACBM. This involves categorizing the
material into one of seven Physical Assessment Classifications.
The results of an AHERA inspection and the assessment must be documented in an
inspection report. This report will be used by the management planner to make
written recommendations on appropriate response actions.
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Chapter 5 Forms
On the following are blank forms, similar to those used by AHERA accredited
inspectors.
Form 1 requires that the inspector enter information pertaining to
homogeneous areas of suspected and known ACBM in a school building.
Using the inspection report, the inspector will: 1) list all of the homogeneous
areas in the school buildings, 2) enter the number of linear or square feet for
each area, 3) indicate whether the material is friable or non-friable, 4) enter
the type of ACBM that is present, and 5) indicate whether the ACBM is
assumed to be ACBM.
Form 2 requires that the inspector enter information in order to relate each
homogeneous area to a functional space. Using the inspection report, the
information entered on Form 1, and the building's floor plan, the inspector
will 1) link the homogeneous areas to a functional space, 2) assign a number to
each homogeneous area, 3) assign a letter to each functional space, and 4)
create a key for the numbers and letters that are used.
Form 3 is representative of a bulk sampling log that should be in the
inspection report.
Form 4 may be used to gather the information needed to show why a certain
category was assigned to ACBM.
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Example Form 1
Inspection Report: List of Homogeneous Areas
Project Name:
Address:
Area #
Area Description
Linear or
Sq. Ft.
-37-
L
S
Friable
Y/N
Type
S/T/M
ACBM
Y/N
CHAPTER 5
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Example Form 2
Functional Spaces/Homogeneous Areas
Building:
Functional Space
Letter
Homogeneous Areas by Number (Obtained from Form 1)
Key: L/S = Linear Feet/Square Feet S/T/M = Surfacing/Thermal/Miscellaneous
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Example Form 3
Bulk Sample Log
Date Sampled
School:
Homogeneous Area
Sampler's Name
Functional Space/Room:
Accreditation No.
Linear Feet:
Type of Suspect Material
Square Feet:
Surfacing
Friable
Manner of Sampling:
AREA DESCRIPTION:
Number
TSI
Non-friable
Location
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Misc.
CHAPTER 5
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Example Form 4
Individual Assessment Form
AREA #:
DESCRIPTION:
AHERA CATEGORY #:
1. Location & Amount
2. Condition, Type of Damage:
Severity of Damage:
Extent/Spread of Damage:
3. Accessibility:
4. Potential for Disturbance:
5. Causes of Damage:
6. Preventive Measures:
TYPE NAME:
ACCREDITATION
AGENCY:
SIGNATURE:
STATE:
ACCREDITATION:
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DATE ISSUED:
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The AHERA Inspection
Inspection Report Compliance Checklist
This checklist is designed to enable you to determine if the inspection report is complete and
contains each and every element required by law.
GENERAL:
1.
2.
3.
4.
The date of the inspection
The signature of each accredited person making the inspection
The State of accreditation of each accredited person making the inspection
If applicable, the accreditation number of each accredited person making the
inspection
INVENTORY OF LOCATIONS:
5. An inventory of the locations of the homogeneous areas where samples were
collected
6. The exact location where each bulk sample was collected
7. The date(s) that each sample was collected
8. The homogeneous areas where friable suspected ACBM is assumed to be ACBM
9. The homogeneous areas where nonfriable suspected ACBM is assumed to be
ACBM
SAMPLING:
10.
11.
12.
13.
A description of the manner used to determine sampling locations
The name and signature of each accredited inspector who collected the samples
The State of accreditation of each accredited inspector who collected the samples
If applicable, the accreditation number of each accredited inspector who collected
the samples
MATERIALS IDENTIFIED IN HOMOGENEOUS AREAS:
14. A list of whether the homogeneous areas identified are surfacing material,
thermal system insulation, or miscellaneous material
ASSESSMENTS:
15.
16.
17.
18.
Assessments made of friable material
The name and signature of each accredited inspector who made the assessment
The State of accreditation of each accredited inspector who made the assessment
If applicable, the accreditation number of each accredited inspector who made the
assessment
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6
THE MANAGEMENT
PLAN
Introduction
Once the accredited inspector has identified the ACBM in the building(s) and has
documented this information in the inspection report, an accredited management
planner will use the report to identify and address hazards or potential hazards
relating to the friable ACBM identified. The information from the inspection report
will become part of the management plan. The management plan, which is a sitespecific guidance document that the LEA designated person must follow in managing
the ACBM present in each school building, must be prepared by an accredited
management planner. A management plan must be updated to keep it current with
ongoing operations and maintenance, periodic surveillance, inspection, reinspections
and response action activities.
Table 6-1 identifies the elements required to be in the management plan under
§ 763.93 of the AHERA Rule. These requirements are discussed in greater detail in
the remainder of this chapter.
Table 6-1
Contents of the Management Plan
General Information
! List of the names and addresses of all school buildings
! Whether the school building contains friable ACBM, nonfriable ACBM,
assumed friable ACBM or assumed nonfriable ACBM
Designated Person Information
! Name, address, and telephone number of the LEA designated person
! Course name, dates, and hours of training taken by the designated person
Inspector Information
! Date of inspection or reinspection
! Name and signature of each accredited person making the inspection or
reinspection
! State and accreditation number of each accredited person making the
inspection or reinspection (or copy of accreditation)
Information on Sampling/Assumed ACBM
! Blueprint, diagram, or written description of each school building that
identifies clearly each location and approximate square or linear footage of
homogeneous areas where material was sampled for ACBM
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!
!
!
!
!
!
!
Exact location where each bulk sample was collected
Date of collection of each bulk sample
Homogeneous areas where friable suspected ACBM is assumed to be ACBM
Homogeneous areas where nonfriable suspected ACBM is assumed to be
ACBM
Description of the manner used to determine sampling locations
Name and signature of each accredited inspector collecting samples
State of accreditation and accreditation number of each accredited inspector
collecting samples (or copies of the accreditation certificates)
Analysis of Samples
! Copy of the analyses of any bulk samples collected and analyzed
! Name and address of any laboratory that analyzed bulk samples
! Statement that any laboratory used meets the accreditation requirements of §
763.87(a) of the AHERA Rule
! National Voluntary Laboratory Accreditation Program number (or certificate)
! Dates of any analyses performed
! Name and signature of the person performing each analysis
Physical Assessment Information
! Description of the assessments required by § 763.88 of the AHERA Rule of
all friable ACBM and suspected ACBM assumed to be ACM.
! Name and signature of each accredited person making the assessments
! State of accreditation and accreditation number of each accredited person
making the assessment (or copies of the accreditation certificates)
Response Action Information
! Recommendations made to the LEA by (an) accredited management
planner(s) regarding response actions
! Name and signature of each person making the recommendations
! State of accreditation and accreditation number of each person making
the recommendations (or copies of the accreditation certificates)
! Detailed description of preventive measures and response actions to be taken,
including methods to be used, for any friable ACBM
! Locations where such measures and actions will be taken
! Reasons for selecting the response action or preventive measure
! Schedule for beginning and completing each preventive measure and
response action
Information on ACBM Remaining after Response Actions
! A blueprint, diagram, or written description of any ACBM or suspected
ACBM assumed to be ACBM that remains in the school once response
actions are undertaken. This should be updated as soon as response actions
are completed,
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Information on Future Activities
! A plan for reinspection under § 763.85 of the AHERA Rule
! A plan for operations and maintenance (O&M) activities under § 763.91 of
the AHERA Rule
! A plan for periodic surveillance under § 763.92 of the AHERA Rule
! Description of the management planner recommendations regarding
additional cleaning under § 763.91(c)(2) of the AHERA Rule as part of an
O&M program
! The response of the LEA to any recommendation for additional cleaning
Information on Required Notifications
! Copies of the notifications and description of steps taken to inform workers
and building occupants (and their guardians) about inspections, reinspections,
response actions, and post-response actions, including periodic surveillance,
and the location and availability of the management plan on an annual basis
Periodic Surveillance Inspection Reports
Cost Estimate
! Evaluation of the resources needed to complete response actions and carry
out reinspection, O&M activities, periodic surveillance and training
Consultant Information
! Name of each consultant who contributed to the management plan and
accreditation certificates
Optional Information
! The LEA may require each management plan to contain a statement signed
by an accredited management plan developer that such person has prepared or
assisted in the preparation of such plan, or has reviewed such plan, and that
such plan is in compliance with AHERA. The statement should not be
signed by a person who, in addition to preparing or assisting in preparing the
management plan, also implements (or will implement) the management
plan.
(See the Management Plan Compliance Checklist at the end of this chapter.)
The Laboratory Report
AHERA requires that laboratories that perform the bulk material sampling analysis
and final clearance air sample analysis using Transmission Electron Microscopy
(TEM) be accredited. The National Institute of Standards and Technology (NIST)
has developed an accreditation program for laboratories, known as the National
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Voluntary Laboratory Accreditation Program (NVLAP). This program replaces the
older EPA interim laboratory proficiency program; after October 30, 1989, all
laboratories accredited under the EPA interim laboratory proficiency program were
required to become NIST accredited. Laboratories performing analyses under
AHERA must maintain appropriate NVLAP certification. If analyses of either bulk
material samples collected during the inspection process or final clearance air
samples collected after a response action and analyzed using Transmission Electron
Microscopy (TEM) are performed by a laboratory without current NVLAP
credentials, the analyses may not be used for AHERA compliance purposes.
Under § 763.87 of the AHERA Rule, a laboratory performing a bulk sample
analysis must submit the following documentation for inclusion into the management
plan:
! The name and address of each laboratory performing an analysis.
! The date of the analysis.
! The name and signature of the person performing the analysis. The name and
signature requirements apply to the microscopist(s) who actually performed
each analysis; it is recommended that the laboratory manager also sign the
reports.
! Proof that the laboratory has received NVLAP accreditation. This proof
should consist of a copy of the laboratory's NVLAP certificate, not just a
statement that the laboratory is accredited. For laboratory reports prepared
before the NVLAP program was started, proof of the laboratory's EPA
interim accreditation is acceptable but should include the laboratory's EPA
laboratory accreditation number.
Response Actions
In the management plan, the accredited management planner must recommend an
appropriate response action (operations and maintenance, repair, encapsulation,
enclosure, or removal) for all areas of thermal system insulation (TSI) and friable
ACBM. The final decision on which action should be taken, however, rests with the
LEA. Under AHERA, the response action to be taken must be "sufficient to protect
human health and the environment." Once it is determined which response actions
meet these criteria, the LEA may choose the action that is the "least burdensome."
AHERA identifies five possible response actions for managing asbestos in schools:
! Operations and Maintenance (O&M) Program -- This is a program of work
practices designed to maintain friable ACBM in good condition and ensure
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cleanup of asbestos fibers previously released. An effective O & M program
can prevent further release by minimizing and controlling friable ACBM
disturbance or damage. (See Chapter 8 for a complete description of the O&M
Program.)
! Repair -- This involves returning damaged ACBM to an undamaged condition
or to an intact state by replacing limited sections or patching damaged areas.
! Encapsulation -- This involves the treatment of ACBM with a material that
surrounds or embeds asbestos fibers in an adhesive matrix to prevent the
release of fibers. The encapsulant either creates a membrane over the surface
(bridging encapsulant) or penetrates the material and binds its components
together (penetrating encapsulant). Both types of encapsulants are applied to
the material surface using airless spray equipment at low pressure to reduce
release of fibers during the application.
! Enclosure -- This involves creating an airtight, impermeable, permanent
barrier around ACBM to prevent the release of asbestos fibers into the air.
The barrier is typically attached physically or sprayed on. For example,
materials such as PVC or corrugated metal may be fastened around insulated
piping, or a barrier may be constructed around asbestos fireproofing on
structural members by spraying material that cures into a hard shell.
! Removal -- This involves the taking out or the stripping of substantially all
ACBM from a damaged area, a functional space, or a homogeneous area in a
school building.
Selecting the Appropriate Response Action
The LEA is required to implement an O&M program whenever any friable ACBM is
present or assumed to be present in a building. An O&M program is not appropriate
as an initial response action for any damaged or significantly damaged material,
however. The flow charts on Figure 6-1 on the following page illustrate when each
response action is appropriate.
Project Design
All persons who design response actions for schools or public and commercial
buildings (including removal, encapsulation, enclosure, or repair -- other than small
scale, short duration repairs) must be accredited as a project designer. A response
action is defined by AHERA as a method that protects human health and the
environment from friable ACBM. Activities which create a high probability that
ACBM will be damaged or weakened to such an extent that it would be rendered
friable are also considered response actions.
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Although a written design is not mandated, EPA cannot recommend them strongly
enough. To undertake a response action without the benefit of a written design plan
to guide the work in progress is not only highly imprudent, but may unnecessarily
expose the public to an asbestos fiber release and/or the building owner to certain
liabilities. A written project design must be prepared by an accredited project
designer. An accredited project designer is one who has received accreditation
under AHERA by completing a prescribed training course for project designers and
passing an exam (See Chapter 9 for further information on accreditation).
Final Air Clearance After Response Actions
Final clearance of a functional space after a response action to remove, encapsulate,
or enclose ACBM or material assumed to be ACBM involves two steps: visual
inspection and the collection and analysis of air samples.
Visual Inspection
A visual inspection involves visually examining the asbestos removal area for
evidence that the abatement has been successfully completed, including thorough
clean-up. Visual inspections are also an important means of determining acceptable
completion of small-scale, short-duration O&M or repair operations.
To avoid a potential conflict of interest, it is highly recommended that the visual
inspection be performed by an inspector not affiliated with the abatement contractor
or anyone else financially associated with the conducting of the asbestos response
action.
The inspection should be conducted as rigorously as possible, with all spaces and
surfaces where the abatement was conducted being extensively examined for residual
ACBM debris. The inspection may involve:
! Scrutinizing every corner and crevice of the area within the containment
barriers used to isolate the functional space for the response action
! Using a ladder to inspect hard-to-physically-reach areas
! Brushing or wiping surfaces to detect dust
! Using a flashlight beam to detect loose debris or airborne residue
! Using a damp cloth to detect dust
! Inspecting permanent fixtures in the area, such as ceiling tile grid bars, pipes,
ducts, etc.
! Inspecting for asbestos-laden water, which may have leaked from the
enclosure onto floor surfaces beneath the abatement area
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! Examining surfaces for water and/or debris markings
! Checking crawl spaces on hands and knees; dirt floors may contain pulverized
or impacted asbestos debris
The aim of the visual inspection is to ensure that:
! Seals on windows, doors, and vents remain in place during final air
monitoring
! Isolation barriers separating the abatement area from non-abatement areas are
in place
! No evidence of residue, debris, or dust is present in the abatement area
The presence of any visible residue on surfaces within the abatement area indicates a
need for additional cleaning of the surfaces. If an area passes visual inspection but
then fails to meet air sampling and analysis requirements after that inspection, the
site must be recleaned and an additional visual inspection be conducted to detect any
material that may have been uncovered or released during recleaning. Only after
visual inspection clearance has been completed may final air sampling be done.
The results of the visual inspection should always be documented and signed by the
person conducting the visual inspection.
Final Air Sampling and Analysis
Section 763.90 of the AHERA Rule requires that the LEA accomplish final air
sampling and analysis of all removal, encapsulation, or enclosure projects by using
the transmission electron microscopy (TEM) method, unless the project involves no
more than 160 square feet or 260 linear feet of ACBM, in which case phase contrast
microscopy (PCM) may be used. Note that no final air clearance is required for
small-scale, short-duration O&M projects. (See Appendix B of the AHERA Rule for
information on the types of projects that qualify as small-scale, short-duration.)
Sampling operations for airborne asbestos following an asbestos abatement action
must be performed by qualified individuals completely independent of the abatement
contractor to avoid possible conflict of interest. EPA recommends that the LEA
obtain professional assistance to perform the sampling and analysis.
! The TEM Method
The TEM Method involves the collection of at 13 samples (five samples inside the
functional space; five samples representative of air entering the abatement site; and
three quality control "blank" samples). The air samples must be collected using
"aggressive" methods or artificially disturbing the air in the functional space before
and during sampling, as described in Appendix A, Section III(B)(7)(d) of the
AHERA Rule. In most cases, only the 5 samples collected inside the functional
space will be analyzed. If the average result of the five samples collected inside the
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functional space is less than 70 structures per square millimeter (70 s/mm2), the
response action is considered complete.
If the Z-test calculation is used, all 13 samples will be needed. The response action
may be considered complete when the average concentration of asbestos of the five
air samples collected within the affected functional space and analyzed by the TEM
method is not statistically significantly different from the average asbestos
concentration of the five air samples collected outside the affected functional space
and analyzed in the same manner, and the average asbestos concentration of the
three quality control samples is below 70 s/mm2. If the average of the three quality
control samples exceeds 70 s/mm2, the test is voided and resampling must be done.
If the difference in average asbestos concentration between the indoor and outdoor
samples is statistically significant, the contractor must reclean the functional space
and resampling must be done -- usually at the contractor's expense.
! The PCM Method
The PCM method may only be used on functional spaces affecting ACBM up to 160
square feet or 260 linear feet or less. In all areas affecting larger amounts of
ACBM, the TEM method must be used.
The PCM method involves collecting at least five samples inside the work area by
aggressive methods as described in Appendix A, Section III (B)(7)(d) of the AHERA
Rule and having them analyzed on a PCM microscope. Unlike the TEM method,
the PCM method does not call for the samples to be averaged; each sample stands on
its own. The clearance standard for PCM is 0.01 fibers per cubic centimeter of air
(0.01 f/cc). If all five samples pass this standard, the response action is considered
complete. If even one sample fails to pass the standard, the contractor must reclean
the area and resampling must be done.
(See the Final Air Clearance Documentation Checklist at the end of this chapter; see
Chapter 10 for a further discussion on documenting final air clearances.)
Implementation of the Management Plan
The LEA designated person is responsible for ensuring that the management plan is
implemented and updated in a timely manner. Table 6-2 below identifies some of
the activities and time requirements that must be met to achieve compliance with the
AHERA Rule. If the designated person determines that an element has not been
implemented as required, it must be implemented as soon as possible to limit
exposure and possible enforcement actions against the school.
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Table 6-2
Implementation Requirements for Operations
Associated with the Management Plan
Requests
Deadline
The Management Plan
The plan must be kept current with ongoing
O & M, periodic surveillance, inspection,
reinspection, and response action activities,
including updating the locations of ACBM after
response actions and O & M activities.
O&M Program
Must begin immediately upon the identification
of any friable ACBM present or assumed to be
present in the building.
O&M Training
In order to work in a building that may contain
asbestos, custodial workers and maintenance
staff members must have completed the 2-hour
training class described in § 763.92(a)(1) within
60 days of employment. Workers must have
completed the 14-hour training requirement
described in § 763.92(a)(2) to conduct O&M
activities which may disturb ACBM.
Periodic Surveillance
Under § 763.92(b)(1) of the AHERA Rule,
periodic surveillance must be conducted at least
once every 6 months after a management plan is
in effect.
Warning Labels
Must be posted as soon as possible after
identification of ACBM in any routine
maintenance area.
(cont.)
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Implementation Requirements for Operations
Associated with the Management Plan (cont.)
Requests
Deadline
Management Plan
Availability for Public
Review
The plan must have been made available for
public review in the administrative office of the
LEA on the date on which it was submitted to
the Governor for review. Notification of the
plan availability must be made annually.
Isolate a Functional
Space with Significantly
Damaged Friable
Surfacing ACBM
Must be isolated immediately and access
restricted if such measures are needed to protect
human health and the environment.
Repair and Maintain
Damaged or
Significantly Damaged
TSI
Must begin as soon as a management planner and
LEA determine that these conditions exist.
Common Management Plan Problems and Deficiencies
EPA has found two common problems in management plans:
! Although management plans were generally complete, in many instances the
location of homogeneous materials was not described clearly, and the material
classification (TSI, surfacing material, or miscellaneous) was often incorrect.
! Many management plans were not "user-friendly" and required specialized
instruction to understand. Because the management plan is the basis for all
asbestos work done in the school and is a guide for anyone who could disturb
ACBM during maintenance or custodial work, EPA recommends that the LEA
review the management plan for clarity and usability. In doing so, the LEA
should ensure that the response actions described in the plan are specific to the
site and to the ACBM involved, and that the implementation schedule is clear.
Management plans also often omit the description of final air sample clearance
locations. The designated person should check the management plan to see that all
clearance criteria were met and documented. Because of the complexity of the
sampling requirements, it is recommended that a professional consultant/air
monitoring firm be retained to assist in this activity.
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FREQUENT PROBLEMS WITH MANAGEMENT PLANS
The Asbestos Management Plans (Plan) should be considered "living" document.
Some Plans are left exactly the same as they were when they were created, with
no updates whatsoever. This is particularly true with respect to required records
of periodic surveillances, annual notifications, response actions or fiber releases,
and for records of the two-hour and sixteen-hour training for school employees and
maintenance workers. In fact, the administrative staff at individual schools are
sometimes unaware of the existence of management plans and/or do not know
where the school's copy of the plan is kept.
Copies of all pertinent certification credentials for AHERA inspectors,
management planners, project designers, workers and supervisors who have
participated in any response actions are required to be in the management plan, but
are not always included. Also proper documentation of air samplers' and
laboratories' accreditations are sometimes missing from Plans.
Homogeneous areas are often not clearly (and frequently are not properly)
defined on the basis of color, texture, size. Plaster and sheetrock are probably the
most often overlooked materials which are likely to comprise major areas of
suspected asbestos-containing building materials (ACBM). Sampling locations
within the individual homogenous areas are often not described precisely enough
to provide for any relocation of individual original sampling sites with any degree
of certainty.
Frequently insufficient numbers of samples are collected from individual
homogeneous areas (the correct minimum number being dependent upon the type
of building material and the homogeneous area size), and the sites for the sampling
which was done may have been selected in a manner other than as is set forth in
the management plan for how sampling locations were to have been determined.
Also, where warning signs are required, they may be missing, or if present, they
may not employ the prescribed text.
Sometimes functional areas are not taken into consideration in the preparation
of assessment and response actions recommendations. Also recommended
response actions may not have been carried out according to schedules shown in
the management plans and explanations or changes in the schedules may be absent.
Portable buildings on school grounds are sometimes overlooked in management
plans, or these units may have been moved onto or off of a school's grounds
without the school's management plan having been updated.
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Chapter 6 Summary
Key Points About the Management Plan
The management plan is a site-specific guidance document that the LEA
designated person must follow in managing the ACBM present in a school
building.
The management plan must be prepared by an accredited management
planner and must be updated in a timely manner.
The management plan must include the documentation required under
§ 763.87 of the AHERA Rule for each laboratory performing a bulk sample
analysis and the results of each analysis.
In the management plan, the management planner must recommend an
appropriate response action (operations and maintenance, repair,
encapsulation, enclosure, or removal) for all areas of TSI and friable ACBM
(including ACBM which has the potential of becoming friable).
All of the initial response actions implemented to control friable asbestos
require a project design specifying how to conduct the abatement project.
Final air clearance of a functional space after a response action to remove,
encapsulate, or enclose ACBM involves a visual inspection and the
collection and analysis of air samples.
Final air sampling must be done using the transmission electron microscopy
(TEM) method, unless the project involves no more than 160 square feet or
260 linear feet, in which case phase contrast microscopy (PCM) may be
used.
The LEA designated person is responsible for ensuring that the activities
related to the management plan are implemented and that the management
plan is updated in a timely manner.
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Table 6-4: Management Plan Compliance Checklist
This checklist is designed to enable you to determine if a management plan contains each and
every element required by law. This checklist is for management plans created for inspections
completed on or after December 14, 1987. Unless otherwise noted, all statutory references are
to the AHERA Rule.
GENERAL INFORMATION
1. List of the name and address of each school building
2. Whether the school building contains friable ACBM, nonfriable ACBM, and
friable and nonfriable ACBM assumed to be ACBM
DESIGNATED PERSON INFORMATION
3. The name, address, and telephone number of the designated person
4. The course name, dates, and hours of training taken by the designated person to
carry out his or her duties
5. Signed statement by the AHERA designated person that the LEA responsibilities
under AHERA Rule has been or will be met
INSPECTOR INFORMATION
6. The date of inspection or reinspection
7. The name and signature of each accredited person making the inspection or
reinspection
8. The State, accreditation number, and name of training provider for each
accredited inspector making the inspection or reinspection (copy of certificate is
ideal)
SAMPLING INFORMATION
9. A blueprint, diagram, or written description of each school building that
identifies clearly each location and approximate square or linear footage of
homogeneous areas where material was sampled for ACM
10. The exact location where each bulk sample was collected
11. The date of collection of each bulk sample
12. The homogeneous areas where friable suspected ACBM is assumed to be ACBM
13. The homogeneous areas where nonfriable suspected ACBM is assumed to be
ACBM
14. A description of how sampling locations were determined
15. The name and signature of each accredited inspector who collected the samples
16. State, accreditation number and name of training provider of each accredited
inspector who collected the samples (copy of accreditation certificate is ideal)
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Management Plan Compliance Checklist (cont.)
ANALYSIS OF SAMPLES
17. A copy of the analyses of any bulk samples collected and analyzed
18. The name and address of any laboratory that analyzed bulk samples
19. A statement that any laboratory used meets the accreditation requirements of
§ 763.87(a) (copy of the accreditation is ideal)
20. The dates of any analyses performed
21. The name and signature of the person performing each analysis
PHYSICAL ASSESSMENT INFORMATION
22. A description of the assessments required by § 763.88 of all friable ACBM and
suspected ACBM assumed to be ACBM.
23. The name and signature of each accredited person making the assessments
24. The State, accreditation number and name of training provider for each person
making the assessments (copy of certificate is ideal).
RESPONSE ACTION INFORMATION
25. Recommendations made to the LEA regarding response actions
26. The name and signature of each person making the recommendations
27. The State, accreditation number, and name of training provider for each person
making the recommendations (copy of certificate is ideal).
28. A detailed description of preventive measures and response actions to be taken,
including methods to be used, for any friable ACBM
29. The locations where such measures and actions will be taken
30. The reasons for selecting the response action or preventive measure
31. A schedule for beginning and completing each preventive measure and response
action
INFORMATION ON ACBM REMAINING AFTER RESPONSE ACTIONS
32. A blueprint, diagram, or written description, updated as response actions are
completed, of any ACBM or suspected ACBM assumed to be ACBM that
remains in the school once response actions are completed
INFORMATION ON OTHER ACTIVITIES
33. A plan for reinspection and copies of the reports required under § 763.85
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Management Plan Compliance Checklist (cont.)
34. A plan for operations and maintenance (O&M) activities under §
35.
36.
37.
38.
39.
40.
41.
763.91
A plan for periodic surveillance and copies of the reports (see §
763.92)
A description of the management planner recommendations
regarding additional cleaning under § 763.91(c)(2) as part of an
O&M program and documentation of cleaning
A description of steps taken to inform workers and building
occupants about inspections, reinspections, response actions, and
post-response actions, including periodic surveillance
An evaluation of the resources needed to complete response actions
and carry out reinspection, O&M activities, periodic surveillance
and training
The name of each consultant who contributed to the management
plan
With respect to each consultant who contributed to the management
plan, a copy of the accreditation certificate (or name of training
provider, State and accreditation number)
The response of the LEA to any recommendation for additional
cleaning
Checklist of Final Air Clearance Documentation
This checklist will indicate whether each final clearance was properly documented.
1. The name and signature of any person collecting any air sample required
to be collected at the completion of a response action
2. The locations where those samples were collected
3. The name and address of the laboratory, analyzing the samples
4. The date(s) of analysis
5. The results of analysis
6. The method of analysis
7. The name and signature of the person performing the analysis
8. Evidence that the laboratory is NVLAP accredited
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7
REINSPECTIONS AND
PERIODIC SURVEILLANCE
Introduction
Every three years after implementation of a management plan, an accredited
inspector must conduct a reinspection of all friable and nonfriable known or assumed
ACBM in every school building in order to determine if there has been any change
in the condition of the ACBM. An accredited management planner must then review
the reinspection report to identify any new hazard potential and revise the
management plan to address newly identified hazards. Based on the updated data,
new response actions to address these hazards must be selected, and these actions
must be carried out in a timely manner.
The reinspection process presents an ideal time for an accredited inspector and
management planner to address any problems found in the initial inspection report
and management plan. EPA's document A Guide to Performing Reinspections
Under the Asbestos Hazard Emergency Response Act (AHERA) (March 1992) is
useful in planning and assessing the reinspection requirements.
Inspector Responsibilities
Under § 763.85(b) of the AHERA Rule, in conducting a reinspection, the inspector
must:
! Visually reinspect and reassess the condition of all friable known or assumed
ACBM.
! Visually inspect material that was previously considered nonfriable and touch
the material to determine whether it has become friable since the last
inspection or reinspection.
! Identify any homogeneous areas in which material has become friable since
the last inspection or reinspection.
! Bulk samples may be collected and submitted for analysis for any
homogeneous area of newly friable material that is already assumed to be
ACBM.
! Perform a physical assessment, in accordance with § 763.88 of the AHERA
Rule, of the condition of the newly friable material in areas where samples
are collected and of newly friable materials in areas assumed to be ACBM.
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! Reassess the condition of friable known or assumed ACBM previously
identified.
! Record and submit the following information for inclusion in the management
plan to the LEA designated person within 30 days of the reinspection:
-- Date of the reinspection
-- Name and signature of the person conducting the reinspection
-- State, accreditation number, and training provider name for any person
conducting the reinspection (copy of certificate is ideal)
-- Exact locations where samples were collected during the reinspection
-- Description of the manner used to determine sampling locations
-- Name and signature of each accredited inspector who collected the
samples
-- State, accreditation number, and training provider name for each inspector
who collected the samples (copy of certificate is ideal)
-- Any assessments or reassessments made of friable material
-- Name and signature of the accredited inspector making the assessments
-- State, accreditation number and training provider name for each inspector
making the assessments (copy of certificate is ideal)
Management Planner Responsibilities
Once a reinspection is completed, the management planner must:
! Review the results of the reinspection. This includes reviewing the original
inspection report, periodic surveillance records, and the completed
reinspection forms and report. The management planner should conduct
school visits and gather other information so that he or she can make effective
response action recommendations.
! Make written response action and preventive measure recommendations for
each area of friable surfacing and miscellaneous ACBM and each area of TSI
ACBM. The management planner should determine whether additional
cleaning is necessary and, if so, specify how, when, and where to perform
cleaning. The management planner should also include an implementation
schedule for the recommended activities and make an estimate regarding the
resources (cost, personnel, equipment, etc.) needed to conduct the activities.
! Review the adequacy of the Operations & Maintenance Program.
! The recommendations should include a record of the name, signature, State,
accreditation number and training provider name for the management planner
(copy of certificate is ideal) and the date on which the management planner
submitted the recommendations.
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Reinspections and Periodic Surveillance
For further information on reinspection requirements, review A
Guide to Performing Reinspections Under the Asbestos Hazard
Emergency Response Act (AHERA) (March 1992).
Periodic Surveillance
At least once every six months after a management plan is in effect, the LEA must
conduct periodic surveillance in each building that contains ACBM or is assumed to
contain ACBM. The surveillance does not have to be conducted by an accredited
person, but it should be conducted either by the LEA designated person (if he or she
is trained) or by someone who is appropriately trained on asbestos (such as a
maintenance person).
Periodic surveillance involves a visual inspection of all areas that are identified in
the management plan as ACBM or assumed ACBM. In evaluating each
homogeneous area, the person conducting the surveillance must visually inspect all
areas identified in the management plan as ACBM or suspected ACBM and record
whether there are any changes in the condition of the material (including if there are
no changes). The date of the surveillance, the name of the person conducting the
surveillance, and any change in condition of the ACBM or assumed ACBM must be
documented and included in the management plan within a reasonable amount of
time, such as 30 days from the periodic surveillance.
Chapter 7 Summary
Key Points About Reinspections and Periodic Surveillance
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Reinspections and Periodic Surveillance
As long as any ACBM remains in a school building, the building must be
reinspected at least once every three years.
The reinspection and assessments/reassessments must be conducted by an
accredited inspector. The results of the inspection must be submitted to the
Designated Person within 30 days to include into the management plan.
The management planner must: 1) review the results of the reinspection,
2) make written response action and preventive measure recommendations for
each area of friable surfacing and miscellaneous ACBM and each area of TSI
ACBM, 3) determine whether additional cleaning is necessary and, if so,
specify how, when, and where to perform cleaning, 4) include an
implementation schedule for the recommended activities and make an
estimate regarding the resources needed to conduct the activities, and
5) review the adequacy of the Operations & Maintenance Program.
At least once every six months after a management plan is in effect, the LEA
must conduct periodic surveillance in each building that contains ACBM or
is assumed to contain ACBM.
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8
THE OPERATIONS AND
MAINTENANCE PROGRAM
Introduction
As discussed in Chapter 6, the management planner is responsible for recommending
appropriate response actions for managing ACBM found in a school building. An
operations and maintenance (O&M) program must be implemented whenever any
asbestos-containing building materials are found in a the school building. The
purpose of the O&M program is to prevent the release of asbestos fibers through
careful management of asbestos-containing building materials.
Managing Asbestos in Place, A Building Owner's Guide to
Operations and Maintenance Programs for ACM (the "Green
Book") offers important information on how to implement an
O&M program effectively.
Objectives of the O&M Program
An O&M program consists of a set of procedures and practices for operating and
maintaining a building to keep it as free of asbestos contamination as possible. The
program should be designed specifically to address the ACBM present in the
building involved.
An O&M program has three main objectives:
! Clean up existing contamination.
! Minimize future fiber release by controlling access to ACBM and instituting
proper work practices.
! Properly maintain the ACBM until it is removed.
Since National Emission Standards for Hazardous Air Pollutants (NESHAP)
regulations (See Chapter 11 for a discussion of NESHAP) require that friable and
nonfriable ACBM which is likely to become friable be removed from buildings
before demolition, the O&M program is not a permanent solution. In addition, the
asbestos NESHAP may regulate the removal of asbestos as part of a renovation. It
is also not a means by which full-scale asbestos abatement can be accomplished.
The intentional disturbance of ACBM should be limited to the repair or removal of
small areas of significantly damaged ACBM or to small areas where removal is
necessary to make maintenance or minor renovation activities easier. Some small
scale, short duration activities may be subject to asbestos NESHAP requirements if
enough ACBM will be disturbed during a calendar year. Larger abatement projects
that require extensive planning and technical expertise may not be part of the
AHERA O&M program. Limited encapsulation and enclosure could be used to
enhance an O&M program by reducing the likelihood of contact with the ACBM,
however.
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Required Elements of An O&M Program
Under § 763.91 of the AHERA Rule, the LEA must ensure that the O&M program
involve the following elements:
! Cleaning
! Specialized work practices and procedures for O&M activities disturbing
friable ACBM
! Training
! Emergency Response Procedures
Cleaning
All areas of a building where friable ACBM and suspected ACBM, or significantly
damaged TSI ACBM is present must be cleaned at least once after the completion of
the AHERA inspection. It must also be cleaned before the initiation of any response
action (other than O&M activities or repair). The exception would be where the
building had been cleaned using similar methods within the previous six months.
The cleaning must include the following:
! HEPA-vacuuming or steam-cleaning all carpets
! HEPA-vacuuming or wet-cleaning all other floors and all other horizontal
surfaces
! Disposing of all debris, filters, mopheads, and cloths in sealed, leak-tight
containers
The management planner may also recommend that additional cleaning be
performed. The methods and frequency of any additional recommended cleaning
should be included in the management plan.
Specialized Work Practices and Procedures
The LEA must ensure that the following procedures are followed for any O&M
activities disturbing friable ACBM:
! Restrict entry into the area by persons other than those necessary to perform
the maintenance project.
! Post signs to prevent entry by unauthorized persons.
! Shut off or temporarily modify the air-handling system and restrict other
sources of air movement.
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! Use work practices or other controls, such as wet methods, protective
clothing, HEPA vacuums, mini-enclosures, and glove bags, as necessary to
inhibit the spread of any released fibers.
! Clean all fixtures or other components in the immediate work area.
! Place the asbestos debris and other cleaning materials in a sealed, leak-tight
container.
Training
Within 60 days of hire, maintenance and custodial staff who may work in a building
that contains ACBM must receive at least two hours of asbestos awareness training.
Those members of the maintenance and custodial staff who conduct any activity that
will disturb ACBM must receive an additional 14 hours of training. Other state and
local training requirements may apply. (See Chapter 9 for further information on
training requirements.)
Emergency Response Procedures
As long as ACBM remains in a building, there is a risk of a fiber release episode.
Custodial and maintenance workers should be aware of this and should always report
any of the following occurrences to the LEA designated person:
! Any debris found on the floor or other horizontal surface
! Any water or physical damage to the ACBM
! Any other evidence of possible fiber release
There are two types of fiber release episodes: minor episodes and major episodes.
The specific procedures that must be followed depend on which type of episode
occurs.
Minor Fiber Release Episode
A minor fiber release episode consists of the falling or dislodging of three square or
linear feet or less of friable ACBM. Section 763.91(f)(1) of the AHERA Rule
requires that when such an event occurs, the LEA must ensure that:
!
!
!
!
The debris is thoroughly saturated using wet methods
The area is cleaned
The asbestos debris is placed in a sealed, leak-tight container
The area of damaged ACBM is repaired with such materials as asbestos-free
spackling, plaster, cement, or insulation; sealed with latex paint or an
encapsulant; or an appropriate response action is implemented as required by
§ 763.90 of the AHERA Rule
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When a minor fiber release episode occurs, AHERA allows the designated person to
assign an appropriately trained O&M in-house team to clean up the debris and make
repairs as soon as possible. (See Chapter 9 on training requirements.) Note,
however, that local regulations may be more stringent than the AHERA
requirements.
Major Fiber Release Episode
A major fiber release episode consists of the falling or dislodging of more than three
square or linear feet of friable ACBM. Section 763.91(f)(2) of the AHERA Rule
requires that when such an episode occurs, the LEA must ensure that:
! Entry into the area is restricted and signs posted to prevent entry into the area
by persons other than those necessary to perform the response action.
! The air-handling system is shut off or temporarily modified to prevent the
distribution of fibers to other areas in the building.
! The response action for any major fiber release episode is designed by
persons accredited to design response actions and conducted by persons
accredited to conduct response actions.
After a response action is implemented to manage a major fiber release episode, the
final air clearance requirements of AHERA must be met before the response action
is considered complete. (See Chapter 6 on the final air clearance requirements.)
Major and minor fiber-release episodes must be documented and included in
the management plan regardless of whether the LEA uses in-house staff or an
outside asbestos abatement contractor to implement an appropriate response
action. If an outside contractor is used, be sure that the contractor's crew has been
properly trained or certified before signing a contract.
(See the Fiber Release Episode Report at the end of this chapter.)
Other Elements of an O&M Program
In addition to the elements required by § 763.91 of the AHERA Rule, other
elements are either recommended or required by the rule or related regulations.
These include:
! Notification
! Labeling
! Employee Protection and Medical Surveillance
! Maintenance and Renovation Permit System
! Special Work Practices for Maintenance Activities
! Special Work Practices for Renovation/Remodeling
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Notification
Once ACBM is identified or assumed to be present in a building, the LEA must
provide an annual written notification to building occupants, employees, and parents
on the locations of asbestos-containing building materials in the school buildings, the
availability of the asbestos management plan, and recent and upcoming asbestos
activities, such as abatement projects, reinspections, etc. Other types of information
to include in the notification are: what asbestos is and how it is typically used; the
health effects associated with asbestos exposure; the type(s) of ACBM present in the
building; the location(s) of these materials; how individuals can avoid disturbing the
ACBM; how damage is recognized and to whom it should be reported; how
custodial and maintenance personnel are dealing with these materials to prevent fiber
release; the asbestos-related training for custodial and maintenance personnel; the
steps that will be taken to protect the health and safety of building occupants; and the
name and telephone number of the LEA designated person responsible for asbestosrelated activities in the building.
Such a notification alerts affected parties to a potential hazard in the building.
Building occupants, employees, and others who are aware of the presence of ACBM
are less likely to disturb the material and cause fiber release.
Notification of building occupants, employees, parents and others is best
accomplished through distributing written notices, which may be tailored to specific
parties. A common practice is to publish the notification in the school's newsletter,
which is distributed to school employees and parents. The designated person must
document the notification process and maintain records of all notifications made.
Labeling
Under § 763.95 of the AHERA Rule, the LEA must attach a warning label
immediately adjacent to any friable and nonfriable ACBM and suspected ACBM that
is located in routine maintenance areas (such as boiler rooms) at each school
building. Such material includes friable ACBM that was responded to by a means
other than removal (e.g., encapsulation) and ACBM for which no response action
was carried out.
The labels must be prominently displayed in readily visible locations, must be in
print that is readily visible due to its large size or bright color, and must remain
posted until the ACBM that is labeled is removed. The warning label must read:
CAUTION: ASBESTOS. HAZARDOUS. DO NOT DISTURB
WITHOUT PROPER TRAINING AND EQUIPMENT.
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Unlike notification, labeling is not intended as a way to disseminate general
information. Instead, it is a last line of defense to prevent unprotected individuals
from unknowingly disturbing ACBM.
Employee Protection & Medical Surveillance Programs
The OSHA Asbestos Standard for the Construction Industry and the EPA Worker
Protection Rule explain when employees are required to wear a negative-pressure
respirator and must be involved in a medical surveillance program (see also OSHA
Asbestos Standard for General Industry). The purpose of a medical surveillance
program is to determine whether or not an employee is healthy enough to wear a
respirator and to detect any health changes in an employee's body resulting from
working in asbestos-contaminated areas. Changes in health may indicate the onset of
an asbestos-related disease.
In addition, any employee who works in an environment where fiber levels are at the
permissible exposure limit or higher or who wears a negative-pressure respirator as
part of his or her job must participate in a respiratory protection program. The only
way to determine whether these fiber levels exist is to collect air samples during
projects that disturb ACBM. In an O&M program, the use of negative-pressure
respirators will make it necessary for most custodial and maintenance workers to
participate in both the medical surveillance program and the respiratory protection
program. Even if fiber levels are below the permissible exposure limit described
above, it is strongly suggested that an LEA establish these programs and require that
employees wear respirators any time they are likely to disturb ACBM.
Maintenance & Renovation Permit System
One of the most difficult tasks that the LEA designated person faces is minimizing
accidental disturbances of ACBM during maintenance and renovation operations.
One way that a designated person can control such disturbances is by establishing a
permit system where all work orders or requests are processed through the
designated person.
In a permit system, all requests for maintenance or renovation activities are given to
the designated person before a work order to proceed is issued. The designated
person then checks the management plan for information about the presence of
ACBM where work is to be performed and physically inspects the area in question to
make sure that the records reflect actual conditions. If no asbestos is present, the
designated person can sign and issue the work order. If ACBM is present, the
designated person can sign the work order and then either ensure that trained
maintenance or renovation workers are properly equipped to handle the ACBM or
dispatch an "emergency response" team to remove the ACBM. In situations where
there are large amounts of ACBM, maintenance or renovation work that does not
have to be done immediately should be postponed until the ACBM in the area can be
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removed by an accredited contractor. The permit system should be in place for all
facility maintenance work conducted by the LEA staff, outside contractors, and
outside short-term workers.
When outside contractors or short-term workers are likely to come into contact with
ACBM in a school building, they must be notified of the locations of ACBM or
suspected ACBM in the building. This notification should be documented. These
workers should have documentation of appropriate training, should they disturb
ACBM during their work. Note that State licensing requirements vary.
(See Example Form 5 at the end of this chapter for an example of a maintenance and
renovation permit application.)
Special Work Practices for Maintenance Activities
In buildings where ACBM is present, routine maintenance activities, such as work
on light fixtures, plumbing fixtures and pipes, air registers, HVAC ducts, and other
accessible parts of a building's utility systems, can disturb ACBM and raise levels of
airborne asbestos. As a result, maintenance workers should be instructed not to
perform any maintenance work that could disturb ACBM unless they are
appropriately trained and use specific work practices. These work practices should
be tailored to reflect the likelihood that an activity will disturb the ACBM and cause
fibers to be released. In determining which work practices should be followed,
activities should be placed in one of four categories:
! Contact with ACBM Unlikely -- In some buildings with ACBM, many
routine maintenance activities can be conducted without contacting the
ACBM. Changing a light bulb in a fixture that has asbestos-containing
acoustical plaster nearby can usually be performed without jarring the fixture,
for example. (Note that under the AHERA Rule, the top of the fixture should
already have been wet-cleaned to remove settled fibers.) In such situations
where contact with ACBM is unlikely, the only precaution other than normal
care generally necessary is to ensure that respirators and a HEPA vacuum are
available if needed. These do not have to be taken to the site of the project;
they should just be available at a known location in the building.
When maintenance is performed in parts of the building that are free of
ACBM, no special precautions are usually necessary. An exception would be
work in an area containing no ACBM that causes vibrations to be transferred
to a location where ACBM is present.
! Accidental Disturbance of ACBM Possible -- Where routine maintenance
and repair activities are conducted on fixtures or system parts that are located
near friable ACBM, maintenance workers may unintentionally disturb the
ACBM and release asbestos fibers. Maintenance work on ventilation ducts in
an air-handling room where asbestos fireproofing is on the structural beams
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could accidentally disturb the fireproofing, for example.
For a discussion of the work practices needed where an accidental disturbance
of ACBM is possible, see the Green Book.
! Disturbance of ACBM Intended or Likely -- Some maintenance and repair
activities will make ACBM disturbance almost unavoidable. Installing new
sprinkler or piping systems will make it necessary to hang pipes from
structural members or from the ceiling, and if the beams or ceilings are
insulated with ACBM, the ACBM will be scraped away to install hangers.
Similarly, pulling cables or wires through spaces with ACBM or ACBM
debris is likely to dislodge pieces of the ACBM or disturb ACBM debris and
dust. Any time ceiling tiles are moved to allow for entry into the space above
a suspended ceiling, settled dust on top of the tiles will be recirculated into
the air. If the beams or decking above the ceiling are covered with ACBM,
the dust is likely to contain asbestos fibers.
A designated person should not allow such intentional disturbances of ACBM
to proceed in an uncontrolled manner. The designated person should ensure
that the elements required under § 763.91 of the AHERA Rule to be part of
an O&M program are implemented effectively and that the regulatory
requirements of the EPA Worker Protection Rule and the OSHA Asbestos
Standard for the Construction Industry are followed.
! A Large Amount of ACBM Will be Disturbed -- If the maintenance work
is part of general building renovation, federal regulations may require that
ACBM be removed before the project begins. Even if smaller amounts of
ACBM are to be disturbed, building owners should consider removing all
ACBM from the area of the building where the maintenance work is planned.
Typically, an outside abatement contractor would be hired for the removal
project before the maintenance work begins. If the LEA decides to use its
own staff to remove the ACBM, these workers must be fully trained and
accredited in asbestos abatement. (See Chapter 9 for information on the
training and accreditation requirements for asbestos abatement.)
Maintenance of Vinyl Asbestos Tile
(Revised from a "Guidelines for the Maintenance of Asbestos-Containing Floor Coverings"
developed by Rhode Island Department of Health and the Environmental Protection Agency, New
England)
Vinyl Asbestos Tile (VAT) is the most prevalent source of asbestos containing
material in our schools and most likely will be for years to come. Although VAT is
considered non-friable, the frictional forces exerted on these materials during routine
floor-care maintenance operations can release asbestos fibers.
The principle types of floor covering maintenance performed routinely on resilient
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floor tiles include:
1) spray-buffing and dry burnishing; and
2) wet scrubbing and stripping followed by refinishing.
The following are guidelines on the maintenance of asbestos-containing floor
coverings. When properly implemented, these guidelines should help you reduce the
potential for the release of asbestos fibers into the air. You may want to keep a copy
of these guidelines in the Operations and Maintenance section of your AHERA
Management Plan.
Stripping of Vinyl Asbestos Floor Coverings
Training
Custodial and maintenance personnel who are responsible for the care and
maintenance of asbestos containing floor coverings should be thoroughly trained to
safely and properly operate the machines, pads and floor care chemicals used at the
facility.
Frequency of Stripping
Stripping of vinyl asbestos floor coverings should be done as infrequently as possible
(e.g., once per year maximum and preferably when the building is unoccupied).
Excessive stripping of floors using aggressive techniques will result in increased
levels of asbestos fibers in the air.
Prior to Stripping
Prior to machine operation, apply an emulsion of chemical stripper in water to the
floor. Use a mop to soften the wax or finish coat.
Stripping Operations
When stripping floors becomes necessary, the machine used for stripping the finish
should be equipped with the least abrasive pad as possible (black pads are usually the
most abrasive and the white pad the least abrasive). Consult with your floor tile and
floor finish product manufacturer for recommendations on which pad to use on a
particular floor covering. Incorporate the manufacturer's recommendations into
your floor maintenance work procedures.
The machine used to remove the wax or finish coat should be run at a low rate of
speed (i.e., ranging between 175-300 rpm) during the stripping operation. There is
a direct correlation between machine speeds and the release of asbestos fibers from
asbestos containing floor coverings. The higher the machine speed the greater the
probability of asbestos fiber release.
Never perform dry stripping. Always strip floors while wet. Do not operate a floor
machine with an abrasive pad on unwaxed or unfinished floor containing-asbestos
materials.
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Consult with floor tile and floor finish product manufacturers concerning specific or
unique problem(s) on the maintenance of your floors.
After Stripping
After stripping and before application of a high solids floor finish, the floor should
be thoroughly cleaned, while wet, preferably with a Wet-Vac HEPA filtration
vacuum system.
Finishing of Vinyl Asbestos Floor Coverings
Use of Sealer and Solids Finish
Prior to applying a finish coat to a vinyl asbestos floor covering, apply 2 to 3 coats
of sealer. Continue to finish the floor with a high percentage solids finish.
It is an industry recommendation to apply several thin coats of a high percentage
solid finish to obtain a good sealing of the floor's surface, thereby minimizing the
release of asbestos fibers during finishing work.
Spray-Buffing Floors
When spray-buffing floors, always operate the floor machine at the lowest rates of
speed possible and equip the floor machine with the least abrasive pad as possible.
A recent EPA study indicated that spray-buffing with high-speed floor machines
resulted in significantly higher airborne asbestos fiber concentrations than
spray-buffing with low speed machines.
Burnishing Floors
When dry-burnishing floors, always operate the floor machine at the lowest rate of
speed possible to accomplish the task (i.e., 1200-1750 rpms), and equip the floor
machine with the least abrasive pad as possible.
Cleaning After Stripping & Sealing Floors
After stripping a floor and applying a new coat of sealer and finish, use a wet mop
for routine cleaning whenever possible. When dry mopping, a petroleum-based mop
treatment is not recommended for use.
Maintenance During Winter
During the winter months when sanding and/or salting of icy parking lots becomes
necessary, it is an industry recommendation that matting be used at the entrance way
to the school building and inside the doorway where feasible. This would
significantly eliminate the scuffing of floors by abrasive sanding materials brought
into the building on the shoes of building occupants. More frequent wet mopping
and dry mopping of floors should be performed during the winter months to
minimize damage to the floors.
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CHAPTER 8
The Operations & Maintenance Program
The same recommendations holds true of schools located on coastal areas where
building occupants could track sand into the schools.
Additional Precautions
Conditions of Glides
Check to see if chair and desk glides are in good condition and replace where
indicated. Worn glides can gouge the floor coverings and possibly cause asbestos
fiber release.
Parking Lot/Walkway Maintenance
During the winter months, have parking lots and walkways swept to avoid tracking
salt and ice-melting compounds into the school by students. These materials can
cause severe scuffing of floor coverings and lead to the release of asbestos fibers into
the school building(s).
Use of Mats
Where feasible, use mats at entrance ways to cafeterias, gymnasiums, libraries, etc.,
to protect against possible scuffing of floor covering(s), etc. from salt and icemelting compounds and from ocean sand.
Special Work Practices for Renovation/Remodeling
Building renovation or building system replacement can cause major disturbances of
ACBM that are beyond the scope of school O&M programs. Moving walls, adding
wings, and replacing heating or air conditioning systems are likely to involve
breaking, cutting, or otherwise disturbing ACBM that may be present. It is highly
recommended that ACBM that may be disturbed be removed before any of these
activities are begun. The LEA may be required to remove the ACBM if the amount
of ACBM that is likely to be disturbed exceeds the threshold amounts of 160 square
feet or 260 linear feet established by the National Emission Standards for Hazardous
Air Pollutants (NESHAP) regulations. (See Chapter 11 for further information on
the Asbestos NESHAP regulations.)
Although remodeling projects change the building structure less dramatically than
renovation projects, disturbances of ACBM are still possible. When a remodeling
project involves direct contact with ACBM (such as painting or wallpapering over
ACBM), the O&M procedures described in § 763.91(d) of the AHERA Rule must
be followed. If the work to be done will make the material friable, the work must
either be limited to small-scale, short-duration or be treated as a response action.
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The Operations & Maintenance Program
Handling and Disposing of Asbestos Wastes
The amount and type of asbestos present both determine whether the LEA must notify
EPA (or delegated states) and what procedures that the LEA must follow to control
asbestos emissions. If the amount exceeds the regulatory threshold, then a written
notification must be submitted ten working days prior to any asbestos stripping or
removal operation or demolition operation. EPA regulations (along with state and
local requirements) provide detailed instructions on the handling, transport, and
disposal of asbestos materials. This includes emission control methods (such as wetting
and leak proof wrapping), labels on the containers, recordkeeping and a trained
representative on-site. Waste must be disposed of at a site meeting federal, state and
local requirements. For a site in your area, contact the local public health department.
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CHAPTER 8
The Operations & Maintenance Program
Chapter 8 Summary
Key Points About the Operations and Maintenance Program
An O&M program must be implemented whenever any friable ACBM is present
or assumed to be present in a school building or whenever any nonfriable ACBM
or assumed nonfriable ACBM is about to become friable as a result of activities
performed in the school building.
Unless the building has been cleaned using similar methods in the previous 6
months, all areas of a building where friable ACBM, friable suspected ACBM
assumed to be ACBM, or significantly damaged TSI ACBM is present must be
cleaned using the methods described at § 763.91(c) of the AHERA Rule at least
once after the completion of the AHERA inspection and before the initiation of
any response action, other than O&M activities or repair.
Specialized work practices and procedures must be followed for any O&M
activities disturbing friable ACBM.
When a fiber release episode occurs, the work practices that must be followed
depend on whether the episode is minor or major in nature. A minor fiber
release episode consists of the falling or dislodging of 3 square or linear feet or
less of friable ACBM. A major fiber release episode consists of the falling or
dislodging of more than 3 square or linear feet of friable ACBM.
Once ACBM is identified or assumed to be present, the LEA should start a
notification and warning program to alert affected parties to a potential hazard
in the building and to provide basic information on how to avoid the hazard.
The LEA is required to attach a warning label immediately adjacent to any friable
and nonfriable ACBM and suspected ACBM that is assumed to be ACBM that is
located in routine maintenance areas.
Where employees work in areas where fiber levels exceed permissible exposure
limits or are required to wear pressure respirators, the LEA must establish
medical surveillance and respiratory protection programs.
A designated person can minimize accidental disturbances of ACBM during
maintenance and renovation activities by establishing a permit system that calls
for all work orders and requests to be processed through the designated person.
The specific work practices that must be followed when routine maintenance
activities are being conducted depend on the likelihood that the activities will
disturb the ACBM and cause fibers to be released.
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CHAPTER 8
The Operations & Maintenance Program
Fiber Release Episode Report
1.
Address, building, and room number(s) (or description of area) where episode occurred:
2.
The release episode was reported by
on
(date).
3.
Describe the episode:
4.
The asbestos-containing material was
procedures. Describe the cleanup:
Signed
/was not
Date:
-76-
cleaned up according to approved
(Asbe
stos
Progr
am
Mana
ger)
CHAPTER 8
The Operations & Maintenance Program
Example Form 5
Work Permit Application
1.
Address, building, and room number (or description) where work is to be performed:
2.
Requested starting date:
3.
Description of work:
4.
Description of any asbestos-containing material that might be affected, if known (include
location and type):
5.
Name and telephone number of requestor:
6.
Name and telephone number of supervisor:
Anticipated finish date:
Submit this application to the asbestos program manager:
NOTE: An application must be submitted for all maintenance work whether or not
asbestos-containing material might be affected. this authorization must then be signed
before any work can proceed.
Granted (Work Permit No.
)
Denied (See Asbestos Program Manager)
Denied (until further sampling is conducted)
Signed
Date:
Asbestos Program Manager
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9
TRAINING AND
ACCREDITATION
Introduction
AHERA requires that LEAs employ accredited persons to perform most of the
activities associated with asbestos management. Building inspectors, management
planners, project designers, contractors/supervisors, and asbestos workers must all
complete EPA- or State-approved courses that result in accreditation. The specific
training requirements for each of these categories of workers are outlined in
Appendix C to the AHERA Rule (the AHERA Model Accreditation Plan). The
AHERA Rule also details specific training requirements for LEA designated persons
and maintenance and custodial workers, although these individuals are not required
to complete any EPA-approved courses or receive accreditation.
Designated Person Training
AHERA requires that the AHERA Designated Person be adequately trained to carry
out his or her responsibilities. Due to the differing needs of school districts based on
the size of the district and the amount and condition of the ACBM, AHERA does
not list a specific training course or specific number of hours of training for the DP.
Further, AHERA does not require the DP to be accredited. Specifically, the
regulations note the training must include the following topics:
! health effects of asbestos;
! detection, identification and assessment of asbestos-containing building
materials;
! options for controlling asbestos-containing building materials; and
! asbestos management programs.
! Relevant Federal and State regulations concerning asbestos, including AHERA
and its implementing regulations and the regulations of the Occupational Safety
and Health Administration, the U.S. Department of Transportation, and the
U.S. Environmental Protection Agency (See Chapter 11 for further information
on regulations related to AHERA.)
The training completed by the designated person must be documented by course
name, dates, and hours of training. This documentation must be kept as a
permanent part of the management plan.
To determine whether reviewing this document would satisfy the training
requirements for the DP, school personnel should consult with the regional asbestos
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CHAPTER 9
Training and Accreditation
coordinator in the EPA Regional Office serving their state.
Maintenance and Custodial Workers
The LEA must ensure that all maintenance and custodial staff who work in a
building that contains ACBM receive a minimum of two hours awareness training,
whether or not they are required to work with ACBM. New custodial and
maintenance employees must be trained within 60 days after the commencement of
employment.
The awareness training must include, but is not limited to:
! Information regarding asbestos and its various uses and forms
! Information on the health effects associated with asbestos exposure
! Locations of ACBM identified throughout each school building in which they
work
! Information on how to recognize damaged, deteriorated, and delaminated
ACBM
! The name and telephone number of the LEA designated person
! Information on the availability and location of the management plan
Staff that disturb ACBM must receive an additional 14 hours of training. Once this
additional training is completed, attendees will be adequately trained to conduct
small-scale, short-duration activities and/or minor fiber release episode cleanup and
repair procedures. The additional training must include, but is not limited to:
! Descriptions of the proper methods for handling ACBM
! Information on the use of respiratory protection as contained in the
EPA/NIOSH Guide to Respiratory Protection for the Asbestos Abatement
Industry (September 1986) and other personal protection measures
! The provisions of the AHERA Rule relating to O&M activities
(§ 763.91) and training and periodic surveillance (§ 763.92) as well as
Appendices A-E of the Rule, EPA regulations contained in 40 CFR Part 763,
subpart G, and in 40 CFR Part 61, Subpart M, and OSHA regulations
! Hands-on training in the use of respiratory protection, other personal
protection measures, and good work practices
Maintenance and custodial worker training does not require EPA approval, although
some States may have more stringent training requirements. It is recommended that
the LEA check with its State on the training requirements for maintenance and
custodial workers.
The completion of all training by maintenance and custodial workers must be
documented. (See Chapter 10 under "Training Information" for a discussion of the
training records that must be kept.)
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CHAPTER 9
Training and Accreditation
Accredited Personnel
Under AHERA, LEAs may employ the following individuals only if they have
completed EPA- or State-approved training courses, passed the exams, and received
accreditation.
Building Inspectors -- Building inspectors must complete a minimum of three days (24
hours) of training. Training course information covers technical information needed to
identify and describe ACBM and information needed to write an inspection report.
Management Planners -- Management planners must complete a two-day (16 hours)
course after they have completed and passed the exam for the building inspector training
described above. This course is an extension of the building inspector training and
teaches how to develop a schedule (or plan) for implementation of response actions for
hazards or potential hazards identified in the inspection report, how to develop an O&M
plan, and how to prepare and update a management plan.
Project Designers -- Project designers must complete a three-day (24 hours) abatement
project designer training course. The project designer course teaches how to design
response actions and abatement projects. It also covers basic concepts of architectural
design, engineering controls and proper work practices as required by the regulation.
Contractors/Supervisors -- Contractors/supervisors must complete a minimum of five
days (40 hours) of training. The course teaches proper work practices and procedures
and covers contractor issues such as legal liability, contract specifications, insurance
and bonding, and air monitoring. The course fulfills the OSHA "competent person"
training requirement and the NESHAP "trained representative" requirement.
Asbestos Workers -- An asbestos worker must complete a minimum of four days (32
hours) of training. The course covers work practices and procedures, personal
protective equipment, health effects of asbestos exposure, and other information critical
to individuals who work in an abatement area with hazardous materials.
Update Training
All project designers, contractors/supervisor, and asbestos workers must complete a one
day annual refresher training course for reaccreditation. Building inspectors must
complete a half-day refresher course. Management planners must attend the half-day
building inspector refresher course as well as a half-day management planner refresher
course. Documentation of any annual training should be kept in the management plan.
Although not specifically required by the AHERA Rule, annual refresher/update
training for maintenance workers is recommended. OSHA requires annual training.
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CHAPTER 9
Training and Accreditation
Table 9-1
LEA Employee Training Requirements
Amount of
Training
(Hours)
Annual
Training
Update (Hours)
Job Title
Subject Matter of Training
Designated
Person
Health effects of asbestos; detection,
identification and assessment of
ACBM; options for controlling
ACBM; asbestos management
program; related federal and state
laws
Adequate
None
All
Maintenance
Workers
Asbestos and its uses and forms;
health effects associated with asbestos
exposure; locating ACBM identified
throughout each school building in
which they work; recognizing various
conditions of ACBM; name and
telephone number of LEA designated
person; information pertaining to the
availability and location of
management plan
2
None
Maintenance
Workers Who
Disturb
ACBM
Proper methods for handling ACBM;
information on proper use of
respiratory protection; hands-on
training in the use of respiratory
protection, other personal protection
measures, and good work practices;
information pertaining to various
regulations; technical information
16 (asbestos
awareness and
14 additional
hours)
None
*
These 14 hours of training are in addition to the 2 hours of asbestos awareness training
that all maintenance workers receive
Note that state and local requirements may be more stringent.
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Training and Accreditation
Table 9-2
Accredited Personnel Training Requirements
Amount of
Training
(Days)
Annual
Training
Update (Days)
Technical information needed to
identify and describe ACBM;
information needed to write an
inspection report
3
1/2
Management
Planners
Extension of the building inspector
training, plus how to develop a
schedule (or plan) for implementation
of response actions for hazards or
potential hazards identified in the
inspection report, how to develop an
O&M plan, and how to prepare a
management plan.
2a
1b
Project
Designers
How to design response actions and
abatement projects; basic concepts of
architectural design, engineering
controls and proper work practices
3
1
Contractors/
Supervisors
Proper work practices and
procedures; contractor issues such as
legal liability, contract specifications,
insurance, and bonding; air
monitoring
5
1
Asbestos
Workers
Work practices and procedures,
personal protective equipment, health
effects of asbestos exposure, and
other critical information
4
1
Job Title
Building
Inspectors
a
b
Subject Matter of Training
Management planners must first complete the building inspector training and pass the exam.
This includes the one-half day building inspector training update.
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CHAPTER 9
Training and Accreditation
Chapter 9 Summary
Key Points About Training and Accreditation
AHERA does not require that designated persons complete EPA- or Stateapproved courses and become accredited, but § 763.84(g)(2) of the AHERA
Rule requires that training for the designated persons provide basic
knowledge of a number of asbestos-related subjects.
The LEA must ensure that all maintenance and custodial staff who may work
in a building that contains ACBM receive a minimum of two hours
awareness training, whether or not they are required to work with ACBM.
All new maintenance and custodial staff must receive asbestos awareness
training within 60 days of hire.
Staff that may disturb ACBM must receive an additional 14 hours of
training.
Building inspectors, management planners, project designers,
contractors/supervisors, and asbestos workers must successfully complete
EPA- or State-approved courses, pass an exam and receive accreditation
before they can perform any asbestos-related activities.
Building inspectors, management planners, project designers,
contractors/supervisors, and asbestos workers must complete annual EPA- or
State-approved refresher courses to maintain their accreditation.
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10
RECORDKEEPING
Recordkeeping of Management Plans
Under § 763.93(g) of the AHERA Rule, each LEA is required to keep in its
administrative office a copy of the management plans for each school. (See Table 61 for a comprehensive list of the required contents of the management plan.) The
management plan must be available, without cost or restriction, for inspection by the
public, including teachers, other school personnel and their representatives, and
parents, as well as by representatives of EPA and the State.
In addition, each school is required to maintain in its administrative office a
complete and updated copy of the management plan for that school. The school
must make the plan available for inspection to those individuals listed above as well
as to workers before work begins in any area of a school building.
It is the responsibility of the LEA designated person to ensure that complete and upto-date records are maintained and included in the management plan. Section
763.94 of the AHERA Rule requires that the LEA maintain the following records
(Note that some of these requirements have been listed in other portions of this
guide).
Training Information
For each person required to be trained under §§ 763.92(a)(1) and (2) of the AHERA Rule
(maintenance and custodial worker training), the LEA must provide:
!
!
!
!
The person's name and job title
The date that training was completed
The location of the training
The number of hours completed in the training
Periodic Surveillance Information
Each time that periodic surveillance is conducted under § 763.92(b) of the AHERA
Rule, the LEA must record:
! The name of each person conducting the surveillance
! The date of the surveillance
! Any changes in the conditions of the materials being examined
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CHAPTER 10
Recordkeeping
Cleaning Information
Each time that cleaning, as required under § 763.91(c), is conducted, the LEA must
record:
!
!
!
!
The name of each person performing the cleaning
The date of the cleaning
The locations cleaned
The methods used to perform the cleaning
Small-Scale, Short-Duration O&M Activity Information
Each time that O&M activities under § 763.91(d) of the AHERA Rule are
performed, the LEA must provide:
!
!
!
!
!
The name of each person performing the activity
The start and completion date of the activity
The locations where such activity occurred
A description of the activity, including the preventive measures used
If ACBM is removed, the name and disposal site of the ACBM
Information on O&M Activities Other Than Small-Scale, Short-Duration
Each time maintenance activities are performed that are not of small scale and short
duration under § 763.91(e) of the AHERA Rule, the LEA must provide:
! The name and signature of each person performing the activity
! The State, accreditation number, and training provider name of each person
performing the activity (a copy of a certificate is ideal)
! The start and completion dates of the activity
! A description of the activity, including preventive measures used
! If the ACBM is removed, the name and location of the ACBM storage or
disposal site
Information on Fiber Release Episodes
For each fiber release episode occurring as the result of O&M activities, the LEA
must provide:
!
!
!
!
The date and location of the episode
The method of repair, preventive measures or response action taken
The name of each person performing the work
If ACBM is removed, the name and location of the ACBM storage or disposal
site
Information on Response Actions and Preventive Measures
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CHAPTER 10
Recordkeeping
For each preventive measure and response action taken for friable and nonfriable
ACBM and friable and nonfriable suspected ACBM assumed to be ACBM, the LEA
must provide:
! A detailed written description of the measure or action, including the method
used
The location where the measure or action was taken
Reasons for selecting the measure or action
The start and completion dates of the work
If applicable, the names and addresses of all contractors involved with the
work
! If applicable, the State, accreditation number, and training provider name of
all contractors involved with the work (a copy of the certificate)
! If ACBM is removed, the name and location of the ACBM storage or disposal
site
!
!
!
!
Air Sampling Information
In addition to the information required to be provided for each preventive measure
and response action taken for friable and nonfriable ACBM and friable and
nonfriable suspected ACBM assumed to be ACBM (See above), when air sampling
is performed for final air clearance of response actions, the LEA must provide:
! The name and signature of any person collecting any air sample required to be
!
!
!
!
!
!
!
!
collected at the completion of a response action
The locations where samples were collected
The date(s) of collection
The name and address of the laboratory analyzing the samples
The date(s) of analysis
The results of the analysis
The method of analysis
The name and signature of the person performing the analysis
A statement that the laboratory is NVLAP accredited or EPA approved
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CHAPTER 10
Recordkeeping
Chapter 10 Summary
Key Points About Recordkeeping
Each LEA must maintain a copy of its management plan in its
administrative office, and the plan must be available to persons for inspection
without cost or restriction.
Each school must maintain a copy of the management plan for that school
in its administrative office, and the plan must be available to persons for
inspection without cost or restriction.
The LEA must also maintain records of events that occur after submission of
the management plan; these records include training information, periodic
surveillance information, cleaning information, small-scale, short-duration O
& M activity information, information on O & M activities other than smallscale, short-duration, information on fiber release episodes, information on
response actions and preventive measures, and air sampling information.
These records should be included in the management plans in a timely
manner.
For each homogeneous area where all ACBM has been removed, the LEA
must retain the records of events for three years after the next reinspection,
or for an equivalent period.
It is the responsibility of the LEA designated person to ensure that complete
and up-to-date records are maintained and included in the management plans.
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11
RELATED
REGULATIONS
Introduction
Although AHERA and its implementing regulations, the AHERA Rule, set out many
of the responsibilities of the LEA, there are several other federal regulations that the
LEA should be aware of when implementing an asbestos management program.
These regulations include:
! National Emission Standards for Hazardous Air Pollutants (NESHAP)
! Occupational Safety and Health Administration (OSHA) Construction Industry
Standard (29 CFR 1926.1101) and General Industry Standard
(29 CFR 1910.1001)
! The EPA Worker Protection Rule (40 CFR § 763.121)
! Department of Transportation (DOT) regulations governing the transport
and disposal of asbestos-containing materials (49 CFR Parts 171 and 172)
Each of these regulations is discussed in greater detail below. By following the
requirements of these related regulations, the LEA can protect not only the people in
its buildings from negative health effects but also may protect itself from legal
liability. These regulations should be considered to establish minimum standards;
going beyond these requirements may help keep buildings as safe as possible. For
further information about these related regulations, call the Asbestos Ombudsman
Clearinghouse Hotline at (800) 368-5888 between 8:00 a.m. and 4:30 p.m., Eastern.
National Emission Standards
for Hazardous Air Pollutants
The LEA (school district) must comply with the National Emission Standards for
Hazardous Air Pollutants for Asbestos (NESHAP) regulations when removing
asbestos materials. These regulations specify control requirements for most asbestos
emissions, and include work practices to be followed to minimize the release of
asbestos fibers during the handling, removal and disposal of asbestos waste
materials. NESHAP regulations are frequently enforced by the State or Local
Agencies.
A significant term, which is used through NESHAP, is Regulated AsbestosContaining Materials (RACM). RACM is where the amount of friable asbestos-88-
CHAPTER 11
Related Regulations
containing material equals or exceeds the threshold amount of 260 linear feet, 160
square feet, or 35 cubic feet.
Prior to the beginning work, an AHERA accredited inspector must inspect the
facility for the presence of asbestos. The amount and type of asbestos present both
determine whether the LEA must notify EPA (or delegated states) and what
procedures that the LEA must follow to control asbestos emissions. If the amount
exceeds the regulatory threshold, then a written notification must be submitted ten
working days prior to any asbestos stripping or removal operation or demolition
operation. The LEA must remove RACM from the facility that is to be demolished
or renovated before any other activity begins that would break up, dislodge, or
similarly disturb this material. The RACM must be handled in accordance with the
asbestos NESHAP regulations, including properly labeling the waste. However,
prior removal is not required if the RACM is in a condition that is excepted from
prior removal, e.g., it is on a facility component that is encased in concrete or other
similarly hard material and is adequately wet whenever exposed during demolition.
Of particular importance to the LEA are the standards for the demolition and
renovation of facilities (40 CFR § 61.145) and for waste disposal for demolition and
renovation operations (40 CFR § 61.150). The standard for asbestos waste disposal
for demolition and renovation operations require that the LEA to: (1) discharge no
visible emissions to the outside air during the collection processing, packaging, or
transporting of any asbestos-containing waste material; (2) adequately wet the
asbestos-containing waste material; (3) process the asbestos-containing waste
material into nonfriable forms; or (4) use an alternative emission control and waste
treatment method that has received prior approval by EPA or the delegated state.
As soon as possible, all asbestos-containing waste material must be taken to an
asbestos waste disposal site or an EPA-approved site that converts regulated
asbestos-containing material and asbestos-containing waste material into asbestosfree material as provided by law. If non-RACM will not be made friable during the
disposal processes, it may be disposed of at a landfill that accepts normal building
debris. Waste shipment records (WSRs), which are only required for RACM, must
be maintained by the LEA and contain the information required by law. The WSRs
must be retained for at least two years.
Occupational Safety and Health Administration
The Occupational Safety and Health Administration's (OSHA) Construction Industry
Standard (29 CFR § 1926.1101) and General Industry Standard (29 CFR §
1910.1001) establish minimum standards for the protection of workers involved in
asbestos-related work or employees exposed to asbestos-contaminated workplaces.
OSHA regulations exclude federal, state, or local government employees (including
public school employees) from its worker protection rules (except in states with
OSHA approved programs). However, EPA has promulgated Worker Protection
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Related Regulations
Rules to cover these employees (see below). These standards include required work
practices, engineering controls, permissible exposure limits, written programs for
respiratory protection and medical surveillance, methods for compliance, hazard
communication, housekeeping, competent person training and responsibilities, and
required recordkeeping. Also included are demolition, removal, alteration, repair,
maintenance (such custodial workers who clean vinyl asbestos tile floors),
installation, clean-up of spills, transportation, disposal and storage of asbestos.
OSHA revised its standards on August 10, 1994. Significant changes to the
standards included the following:
-
PEL decrease to 0.1 f/cc; action level deleted;
-
Asbestos Containing Material defined as material containing more than 1%
asbestos (now consistent with EPA);
-
Building owners are now covered and have specific duties to identify building
materials and notify/communicate with others;
-
All asbestos work, regardless of exposure levels, requires at least basic controls
and work practices, and exposure monitoring;
-
Construction work is classified according to friability of the asbestos and
hazardousness of the operation. Increasingly friable and hazardous operations
require increasingly stringent engineering controls, work practices, protective
equipment, training and monitoring; and
-
Training requirements changed to correspond to EPA training.
Two programs are of particular importance to the LEA. OSHA requires
establishment of a respiratory protection program (29 CFR § 1910.134) that is
designed to protect persons, including the designated person and any employees,
who do any work with ACBM. The program requires that such persons be equipped
with a respirator that provides adequate protection against asbestos. Further, the
program must include written standard operating procedures governing the selection
and use of respirators, selection of respirators based on the hazards to which workers
are exposed, an instruction and training program in the proper use of respirators and
its limitations, and requirements for the cleaning, disinfecting, inspecting, and
storing of respirators. The written program must be on the job site when asbestos
work is being conducted. (See Chapter 8 under the heading "Employee Protection
& Medical Surveillance Programs" for a further discussion of this program.)
(See the Model Respiratory Protection Program Checklist at the end of this chapter.)
The second program is the medical surveillance program, which requires that every
person who is assigned to work using a respirator must first have a medical
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Related Regulations
examination to determine whether he or she is fit to work in a respirator. A written
assurance to that effect signed by the examining physician is required and must be
maintained with the employee's medical surveillance records. The employer must
keep proof of a medical surveillance program on site where the asbestos work is
being performed. (See Chapter 8 under the heading "Employee Protection &
Medical Surveillance Programs" for a further discussion of this program.)
(See the Medical Examination Checklist at the end of this chapter.)
EPA Worker Protection Rule
The OSHA asbestos standards do not cover all state and local government
employees. The EPA Worker Protection Rule (40 CFR § 763.121) extends the
protection afforded by the OSHA standards to all state and local government
employees who are engaged in asbestos abatement and who are not otherwise
covered by OSHA or an OSHA-approved state plan. Thus, when conducting
asbestos abatement activities, an employee of a school district is either covered by
the OSHA asbestos standards or that employee is protected by EPA's Worker
Protection Rule.
Department of Transportation Regulations
Department of Transportation (DOT) regulations (49 CFR Parts 171 and 172)
require that asbestos-containing materials be labeled as Class 9 hazardous materials
and establish requirements relating to the shipment of ACBM by air, rail or motor
vehicles, including the type of packaging, labeling, shipping papers and placards
required.
The designated person is responsible for having the ACBM properly transported
from a site. The LEA is the generator of the waste product and maintains this
responsibility during transportation and disposal. Disposal of asbestos waste also is
subject to each state's solid waste regulations.
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CHAPTER 11
Related Regulations
Chapter 11 Summary
Key Points About Related Regulations
An asbestos management program is subject not only to AHERA and the
AHERA Rule, but also may be subject to NESHAP, OSHA, and DOT
regulations, and the EPA Worker Protection Rule.
Relevant provisions of NESHAP establish work practices for asbestos air
emission control when a facility is being demolished or renovated, and for
the disposal of asbestos-containing waste material.
The OSHA established minimum standards for the protection of workers
involved in asbestos-related work or employees exposed to asbestoscontaminated workplaces. These standards include required work
practices, engineering controls, permissible exposure limits, written
programs for respiratory protection and medical surveillance, methods for
compliance, hazard communication, housekeeping, competent person training
and responsibilities, and required recordkeeping. OSHA excludes federal,
state, or local government employees from its worker protection rules
(including public school employees).
The EPA Worker Protection Rule extends the protection afforded by
OSHA to all employees in asbestos abatement who may have been excluded
from protection by OSHA.
Relevant provisions of DOT regulations establish labeling, packaging and
shipping standards for the transporting of asbestos-containing materials.
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CHAPTER 11
Related Regulations
Model Respiratory Protection Program Checklist
Protecting workers from exposure is the responsibility of the employer. Employers are required
by law to establish and maintain an effective respiratory protection program as outlined in
American National Standards Institute (ANSI) Standard Z88.2-1969. (The more recent edition
of ASNI Z88.2 (1980) contains more comprehensive requirements which are not yet
incorporated in the OSHA regulation.) This checklist presents a model respiratory protection
program for asbestos abatement operations which meets or exceeds the requirements of the
present OSHA standard.
The recommendations of this guide not only satisfy the current respiratory protection
requirements of existing Federal regulations, but also include recommendations based on current
information on respiratory protection.
An effective respirator program should include:
1. A written statement of company policy, including assignment of individual
responsibility, accountability, and authority for required activities of the
respiratory protection program
2. A written standard operating procedures governing the selection and use of
respirators
3. Respirator selection (from NOISH/MSHA approved and certified models) on the
basis of hazards to which the worker is exposed
4. The medical examination of workers to determine whether or not they may be
assigned an activity where respiratory protection is required
5. User training in the proper use and limitations of respirators (which also is a way
to evaluate the skill and knowledge obtained by the worker through training)
6. Respirator fit testing
7. Regular cleaning and disinfecting of respirators
8. Routine inspection of respirators during cleaning, and at least once a month and
after each use for those respirators designated for emergency use
9. Storage of respirators in convenient, clean, and sanitary locations
(cont.)
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CHAPTER 11
Related Regulations
Model Respiratory Protection Program Checklist (cont.)
10. Surveillance of work area conditions and degree of employee exposure
(e.g., through air monitoring)
11. Regular inspection and evaluation of the continued effectiveness of the program
12. Recognition and resolution of special problems as they affect respirator use (e.g.,
facial hair, eye glasses, etc.)
13. Proper respirator use (e.g., procedures for putting on and taking off respirators
when entering and exiting the abatement area)
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CHAPTER 11
Related Regulations
Medical Examination Checklist
A medical examination is the first step in a medical surveillance program. This checklist may
be used to determine the thoroughness of the medical examination administered. Although the
scope of a medical examination may vary among medical facilities, at a minimum it should
include the following:
1. Medical History (completed by examinee)
2. Initial or Periodic Medical Questionnaire for Asbestos Exposure
3. Respiratory History
4. Anthropometric Measurements
A. Height
B. Weight
5. Vital Signs
A. Blood Pressure
B. Pulse
C. Temperature
6. Ophthalmologic Screening
A. Visual Acuity - Near and Far
B. Color Vision
C. Depth perception
7. Urinalysis
8. Pulmonary Function Screen
9. Chest X-ray (administered at the discretion of the physician)
10. Complete Physical Examination by Physician
11. Physician Evaluation for Respirator Use/Clearance
12. Report of Medical Evaluation
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Glossary
Air erosion: the passage of air over friable ACBM which may result in the release of asbestos
fibers.
Asbestos: the asbestiform varieties of Chrysotile (serpentine); crocidolite (riebeckite); amosite
(cummingtonitegrunerite); anthophyllite; tremolite; and actinolite.
Asbestos-containing material (ACM): any material or product which contains more than 1
percent asbestos.
Asbestos-containing building material (ACBM): surfacing ACM, thermal system insulation
ACM, or miscellaneous ACM that is found in or on interior structural members or other parts
of a school building.
Asbestos debris: pieces of ACBM that can be identified by color, texture, or composition, or
means dust, if the dust is determined by an accredited inspector to be ACM.
Damaged friable miscellaneous ACM: friable miscellaneous ACM which has deteriorated or
sustained physical injury such that the internal structure (cohesion) of the material is inadequate
or, if applicable, which has delaminated such that its bond to the substrate (adhesion) is
inadequate or which for any other reason lacks fiber cohesion or adhesion qualities. Such
damage or deterioration may be illustrated by the separation of ACM into layers; separation of
ACM from the substrate; flaking, blistering, or crumbling of the ACM surface; water damage;
significant or repeated water stains, scrapes, gouges, mars or other signs of physical injury on
the ACM. Asbestos debris originating from the ACBM in question may also indicate damage.
Damaged friable surfacing ACM: friable surfacing ACM which has deteriorated or sustained
physical injury such that the internal structure (cohesion) of the material is inadequate or which
has delaminated such that its bond to the substrate (adhesion) is inadequate, or which, for any
other reason, lacks fiber cohesion or adhesion qualities. Such damage or deterioration may be
illustrated by the separation of ACM into layers; separation of ACM from the substrate;
flaking, blistering, or crumbling of the ACM surface; water damage; significant or repeated
water stains, scrapes, gouges, mars or other signs of physical injury on the ACM. Asbestos
debris originating from the ACBM in question may also indicate damage.
Damaged or significantly damaged thermal system insulation ACM: thermal system
insulation ACM on pipes, boilers, tanks, ducts, and other thermal system insulation equipment
where the insulation has lost its structural integrity, or its covering, in whole or in part, is
crushed, water-stained, gouged, punctured, missing, or not intact such that it is not able to
contain fibers. Damage may be further illustrated by occasional punctures, gouges or other
signs of physical injury to ACM; occasional water damage on the protective coverings/jackets;
or exposed ACM ends or joints. Asbestos debris originating from the ACBM in question may
also indicate damage.
Encapsulation: the treatment of ACBM with a material that surrounds or embeds asbestos
fibers in an adhesive matrix to prevent the release of fibers, as the encapsulant creates a
membrane over the surface (bridging encapsulant) or penetrates the material and binds its
components together (penetrating encapsulant).
Enclosure: an airtight, impermeable, permanent barrier around ACBM to prevent the release
of asbestos fibers into the air.
EPA Worker Protection Rule: extends the protection afforded by OSHA to all employees in
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asbestos abatement who may have been excluded from protection by OSHA.
Fiber release episode: any uncontrolled or unintentional disturbance of ACBM resulting in
visible emission.
Friable: when referring to material in a school building means that the material, when dry,
may be crumbled, pulverized, or reduced to powder by hand pressure, and includes previously
nonfriable material after such previously nonfriable material becomes damaged to the extent
that when dry it may be crumbled, pulverized, or reduced to powder by hand pressure.
Friable asbestos-containing material (ACM): any material containing more than one percent
asbestos which has been applied on ceilings, walls, structural members, piping, duct work, or
any other part of a building, which when dry, may be crumbled, pulverized, or reduced to
powder by hand pressure. Includes non-friable asbestos-containing material after such
previously non-friable material becomes damaged to the extent that when dry it may be
crumbled, pulverized, or reduced to powder by hand pressure.
Friable asbestos-containing building material (ACBM): any friable ACM that is in or on
interior structural members or other parts of a school or public and commercial building.
Functional space: a room, group of rooms, or homogeneous area (including crawl spaces or
the space between a dropped ceiling and the floor or roof deck above), such as classroom(s), a
cafeteria, gymnasium, hallway(s), designated by a person accredited to prepare management
plans, design abatement projects, or conduct response actions.
High-efficiency particulate air (HEPA): refers to a filtering system capable of trapping and
retaining at least 99.97 percent of all monodispersed particles 0.3 µm in diameter or larger.
Homogeneous area: an area of surfacing material, thermal system insulation material, or
miscellaneous material that is uniform in color and texture.
Inspection: an activity undertaken in a school building, or a public and commercial building,
to determine the presence or location, or to assess the condition of, friable or non-friable
asbestos-containing building material (ACBM) or suspected ACBM, whether by visual or
physical examination, or by collecting samples of such material. This term includes
reinspections of friable and non-friable known or assumed ACBM which has been previously
identified. The term does not include the following:
(1) Periodic surveillance of the type described in 40 CFR 763.92(b) solely for the purpose of
recording or reporting a change in the condition of known or assumed ACBM;
(2) Inspections performed by employees or agents of Federal, State, or local government solely
for the purpose of determining compliance with applicable statutes or regulations; or
(3) Visual inspections of the type described in 40 CFR 763.90(i) solely for the purpose of
determining completion of response actions.
Local education agency:
(1) Any local educational agency as defined in section 198 of the Elementary and Secondary
Education Act of 1965 (20 U.S.C. 3381).
(2) The owner of any nonpublic, nonprofit elementary, or secondary school building.
(3) The governing authority of any school operated under the defense dependents' education
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system provided for under the Defense Dependents' Education Act of 1978 (20 U.S.C. 921,
et seq.).
Major fiber release episode: any uncontrolled or unintentional disturbance of ACBM, resulting
in a visible emission, which involves the falling or dislodging of more than 3 square or linear
feet of friable ACBM.
Management Plan: a site-specific guidance document that the LEA designated person must
follow in managing the ACBM present in a school building.
Minor fiber release episode: any uncontrolled or unintentional disturbance of ACBM, resulting
in a visible emission, which involves the falling or dislodging of 3 square or linear feet or less
of friable ACBM.
Miscellaneous ACM: other, mostly nonfriable ACM, products and materials (found on
structural components, structural members or fixtures) such as floor tile, ceiling tile,
construction mastic for floor and ceiling materials, sheet flooring, fire doors, asbestos cement
pipe and board, wallboard, acoustical wall tile, and vibration damping cloth.
miscellaneous material that is ACM in a school building.
Miscellaneous material: interior building material on structural components, structural
members or fixtures, such as floor and ceiling tiles, and does not include surfacing material or
thermal system insulation.
Nonfriable: material in a school building which when dry may not be crumbled, pulverized, or
reduced to powder by hand pressure.
Operations and maintenance program: a program of work practices to maintain friable
ACBM in good condition, ensure clean up of asbestos fibers previously released, and prevent
further release by minimizing and controlling friable ACBM disturbance or damage.
Potential damage: circumstances in which:
(1) Friable ACBM is in an area regularly used by building occupants, including maintenance
personnel, in the course of their normal activities.
(2) There are indications that there is a reasonable likelihood that the material or its covering
will become damaged, deteriorated, or delaminated due to factors such as changes in
building use, changes in operations and maintenance practices, changes in occupancy, or
recurrent damage.
Potential significant damage: circumstances in which:
(1) Friable ACBM is in an area regularly used by building occupants, including maintenance
personnel, in the course of their normal activities.
(2) There are indications that there is a reasonable likelihood that the material or its covering
will become significantly damaged, deteriorated, or delaminated due to factors such as
changes in building use, changes in operations and maintenance practices, changes in
occupancy, or recurrent damage.
(3) The material is subject to major or continuing disturbance, due to factors including, but not
limited to, accessibility or, under certain circumstances, vibration or air erosion.
Preventive measures: actions taken to reduce disturbance of ACBM or otherwise eliminate the
reasonable likelihood of the material's becoming damaged or significantly damaged.
Public and commercial building: the interior space of any building which is not a school
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building, except that the term does not include any residential apartment building of fewer than
10 units or detached single-family homes. The term includes, but is not limited to: industrial
and office buildings, residential apartment buildings and condominiums of 10 or more dwelling
units, government-owned buildings, colleges, museums, airports, hospitals, churches,
preschools, stores, warehouses and factories. Interior space includes exterior hallways
connecting buildings, porticos, and mechanical systems used to condition interior space.
Removal: the taking out or the stripping of substantially all ACBM from a damaged area, a
functional space, or a homogeneous area in a school building.
Repair: returning damaged ACBM to an undamaged condition or to an intact state so as to
prevent fiber release.
Response action: a method, including removal, encapsulation, enclosure, repair, operations
and maintenance, that protects human health and the environment from friable ACBM.
Routine maintenance area: an area, such as a boiler room or mechanical room, that is not
normally frequented by students and in which maintenance employees or contract workers
regularly conduct maintenance activities.
School: any elementary or secondary school as defined in section 198 of the Elementary and
Secondary Education Act of 1965 (20 U.S.C. 2854).
School building:
(1) Any structure suitable for use as a classroom, including a school facility such as a
laboratory, library, school eating facility, or facility used for the preparation of food.
(2) Any gymnasium or other facility which is specially designed for athletic or recreational
activities for an academic course in physical education.
(3) Any other facility used for the instruction or housing of students or for the administration of
educational or research programs.
(4) 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).
(5) Any portico or covered exterior hallway or walkway.
(6)
Any exterior portion of a mechanical system used to condition interior space.
Significantly damaged friable miscellaneous ACM: damaged friable miscellaneous ACM
where the damage is extensive and severe.
Significantly damaged friable surfacing ACM: damaged friable surfacing ACM in a
functional space where the damage is extensive and severe.
Small-scale, short-duration activities (SSSD): tasks such as, but not limited to:
(1)
(2)
(3)
(4)
(5)
Removal of asbestos-containing insulation on pipes.
Removal of small quantities of asbestos-containing insulation on beams or above ceilings.
Replacement of an asbestos-containing gasket on a valve.
Installation or removal of a small section of drywall.
Installation of electrical conduits through or proximate to asbestos-containing materials.
SSSD can be further defined by the following considerations:
(1) Removal of small quantities of ACM only if required in the performance of another
maintenance activity not intended as asbestos abatement.
(2) Removal of asbestos-containing thermal system insulation not to exceed amounts greater
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than those which can be contained in a single glove bag.
(3) Minor repairs to damaged thermal system insulation which do not require removal.
(4) Repairs to a piece of asbestos-containing wallboard.
(5) Repairs, involving encapsulation, enclosure, or removal, to small amounts of friable ACM
only if required in the performance of emergency or routine maintenance activity and not
intended solely as asbestos abatement. Such work may not exceed amounts greater than
those which can be contained in a single prefabricated mini-enclosure. Such an enclosure
shall conform spatially and geometrically to the localized work area, in order to perform its
intended containment function.
Surfacing ACM: interior ACM that has been sprayed on, troweled on, or otherwise applied to
surfaces (structural members, walls, ceilings, etc.) for acoustical, decorative, fireproofing, or
other purposes.surfacing material that is ACM.
Surfacing material: material in a school building that is sprayed-on, troweled-on, or otherwise
applied to surfaces, such as acoustical plaster on ceilings and fireproofing materials on
structural members, or other materials on surfaces for acoustical, fireproofing, or other
purposes.
Thermal system insulation: material in a school building applied to pipes, fittings, boilers,
breeching, tanks, ducts, or other interior structural components to prevent heat loss or gain, or
water condensation, or for other purposes.
Thermal system insulation ACM: insulation used to control heat transfer or prevent
condensation on pipes and pipe fittings, boilers, breeching, tanks, ducts, and other parts of hot
and cold water systems; heating, ventilation, and air-conditioning (HVAC) systems; or other
mechanical systems that is ACM.
Vibration: the periodic motion of friable ACBM which may result in the release of asbestos
fibers.
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Acronyms
ACM:
Asbestos-Containing Material
ACBM:
Asbestos-Containing Building Material
AHERA:
Asbestos Hazardous Emergency Response Act
ASHARA: Asbestos School Hazard Abatement Reauthorization Act
DOT:
Department of Transportation
EPA:
Environmental Protection Agency
HEPA:
High Efficiency Particulate Air
HVAC:
Heating, Ventilation and Air-Conditioning
LEA:
Local Education Agency
MAP:
Asbestos Model Accreditation Plan
NESHAP: National Emission Standard for Hazardous Air Pollutants
NIOSH:
National Institute of Occupational Safety and Health
O&M:
Operations and Maintenance
OSHA:
Occupational Safety and Health Administration
PCM:
Phase Contrast Microscopy
PLM:
Polarized Light Microscopy
SSSD:
Small Scale, Short Duration
TEM:
Transmission Electron Microscopy
TSI:
Thermal System Insulation
VAT:
Vinyl Asbestos Tile
VOC:
Volatile Organic Compounds
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Figure 5-1
Decision Tree to Determine
Physical Assessment Categories
FUNCTIONAL SPACE
What Type ACBM?
TSI
Surfacing
Condition?
Significant
Damage
CAT. #3
Damage
Misc.
Condition?
Good
Significant
Damage
Damage
Condition?
Good
Potential
Significant
Damage
Potential
Damage
Low
Potential
Potential
Significant
Damage
Potential
Damage
CAT. #6
CAT. #5
CAT. #7
CAT. #6
CAT. #5
Good
Potential for
Disturbance
Potential for
Disturbance
Potential for
Disturbance
Damage
CAT. #4
CAT. #1
CAT. #2
Significant
Damage
Low
Potential
CAT. #7
Potential
Significant
Damage
CAT. #6
Potential
Damage
Low
Potential
CAT. #5
CAT. #7
CHAPTER 6
FIGURE 6-1
The Management Plan
Flow Charts of Possible Response Actions
DAMAGED OR SIGNIFICANTLY DAMAGED TSI ACM
Remove, if Repair not
Technologically Feasible
At Least Repair the Damaged Area
Maintain coverings in an Intact
State and Undamaged C ondtion
SIGNIFICANTLY DAMAGED FRIABLE SURFACING OR
SIGNIFICANTLY DAMAGED FRIABLE MISCELLANEOUS
ACM
Immediately Isolate Functional
Space and Restrict Access
Removal
Encapsulation
Enclosure
DAMAGED FRIABLE SURFACING OR DAMAGED FRIABLE
MISCELLANEOUS ACM
Enclosure
Removal
Encapsulation
FRIABLE SURFACING, TSI OR FRIABLE MISCELLANEOUS ACM
WITH POTENTIAL FOR DAMAGE
Potential for Significant Damage
Potential for Damage
Implement an O&M Program
Institute Preventive Measures to Eliminate
Reasonable Likelihood that ACM or its covering
Will Be Significantly Damaged, Deteriorated, or
Delaminated
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If Effective Measures Cannot Be
Implemented, Remove
Repair
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