Mandatory Asbestos Program Requirements

iStock_000065034755_SmallSchools need to comply with several mandatory asbestos-related plans and programs.  The widely known Asbestos Hazard Emergency Response Act (AHERA), which was designed especially for schools, is only one of the mandated programs.

Read on for a summary of its requirements, as well as additional mandatory programs.

AHERA – REQUIRED
The Asbestos Hazard Emergency Response Act (AHERA), developed specifically for schools and enacted by the EPA in 1987, requires the following:

  • Inspection: A trained, qualified, and EPA-certified professional needs to inspect each building to determine whether asbestos-containing materials (ACM) are present.
  • 3-Year Re-Inspection: Schools must have all known or assumed asbestos-containing materials in each building re-inspected every three years by an EPA-certified inspector.
  • Asbestos Management Plan: A certified professional must develop, maintain, and update an Asbestos Management Plan and keep a copy at the school and a second copy at a “central location” such as the District Office, the Designated Person’s office, etc. The copies must be identical. All updates must be in both copies.
  • Reports: All inspection and re-inspection reports must be kept in an archive.
  • Yearly Notification: At least once a year the district must provide written notification to parents, teachers, and employee organizations on the availability of the school’s Asbestos Management Plan and any asbestos-related actions taken or planned in the school.
  • Designated Person: Designate a contact person to ensure the responsibilities of the school district are properly implemented. Each district must have an AHERA-certified “Designated Person” to manage their asbestos program. This is a one-time training with no required refresher trainings.
  • 6-Month Surveillance: Every 6 months, the Designated Person must ensure and document that all asbestos-containing materials are looked at to ensure their condition hasn’t changed.
  • Training and License: Ensure that only properly trained and licensed professionals perform inspections, generate or update the Asbestos Management Plan, and take response actions. Provide custodial and maintenance staff with asbestos-awareness training.

ASBESTOS “GOOD FAITH” INSPECTION OR SURVEY – REQUIRED
Federal and Washington State (EPA and DOSH) regulations require a “Good Faith” asbestos inspection prior to any remodel, renovation, or demolition of a building. This includes any and all building material(s) that may be disturbed during the project. The Good Faith inspection is intended to go beyond the scope of the AHERA inspections, which only included accessible locations inside school buildings. AHERA did not include roofing materials, exterior components of the building, or demolition sampling (under carpets, inside walls, etc.) in its scope. For this reason, the AHERA Management Plan does not suffice as a “Good Faith” inspection report. “Good Faith” requirements also include employee protection provisions.

ASBESTOS TRAINING – REQUIRED
Different trainings may be required for different staff, depending on their duties. Read below to help determine which training is required and appropriate for staff.

  • Awareness Training: This training is designed for maintenance and custodial staff involved in cleaning and minor maintenance tasks where asbestos containing material may be accidentally disturbed. New maintenance and custodial staff must be trained within 60 days of employment
  • Asbestos Worker Training: If district employees work in asbestos response, they will need additional training (depending on the level of work), and annual refreshers.
  • Training for the “Designated Person”: The person who manages the district asbestos program must be AHERA-certified. This is a one-time training with no required refresher trainings.

References
EPA: Asbestos and School Buildings
EPA: The ABCs Of Asbestos In Schools

Resources

Please find a list of some of the companies in the area that provide training and asbestos-related services (not an all-inclusive list):

  • Argus Pacific (now merged with RGA) – Seattle
  • Cole and Associates – Kent
  • NOW Environmental – Tacoma
  • PBS Engineering and environmental – Seattle
  • Seattle Asbestos Test, LLC
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