United States
Environmental Protection
Agency
Office of Pollution
Prevention and Toxics
Washington, D.C. 20460
EPA 700/B-92/001
FEBRUARY 1992
a ppjy A GUIDE TO PERFORMING
REINSPECTIONS UNDER THE
ASBESTOS HAZARD EMERGENCY
RESPONSE ACT (AHERA)
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A GUIDE TO PERFORMING REINSPECTIONS
UNDER THE ASBESTOS HAZARD EMERGENCY
RESPONSE ACT (AHERA)
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics
Environmental Assistance Division
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Bpufevard, 12th floor
Chicago, It 60604-3590
February 1992
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ACKNOWLEDGEMENTS
The Environmental Protection Agency (EPA) would like to take this opportunity to
acknowledge a number of individual contributors from inside and outside EPA that strengthened the
development of this guidance document. The individuals identified below contributed immensely to
this publication, therefore ensuring that school districts, inspectors, management planners, and
training providers receive the foremost technical guidance available.
The EPA project coordinator for development of this guidance document was Betty Weiner,
from the Environmental Assistance Division. Betty's diligence and perseverance led to the successful
development of this manual.
To assist in the preparation of this document, EPA entered into a contractual agreement with
WESTAT, Inc. of Rockville, Maryland. The following individuals associated with WESTAT, Inc. were
instrumental in the unfolding of this document:
Susan Marie Viet, CIH
Alexa Fraser, Ph.D.
Dale L. Keyes, Ph.D.
EPA Regional Staff
James Bryson
Louis Bevilacqua
A1 Kramer
Carole Dougherty
Rhonda Evans
Terrence Stanuch
Steve Vargo
Wolfgang Brandner
Greg Crable
David Combs
Jo Ann Semones
Matt Wilkening
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
U.S. EPA
Region I
Region II
Region II
Region III
Region IV
Region V
Region VI
Region VII
Region VII
Region VIII
Region IX
Region X
EPA Headquarters Staff
Tom Ripp
Mary Jane Angelo -
Cindy Fournier
Sally Sasnett
Sanda Howland
Stationary Source
Compliance Division
Office of General
Counsel, Pesticides and
Toxic Substances Div.
Pesticides and Toxics
Enforcement Division
Office of Compliance
Monitoring
Office of Compliance
Monitoring
Environmental Assistance Division
Dave Kling
Bob McNally
Gina Bushong
Joe Schechter
Phil King
Bob Jordan
Diane Sheridan
Other Federal and Outside Organizations
National Association of Independent Schools -
James T. Kaull
Council for American Private Education -
Greg D. Kubiak
The National Association of Elementary School
Principals - Ed Keller
The Council of the Great City Schools -
Michael Casserly
American Association of School Administrators •
Joyce Hill
U.S. Catholic Conference -
Rev. William F. Davis
National Education Association - Joel Packer
National Parent Teacher Association -
Carolyn Henrich
Department of Defense Stateside Dependents
Schools - Dr. Hector O. Nevarez
Occupational Safety and Health Administration •
Dr. Carol J. Jones
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TABLE OF CONTENTS
Chapter Page
1 INTRODUCTION 1-1
1.1 The Purpose of this Guide 1-1
1.2 Time Periods for Reinspections 1-2
1.3 Terminology Used in this Guide 1-3
1.4 Summary of Relevant AHERA Evaluation Study
Reinspection Findings 1-4
2 AHERA DESIGNATED PERSON'S REINSPECTION
PLANNING RESPONSIBILITIES 2-1
3 INSPECTOR'S REINSPECTION RESPONSIBILITIES 3-1
4 MANAGEMENT PLANNER'S REINSPECTION
RESPONSIBILITIES 4-1
5 AHERA DESIGNATED PERSON'S RECORDKEEPING
RESPONSIBILITIES 5-1
List of Appendices
Appendix Page
A AHERA Regulatory Citations for Reinspections A-l
B Sample Reinspection Form 1: Original AHERA Inspection
Information Abstracted from the Management Plan and
Instructions for Using Reinspection Form 1 B-l
C Sample Reinspection Form: Reinspection of ACBM: Findings
and Management Planner Recommendations and Instructions
for Using Reinspection Form 2 C-l
ii
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TABLE OF CONTENTS (continued)
List of Appendices (continued)
Appendix Page
D Answers to the Most Frequently Asked Questions About
Reinspections Under the AHERA Asbestos-in-Schools Rule D-l
E Glossary of Terms E-l
F References F-l
G Pull-out copies of:
1. Sample Reinspection Form 1: Original AHERA
Inspection Information Abstracted from the
Management Plan G-2
2. Sample Reinspection Form 2: Reinspection of
ACBM: Findings and Management Planner
Recommendations G-3
3. Recommended Reinspection Checklist for the
AHERA Designated Person-Planning for the
Reinspection G-4
4. Recommended Reinspection Checklist for the
Inspector G-5
5. Recommended Reinspection Checklist for the
Management Planner G-8
6. Recommended Reinspection Checklist for the
AHERA Designated Person-Recordkeeping G-9
7. Recommended Sample Reinspection Notification
Letter G-10
H Message from the Administrator of EPA H-l
I Points of Contact
The Regional Asbestos Coordinators and the State AHERA
Designees 1-1
in
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TABLE OF CONTENTS (continued)
List of Exhibits
Exhibit Page
A Recommended Reinspection Checklist for the AHERA
Designated Person - Planning for the Reinspection 2-2
B Recommended Reinspection Checklist for the Inspector 3-2
C Recommended Reinspection Checklist for the
Management Planner 4-2
D Recommended Reinspection Checklist for the AHERA
Designated Person - Recordkeeping 5-2
E Recommended Sample Reinspection Notification Letter 5-4
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CHAPTER 1. INTRODUCTION
1.1 The Purpose of This Guide
Under the Asbestos Hazard Emergency Response Act (AHERA)1, the United States
Environmental Protection Agency (EPA) requires each elementary and secondary school to
perform an inspection for asbestos-containing building material (ACBM) and to prepare an
asbestos management plan. The AHERA regulations further require a reinspection of the ACBM
at least once every 3 years.
This reinspection guide will assist:
¦ Local Education Agencies (LEAs),
¦ AHERA designated persons,
¦ Asbestos inspectors, and
¦ Management planners
in meeting the specific requirements for an AHERA reinspection. Further, it provides guidance
for improving the accuracy and quality of information available about ACBM during the
reinspection.
The reinspection period provides an excellent opportunity for schools to re-evaluate
and update their programs for managing asbestos. EPA recently issued general guidelines for
asbestos in buildings in an advisory letter from the EPA Administrator which was sent to all LEAs.
The letter summarizes EPA's policies for asbestos control in schools and other buildings in the
form of "Five Facts." This letter is presented in Appendix H.
This guide addresses only the Federal requirements for reinspections. A school may
also be subject to State or local requirements not discussed here. The Regional Asbestos
Coordinators and the State AHERA designees are both listed at the end of Appendix I. These
individuals can provide more specific information about local regulations, and information on how
to obtain further training and assistance.
^40CFR763, Asbestos-Containing Materials in Schools: Final Rule and Notice, U.S. Environmental Protection Agency, October 1987.
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12
Time Periods for Reinspections
The AHERA regulation states that schools must perform reinspections at least once
every 3 years after the management plan is implemented. It also required management plans be
implemented by July 9, 1989. Therefore, LEAs must complete the first round of reinspections on
or before July 9, 1992. If a management plan was implemented before July 9, 1989, the LEA must
complete its reinspection within 3 years of the earlier date. Additional questions concerning the
AHERA requirements for reinspections are answered in the EPA publication, Answers to the
Most Frequently Asked Questions about Reinspections. A copy of this publication is in Appendix
D.
Example 1. The LEA implements the school's management plan on January 30,1989.
The first reinspection must be completed by January 30, 1992,
The second reinspection must be completed by January 30, 1995, and so forth.
The LEA must submit management plans to the State Governor's office for buildings
brought into service after October 12, 1988, prior to their use as a school building. The AHERA
regulation also requires reinspection of these buildings at least every 3 years from the date of
management plan implementation.
Example 2. The LEA begins to use a building as a school building on September 3, 1991. The
LEA performs the original inspection and submits the management plan to the State
Governor, as required, on August 30, 1991. Upon expiration of the 90-day period for
State review, the plan is implemented on November 30,1991 (unless the plan has been
disapproved by the state).
The first reinspection for this building must be completed by November 30,
1994.
Example 3. The school implements its management plan on July 9, 1989. The school takes the
building out of service as a school building on January 1, 1992.
If the school returns the building to service on June 1, 1992, the reinspection
must be completed by July 9, 1992, within the original 3 year reinspection
period.
If the school returns the building to service on September 1, 1992, the
reinspection must be completed by October 1, 1992, within 30 days after
commencement of use, for whatever reason.
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Note: If the school had not retained the original management plan and inspection
reports when the building was taken out of service, a complete original AHERA
inspection must be performed (including bulk sample collection), and a new
management plan must be developed prior to using the building as a school building
again. (See Example 2 above.)
Reinspections are considered complete after four steps occur. These are (1)
inspector's completion of the visual examination and assessments of ACBM as detailed in
40CFR763.85(b), (2) inspector's submission of the reinspection findings to the designated person
within 30 days following the field work, (3) management planner's review of the results of the
reinspection, and (4) management planner's submission of recommendations for response actions
to the designated person.
13 Terminology Used in this Guide
This section presents important terms or concepts that are used throughout the guide.
See Appendix E for a glossary of other key terms.
Functional Space versus Room/Area
AHERA regulations define a functional space as "a room, group of rooms, or
homogeneous area designated by a management planner, project designer, or person accredited to
conduct response actions." The AHERA Preamble refers to functional space as a "term of art"
used by the accredited expert to appropriately characterize an area as containing "significantly
damaged friable surfacing ACM" or "significantly damaged friable miscellaneous ACM." In the
context of response actions, the affected functional space is that area within the containment area.
This indicates that a functional space can be a grouping of areas with similar response
action recommendations. The AHERA definition requires that management planners, not
inspectors, define functional spaces.
For the discussion in this guide, the term room/area refers to spaces defined by the
inspector during the reinspection. The inspector may interpret this as an individual space
surrounded by walls, such as a hallway or classroom; a group of individual spaces; or the entire
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homogeneous sampling area. We strongly recommend the first interpretation, i.e., an individual
space surrounded by walls. This clearly-defined space will enable the LEA, school staff, and
parents to easily review information about ACBM for a specific location.
Original Inspection Versus Reinspection
Original inspection or original AHERA inspection refers to the initial inspection
(generally performed before July 9,1989) to meet AHERA requirements.
Reinspection refers to the required reinspection of all ACBM identified during the
original AHERA inspection. LEAs must perform reinspections at least once every 3 years.
When we refer to materials that were not identified during the original AHERA
inspection and which are found at a later date (possibly as part of the reinspection activity), we use
the term inspection since it refers to the first recording of these materials in the management plan.
LEA Versus AHERA Designated Person
The LEA must designate and train a person to ensure that the AHERA regulations
are properly implemented. Since this designated person acts on behalf of the LEA, we use the
terms LEA and AHERA designated person or designated person interchangeably in this guide.
1.4 Summary of Relevant AHERA Evaluation Study Reinspection Findings
In June, 1991, the EPA released the report entitled Evaluation of the Asbestos
Hazard Emergency Response Act (AHERA). This report was prepared as part of a commitment to
Congress by EPA to evaluate the effectiveness of the AHERA regulation and to determine which
elements might be used in future regulation of public and commercial buildings. A summary
document entitled Asbestos in Schools: Evaluation of the Asbestos Hazard Emergency Response
Act (AHERA): A Summary Report presents the Evaluation Study's major findings. The summary
document can be obtained by calling the Toxic Substances Control Act (TSCA) Hotline (see
Appendix F). The Evaluation of AHERA: A Fact Sheet, which was sent to all schools in the
summer of 1991, can also be obtained through the hotline.
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The evaluation study was based on a national statistical sample of 198 schools in 30
communities. The study focused only on occupied school buildings in the United States with
students in any of grades 1 through 12. There were a few exclusions: buildings constructed after
October 1988, buildings where the original AHERA inspection found no asbestos, and buildings
where no inspection was conducted in response to AHERA. The report estimates that the schools
in the target population, from which the sample for this evaluation was drawn, represent
approximately 80 percent of the 106,000 schools in the nation.
The evaluation study covered six major areas of the AHERA regulation:
¦ identification and assessment of material;
¦ management plan evaluation;
¦ response action evaluation;
¦ original AHERA inspection evaluation;
¦ process of notification; and
¦ maintenance and custodial worker training and experience.
The following represent the findings of the AHERA Evaluation that pertain to
performing reinspections:
¦ unidentified materials
Many original AHERA inspections did not identify at least one suspect
material present. The most consistently unidentified materials were:
fire doors
duct insulation
resilient sheet flooring/linoleum
vibration dampening cloth
The study did not evaluate smooth wall materials [such as gypsum wallboard
(also called sheetrock or drywall), joint compound, and hard plaster]. However,
the EPA believes original inspections may have frequently missed these
materials.
¦ material locations
Only 56 percent of the areas where ACBM was identified had the exact location
recorded in the management plan.
¦ material quantity
An estimated 89 percent of the total quantity of suspect ACBM reinspected in
the evaluation was reported in the original AHERA inspection.
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¦ material assessments
Ninety-two percent of the ACBM that should have been assessed according to
AHERA was actually assessed. Forty-four percent of the ACBM assessed used
AHERA categories reporting the amount of damage and potential for damage
at the time of inspection.
¦ management plans
Written management plans generally contain all the required information. This
information is often difficult to understand, however, without specialized
instruction.
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CHAPTER 2. AHERA DESIGNATED PERSON'S REINSPECTION PLANNING
RESPONSIBILITIES
Exhibit A presents the first of two checklists for the AHERA designated person. He
or she must take a number of steps in planning for the reinspection prior to any field activities.
Each of these steps is discussed below.
1~1 Al. Select the inspector(s) and management planner to perform reinspection activities;
obtain proof of their current accreditations.
A person's accreditation is current if he or she has successfully completed an EPA or
State approved accreditation or refresher course within 1 year prior to the
reinspection activity. Similarly, the management planner reviewing the reinspection
results must be accredited under AHERA as a management planner and his or her
accreditation must be current. While there is an additional 1-year grace period to
take the refresher course without having to take the full course over again (total of 2
years since the last accreditation course), an individual is not considered accredited
during the second-year period. There are no other restrictions on the inspector or
management planner, with the exception of possible conflict of interest (see page 2-3).
The inspector and management planner may be:
the person(s) who performed the original inspection and/or prepared the
management plan, if accreditation is still current. His or her familiarity with
the school could increase efficiency and thus save some time and money. On
the other hand, these individuals may repeat errors made during the original
inspection;
the AHERA designated person or other LEA employee, if accredited.
However, the LEA must ensure that reinspections are performed
conscientiously. Someone who works in a building every day may not be
attuned to changes in ACBM condition or may fail to identify suspect materials
not reported in the original inspection; or
a consultant or consulting company employee, if accredited.
Request copies of inspector and management planner certificates to verify that
accreditations are current. Include these in the management plan.
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Exhibit A. Recommended Reinspection Checklist for the AHERA Designated Person-
Planning for the Reinspection
~ I-
~ 2.
~
~
~
~
~
~ 3.
~
~
~
~
Select the inspector(s) and management planner to perform reinspection activities;
obtain proof of their current accreditations.
Determine the scope of work.
2a. Clarify which buildings are to be included in the reinspection. Determine whether
each building is used as a school building.
2b. Determine whether previously grouped, similar materials (e.g., all floor tile) should
be separated into distinct materials.
2c. Determine whether previously assumed ACBM should be bulk sampled.
Determine whether other bulk samples should be collected.
2d. Determine whether quantities of ACBM should be re-estimated.
2e. Determine whether the inspector should look for previously unidentified suspect
materials. (Highly recommended by the EPA.)
Determine how the reinspection results will be reported.
3a. Determine whether locations of ACBM should be reported on a room-by-room
basis, rather than by a building or homogeneous sampling area basis.
3b. Determine whether a floorplan or written description, or both, will be used to
locate ACBM.
3c. Determine whether ACBM will be assessed on a room by room, homogeneous
sampling area, or some other basis.
3d. Determine whether photographs or videotape will be used to document material
condition.
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Conflict of Interest
Although any person whose inspector or management planner accreditation is current
may perform their respective roles, the LEA should consider whether a conflict of
interest exists. This is particularly important where one person or firm may serve two
or more roles at the school. For example, a conflict of interest might exist if the
management planner and the asbestos contractor both worked for the same firm. The
planner might recommend response actions that are more expensive than necessary to
protect human health and the environment. A similar conflict of interest might arise
if the same person acts as both inspector and management planner for the school.
Reinspection Assistants
Only an accredited inspector may perform required reinspection activities. An
unaccredited assistant cannot locate, touch, or assess ACBM or sign reinspection
forms. Such an assistant can, however, record information dictated by the inspector,
carry supplies, assist in gaining access to areas, and perform other non-regulated
tasks.
n A2. Determine the scope of work.
You may want to expand upon the minimum requirements for a reinspection, as
discussed below. Carefully consider the work required before beginning the field
work.
1~1 A2a. Clarify which buildings are to be included in the reinspection. Determine
whether each building is used as a school building.
List the buildings to be reinspected. Include any temporary buildings. LEAs
must reinspect all buildings or portions of buildings which were originally
inspected and which they "lease, own or otherwise use as a school building"
[see 40CFR763.85(b)(l)]. Administrative and maintenance buildings, storage
areas, garages, utility facilities, and student housing essential to operating the
school and under the authority of the LEA must all be reinspected, if they
contain friable or nonfriable known or assumed ACBM.
Management plans are to be developed on a "per school" basis. Homo-
geneous sampling areas are to be identified for each "school building.11 A
"school" may be comprised of numerous "school buildings." Management
plans, however, often do not distinguish between buildings on the same
campus. In addition, homogeneous sampling areas are sometimes incorrectly
defined across several buildings. For example, one homogeneous sampling
area may be "2x4 ceiling tile in Buildings 1, 2, and 3." Treat each building
individually for reporting and bulk sampling purposes. Review whether these
types of errors occur in the reports for buildings scheduled for reinspection,
and instruct the inspector to correct any possible deficiencies.
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Buildings which may not need reinspection include:
¦ Buildings no longer used as school buildings.
Buildings do not require a reinspection if they are no longer used as
school buildings when a reinspection is scheduled. This is true even if
the LEA still owns or leases them. An example is a temporary trailer
which is unused due to decreased enrollment.
It is recommended that the LEA provide a statement in the
management plan that the building is not currently used as a school
building. If the LEA decides to use the building at a later date, the
building must be reinspected (see Section 1.2). Remember, however,
that LEA buildings not currently or ever used as classrooms (e.g.,
storage or administrative buildings) are subject to AHERA.
¦ Buildings in which no known or assumed ACBM was reported in the
original AHERA inspection.
If no known or assumed ACBM was reported during the original
inspection, the building does not have to be reinspected. There should
be a statement in the management plan that no ACBM was present.
Further, no reinspection is required if the management plan contains a
signed statement that the building is asbestos-free in accordance with
40CFR763.99(a).
We recommend, however, that the LEA reinspect each building for
materials often not identified in the original inspection. Such materials
include fire doors, resilient sheet flooring/linoleum, interior and
exterior duct insulation, vibration dampening cloth, and suspect wall
materials. It would also be prudent to look for other suspect materials
not identified during the original inspection. (See page 2-7, A2e.)
¦ Buildings in which all known or assumed ACBM has been removed.
In strict accordance with the AHERA regulation, a building does not
have to be reinspected if all ACBM has been removed. Include
documentation of the removal in the management plan.
We recommend that the LEA verify that the removal of ACBM has
been complete with no debris left behind, and that there are not still
suspect materials in the building which were unidentified during the
original AHERA inspection.
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Buildings constructed after October 12,1988.
School buildings built after October 12, 1988 do not require
reinspection if an architect or project engineer responsible for the
construction of the building, or an accredited inspector, signs a
statement that no ACBM was specified in the construction documents
or, to the best of the person's knowledge, that ACBM was not used as a
building material.
|~1 A2b. Determine whether previously grouped, similar materials (e.g., all floor tile)
should be separated into distinct materials.
Grouping different materials into one homogeneous sampling area was
common during the original inspections. Grouped materials were generally
assumed to be ACBM. For example, a management plan might describe all
floor tile in a building as a single homogeneous area of ACBM, even though
there were five colors or various sizes of floor tile. If this practice occurred, it
was a misinterpretation of the homogeneous area concept and should be
corrected.
Determine whether the original inspector grouped any unlike materials in
your building. Decide whether to treat these materials as different
homogeneous sampling areas based on distinguishing factors, such as texture,
color, or location. By breaking these groups into their individual materials, a
significant quantity of material might be reclassified as non-ACBM (based on
results of laboratory analysis).
|~1 A2c. Determine whether previously assumed ACBM should be bulk sampled.
Determine whether other bulk samples should be collected.
There are two choices in dealing with previously assumed ACBM during a
reinspection:
(1) continue to assume the material is ACBM, or
(2) collect bulk samples for laboratory analyses, in which case the material
can be reclassified as either known ACBM or non-ACBM.
Factors which might affect the decision to collect bulk samples of previously
assumed ACBM include:
¦ additional resources for laboratory analysis are available, or
¦ assumed ACBM is the only ACBM remaining in a building. The LEA
could eliminate periodic surveillance and other ongoing management
activities if laboratory analysis confirmed the material as non-ACBM.
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¦ the LEA is planning removal projects or renovations which might affect
the assumed ACBM. It is then required to determine whether the
material does, in fact, contain asbestos.
The LEA may want to collect additional bulk samples in the following cases:
¦ the number of samples of pipe fitting insulation or a miscellaneous
material appear insufficient to determine if the material is or is not
ACBM. An example is where homogeneous areas are very large. EPA
strongly recommends that at least three samples be taken in large
homogeneous areas, even when the regulations do not require it.
¦ previously unidentified suspect materials are found during the
reinspection. These may be bulk sampled or assumed to contain
asbestos.
¦ materials grouped together for efficiency during the original inspection
are now separated into distinct homogeneous sampling areas. An
example would be blue 9x9 floor tile and green 9x9 floor tile previously
grouped and designated as "all floor tile throughout the building."
I | A2d. Determine whether quantities of ACBM should be re-estimated.
Consider whether the original ACBM quantities were sufficiently accurate
for proper management of the material. If actual quantities are significantly
different than reported, adjusted cost estimates may affect plans for response
actions. In addition, if the LEA now wants to record ACBM quantities room
by room, rather than by building, new measurements must be taken. In
either case, inspectors' estimates of ACBM quantity are intended for
planning purposes only. We recommend that the LEA have their project
designer verify the quantities of ACBM in each abatement project during the
design development phase.
Decide how the inspector should report quantities of ACBM, i.e., in square
feet or linear feet. The AHERA regulations require inspection
measurements reported in linear feet or square feet.
Decide also how unit quantities should be handled (as in the case of insulated
pipe joints). For abatement purposes, the project designer and contractor
normally base their estimates on the number of joints and the diameter of the
pipe. This method of reporting is, in fact, easier to track if the location is
specific. It may be used in addition to the linear or square feet calculations.
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|"~1 A2e. Determine whether the inspector should look for previously unidentified
suspect materials. (Highly recommended by the EPA.)
The LEAs must conduct reinspections of all "friable and nonfriable known or
assumed ACBM " [see 40CFR763.85(b)]. Thus, if an inspector overlooked a
suspect material during the original AHERA inspection, there is no specific
requirement that it be included in the reinspection. However, any missed
actual or suspect ACBM present in the school represents a violation of
AHERA for which both the LEA and the original inspector could be liable.
Moreover, since an LEA cannot properly manage asbestos in a building
unless it is all identified, we recommend that the original AHERA inspection
information be verified, and corrected if necessary, during the reinspection
process. With this goal in mind, consider the following materials for
inspection:
¦ materials that were frequently missed in the original inspection - fire
doors, resilient sheet flooring/linoleum, interior and exterior duct
insulation, and vibration dampening cloth;
¦ suspect wall materials such as gypsum wallboard (also called sheetrock
or drywall), joint compound and hard plaster which the EPA suspects
were frequently overlooked;
¦ distinct materials which were improperly grouped together as a single
homogeneous sampling area. Examples are different types or styles of
floor tiles and ceiling tiles, and similar acoustical plaster applied at
different dates;
¦ other materials such as boiler fire brick, gaskets, and caulking which
may have been missed;
¦ specific materials of interest to the LEA, such as exterior roofing
materials, auditorium curtains, light socket collars, electrical wire
insulation, or stored building materials. The regulation does not,
however, require inspection of these materials; and
¦ materials introduced to the building during renovations which have not
been properly documented as ACBM or non-ACBM.
|~~1 A3. Determine how the reinspection results will be reported.
Management plans present original inspection results in a variety of formats, many of
which are difficult to follow without specialized instruction. The AHERA regulation
does not specify the format for reinspection results.
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Determine what format will work best for the school. Issues to consider include: Has
the original plan been a useful reference in answering questions about ACBM in the
school? Are parents and staff interested in detailed reports? Are there numerous
materials or numerous ACBM locations, or both, to manage in the school? Do State
or local laws have required formats? Do State or local laws exceed Federal
requirements?
A3a. Determine whether locations of ACBM should be reported on a room-by-room
basis, rather than by a building or homogeneous sampling area basis.
The reinspection is a good time to address how to report locations of ACBM.
Some management plans report only general locations, e.g., "ceiling tile
throughout building." This reporting may be acceptable where 1) only one
kind of ceiling tile is present in the building, 2) the material's location is
clearly indicated, and 3) the quantity of material is clearly shown. This type
of reporting is unacceptable where two or more tile types are present or
where both asbestos-containing tiles and non-asbestos-containing tiles are
present in the same building.
Reporting locations of ACBM room by room is clearer. Although it may
generate extra paperwork for the inspector, it provides the best information
for properly managing the materials. In some cases, it may be useful to
further describe the location within the room/area. An example would be
stating that "transite paneling is installed on the north wall of Room 127"
where the other three walls are visually-identical, concrete block walls.
Another approach is to locate each ACBM by describing its entire
homogeneous sampling area. In this case, the inspector must clearly define
the homogeneous sampling area by an inclusive and exhaustive listing of
rooms. Rooms should be identified by number rather than use (such as
music room, etc.) since room functions may change. An alternative is for the
inspector to highlight on a floorplan all rooms in which the material is
present.
A3b. Determine whether a floorplan or written description, or both, will be used to
locate ACBM.
Decide whether the inspector will record the locations of ACBM by a written
description or by highlighting a floorplan, or by some combination of each.
In rare cases, floorplans may not be available or readily generated. A
floorplan is decidedly more useful than a written description if rooms are not
numbered or where numbers may be changed. Even where rooms are
numbered, a highlighted floorplan may be the most efficient means of
communication. Remember, however, that highlights do not photocopy well.
2-8
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|~1 A3C.
Determine whether ACBM will be assessed on a room by room, homogeneous
sampling area, or some other basis.
Management plans generally report assessment categories for entire
homogeneous sampling areas. Although this meets the requirements of the
regulation, it may result in small areas with significant damage being ignored
because they are part of a larger category of damaged ACBM.
In addition, some management plans do not specify where the damaged
ACBM is, e.g., "pipe insulation damage observed in random locations above
suspended ceilings." It is useful to assess ACBM in small and specific areas.
In this way, the management plan indicates the exact locations of the
damaged ACBM.
A3d. Determine whether photographs or videotape will be used to document
material condition.
Visual records, either photographs or videotape, of ACBM can be very
valuable during reinspections. These will show actual changes in materials
over time, thus permitting direct comparison between reinspections. These
records add to the cost of reinspection, however, and the AHERA regulation
does not require them.
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CHAPTER 3. INSPECTOR'S REINSPECTION RESPONSIBILITIES
Exhibit B presents the checklist of reinspection activities performed by the inspector.
It includes preparatory activities, fieldwork and recordkeeping.
|~1 B1. Review the items on the Reinspection Checklist for the AHERA Designated Person -
Planning for the Reinspection.
Review and understand the decisions made by the designated person for each item on
the designated person's reinspection planning checklist (Exhibit A). It is a good idea
to meet with the designated person to discuss the scope of work and any specific
requests he or she may have.
|~] B2. Select the field forms to be used (reinspection, reassessment, inspection, bulk sample
logs, photograph logs, chain of custody, floorplans).
Appropriate field forms include:
¦ reinspection form (see Sample Reinspection Form 2 in Appendix C);
¦ assessment form, if a separate form is to be used;
¦ chain of custody and bulk sample collection forms, if additional sampling is
expected;
¦ inspection forms, if previously unidentified materials are to be inspected;
¦ copies of floorplans, if available; and
¦ photograph log forms, if photographs are requested.
Ask the designated person to determine whether the forms meet the LEA's specific
requirements for the reinspection. Most inspection firms have standardized forms.
However, it is usually not too complicated to adopt new formats prior to going into the
field.
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Exhibit B.
Recommended Reinspection Checklist for the Inspector
Plannina for the reinsDection field activities
~
1.
Review the items on the Reinspection Checklist for the AHERA Designated Person -
Planning for the Reinspection.
~
2.
Select the field forms to be used (reinspection, reassessment, inspection, bulk sample
logs, photograph logs, chain of custody, floorplans).
~
3.
Review the management plan for the school (see Sample Reinspection Form 1 in
Appendix B).
~
3a.
Obtain or generate a list of all ACBMs and non-ACBMs (and associated
identification numbers, if provided) and material categories reported during the
original inspection.
~
3b.
Record the sample results for each homogeneous sampling area of suspect
material.
~
3c.
Record all reported locations of material (descriptions and/or location diagrams)
for each homogeneous sampling area.
~
3d.
Copy the location diagrams, if possible.
~
3e.
Record the original inspection assessment category assigned to ACBM in each
room/area.
~
3f.
Record any response actions which have occurred and the location of each.
~
3g.
Record any renovations which have occurred and the location of each.
~
3h.
Review records of periodic surveillance.
~
4.
Arrange administrative details - time of inspection, school escort, and keys.
~
5.
Assemble all field materials.
~
5a.
A supply of all field forms, pens, calculator, tape measure, flashlight, and tools.
~
5b.
Blank floorplans and inspection location diagrams, if available.
~
5c.
Bulk sample collection tools and clean-up supplies, if required.
~
5d.
Personal protective equipment, if needed.
~
5e.
A ladder, if needed.
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Exhibit B.
Recommended Reinspection Checklist for the Inspector (Continued)
Performina the field activities
~
6.
Meet the school escort.
~
7.
Select the first room/area to be reinspected.
~
8.
Observe and record each ACBM in the selected room/area, referring to the list of
homogeneous areas of ACBM and non-ACBM abstracted from the management plan
(see Sample Reinspection Form 2).
~
9.
Mark the rooms/areas where each ACBM was observed on the diagram or floorplan
(optional).
~
10.
Re-estimate the quantity of each ACBM in the selected room/area (if requested by the
designated person).
~
11.
Touch each ACBM in the room/area to determine whether it is friable.
~
12.
Collect additional bulk samples, as instructed by the designated person.
~
13.
Look at the condition and determine the potential for damage or significant damage to
each friable ACBM and asbestos-containing TSI in the room/area.
~
14.
Assign a reassessment category to each friable ACBM and asbestos-containing TSI in
the room/area.
~
15.
Record the justification of the assigned reassessment category (can use assessment
form or notes).
~
16.
Photograph the material, if requested by the designated person.
~
17.
Assess previously unidentified materials in the room/area, if requested by the
designated person.
~
18.
Move to next room/area, and repeat as above.
Recordkeepina
~
19.
Complete all field form data items.
~
20.
Record name, signature, date, and accreditation number and State (if applicable) on the
reinspection form.
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Exhibit B. Recommended Reinspection Checklist for the Inspector (Continued)
Recordkeeping (continued)
I | 21. If additional bulk samples were collected, include the exact locations where they were
taken. Also include a description of the process used to select sample locations, and
the name, signature, date, and accreditation number and State (if applicable) of the
inspector(s) collecting each bulk sample in each copy of the school's management
plan.
|~1 22. Submit the results of the reinspection to the AHERA designated person within 30 days
after the reinspection is completed. Note, at a minimum, any changes in ACBM
assessment.
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[~1 B3. Review the management plan for the school (see Sample Reinspection Form 1 in
Appendix B).
It can be difficult to abstract the original inspection data necessary to perform the
reinspection properly. This is especially so where a different inspector or company is
performing the reinspection.
Management plans present the original AHERA inspection data in a wide variety of
formats. The way AHERA regulations list required elements in a management plan
commonly led to separation of different types of information into distinct chapters.
This forces the reader to flip from chapter to chapter, or table to table, in order to find
all the information about a particular material.
In some cases, management plans describe the same material in different ways. Often
the plans use material numbers and verbal descriptions interchangeably or
inconsistently. In other instances, suspect ACBMs which did not contain asbestos are
not clearly indicated as distinct homogeneous sampling areas. Indeed, the only
reference to these materials may be in the laboratory report of analyses.
Some states have standardized reporting forms. Where the forms are logically
sequenced, cross-referenced, and properly completed, it is generally straightforward to
abstract the necessary information. Unfortunately, however, management plans
generally do not include instructions for use of these standardized forms.
Sample Reinspection Form 1: Original AHERA Inspection Information Abstracted
from the Management Plan (Appendix B) shows one way to record all the information
necessary for reinspection concisely. Most buildings have less than 10 suspect ACBMs
so, the inspector should need only two or three pages of this form. This form is not
mandatory. A few pages of the management plan may contain all the necessary
information and can be photocopied to take into the field. Most management plans
are too bulky to use in the field.
|~] B3a. Obtain or generate a list of all ACBMs and non-ACBMs (and associated
identification numbers, if provided) and material categories reported during the
original inspection.
The AHERA regulation requires a "list of whether homogeneous areas...are
surfacing material, thermal system insulation, or miscellaneous material" and
"an inventory of the locations of the homogeneous areas..." in the
management plan. Based on these requirements, most management plans
have some listing of materials from which to begin the complete listing. Do
not, however, assume that any single list represents all suspect materials
addressed by the inspection. Review the entire management plan to discover
whether additional materials are reported elsewhere.
Read the text for any references to miscellaneous materials which were not
recorded in the inspection data. For example, firedoors were rarely listed as
a suspect material. If addressed at all, they were usually discussed generically
as suspect ACBM.
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It is just as important to obtain information about non-ACBMs as ACBMs.
Later, during the inspection, each material in the building can be clearly
identified as ACBM, non-ACBM, or a material which was not previously
identified. Often, the only information about non-ACBMs is found in the
laboratory results section.
Sometimes management plans discuss fiberglass, foam glass, and rubber
materials to explain why certain materials in the building were not sampled.
This information could be useful during the reinspection. Record any
available information.
I I B3b. Record the sample results for each homogeneous sampling area of suspect
material.
After generating the list of ACBMs and non-ACBMs, relate each material to
the management plan's findings. These findings are either bulk sample
results or the designation "assumed ACBM".
The material description on the bulk sample form or laboratory results and
the material descriptions for the homogeneous sampling areas may not be
the same. In these cases, it may be possible to match laboratory results to
materials by comparing the bulk sample location with the listed locations of
the homogeneous sampling areas.
|~~1 B3c. Record all reported locations of material (descriptions and/or location
diagrams) for each homogeneous sampling area.
Record the location of each ACBM listed in the management plan. As
above, scan the entire management plan for location information. For
example, non-ACBMs may be indicated only on the bulk sample collection
form. Although this form will probably not list all locations, it is a start and
should permit the inspector to identify the material.
Occasionally management plans interchange a room number and a room
name. For instance, Room 101 may be called the art room in some sections
of the management plan. Discuss these problems with the designated person
or building maintenance staff, or refer to the building floorplan.
I | B3d. Copy the location diagrams, if possible.
Some management plans contain marked floorplans to show the locations of
each ACBM or homogeneous sampling area. This information is useful and
can replace listing of locations if copies can be carried into the field. Note
that highlighters don't photocopy well. Make sure you have the original.
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1~1 B3e. Record the original inspection assessment category assigned to ACBM in each
room/area.
Record the assessment category assigned to each ACBM during the original
inspection. Since the reinspection is a comparison to the original AHERA
inspection, be careful not to record assessments from a more recent periodic
surveillance report.
The AHERA regulation does not require assessment of undamaged
nonfriable ACBM (except asbestos-containing TSI). However, some
management planners created a new assessment category 8 for nonfriable
ACBM. Others listed them as either category 5 or 6, ACBM with potential
for damage or significant damage, respectively. Thus, if a surfacing or
miscellaneous ACBM remains nonfriable and undamaged at the time of the
reinspection, indicate "no change in assessment." (See page 3-11 for a list of
the AHERA assessment categories.)
n B31. Record any response actions which have occurred and the location ol each.
Record where response actions [including Operations and Maintenance
(O&M)] were taken. This information is necessary to perform the
reinspection properly. For example, if the LEA removed ACBM from a
previously documented location, no material should be found in that location.
If the LEA encapsulated ACBM, you must determine the friability and
overall condition of the material and encapsulant.
The AHERA regulation requires that management plans contain all
documentation about ACBM in a building. Thus, records about any response
actions, including initial cleaning, should be available for review. Some
records may be bound separately from the original plan. For example,
removal project specifications can be very long. Ask the designated person to
provide the complete asbestos file for the building.
In some cases, there may be no record of an originally recommended
response action being taken. Damaged or significantly damaged ACBM
involved in these situations should be carefully checked in the field. If you
find that, in fact, the recommended response actions have not been carried
out (except for response actions scheduled for some future date), you should
bring this information to the designated person's attention.
| | B3g. Record any renovations which have occurred and the location of each.
Although management plans do not have to record general renovations,
previously unidentified materials may be exposed by such activities. Review
information about renovations so newly revealed suspect materials can be
inspected. In order to have accurate information about all ACBM or suspect
ACBM, schools should maintain records on the asbestos content of materials
installed in their buildings after October 12, 1988.
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Under the National Emission Standards for Hazardous Air Pollutants
(NESHAP) Asbestos Standard, a school is considered a "facility" and is
subject to the requirements of the standard for demolition and renovation.
|~~| B3h. Review records for results of periodic surveillance.
Periodic surveillance records may contain useful information about an
ACBM not recorded elsewhere. Examples include the recording of a small
repair activity performed during the periodic surveillance or comments about
the cause of new damage to a material.
Remember that the reinspection results must compare current conditions to
the original inspection conditions. Be careful not to confuse the results of
periodic surveillances with the original inspection results. Periodic
surveillances do not have to be performed by accredited inspectors nor are
they as comprehensive as a complete AHERA inspection or reinspection.
|~| B4. Arrange administrative details - time of inspection, school escort, and keys.
Arrange all administrative details with the designated person before beginning field
activities. Many schools do not allow contractors in buildings during school hours.
Some may have to arrange for appropriate school personnel to work overtime in the
evenings to escort the inspector. Request the keys for all locked areas.
I | B5. Assemble all field materials.
To conduct an efficient reinspection, bring all necessary field materials with you to the
building. We suggest the following items:
I | B5a. A supply of all field forms, pens, calculator, tape measure, flashlight, and tools.
Assemble adequate copies of all field forms (see page 3-1, B2). If ACBM
quantities are to be re-estimated, you should have a calculator and tape
measure. A flashlight is frequently needed to look in areas such as above
suspended ceilings, crawlspaces, and closets. Screwdrivers and pliers may be
needed to remove access panels, grilles, vents, and electrical plates.
I | B5b. Blank floorplans and inspection location diagrams, if available.
As discussed above, homogeneous sampling area location diagrams
generated during the original AHERA inspection are useful. Blank
floorplans are also helpful in assuring you have seen all locations and can be
used to generate location diagrams. Fire and emergency escape floorplans,
usually available for school buildings, are satisfactory substitutes.
3-8
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HI B5c. Bulk sample collection tools and cleanup supplies, if required.
If the designated person requests that you collect bulk samples of assumed
ACBM or previously unidentified materials or makes some other special bulk
sample request, assemble appropriate bulk sampling tools. Include clean up
supplies such as a spray bottle of encapsulant, paper towels, labeled disposal
bags, and a high efficiency particulate air (HEPA) vacuum.
n B5d. Personal protective equipment, if needed.
You may encounter areas where personal protective equipment is needed.
You might need these in a crawlspace or when bulk samples are collected.
Pack an appropriate respirator and protective clothing in accordance with the
school's or your employer's policies.
B5e. A ladder, if needed.
Determine whether you need a ladder to gain access to any area in the
school, e.g., above suspended ceilings. Also, find out whether the school will
provide a ladder for this activity. Many schools will not provide ladders.
| | B6. Meet the school escort.
Most schools require that a school representative escort building visitors. Review the
purpose of the reinspection with the assigned escort and answer his or her questions
before beginning the reinspection.
|~~1 B7. Select the first room/area to be reinspected.
Many original inspections began in the boiler room since most thermal system
insulation was found there. Tlie first room/area to be reinspected is not as critical
since the ACBM types in the building have been identified. Once the first room has
been selected, move in a logical pattern through the building so that all areas are
reinspected.
I | B8. Observe and record each ACBM in the selected room/area, referring to the list of
homogeneous areas of ACBM and non-ACBM abstracted from the management plan
(see Sample Reinspection Form 2).
Each suspect ACBM in the room/area should be on the list of information abstracted
from the management plan. Identify each ACBM, assumed ACBM, and non-ACBM
material. Note the description of each and use consistently in other rooms/areas.
If debris, residue, or overspray of an ACBM is noted in a room/area where it was
reported to have been removed, this should be recorded so that the response action
can be completed.
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If an observed material is not on the list of abstracted information, determine whether
the unlisted material is fiberglass, foam glass, rubber or other material which the
AHERA regulation excludes from inspection. If it is not an excluded material, it is a
previously unidentified material. Proceed in accordance with instructions from the
designated person (see page 2-7, A2e).
f~| B9. Mark the rooms/areas where each ACBM was observed on the location diagram or
floorplan (optional).
Describe the location of each ACBM on the reinspection form. If the designated
person wishes additional location diagrams or floorplans, mark them while in each
room/area.
I | B10. Re-estimate the quantity of each ACBM in the selected room/area (if requested by the
designated person).
If the designated person has requested re-estimation of ACBM quantities, measure
each ACBM. Also, make original estimates of the quantity of newly identified suspect
material.
[~| B11. Touch each ACBM in the room/area to determine whether it is friable.
Touch each ACBM in at least one location. Determine whether the ACBM is friable
or nonfriable. A friable material is one which can, when dry, be crumbled, pulverized,
or reduced to powder by hand pressure.
It is not advisable to touch friable materials in every location as this may cause
unnecessary fiber release. Once you determine a material is friable, you may
discontinue touching it. If, however, the material has been encapsulated in a
room/area, you should examine it closely across the entire surface and touch it in
various locations to ensure the encapsulation is complete for the entire homogeneous
area.
Based on the touch determination, the friability rating of an ACBM may be changed
during the reinspection:
Previously considered nonfriable materials may be reclassified as friable, e.g.,
where water has deteriorated the bonding matrix; or
Previously considered friable materials may be reclassified as nonfriable, e.g., if
an adequate encapsulation of surfacing material or enclosure of TSI has been
performed.
|~1 B12. Collect additional bulk samples, as instructed by the designated person.
If the designated person wants the inspector to collect bulk samples, it is most efficient
to collect them while in the room/area. However, in some cases, reinspection must be
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completed before bulk sampling can begin. In these cases, define new homogeneous
sampling areas and determine random sampling locations in accordance with
40CFR763.86. Whenever the homogeneous area is large, EPA recommends that at
least three samples be taken.
B13. Look at the condition and determine the potential for damage or significant damage to
each friable ACBM and asbestos-containing TSI in the room/area.
Look at the condition of each friable ACBM and asbestos-containing TSI to determine
if the material is not damaged, damaged, or significantly damaged. Familiarize
yourself with the definition of damaged and significantly damaged friable ACBM as
given in the AHERA regulations and interpretive documents. For information on
obtaining these documents see Appendix F.
Determine the reasonable potential for damage or significant damage to undamaged
friable ACBM and TSI. The AHERA regulations do not specify the procedure for
making this determination. Some suggestions include considering the use of the area
or the presence of water, vibration, or air streams. An additional factor is the
likelihood of human contact with the material. Most inspection companies have
created decision trees for use by their employees. Inspector training curricula also
provide decision trees for determining potential for damage.
The spatial unit for determination of damage and potential for damage may vary. The
entire homogeneous area, the ACBM in each room, or some grouping of rooms/areas
may be used. In any case, it is best to record ACBM condition in each room
quantitatively and descriptively. For example, record "Room B3 - 10 square feet of
surfacing material severely damaged due to water leak above."
B14. Assign a reassessment category to each friable ACBM and asbestos-containing TSI in
the room/area.
Assign a category to each friable ACBM and each asbestos containing TSI in the
room/area. Assign the appropriate AHERA 1 through 7 category (either numerically
or in exact words) based on damage, potential for damage, and material category.
Examine the original assessments carefully as the correct number may not have been
used, or numbers may not have been used at all. Also other assessment rankings have
been developed and you may use these in addition to but not instead of, the AHERA
categories to add detail to the assessments. The seven AHERA assessment categories
are as follows:
1. Damaged or significantly damaged TSI ACBM.
2. Damaged friable surfacing ACBM.
3. Significantly damaged friable surfacing ACBM.
4. Damaged or significantly damaged friable miscellaneous ACBM.
5. ACBM with potential for damage.
6. ACBM with potential for significant damage.
7. Any remaining friable ACBM or friable suspected ACBM.
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Even when inspectors use the same assessment scheme, assessment variability may be
high. Thus, it is important to review the initial assessment rather than performing
"blind" reassessments. If the assessment is different than the original AHERA
assessment, but the condition of the material is probably the same, explain this
difference. For example, "assessed each room rather than the entire homogeneous
sampling area." Use periodic surveillance records as a reference for change.
B15. Record the justification of the assigned reassessment category (can use assessment
form or notes).
The AHERA regulations require a justification for each reassessment category
assigned. This may be done by completing a separate assessment form or simply
explaining the assigned category.
Material category, current amount of damage, and potential for damage are the
minimum considerations in justifying the assigned assessment category. However, the
causes of the damage, the type of damage, the amount and location and accessibility of
the material, and types and number of occupants using the area are all important to
the management planner in determining appropriate response actions.
B16. Photograph the material, if requested by the designated person.
Photograph ACBM in the room/area in accordance with instructions from the
designated person.
B17. Assess previously unidentified materials in the room/area, if requested by the
designated person.
If the designated person wants previously unidentified suspect materials inspected,
assess these materials while in the room/area. Classify each material into one of the
three material type categories (thermal system insulation, surfacing material, or
miscellaneous material), determine friability, and assign an assessment category.
If previously unidentified materials are found, but have not been included as part of
the reinspection, we suggest you inform the designated person of the additional
material.
B18. Move to next room/area and repeat as above.
Start the reinspection in one room/area and proceed in a logical sequence from room
to room until all rooms/areas of the building with ACBM have been reinspected.
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The AHERA regulation does not require reinspection of rooms/areas in which no
ACBM was reported during the original AHERA inspection. Confirm the full scope
of the reinspection with the designated person prior to field work. LEAs are being
encouraged to reinspect all rooms/areas to correct any deficiencies from the original
inspection.
We recommend that rooms/areas in which the presence or absence of ACBM is not
well documented be reinspected. Such areas might include:
¦ areas locked or otherwise inaccessible during the original inspection;
¦ areas where ACBM might be present but were not clearly indicated in the
management plan. Examples include rooms where pipe elbow insulation might
be present above the suspended ceiling, or student restrooms which are attached
to classrooms but not indicated as containing floor tile;
¦ areas where renovation may have exposed new material. The EPA did not
intend that inspectors undertake destructive steps in locating suspect ACBM
and, thus, some materials that were hidden at the time of the original inspection
may now be visible because of building renovations; and
¦ areas where ACBM has been removed (to ensure the completeness of the
removal activity).
B19. Complete all field form data items.
Review each form to ensure you have completed all data items. Clarify any entries
that are incomplete or vague. Make sure your handwriting is legible, and all
abbreviations used are clear.
B20. Record name, signature, date, and accreditation number and State (if applicable) on the
reinspection form.
Sign and date the form and provide current accreditation information.
B21. If additional bulk samples were collected, include the exact locations where they were
taken. Also include a description of the process used to select sample locations, and
the name, signature, date, and accreditation number and State (if applicable) of the
inspector(s) collecting each bulk sample in each copy of the school's management
plan.
Record all of the information listed above whenever a bulk sample is collected. Many
management plans do not describe the procedures used to determine each sampling
location. Often, the plan merely quotes the AHERA requirements for the number of
random samples based on quantity of surfacing material present. Many do not state
how sample locations are determined for each thermal system insulation and
miscellaneous material.
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B22. Submit the results of the reinspection to the AHERA designated person within 30 days
after the reinspection is completed. Note, at a minimum, any changes in ACBM
assessment.
Deliver the reinspection report to the designated person within 30 days after
completing the field activities. This report must indicate any changes in ACBM
assessment. Thus, if you found no changes in assessment, the reinspection report can
be as simple as a letter stating that fact. The designated person may, however, have
requested a more elaborate report documenting the actual locations and the specific
ACBMs reinspected.
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CHAPTER 4. MANAGEMENT PLANNER'S REINSPECTION RESPONSIBILITIES
Exhibit C presents the management planner's checklist of reinspection activities,
including recommendations for response actions and recordkeeping. These activities are
described in this chapter.
|~] C1. Review the results of the original AHERA inspection, periodic surveillance records, and
the reinspection.
Review the original inspection report, periodic surveillance records, and the
completed reinspection forms and report in preparation for making response action
recommendations.
[~| C2. Visit the school or take other necessary actions to recommend response actions to the
LEA.
Take any additional steps needed to make response action recommendations. Such
steps may include visiting the building to consider the possible alternative response
actions, talking with the inspector to clarify the reassessment information, and
reviewing the budget constraints and planned response actions at the school with the
designated person.
| | C3. For each friable surfacing and miscellaneous ACBM and each asbestos-containing TSI
reported by the inspector, make written response action recommendations.
Written recommendations for response actions are particularly important if either the
assessment or friability determination has changed since the original inspection, or if
the reinspection discovers previously unidentified ACBM.
| | C3a. Describe preventive measures and response actions for each assessment
location of the ACBM.
Describe the exact response actions or preventive measure you recommend.
For example, preventive measures might include repairing a water leak to
prevent further deterioration of pipe joint insulation, installing a doorstop to
prevent damage to asbestos waUboard, or instructing teachers not to hang
anything from asbestos-containing ceiling tiles.
Describe "how to" perform repairs to ACBM if this response action is
recommended. For example, do not say "repair damaged pipe insulation."
Rather, say "use wettable lagging and encapsulant to repair damage."
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Exhibit C.
Recommended Reinspection Checklist for the Management Planner
Recommendations for resoonse actions
~
1.
Review the results of the original AHERA inspection, periodic surveillance records, and
the reinspection.
~
2.
Visit the school or take other necessary actions to recommend response actions to the
LEA.
~
3.
For each friable surfacing and miscellaneous ACBM and each asbestos-containing TSI
reported by the inspector, make written response action recommendations.
~
3a. Describe preventive measures and response actions for each assessment
location of the ACBM.
~
3b. Consider whether cleaning in accordance with procedures in 40CFR763.91(c)
should be performed in each area and make appropriate recommendations in
writing.
~
4.
Include a schedule for beginning and completing the recommended cleaning and
response actions.
~
5.
Estimate the resource requirements for the recommended response actions.
~
6.
Review the adequacy of the O&M Plan.
RecordkeeDina
~
7.
Record name, signature, date, and accreditation number and State (if applicable) on the
reinspection form.
~
8.
Submit written recommendations for the response actions to the designated person.
4-2
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[~1 C3b. Consider whether cleaning in accordance with procedures in 40CFR763.91(c)
should be performed in each area and make appropriate recommendations in
writing.
Recommend additional cleaning where friable ACBM, assumed friable
ACBM, or damaged or significantly damaged TSI is present. Specify
cleaning methods and frequency. Indicate each specific room/area requiring
cleaning. Rather than parrot the regulation's statement that cleaning must be
performed in certain instances, specify how, when, and where to perform
cleaning.
l~] C4. Include a schedule for beginning and completing the recommended cleaning and
response actions.
Specify a schedule that designates actual dates for beginning and completing each
response action recommended so that human health and the environment are
protected.
|~| C5. Estimate the resource requirements for the recommended response actions.
Estimate the resource requirements for all response actions you recommend. This
should be a comprehensive presentation of all estimated costs. Include purchase of
required ACBM maintenance equipment and supplies, training of personnel, removal
costs (including design fees), and air sampling and laboratory costs.
|~~l C6. Review the adequacy of the O&M Plan.
Although not specifically required by the AHERA regulation, you should review the
adequacy of the written O&M Plan to maintain all ACBM in good condition. If
deficiencies are found, make recommendations for changes to the designated person.
An example might be to recommend additional training for maintenance personnel in
a school where repairs to ACBM have not been sufficient to prevent the release of
fibers into the air.
|~1 C7. Record name, signature, date, and accreditation number and State (if applicable) on the
recommendation form.
Sign the written recommendations for response actions and provide current
accreditation information.
4-3
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~ C8. Submit written recommendations for response actions to the designated person.
Forward the written recommendations to the designated person. The AHERA
regulations do not specify a time frame for this submittal, but it is important to be as
prompt as possible and probably should not exceed 30 days. The reinspection is not
complete until the management planner has submitted written recommendations.
4-4
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CHAPTER 5. AHERA DESIGNATED PERSON'S RECORDKEEPING RESPONSIBILITIES
The designated person has the final responsibility for recordkeeping. This
recordkeeping is detailed in Exhibit D.
f~l D1. Include the reinspection report and recommended response actions in each copy of the
school's management plan.
Include a reinspection report in every copy of the management plan. In addition to
maintaining the report at the district administrative offices and the school's
administrative office, as required, the LEA may have copies maintained at
maintenance or custodial offices and the designated person's office.
n D2. Include a written statement indicating agreement or disagreement with the management
planner's recommendations lor response actions, justification for any disagreement,
and an implementation schedule for the response actions in the management plan.
(Recommended by the EPA.)
Write a statement showing agreement or disagreement with the recommended
response actions. Assist in the preparation of a schedule for implementation of the
response actions. This schedule must be within the time frame specified by the
management planner. If this is not possible, present justification for why the time
frame will not be met, and a plan for how the affected materials will be managed in the
interim under the O&M Plan.
[~| D3. Include inspection report findings for any previously unidentified materials (and, if
ACBM is found, include management planner recommendations) in the management
plan.
If previously unidentified materials were inspected, include the inspection report in
the management plan. An inspection report is similar to the reinspection report with
additional information. Refer to the AHERA regulation or contact a State or EPA
Regional Asbestos Coordinator (Appendix I) for details on inspection reports.
f"~l D4. Include a copy of a document describing steps taken to inform workers and building
occupants, or their legal guardians, about the reinspection in each copy of the school's
management plan.
The AHERA regulation allows a great deal of flexibility in the methods used to notify
parents and staff of the reinspection. Letters to PTA and the employee's union, an
article in an LEA newsletter, or letters to each parent about the reinspection are all
appropriate methods of notification. At a minimum, inform parents and staff that a
reinspection has occurred. It may also be useful to tell them of any new materials
5-1
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Exhibit D. Recommended Reinspection Checklist for the AHERA Designated Person -
Recordkeeping
fl 1- Include the reinspection report and recommended response actions in each copy of the
school's management plan.
f~~l 2. Include a written statement indicating agreement or disagreement with the management
planner's recommendations for response actions, justification for any disagreement,
and an implementation schedule for the response actions in the management plan.
(Recommended by the EPA.)
[~l 3. Include inspection report findings for any previously unidentified materials (and, if
ACBM found, include management planner recommendations) in the management
plan.
[~~| 4. Include a copy of a document describing steps taken to inform workers and building
occupants, or their legal guardians, about the reinspection in each copy of the school's
management plan.
f~] 5. Evaluate the effectiveness of the asbestos operations and maintenance (O&M) program
and periodic surveillance. Revise, as appropriate.
5-2
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found. Parents and staff generally prefer a letter for each school with comments about
specific materials. Exhibit E presents a sample letter for notification of reinspection.
Information about reinspections must also be included in the required annual
notification to parents and workers.
The AHERA regulations do not clearly specify the time frame for providing
notification of reinspections. It is best however, that the LEA or school provide
notification as soon as possible after receiving the reinspection report and
recommendations. At a minimum, include information about the reinspection in the
annual notification about management plan availability.
Once parents and staff are notified, include a dated notification in the management
plan as documentation. Notify the State, if required.
|~1 D5. Evaluate the effectiveness of the asbestos Operations and Maintenance (O&M) Program
and periodic surveillance. Revise, as appropriate.
When the reinspection is complete, take time to evaluate whether the asbestos O&M
Program has been effective in maintaining all ACBM. Think about problems the staff
has experienced in implementing O&M procedures. Consider alternative procedures
and revise the written O&M Program to reflect these changes. An example is adding
a written work permit system to prevent maintenance staff from drilling into asbestos-
containing ceiling material. Also, consider whether the periodic surveillance was
effective in identifying areas of increased deterioration and damage, and alter the
schedule for areas needing closer scrutiny.
Delete any O&M procedure which is no longer applicable. An example is deleting the
written procedure for repairing pipe elbow insulation after all TSI is removed from the
school.
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Exhibit E. Recommended Sample Reinspection Notification Letter
EASTS1DE COMMUNITY PUBLIC SCHOOLS East Park Avenue
Eastside, CA 91005
(999) 922-3333
Bob Smith, Superintendent
Notification of Asbestos Reinspections
TO: Parents and Staff of Eastside Middle School
FROM: Bob Smith, Superintendent of Schools
DATE: December 15,1991
In compliance with the U.S. Environmental Protection Agency (EPA) Asbestos Hazard Emergency
Response Act (AHERA), in the fall of 1988 we performed inspections of each of our school buildings for
asbestos-containing building materials. The inspection findings and asbestos management plans have
been on file in each school administrative office since that time.
The EPA requires us to perform reinspections of the asbestos materials every three years. During
the months of September through November 1991, accredited asbestos inspectors performed these
reinspections. An accredited management planner reviewed the results of the reinspections and
recommended actions we should take to safely manage each asbestos material in our buildings.
Two significant findings were noted during the reinspection of Eastside Middle School:
¦ Asbestos-containing water pipe insulation in the kitchen over the dishwasher is slowly
deteriorating due to high humidity. The material is scheduled for removal over the Christmas
break.
¦ Linoleum in all bathrooms was not included in the original AHERA inspection. The backing
(between the vinyl layer and the floor) is assumed to contain asbestos. The vinyt layer is in
good condition and provides an effective barrier, preventing asbestos fiber release. This
material has been added to our asbestos maintenance program and we will monitor it for any
changes in condition.
All other asbestos materials in this school are in good condition and we will continue to manage
them in place, as recommended by the accredited management planner.
The results of the reinspection are on file in the management plan in the school's administrative
office. Everyone is welcome to view these anytime during normal school hours (M-F, 8:00 a.m. - 4:30
p.m.). The Asbestos Program Manager, Jill Williams, is available to answer any questions you may have
about asbestos in our buildings at (999) 922-3334.
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APPENDIX A
AHERA REGULATORY
CITATIONS FOR REINSPECTIONS
A-l
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AHERA REGULATORY CITATIONS FOR REINSPECTIONS
The following are quotations cited in this document from the AHERA regulations
published October 30, 1987. They are presented to assist LEAs, AHERA designated persons,
inspectors, and management planners in performing their responsibilities.
40 CFR 763.84 General Local Education Agency Responsibilities
(c) Ensure that workers and building occupants, or their legal guardians, are informed at
least once each school year about inspections, response actions, and post-response
action activities, including periodic reinspection and surveillance activities that are
planned or in progress.
40 CFR 763.85 Inspections and Reinspections
(b) Reinspections
(1) At least once every 3 years after a management plan is in effect, each local
education agency shall conduct a reinspection of all friable and nonfriable
known or assumed ACBM in each school building that they lease, own, or
otherwise use as a school building.
(2) Each inspection shall be made by an accredited inspector.
(3) For each area of a school building, each person performing a reinspection shall:
(i) Visually reinspect, and reassess, under § 763.88, the condition of all
friable known or assumed ACBM.
(ii) Visually inspect material that was previously considered nonfriable
ACBM and touch the material to determine whether it has become
friable since the last inspection or reinspection.
(iii) Identify any homogeneous areas with material that has become friable
since the last inspection or reinspection.
(iv) For each homogeneous area of newly friable material that is already
assumed to be ACBM, bulk samples may be collected and submitted for
analysis in accordance with § 763.86 and § 763.87.
(v) Assess, under § 763.88, the condition of the newly friable material in
areas where samples are collected, and newly friable materials in areas
that are assumed to be ACBM.
A-2
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(vi) Reassess, under § 763.88, the condition of friable known or assumed
ACBM previously identified.
(vii) Record the following and submit to the person designated under § 763.84
a copy of such record for inclusion in the management plan within 30
days of the reinspection:
(A) The date of the reinspection, the name and signature of the person
making the reinspection, State of accreditation, and if applicable,
his or her accreditation number, and any changes in the condition
of known or assumed ACBM.
(B) The exact locations where samples are collected during the
reinspection, a description of the manner used to determine
sampling locations, the name and signature of each accredited
inspector who collected the samples, State of accreditation, and, if
applicable, his or her accreditation number.
(C) Any assessments or reassessments made of friable material, the
name and signature of the accredited inspector making the
assessments, State of accreditation, and if applicable, his or her
accreditation number.
40 CFR 763.93 Management Plans
(d) Each local educational agency shall maintain and update its management plan to keep
it current with ongoing operations and maintenance, periodic surveillance, inspection,
reinspection, and response action activities. All provisions required to be included in
the management plan under this section shall be retained as part of the management
plan, as well as any information that has been revised to bring the plan up-to-date.
(e) The management plan shall be developed by an accredited management planner and
shall include:
(1) A list of the name and address of each school building and whether the school
building contains friable ACBM, nonfriable ACBM, and friable and nonfriable
suspected ACBM assumed to be ACM.
(2) For each inspection conducted before December 14, 1987:
(i) The date of the inspection.
(ii) A blueprint, diagram, or written description of each school building that
identifies clearly each location and approximate square or linear footage
of any homogeneous or sampling area where material was sampled for
ACM, and, if possible, the exact locations where bulk samples were
collected, and the dates of collection.
A-3
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(iii) A copy of the analyses of any bulk samples, dates of analyses, and a copy
of any other laboratory reports pertaining to the analyses.
(iv) A description of any response actions or preventive measures taken to
reduce asbestos exposure, including if possible, the names and addresses
of all contractors involved, start and completion dates of the work, and
results of any air samples analyzed during and upon completion of the
work.
(v) A description of assessments, required to be made under § 763.88, of
material that was identified before December 14, 1987, as friable ACBM
or friable suspected ACBM assumed to be ACM, and the name and
signature, State of accreditation, and if applicable, accreditation number
of each accredited person making the assessments.
(3) For each inspection and reinspection conducted under § 763.85:
(i) The date of the inspection or reinspection and the name and signature,
State of accreditation and, if applicable, the accreditation number of each
accredited inspector performing the inspection or reinspection.
(ii) 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, the exact
location where each bulk sample was collected, date of collection,
homogeneous areas where friable suspected ACBM is assumed to be
ACM, and where nonfriable suspected ACBM is assumed to be ACM.
(iii) A description of the manner used to determine sampling locations, and
the name and signature of each accredited inspector collecting samples,
the State of accreditation, and if applicable, his or her accreditation
number.
(iv) A copy of the analyses of any bulk samples collected and analyzed, the
name and address of any laboratory that analyzed bulk samples, a
statement that the laboratory meets the applicable requirements of
§ 763.87(a) the date of analysis, and the name and signature of the
person performing the analysis.
(v) A description of assessments, required to be made under § 763.88, of all
ACBM and suspected ACBM assumed to be ACM, and the name,
signature, State of accreditation, and if applicable, accreditation number
of each accredited person making the assessments.
(4) The name, address, and telephone number of the person designated under
§ 763.84 to ensure that the duties of the local education agency are carried out,
and the course name, and dates and hours of training taken by that person to
carry out the duties.
A-4
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(5) The recommendations made to the local education agency regarding response
actions, under § 763.88(d), the name, signature, State of accreditation of each
person making the recommendations, and if applicable, his or her accreditation
number.
(6) A detailed description of preventive measures and response actions to be taken,
including methods to be used, for any friable ACBM, the locations where such
measures and action will be taken, reasons for selecting the response action or
preventive measure, and a schedule for beginning and completing each
preventive measure and response action.
(7) With respect to the person or persons who inspected for ACBM and who will
design or carry out response actions, except for operations and maintenance,
with respect to the ACBM, one of the following statements:
(i) If the State has adopted a contractor accreditation program under
section 206(b) of Title II of the Act, a statement that the person(s) is
accredited under such plan.
(ii) A statement that the local education agency used (or will use) persons
who have been accredited by another State which has adopted a
contractor accreditation plan under section 206(b) of Title II of the Act
or is accredited by an EPA-approved course under section 206(c) of Title
II of the Act.
(8) A detailed description in the form of a blueprint, diagram, or in writing of any
ACBM or suspected ACBM assumed to be ACM which remains in the school
once response actions are undertaken pursuant to § 763.90. This description
shall be updated as response actions are completed.
(9) A plan for reinspection under § 763.85, a plan for operations and maintenance
activities under § 763.91, and a plan for periodic surveillance under § 763.92, a
description of the recommendation made by the management planner
regarding additional cleaning under § 763.91(c)(2) as part of an operations and
maintenance program, and the response of the local education agency to that
recommendation.
(10) A description of steps taken to inform workers and building occupants, or their
legal guardians, about inspections, reinspections, response actions, and post-
response action activities, including periodic reinspection and surveillance
activities that are planned or in progress.
(11) An evaluation of the resources needed to complete response actions
successfully and carry out reinspection, operations and maintenance activities,
periodic surveillance and training.
A-5
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(12) With respect to each consultant who contributed to the management plan, the
name of the consultant and one of the following statements:
(i) If the State has adopted a contractor accreditation plan under section
206(b) of Title II of the Act, a statement that the consultant is accredited
under such plan.
(ii) A statement that the contractor is accredited by another State which has
adopted a contractor accreditation plan under section 206(b) of Title II
of the Act, or is accredited by an EPA-approved course developed under
section 206(c) of Title II of the Act.
40 CFR 763.99 Exclusions
(a) A local education agency shall not be required to perform an inspection under
§ 763.85(a) in any sampling area as defined in 40 CFR 763.103 or homogeneous area
of a school building where:
(1) An accredited inspector has determined that, based on sampling records, friable
ACBM was identified in that homogeneous or sampling area during an
inspection conducted before December 14, 1987. The inspector shall sign and
date a statement to that effect with his or her State of accreditation and if
applicable, accreditation number and, within 30 days after such determination,
submit a copy of the statement to the person designated under § 763.84 for
inclusion in the management plan. However, an accredited inspector shall
assess the friable ACBM under § 763.88.
(2) An accredited inspector has determined that, based on sampling records,
nonfriable ACBM was identified in that homogeneous or sampling area during
an inspection conducted before December 14, 1987. The inspector shall sign
and date a statement to that effect with his or her State of accreditation and if
applicable, accreditation number and, within 30 days after such determination,
submit a copy of the statement to the person designated under § 763.84 for
inclusion in the management plan. However, an accredited inspector shall
identify whether material that was nonfriable has become friable since that
previous inspection and shall assess the newly-friable ACBM under § 763.88.
(3) Based on sampling records and inspection records, an accredited inspector has
determined that no ACBM is present in the homogeneous or sampling area and
the records show that the area was sampled, before December 14, 1987 in
substantial compliance with § 763.85(a), which for purposes of this section
means in a random manner and with a sufficient number of samples to
reasonably ensure that the area is not ACBM.
(i) The accredited inspector shall sign and date a statement, with his or her
State of accreditation and if applicable, accreditation number that the
homogeneous or sampling area determined not to be ACBM was
sampled in substantial compliance with § 763.85(a).
A-6
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(ii) Within 30 days after the inspector's determination, the local education
agency shall submit a copy of the inspector's statement to the EPA
Regional Office and shall include the statement in the management plan
for that school.
(4) The lead agency responsible for asbestos inspection in a State that has been
granted a waiver from § 763.85(a) has determined that, based on sampling
records and inspection records, no ACBM is present in the homogeneous or
sampling area and the records show that the area was sampled before
December 14, 1987, in substantial compliance with § 763.85(a). Such
determination shall be included in the management plan for that school.
(5) An accredited inspector has determined that, based on records of an inspection
conducted before December 14, 1987, suspected ACBM identified in that
homogeneous or sampling area is assumed to be ACM. The inspector shall sign
and date a statement to that effect, with his or her State of accreditation and if
applicable, accreditation number and, within 30 days of such determination,
submit a copy of the statement to the person designated under § 763.84 for
inclusion in the management plan. However, an accredited inspector shall
identify whether material that was nonfriable suspected ACBM assumed to be
ACM has become friable since the previous inspection and shall assess the
newly friable material and previously identified friable suspected ACBM
assumed to be ACM under § 763.88.
(6) Based on inspection records and contractor and clearance records, an
accredited inspector has determined that no ACBM is present in the
homogeneous or sampling area where asbestos removal operations have been
conducted before December 14, 1987, and shall sign and date a statement to
that effect and include his or her State of accreditation and, if applicable,
accreditation number. The local education agency shall submit a copy of the
statement to the EPA Regional Office and shall include the statement in the
management plan for that school.
(7) 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, to the best of his or her knowledge,
no ACBM was used as a building material in the building. The local education
agency shall submit a copy of the signed statement of the architect, project
engineer, or accredited inspector to the EPA Regional Office and shall include
the statement in the management plan for that school.
A-7
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APPENDIX B
SAMPLE REINSPECTION FORM Is
ORIGINAL AHERA INSPECTION INFORMATION
ABSTRACTED FROM THE MANAGEMENT PLAN
AND INSTRUCTIONS FOR USING REINSPECTION FORM 1
B-l
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Sample Reinspection Form 1. Original AHERA Inspection Information Abstracted from the Management Plan Page of
School Building Date(s) of Original AHERA Inspection
Homogeneous sampling areas
Material
category
Asbestos
content
Friability
AHERA
assessment
category
(1-7, X, None)
Recorded locations of material
for each assessment category
Response actions taken/
renovations/other comments
ID number
Material description
TSI
Surf.
Misc.
Assumed
Yes
No
F
NF
X
TSI
Surf.
Misc.
Assumed
Yes
No
F
NF
X
TSI
Surf.
Misc.
Assumed
Yes
No
F
NF
X
TSI
Surf.
Misc.
Assumed
Yes
No
F
NF
X
TSI
Surf.
Misc.
Assumed
Yes
No
F
NF
X
TSI
Surf.
Misc.
Assumed
Yes
No
F
NF
X
information abstracted by Date
Friability: F = friable, NF = nonfriabie, X = not applicable (material is non-ACBM)
AHERA assessment category: 1 = Damaged or significantly damaged TSI ACBM, 2 = Damaged friable surfacing ACBM, 3 = Significantly damaged friable surfacing ACBM, 4 = Damaged or
significantly damaged friable miscellaneous ACBM, 5 = ACBM with potential for damage, 6 = ACBM with potential for significant damage, 7 * Any remaining friable
ACBM or friable suspected ACBM, X - not applicable (material is non-ACBM or nonfriabie surfacing or miscellaneous material), None = No assessment category provided
in original inspection.
-------
SAMPLE REINSPECTION FORM 1:
ORIGINAL AHERA INSPECTION INFORMATION
ABSTRACTED FROM THE MANAGEMENT PLAN
Instructions for Use
Assemble the management plan and all related documentation, e.g., removal records and
periodic surveillance reports, for the school. It is best if the inspector who will perform the
reinspection completes this form, but anyone familiar with inspection and reinspection
protocols may do so. A completed example of Form 1 is presented on page B-6 to illustrate the
process.
School
Enter the name of the school whose AHERA management plan you are reviewing.
Building
Enter the name of the first building whose inspection information you are reviewing. If
there is more than one building at the school, complete a separate Form 1 for each
building.
Date(s) of Original AHERA Inspection
Locate the date(s) on which the original AHERA inspection occurred in the building and
record.
Homogeneous sampling areas - ID number
Scan the management plan for a list or other description of homogeneous sampling areas,
including all non-ACBM homogeneous sampling areas. As you find each one, record the
identification number assigned to the material. If an identification number was not
assigned, enter "X" in this block.
Homogeneous sampling areas - Material description
Record the complete, word-for-word description of each ACBM and non-ACBM
homogeneous sampling area next to the appropriate ID number. An example is "2x4 white
lay-in ceiling tile" or "2x4 off-white ceiling tile." Small variations in descriptions can be
important in differentiating homogeneous sampling areas during subsequent fieldwork.
Fill in the quantity of the material where that could help in differentiating between similar
materials. Check the list of bulk samples collected and the laboratory report for possible
non-ACBMs.
B-3
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Material category
Find the assigned material category for each material identified (TSI, surfacing material or
miscellaneous material) and circle the corresponding category in this column.
Asbestos content
Find the asbestos content of each homogeneous sampling area. Circle "Assumed" if the
material was assumed to contain asbestos, "Yes" if the material is known to contain
asbestos based on laboratory analysis of bulk samples, or "No" if the material is known to
be non-asbestos-containing based on laboratory analysis of bulk samples, or non-ACBM by
definition (e.g., metal, wood, fiberglass, or rubber).
Friability
Find the AHERA inspection's friability determination for the known and assumed ACBM.
Circle "F" if the material was rated as friable, "NF" if the material was rated as nonfriable,
or "X" if the material was determined to be non-ACBM.
AHERA assessment category (1-7, X, None)
Find the assessment category(ies) assigned to the friable homogeneous sampling areas of
ACBM and the asbestos-containing TSI. If they were assigned as AHERA category 1-7,
record in this column. Examine the original assessments carefully as the correct number
may not have been used, or numbers may have not been used at all. Refer to the
definitions on the bottom of Sample Form 1 if words are used in the original management
plan. If more than one category was assigned, write each of these in a separate row next to
the appropriate locations (see the two pipe elbow insulation entries on the completed
example of Sample Form 1). If the original AHERA inspection did not use the AHERA 1-
7 categories, record the original insepction's actual words in this column.
If the material is non-ACBM or was rated nonfriable surfacing or miscellaneous material,
no assessment was required. Enter "X" in this column. If no assessment category is
provided for friable ACBM as required, record "none" in this column.
Recorded locations of material for each assessment category
Scan the management plan for all listed or otherwise described locations of the material.
Be sure to check bulk sample collection locations, especially for non-ACBMs. Record each
room/area in which the material is present.
If a floorplan shows the locations of the material in the management plan, a copy of the
floorplan can replace the listing of all rooms/areas in this column. In this case, simply
write "see attached floorplan" in the space provided.
B-4
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You should list the rooms/areas by assessment category and general location in the school
on this form. For example, if pipe elbow insulation in the boiler room was reported as
assessment category 1, list the boiler room in a separate row next to assessment category 1.
If the pipe elbow insulation above ceiling tiles was reported as assessment category 5, list
these areas in a separate row next to assessment category 5 (see the completed example of
Sample Form 1).
Response Actions Taken/Renovations/Other Comments
Review the management plan for all completed response actions. In addition, consult the
designated person about response actions taken and renovations which have occurred in
the building. Renovations, in particular, may not be indicated in the management plan.
Summarize response actions and renovations in the space provided.
If a material is non-ACBM, AHERA regulations do not require response actions. Enter
"X" in this column (see row 3 of completed example of Sample Form 1). If an ACBM is
nonfriable, response action recommendations are not required but were often
recommended or performed. Enter "X" or a brief summary, as appropriate. Row 1 of
Sample Form 1 shows an example of this latter situation where floor tile rated as
nonfriable was included in the O&M program.
Information Abstracted By Date
Sign the form and record the date on the lines provided.
Continue to the next blank row for each homogeneous sampling area reported in the
management plan until you have described all materials in the building. Use more than
one Form 1 when there are more than six materials with different assessment categories
in a building. Number all pages when inspection information has been abstracted for all
materials in the building. For example, number two pages, page 1 of 2 and page 2 of 2.
If there is more than one building to be reinspected at the school, complete one or more
Form Is for each building.
B-5
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COMPLETED EXAMPLE
Sample Reinspection Form t. Original AHERA Inspection Information Abstracted from the Management Plan
/£*/C^> Building re? osw /coZ/ste? c2
School
/l^a y eJ-fe'
Date(s) of Original AHERA Inspection.
Page
/ of /
Homogeneous sampling areas
Material
category
Asbestos
content
Friability
AHERA
assessment
category
(1-7, X, None)
Recorded locations of material
for each assessment category
Response actions taken/
renovations/other comments
ID number
Material description
^Joar 77/e-
TSI
Surf.
QisQ
c—
Jtesumed)
Yes
No
F
y 1 1
CnfD
''i .
X
X
/ h s~0 4 <2
S'<^4 OO /
7~V? s / ¦n
d) y~ /^ra
NF
X
S"
/£?/- //O;
/<£<0-c4e^S /^o>n<9e.
/¦?¦// So>/a-&
No
CE>
NF
X
/
/ '/&*• ,
No
db
X
/2&at>c
"77 Vfi, VA^OCfJlOCs/
"Be/ /y-
w
o\
Information abstracted by
Oate
/d/V
Friability: F = friable, NF = nonfriable, X = not applicable (material is non-ACBM)
AHERA assessment category: t - Damaged or significantly damaged TSI ACBM, 2 = Damaged friable surfacing ACBM, 3 = Significantly damaged friable surfacing ACBM, 4 = Damaged or
significantly damaged friable miscellaneous ACBM, 5 - ACBM with potential for damage, 6 = ACBM with potential for significant damage, 7 = Any remaining friable
ACBM or friable suspected ACBM, X = not applicable (material is non-ACBM or nonfriable surfacing or miscellaneous material), None = No assessment category provided
in original inspection.
-------
APPENDIX C
SAMPLE REINSPECTION FORM 2:
REINSPECTION OF ACBM: FINDINGS AND MANAGEMENT
PLANNER RECOMMENDATIONS AND
INSTRUCTIONS FOR USING REINSPECTION FORM 2
C-l
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Sample Reinspection Form 2. Reinspection of ACBM: Findings and Management Planner Recommendations Page of
School Building Date(s) of Reinspection
Homogeneous Sampling Area: Material Description ID Number
Q
ts>
REINSPECTION FINDINGS FOR ACBM
MANAGEMENT PLANNER RECOMMENDATIONS
Location (s) of ACBM
by assessment category
Quantity
Fria-
bility
Assess-
ment
cate-
gory
(1-7, X)
Justification of
assessment category
Change
in
assess-
ment
Preventive measures,
response actions, and
initial/additional cleanings
Schedule
Begin
Com-
plete
F
NF
Yes
No
F
NF
Yes
No
F
NF
Yes
No
Were additional samples of this ACBM collected? Yes No
Date of manaoement olanner review:
Inspector name
Manaaement planner name
Inspector signature
Management planner siqnature
Accreditation #/State
Accreditation #/State
Expiration date
Exoiration date
1, the LEA's Desianated Person, have read and understood the recommendations made above: Date:
-------
SAMPLE REINSPECTTON FORM 2:
REINSPECTION OF ACBM FINDINGS AND
MANAGEMENT PLANNER RECOMMENDATIONS
Instructions For Use
Use Form 2 to record information about a single homogeneous sampling area of ACBM.
Complete a separate Form 2 for each different ACBM observed. Note, however, that this form
does not fulfill all requirements for a reinspection under AHERA.
The inspector, management planner, and designated person each have a role in completing this
form. The inspector completes the left-hand portion of the form as described below on pages
C-3 to C-6. The management planner completes the right-hand portion of the form as
described on pages C-7 to C-8. The designated person completes the bottom row of the form as
described on page C-9. A completed Form 2 is presented on page C-10 to aid in understanding
these instructions.
School
Enter the name of the school to be reinspected.
Building
Enter the name of the first building to be reinspected. If there is more than one building at
the school, complete a separate set of forms for each building.
Date(s) of Reinspection
Enter the date(s) during which the building reinspection occurs.
Homogeneous Sampling Area: Material Description
Refer to the original inspection information on Form 1 (or other similar source). On Form
2, write the complete, word-for-word description of one asbestos-containing homogeneous
sampling area observed in the first room. It is important to differentiate similar
homogeneous areas of material at this point, e.g., 2x4 white lay-in ceiling tile (or panels)
versus 2x4 off-white ceiling tile.
Homogeneous Sampling Area - ID Number
If the management plan assigns identification numbers to the asbestos-containing
homogeneous sampling area, record the number in the space provided. If identification
numbers were not assigned, enter "X" in this block.
C-3
Inspector
-------
Locations of ACBM by assessment category
Record each room/area where you observe the material during the reinspection. It is
preferable to list each individual room/area where the material is present, one to a row, in
this column. However, grouping rooms is acceptable as long as it is clear which rooms are
included in the grouping. Each room/area in a group must receive the same assessment
category. For example, recording "Rooms #101-110" is acceptable if (1) all 10 rooms
contain the material, (2) all material is in the same condition, and (3) all material has the
same potential for damage. Maintaining the same groupings of rooms as used in the
original inspection may ease comparison between assessments and reassessments.
If the designated person has requested that the inspector mark a floorplan with the location of
each material, do that now.
Quantity
If the reinspection will re-estimate material quantities or report them on a room by room
basis, measure the dimensions of the material in the room/area and record in the space
provided. If the reinspection will not re-estimate quantities, enter "X" in the space
provided.
Friability
Touch the material as required to make the friability determination for the room/area.
Circle "F" if the material is friable, or "NF" if it is nonfriable.
Assessment category
Assign the appropriate assessment category 1-7 to friable ACBM and all asbestos-
containing TSI. Enter the number in this column. If you are segregating the material into
two or more assessment categories, write each number in a separate row adjacent to the
room/area descriptions appropriate to the assessment (note the three assessment
categories assigned the lxl ceiling tile on the completed example of Sample Form 2).
If the material is nonfriable surfacing or miscellaneous ACBM, enter "X" in this column
(see row 1 on the completed example of Sample Form 2).
Justification of assessment categoiy
Briefly describe the rationale for assigning the assessment category, mentioning the cause
of any damage or potential for damage. The justification is particularly important if a
change in the assessment has occurred.
C-4
Inspector
-------
Some inspection companies use specialized assessment forms to record the factors they
consider in assigning the assessment category. Many have a decision tree leading the
inspector to the assigned assessment category based on the information from the
assessment form. These forms are acceptable alternatives to the written justification used
on Form 2. If you use these forms, write "see assessment form(s)" in this column and
attach the completed forms.
Change in assessment
Compare the AHERA inspection assessment data on Form 1 (or equivalent) for the
material in the location selected. If there is a difference between the original and the
reinspection assessment, circle "Yes". If no difference was noted, circle "No".
If different spatial units are used for the reassessments, consider whether substantive
changes have actually occurred to the material in the selected location and circle "Yes" or
"No" accordingly.
When all ACBM in the selected room/area has been reinspected, go to the next room/area and
repeat as above until each room listed in the original EPA inspection as having ACBM has
been reinspected.
Continue to the next row on Form 2 and record each location in which an ACBM is observed.
Use more than one Form 2 when there are more than three locations of an ACBM with
different assessment categories in a building. Number all pages when all rooms/areas have
been reinspected. Count the number of pages for each ACBM, then number page 1 of 2, page 2
of 2, and so forth.
Before leaving a room/area, perform an inspection for previously unidentified materials if
designated person has requested one.
Were additional samples of this ACBM collected?
If additional bulk samples of the ACBM are collected, circle "Yes". This is a flag to the
management planner and designated person to look for the bulk sample records and
laboratory analysis results. If no bulk samples of the ACBM were collected, circle "No."
C-5
Inspector
-------
Inspector name
Clearly print your name.
Inspector signature
Sign your name.
Accreditation #/State
Record your AHERA inspector accreditation number and state of accreditation, if
applicable.
Expiration date
Record the expiration date of your accreditation. This date must be later than the date of
the reinspection.
Submit the reinspection form(s) to the designated person who will submit it to the management
planner for recommendations for response actions.
C-6
Inspector
-------
The management planner completes the right-hand portion of Sample Form 2. The
management planner may need to visit the building or take other actions to determine
appropriate response actions. This should be done before completing the form, as required.
Preventive measures, response actions and initial/additional cleanings
Review the results of the reinspection of each ACBM in each room/area and recommend
the appropriate response actions including preventive measures. Consider whether initial
cleaning should be performed around newly friable ACBM and whether additional
cleaning is required for materials which remain friable.
Schedule/Begin
Specify a schedule for beginning the recommended response action. You may have to
discuss the best time for activities, such as removal, with the designated person.
Schedule/ Complete
Specify a schedule for completing the recommended response action. You may need to
consult the designated person or a project designer to determine a feasible time frame for
certain activities, such as removal.
Date of management planner review
Record the date on which you reviewed the reinspection findings and made the
recommendations for response actions.
Management planner name
Clearly print your name.
Management planner signature
Sign your name.
Accreditation #/State
Record your AHERA management planner accreditation number and State of
accreditation, if applicable.
C-7
Management Planner
-------
Expiration date
Record the expiration date of the accreditation. This date should be later than the date of
the reinspection.
Once the recommended response action for each ACBM in each location is recorded, submit
reinspection forms to the designated person.
C-8
Management Planner
-------
The AHERA designated person fills in the bottom line of Sample Form 2.
I, the LEA's Designated Person, have read and understood the recommendations made above:
Sign Form 2 where indicated as acceptance of the completed reinspection document.
Prepare a separate statement indicating your agreement with the recommendations made
and the reason(s) for your determination. Provide the LEA's schedule for implementation
in this statement.
Date
Date your signature.
Include the completed reinspection forms in each copy of the management plan for the school.
C-9
Designated Person
-------
COMPLETED EXAMPLE
Sample Reinspection Form 2. Reinspection of ACBM: Findings and Management Planner Recommendations Page o2 of
Scho., Building C/aSSSoMj&t/S,*,, D»W«****** /V-fV
Homogeneous Sampling Area: Material Description _ / X- / (2 //'/£&>*
Yes
No
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rernove at least Jo damped
tiles foUoutm^ project
designer Sf^cs.
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tS,
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Prior'
to
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a>
NF
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Yes
No
gncafSu.la.te tiles jo/hkitna
project dssmer specs,
limit access to K-J students
June l,
im
August
W*>
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T
Were additional samples of this ACBM collected? Yes <^No^)
Date of management planner review: 10 ?I I
'<2 n
-------
APPENDIX D
ANSWERS TO THE MOST FREQUENTLY
ASKED QUESTIONS ABOUT REINSPECTIONS
UNDER THE AHERA ASBESTOS-IN-
SCHOOLS RULE
D-l
-------
Answers to the
Most Frequently Asked Questions
About Reinspections
Under the AHERA Asbestos-In-Schools Rule
This document has been prepared in response to the many inquiries that have
been received by the Environmental Protection Agency (EPA) concerning the
reinspection requirements and related provisions of the Asbestos Hazard
Emergency Response Act (AHERA) regulations.
The answers developed here represent the Agency's responses to the most
frequently asked questions on this subject. We believe most problem areas have
been addressed. However, it is likely that additional questions will occur as the
reinspection cycle gets underway. This document is not intended to cover every
conceivable query about the reinspection process. It should be used as an adjunct
to the AHERA rule for additional clarification of the regulations.
Any questions not answered by this document can be referred to the appropriate
Regional Asbestos Coordinator listed on the last page or the EPA Toxics Hotline
in Washington, D.C. at 202/554-1404.
Office of Toxics Substances
Office of Pesticides and Toxic Substances
U.S. Environmental Protection Agency
Washington, D.C. 20460
May, 1991
D-2
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REESrSPECTIONS
Questions & Answers
Question 1: By what date must an LEA have had its school reinspected?
Answer: Under AHERA, school buildings must be reinspected every three years.
The first triennial reinspection must occur within three years after a
management plan is in effect [See Section 763.85(b)]. Each LEA was
required to develop a management plan no later than May 9,1989.
Implementation of the plan was required to begin by July 9,1989.
Therefore, the first round of three year reinspections must be completed by
July 9,1992.
Question 2: If implementation of the management plan began prior to July 9,1989,
must the reinspection take place within three years of the actual date the
plan was first implemented?
Answer: YES. The original management plan should have contained reinspection
guidelines. These guidelines should have emphasized that as part of
implementing the management plan, all reinspection information must be
incorporated into the document. If implementation of a management plan
began prior to July 9» 1989, the first reinspection should take place within
three years of the date the plan was first implemented. However, since
implementation of all management plans had to begin no later than July 9,
1989, if the date when implementation first occurred cannot be specifically
ascertained, reinspection must take place no later than July 9,1992.
Question 3: If a management plan was first implemented on January 10,1989 and the
LEA had a reinspection on January 10,1992, could the second reinspection
date be extended to July 9,1995, or would it have to be done by January 10,
1995?
Answer: Section 763.85 (b) requires reinspections to be done "at least once every
three years." Therefore, the next triennial reinspection would have to be
done on or before January 10,1995, within three years of the first
reinspection.
Question 4; If the original inspection overlooked some asbestos-containing building
materials (ACBM) or if some areas of the building were not accounted for
in the first inspection, must the reinspection include the inspection,
assessment and documentation of these overlooked areas?
Answer: NOT REQUIRED by regulation BUT STRONGLY
RECOMMENDED BY EPA. While it is not an AHERA
requirement, we strongly urge all schools to reinspect those areas or
D-3
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materials in their buildings that may have been overlooked in their initial
school inspections.
As a result of an EPA-sponsored AHERA evaluation study and various
enforcement activities, it was discovered that, in the original inspections,
certain categories of ACBM were frequently missed by inspectors and do
not appear in many management plans. Therefore, inspectors conducting
reinspections should make sure that materials such as ceiling tile,
wallboard, plaster walls, linoleum, fire doors, duct insulation and vibration
dampening cloth, which are considered suspect ACBM, are identified and
included in the management plan.
The regulations regarding reinspections impose no requirement beyond
reinspecting the materials and areas covered in the original inspection, plus
any additional materials discovered subsequent to the original inspection;
that is, reinspection encompasses "all friable and nonfriable known or
assumed ACBM." [Section 763.85(b)(3)(i)]. EPA strongly recommends,
however, that the reinspection be thorough so that any deficiencies in the
original inspection will be addressed in the reinspection. Any actual or
assumed ACBM not previously identified that is discovered during
reinspection (or periodic surveillance) should be included in an update to
the management plan. The update must include a management planner's
recommendations for appropriate response actions based on an accredited
inspector's assessment [See Section 763.88(d)].
Question 5: If the time interval for a 6 month periodic surveillance inspection should
coincide with the date for the reinspection, can the reinspection also satisfy
the periodic surveillance requirement?
Answer: YES, since reinspection includes everything that would be covered in the
6 month surveillance.
Question 6: Is reinspection required for buildings in which no ACBM, known or
assumed, was found in the original inspection, or where abatement
subsequent to the original AHERA inspection removed all ACBM?
Answer: NO. Since the AHERA rule confines the reinspection to "all friable and
nonfriable known or assumed ACBM," reinspection is not required for
buildings which contain no ACBM. However, in accordance with Sections
763.93(d) and (e), management plans should document the asbestos
removal as a response action activity in accordance with Sections 763.94(b)
and (g); or, if applicable, contain an inspection report or architect's
statement that the building is asbestos-free; or that no ACBM was specified
in its construction [see Sections 763.99(a)(6) and (7)]. Schools that have
conducted asbestos abatement to remove all ACBM should conduct a
reinspection in case some ACBM was missed. In addition, LEAs must
D-4
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continue to appoint a "designated person," retain their management plans
indefinitely, and provide annual written notification to parent, teacher, and
employee organizations of the availability of the plan.
Question 7: Will areas of newly friable ACBM or assumed ACBM be required to
undergo initial cleaning in accordance with Section 763.91?
Answer: YES. If upon reinspection (or during a periodic surveillance) the condition
of ACBM or assumed ACBM has changed from the original AHERA
inspection to friable from nonfriable, and the building has not been cleaned
since the original inspection, the following requirements as stated in Section
763.91(c)(1) will apply: "Initial cleaning. Unless the building has been
cleaned using equivalent methods within the previous 6 months, all areas of
a school building where friable ACBM, damaged or significantly damaged
thermal system insulation ACM, or friable suspected ACBM assumed to be
ACM are present shall be cleaned at least once after the completion of the
inspection required by Section 763.85(a) and before the initiation of any
response action, other than O & M activities or repair...."
Question 8: AHERA requires that an an accredited management planner review the
results of each inspection and assessment. Is this also required for
reinspections?
Answer: YES. Section 763.88(d) states that "the local education agency shall select
a person accredited to develop management plans to review the results of
each inspection, reinspection, and assessment for the school building and to
conduct any other necessary activities in order to recommend in writing to
the local education agency appropriate response actions."
The review and response action recommendations are particularly important
if assessments of known or assumed ACBM have changed from the initial
AHERA inspection, or if known or assumed ACBM, previously identified
as nonfriable, has become friable.
Question 9: Must an LEA reinspect a building that is no longer in use as a school?
Answer: NO. Section 763.85(b)(1) indicates that LEAs shall conduct a reinspection
in buildings that they "lease, own, or otherwise use as a school building."
However, if the building is not being used as a school at the time its
reinspection would have occurred (even if the LEA continues to lease or
own the building), the LEA must be able to certify that it is no longer using
the building as a school. In addition, if an LEA has stopped using a
building as a school, and later decides to use the building as a school, it
must be reinspected in accordance with Section 763.85(b).
D-5
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Question 10: When must an LEA reinspect a school brought into service after October
12,1988?
Answer: Section 763.85(a)(2) requires inspection of schools brought into service
after October 12,1988 prior to use of a building as a school. Section
763.93(a)(3) requires submission of a management plan for such schools to
the Governor prior to use of the building. The management plan of a
school building brought into service after October 12,1988 would be in
effect 90 days after submission of the plan to the State Governor unless the
plan is disapproved. Reinspection must occur within 3 years of the date the
plan is in effect, that is, 90 days after submission to the Governor.
Question 11: What reinspection records must be included in the management plan?
Answer: In accordance with Section 763.85(b)(3)(vii), the following records must be
included:
• The date of the reinspection, the name and signature of the person
making the reinspection, State of accreditation, and, if applicable, his
or her accreditation number.
• Any changes in the condition of known or assumed ACBM.
• The exact locations where samples were collected during the
reinspection, a description of the manner used to determine sampling
locations, the name and signature of each accredited inspector who
collected the samples, State of accreditation and, if applicable, his or
her accreditation number.
• Any assessments or reassessments made of friable material, the name
and signature of the accredited inspector making the assessments,
State of accreditation, and if applicable, his or her accreditation
number.
In addition, the written recommendations of the management planner must
be included in the management plan [See Section 763.88(d)].
Question 12: How should assessments or reassessments made as a result of the
reinspection be documented?
Answer: Sections 763.88(a)(1) and (2) require that the accredited inspector provide a
written assessment of all known or assumed friable ACBM in the school
building, and submit a copy of the assessment to the designated person
within 30 days of the assessment If there is no change in the material from
the initial inspection, the accredited person can simply refer to the initial
assessment.
D-6
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Question 13: What are the necessary components of an AHERA reinspection?
Answer: An accredited inspector should visually reinspect and reassess the condition
of all known or assumed friable ACBM; visually inspect previously
considered nonfriable ACBM and touch it to determine if it has become
friable; identify homogeneous areas of material that have become friable
since the last inspection; develop required records (detailed in the Answer
to Question 11) and submit such records to the LEA's designated person
within 30 days of reinspection.
Question 14: What are the required qualifications for the persons involved in the
reinspection?
Answer: The person conducting the reinspection must be accredited under AHERA
as an inspector, and his/her accreditation must be current for the period in
which the reinspection takes place. The management planner responsible
for the review of the results of the reinspection and recommendations for
response actions must be accredited as a management planner under
AHERA and his/her accreditation must be current for the period in which
the review of the reinspection takes place.
Question 15: When the management plan is revised as a result of the reinspection, does
the updated plan have to be resubmitted to the State?
Answer: NO. A management plan has to be submitted to the Governor of the State
when it is first developed. AHERA does not require subsequent updates or
other changes to the plan to be submitted to the State.
D-7
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APPENDIX E
GLOSSARY OF TERMS
E-l
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GLOSSARY OF TERMS
ACBM Asbestos-containing building material, which includes
surfacing material, thermal system insulation, or
miscellaneous material that is found in or on interior
structural members or other parts of a building.
ACBM Condition Good: No visible damage or deterioration, or showing only
very limited damage or deterioration.
Damaged: Physical injury or deterioration such that the
internal structure of the material is inadequate, material
which has delaminated such that its bond to the substrate is
inadequate, or which lacks fiber cohesion or adhesion
properties for any other reason. Thermal system insulation
(TSI) is considered damaged when it is lacking part or all of
its covering. Such damage may be shown by the separation
of ACM into layers; flaking, blistering, or crumbling; water
damage or stains; scrapes, mars or gouges; exposed TSI
beneath its covering.
Significantly Damaged: Damage that is extensive and
severe.
Administrator (EPA) The person appointed by the President to run the EPA.
AHERA The Asbestos Hazard Emergency Response Act. This Act
was signed into law on October 22, 1986 by President
Reagan. It established the framework for a regulation which
requires, among other things, that elementary and secondary
schools identify asbestos-containing materials in school
buildings, institute programs aimed at minimizing the risk of
asbestos exposure in those buildings, and reinspect those
materials at least every 3 years.
AHERA regulation/rule 40 CFR 763, Asbestos-Containing Materials in Schools:
Final Rule and Notice, U.S. Environmental Protection
Agency, February, 1987.
E-2
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AHERA1-7 Categories
AHERA Designated
Person/Designated
Person
Seven categories defined in the AHERA regulations, one of
which must be assigned to each friable surfacing and
miscellaneous ACBM and each asbestos-containing TSI
during an inspection or reinspection.
1. Damaged or significantly damaged TSI ACBM.
2. Damaged friable surfacing ACBM.
3. Significantly damaged friable surfacing ACBM.
4. Damaged or significantly damaged friable
miscellaneous ACBM.
5. ACBM with potential for damage.
6. ACBM with potential for significant damage.
7. Any remaining friable ACBM or friable suspected
ACBM.
Person designated by the Local Education Agency to ensure
that the AHERA requirements are properly implemented.
Asbestos
Naturally-occurring fibrous mineral used in many building
materials, primarily for fireproofing, thermal system
insulation, sound insulation, and decoration.
Asbestos-containing
Any material, when referring to school buildings, which
contains more than one percent asbestos.
Assessment
Evaluation of the physical condition and potential for
damage of all friable ACBM and asbestos-containing
thermal system insulation. AHERA requires classification
of each ACBM assessed into one of seven categories based
on material type and damage/potential for damage.
Assumed ACBM
Bulk Sample
Suspect building material that has not been sampled and
analyzed for asbestos content and must, therefore, be
treated as an ACBM by the LEA.
A small portion (usually about thumbnail size) of a suspect
asbestos-containing building material collected by the
inspector for laboratory analysis to determine asbestos
content.
E-3
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Completed Reinspection The entire process of the visual examination and assessment
of known and assumed ACBM in a school building;
recommended response actions by the management planner;
and submission of reinspection findings and
recommendations to the designated person. Reinspections
are required by AHERA every 3 years after management
plan implementation.
Current Accreditation
Having successfully completed an EPA-approved
accreditation or refresher course within 1 year of the
reinspection (for inspectors) or the management plan review
(for management planners.)
Encapsulation
Treatment of asbestos-containing material with a liquid that
covers the surface with a protective coating or embeds fibers
in an adhesive matrix to prevent the release of asbestos
fibers.
Enclosure
An airtight, impermeable, permanent barrier around as-
bestos-containing material to prevent the release of fibers.
EPA
U.S. Environmental Protection Agency.
Evaluation Study
An EPA report entitled Evaluation of the Asbestos Hazard
Emergency Response Act (AHERA)
Exclusion
One of several situations which permits the LEA to delete
one or more of the items required by AHERA. For
example, records of previous sample collection and analysis
may be used by the accredited inspector in lieu of AHERA
bulk sampling.
Exterior Areas
Subdivision of areas of a building with one or more walls
open to the outside, such as covered walkways or porticos.
E-4
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Form Any document the inspector uses to record information for
the reinspection, or for inspection of previously unidentified
materials. Two forms were developed for this reinspection
guide:
Sample Reinspection Form 1. Original AHERA Inspection
Information Abstracted from the Management Plan.
Sample Reinspection Form 2. Reinspection of ACBM:
Findings and Management Planner Recommendations.
Friable When referring to a school building, material that, when dry,
may be crumbled, pulverized, or reduced to powder by hand
pressure. Includes previously nonfriable material after it
becomes damaged to the extent that, when dry, it may be
crumbled, pulverized, or reduced to powder by hand
pressure.
Functional Space
Under AHERA, a room, group of rooms, or homogeneous
area designated by a person accredited to prepare
management plans, design abatement projects, or conduct
response actions.
HEPA
High efficiency particulate air. A special type of filter used
in equipment for removing asbestos fibers, e.g., vacuums, air
filtration devices.
Homogeneous Sampling
Area
In accordance with AHERA definitions, an area of surfacing
material, TSI, or miscellaneous material that is uniform in
color and texture.
HVAC
Heating, ventilation and air-conditioning systems in a
building.
Identified Material
Any AHERA-defined suspect material found during the
original AHERA inspection that was also recorded in the
management plan for the building.
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Local Education An educational agency at the local level that exists primarily
Agency (LEA) to operate schools or to contract for educational services for
elementary and secondary public and non-profit private
schools. For non-profit private schools, this includes the
building owner.
Management Plan
A document that each Local Education Agency is required
to prepare under AHERA regulations. It describes all
activities planned and undertaken by a school to comply with
AHERA regulations, such as building inspections to identify
asbestos-containing materials, response actions, and
operations and maintenance programs to minimize the risk
of exposure to asbestos in school buildings.
Material Category
Broad classification of suspect materials into TSI, surfacing
material, and miscellaneous material.
Miscellaneous
Material
Interior building material on structural components, such as
floor or ceiling tiles. Does not include TSI or surfacing ma-
terial.
NESHAP
National Emission Standards for Hazardous Air Pollutants,
EPA rules under the Clean Air Act.
Nonfriable
Material that, when dry, cannot be crumbled, pulverized, or
reduced to powder by hand pressure.
Operations and
Maintenance
Program (O&M)
Program of work practices to maintain friable ACBM in
good condition, ensure cleanup of asbestos fibers previously
released, and prevent future release by minimizing and
controlling friable ACBM disturbance or damage.
Original AHERA Examination of school buildings arranged by Local Educa-
Inspection/Original tion Agency, pursuant to AHERA, to initially identify
Inspection asbestos-containing materials, evaluate the condition of
those materials, and take samples of materials suspected to
contain asbestos. Inspections are performed by inspectors
accredited by the EPA or by EPA-approved State
accreditation programs.
E-6
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Periodic Surveillance
A visual examination for any change in material condition of
ACBM and assumed ACBM in a school building. AHERA
requires a periodic surveillance at least once every 6 months.
Previously Unidentified
Material
Any AHERA-defined suspect material present in a building
at the time of the original AHERA inspection that is not
reported in the management plan.
Recorded Location
An area in which a suspect material was present during the
inspection, and which is indicated in the management plan
as having the material present.
Reinspection
The re-examination, by an accredited inspector, of a school
building for which an original AHERA inspection was
previously performed, including a re-evaluation and
response action recommendations by an accredited
management planner. Reinspection of school buildings
containing ACBM is required by AHERA regulations at
least once every 3 years.
Removal
Taking out or stripping ACBM from an area, a functional
space, or a homogeneous area.
Repair
Procedures used to patch or cover damaged asbestos-
containing materials, other than enclosure or encapsulation.
Examples include covering the damage with plastic sheeting,
duct tape, or plaster.
Resilient Sheet Flooring/
Linoleum
A type of floor covering which is preformed in long sheets.
Generally, the sheets are unrolled and secured to the floor
with an adhesive. These commonly have a vinyl-based upper
surface. The backing may contain asbestos.
Response Actions
Methods, including removal, encapsulation, enclosure,
repair, and operations and maintenance, that protect human
health and the environment from friable ACBM.
E-7
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Room/Area A well-defined space within a building, generally a distinct
room, but also a hall, crawlspace, or other distinct space.
This term may refer to the entire homogeneous sampling
area or to a functional space but is generally a subset of
these.
School Building Any structure essential to the operation of a school and
under the authority of the LEA, including classrooms,
student housing, athletic facilities, administrative areas,
garages, and maintenance areas. Several buildings may be
present at one school.
Surfacing Material Material sprayed or troweled onto structural members
(beams, columns, or decking) for fire protection; or on ceil-
ings or walls for fireproofing, acoustical or decorative pur-
poses. Includes fireproofing, textured plaster, and other tex-
tured wall and ceiling surfaces.
Suspect Material
Building material suspected to contain asbestos because of
past practices in its manufacture and use. Includes surfacing
material, gypsum wallboard (also called sheetrock or
drywall), floor tile, ceiling tile, thermal system insulation,
and miscellaneous other materials. Suspect materials are
classified as ABCM or non-ACBM by analyzing bulk sam-
ples to determine asbestos content.
Total Amount
Estimated amount (in square or linear feet) of suspect
material in a building/s at the time of the original AHERA
inspection.
TSI
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.
Underestimated Quantity The difference between the total amount of a suspect
material found during the Evaluation Study and the amount
of the same material recorded in the management plan,
when the latter quantity is less than 80 percent of the
former.
E-8
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Vibration Dampening
Cloth (VDC)
Cloth commonly found on ductwork where duct size
changes, used to reduce noise.
Wallboard
Generic term for any wall surface installed as sheets, rather
than applied wet. Includes gypsum wallboard (also called
sheetrock or drywall), transite panels, etc.
E-9
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APPENDIX F
REFERENCES
F-l
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REFERENCES
These documents can be obtained from the Toxic Substances Control Act (TSCA) Hotline
by calling (202) 554-1404.
USEPA. 1991. U.S. Environmental Protection Agency. Asbestos in Schools: Evaluation of the
Asbestos Hazard Emergency Response Act (AHERA): A Summary Report. June, 1991.
USEPA. 1990. U.S. Environmental Protection Agency. Managing Asbestos In Place: A Building
Owner's Guide to Operations and Maintenance Programs for Asbestos-Containing Materials. July,
1990. ("Green Book")
USEPA. 1987. U.S. Environmental Protection Agency. Asbestos-Containing Materials in Schools:
Final Rule and Notice. 40CFR763. February, 1987.
USEPA. 1988. U.S. Environmental Protection Agency. 100 Commonly Asked Questions about the
New AHERA Asbestos-in-Schools Rule. May, 1988.
USEPA. 1985. U.S. Environmental Protection Agency. Asbestos in Buildings: Simplified Sampling
Scheme for Surfacing Materials. Washington, DC, EPA 560/5-85-030A. ("Pink Book")
USEPA. 1985. U.S. Environmental Protection Agency. Guidance for Controlling Asbestos-
Containing Materials in Buildings. Washington, DC, EPA 560/5-85-024. ("Purple Book")
F-2
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APPENDIX G
PULL-OUT COPIES OF:
1.
SAMPLE REINSPECTION FORM 1: ORIGINAL AHERA INSPECTION
INFORMATION ABSTRACTED FROM THE MANAGEMENT PLAN
2.
SAMPLE REINSPECTION FORM 2: REINSPECTION OF ACBM:
FINDINGS AND MANAGEMENT PLANNER RECOMMENDATIONS
3.
RECOMMENDED REINSPECTION CHECKLIST FOR THE AHERA
DESIGNATED PERSON-PLANNING FOR THE REINSPECTION
4.
RECOMMENDED REINSPECTION CHECKLIST FOR THE INSPECTOR
5.
RECOMMENDED REINSPECTION CHECKLIST FOR THE MANAGEMENT
PLANNER
6.
RECOMMENDED REINSPECTION CHECKLIST FOR THE AHERA
DESIGNATED PERSON-RECORDKEEPING
7.
RECOMMENDED SAMPLE REINSPECTION NOTIFICATION LETTER
G-l
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Sample Reinspection Form 1. Original AHERA Inspection Information Abstracted from the Management Plan Page of
School Building Date(s) of Original AHERA Inspection
Homogeneous sampling areas
Material
category
Asbestos
content
Friability
AHERA
assessment
category
(1-7, X, None)
Recorded locations of material
for each assessment category
Response actions taken/
renovations/other comments
ID number
Material description
TSI
Surf.
Misc.
Assumed
Yes
No
F
NF
X
TSI
Surf.
Misc.
Assumed
Yes
No
F
NF
X
TSI
Surf.
Misc.
Assumed
Yes
No
F
NF
X
TSI
Surf.
Misc.
Assumed
Yes
No
F
NF
X
TSI
Surf.
Misc.
Assumed
Yes
No
F
NF
X
TSI
Surf.
Misc.
Assumed
Yes
No
F
NF
X
Information abstracted by Date
Friability: F = friable, NF = nonfriable, X = not applicable (material is non-ACBM)
AHERA assessment category: 1 = Damaged or significantly damaged TSI ACBM, 2 = Damaged friable surfacing ACBM, 3 = Significantly damaged friable surfacing ACBM, 4 = Damaged or
significantly damaged friable miscellaneous ACBM, 5 = ACBM with potential for damage, 6 = ACBM with potential for significant damage, 7 = Any remaining friable
ACBM or friable suspected ACBM, X = not applicable (material is non-ACBM or nonfriable surfacing or miscellaneous material), None = No assessment category provided
in original inspection.
-------
Sample Reinspection Form 2. Reinspection of ACBM: Findings and Management Planner Recommendations Page of
School Building Date(s) of Reinspection
Homogeneous Sampling Area: Material Description ID Number
REINSPECTION FINDINGS FOR ACBM
MANAGEMENT PLANNER RECOMMENDATIONS
Assess-
Schedule
ment
Change
cate-
in
Preventive measures,
Location (s) of ACBM
Fria-
gory
Justification of
assess-
response actions, and
Com-
by assessment category
Quantity
bility
(1-7, X)
assessment category
ment
initial/additional cleanings
Begin
plete
F
Yes
NF
No
F
Yes
NF
No
F
Yes
NF
No
Were additional samples of this ACBM collected? Yes No
Date of manaaement Dlanner review:
Inspector name
Manaqement planner name
Inspector signature
Manapement planner signature
Accreditation #/State
Accreditation #/State
Expiration date
Exoiration date
1. the LEA's Desianated Person, have read and understood the recommendations made above:
Date:
-------
Recommended Reinspection Checklist for the AHERA Designated Person-Planning for the
Reinspection
~
1.
Select the inspector(s) and management planner to perform reinspection activities;
obtain proof of their current accreditations.
~
2.
Determine the scope of work.
~
2a. Clarify which buildings are to be included in the reinspection. Determine whether
each building is used as a school building.
~
2b. Determine whether previously grouped, similar materials (e.g., all floor tile) should
be separated into distinct materials.
~
2c. Determine whether previously assumed ACBM should be bulk sampled.
Determine whether other bulk samples should be collected.
~
2d. Determine whether quantities of ACBM should be re-estimated.
~
2e. Determine whether the inspector should look for previously unidentified suspect
materials. (Highly recommended by the EPA.)
~
3.
Determine how the reinspection results will be reported.
~
3a. Determine whether locations of ACBM should be reported on a room-by-room
basis, rather than by a building or homogeneous sampling area basis.
~
3b. Determine whether a floorplan or written description, or both, will be used to
locate ACBM.
~
3c. Determine whether ACBM will be assessed on a room by room, homogeneous
sampling area, or some other basis.
~
3d. Determine whether photographs or videotape will be used to document material
condition.
G-4
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Recommended Reinspection Checklist for the Inspector
Plannina for the reinsDection field activities
~
1.
Review the items on the Reinspection Checklist for the AHERA Designated Person -
Planning for the Reinspection.
~
2.
Select the field forms to be used (reinspection, reassessment, inspection, bulk sample
logs, photograph logs, chain of custody, floorplans).
~
3.
Review the management plan for the school (see Sample Reinspection Form 1 in
Appendix B).
~
3a.
Obtain or generate a list of all ACBMs and non-ACBMs (and associated
identification numbers, if provided) and material categories reported during the
original inspection.
~
3b.
Record the sample results for each homogeneous sampling area of suspect
material.
~
3C.
Record all reported locations of material (descriptions and/or location diagrams)
for each homogeneous sampling area.
~
3d.
Copy the location diagrams, if possible.
~
3e.
Record the original inspection assessment category assigned to ACBM in each
room/area.
~
3f.
Record any response actions which have occurred and the location of each.
~
3g.
Record any renovations which have occurred and the location of each.
~
3h.
Review records of periodic surveillance.
~
4.
Arrange administrative details - time of inspection, school escort, and keys.
~
5.
Assemble all field materials.
~
5a.
A supply of all field forms, pens, calculator, tape measure, flashlight, and tools.
~
5b.
Blank floorplans and inspection location diagrams, if available.
~
5c.
Bulk sample collection tools and clean-up supplies, if required.
~
5d.
Personal protective equipment, if needed.
~
5e.
A ladder, if needed.
G-5
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Recommended Reinspection Checklist for the Inspector (Continued)
Performina
the field activities
~
6.
Meet the school escort.
~
7.
Select the first room/area to be reinspected.
~
8.
Observe and record each ACBM in the selected room/area, referring to the list of
homogeneous areas of ACBM and non-ACBM abstracted from the management plan
(see Sample Reinspection Form 2).
~
9.
Mark the rooms/areas where each ACBM was observed on the diagram or floorplan
(optional).
~
10.
Re-estimate the quantity of each ACBM in the selected room/area (if requested by the
designated person).
~
11.
Touch each ACBM in the room/area to determine whether it is friable.
~
12.
Collect additional bulk samples, as instructed by the designated person.
~
13.
Look at the condition and determine the potential for damage or significant damage to
each friable ACBM and asbestos-containing TSI in the room/area.
~
14.
Assign a reassessment category to each friable ACBM and asbestos-containing TSI in
the room/area.
~
15.
Record the justification of the assigned reassessment category (can use assessment
form or notes).
~
16.
Photograph the material, if requested by the designated person.
~
17.
Assess previously unidentified materials in the room/area, if requested by the
designated person.
~
18.
Move to next room/area, and repeat as above.
Recordkeeoina
~
19.
Complete all field form data items.
~
20.
Record name, signature, date, and accreditation number and State (if applicable) on the
reinspection form.
G-6
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Recommended Reinspection Checklist for the Inspector (Continued)
Recordkeeping (continued)
I I 21. If additional bulk samples were collected, include the exact locations where they were
taken. Also include a description of the process used to select sample locations, and
the name, signature, date, and accreditation number and State (if applicable) of the
inspector(s) collecting each bulk sample in each copy of the school's management
plan.
|~1 22. Submit the results of the reinspection to the AHERA designated person within 30 days
after the reinspection is completed. Note, at a minimum, any changes in ACBM
assessment.
G-7
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Recommended Reinspection Checklist for the Management Planner
Recommendations for response actions
~
1.
Review the results of the original AHERA inspection, periodic surveillance records, and
the reinspection.
~
2.
Visit the school or take other necessary actions to recommend response actions to the
LEA.
~
3.
For each friable surfacing and miscellaneous ACBM and each asbestos-containing TSI
reported by the inspector, make written response action recommendations.
~
3a. Describe preventive measures and response actions for each assessment
location of the ACBM.
~
3b. Consider whether cleaning in accordance with procedures in 40CFR763.91(c)
should be performed in each area and make appropriate recommendations in
writing.
~
4.
Include a schedule for beginning and completing the recommended cleaning and
response actions.
~
5.
Estimate the resource requirements for the recommended response actions.
~
6.
Review the adequacy of the O&M Plan.
Recordkeepina
~
7.
Record name, signature, date, and accreditation number and State (if applicable) on the
reinspection form.
~
8.
Submit written recommendations for the response actions to the designated person.
G-8
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Recommended Reinspectton Checklist fertile AKS3A Dss'gr.zSsii Parser! -
Recordkeeping
1. Include the reimspectSion report and recommended res^ense gs'iiens :n each sop-? c!! th©
school's management pilars.
2. Include a written statement indicating agreement or disagreement ws4h th® TusrsigeriMini
planner's recommendations for response actions, justlvicsEjo.^ for any disagree
and an implementation schedule for the response actions !n Shs ntansganraitS pisju,
(Recommended by the EPA.)
3. Include inspection report findings for any prsvfe;»jv ^rJcsr.SlflsS msfiertaE# (and, if
ACBM found, include management plsnnsir 'sscrrr.s'dat'cr?-'?; in Slia rnsriageraersS
plan.
4. Include a copy of 8 document describing steps ^en tc inform workers and SuHd'csj
occupants, or their !ega! guardians, about the reinspest'on in -sac?! copy cf tJts school's
management plan.
5. Evaluate the effectiveness of the asfesseos operations and rr.alntsjtar.es pSM) program
and periodic surveillance. Revise, as appropriate.
-------
Recommended Sample Reinspection Notification Letter
EASTSIDE COMMUNITY PUBLIC SCHOOLS East Park Avenue
Eastside, CA 91005
(999) 922-3333
Bob Smith, Superintendent
Notification of Asbestos Reinspections
TO: Parents and Staff of Eastside Middle School
FROM: Bob Smith, Superintendent of Schools
DATE: December 15, 1991
In compliance with the U.S. Environmental Protection Agency (EPA) Asbestos Hazard Emergency
Response Act (AHERA), in the fall of 1988 we performed inspections of each of our school buildings for
asbestos-containing building materials. The inspection findings and asbestos management plans have
been on file in each school administrative office since that time.
The EPA requires us to perform reinspections of the asbestos materials every three years. During
the months of September through November 1991, accredited asbestos inspectors performed these
reinspections. An accredited management planner reviewed the results of the reinspections and
recommended actions we should take to safely manage each asbestos material in our buildings.
Two significant findings were noted during the reinspection of Eastside Middle School:
¦ Asbestos-containing water pipe insulation in the kitchen over the dishwasher is slowly
deteriorating due to high humidity. The material is scheduled for removal over the Christmas
break.
¦ Linoleum in all bathrooms was not included in the original AHERA inspection. The backing
(between the vinyl layer and the floor) is assumed to contain asbestos. The vinyl layer is in
good condition and provides an effective barrier, preventing asbestos fiber release. This
material has been added to our asbestos maintenance program and we will monitor it for any
changes in condition.
All other asbestos materials in this school are in good condition and we will continue to manage
them in place, as recommended by the accredited management planner.
The results of the reinspection are on file in the management plan in the school's administrative
office. Everyone is welcome to view these anytime during normal school hours (M-F, 8:00 a.m. - 4:30
p,m.). The Asbestos Program Manager, Jill Williams, is available to answer any questions you may have
about asbestos in our buildings at (999) 922-3334.
G-10
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APPENDIX H
MESSAGE FROM THE
ADMINISTRATOR OF EPA
H-l
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAR 6 1991
THE ADMINISTRATOR
An Advisory to the Public on Asbestos in Buildings:
The Facts About Asbestos in Buildings
In recent months, there have been a number of scientific and
news reports about asbestos in buildings. Unfortunately, some of
these may have confused, rather than enlightened, the public
about the potential health risks of asbestos exposure and the
Environmental Protection Agency's (EPA) policies regarding
asbestos in schools and other buildings.
I want to summarize the EPA's policies for asbestos control
in schools and other buildings. I am providing this summary in
the form of five major facts that the Agency has presented in
congressional testimony.
FACT ONE: Although asbestos is hazardous, human risk of
asbestos disease depends upon exposure.
Asbestos is known to cause cancer and other diseases if
asbestos fibers are inhaled into the lung and remain there. This
conclusion is based upon studies involving human exposure,
particularly exposure at high levels. A recent Science magazine
article indicated exposure to chrysotile (common "white"
asbestos) may be less likely to cause some asbestos-related
diseases. Although there is more evidence of hazard for some
types of asbestos, EPA believes there is reason to be concerned
about other types, such as chrysotile, for which the data are
less conclusive. Based on careful evaluation of available
scientific evidence, EPA has adopted a prudent approach in its
regulations of assuming that all fibers are of equal concern.
Various scientific and regulatory organizations, including the
National Academy of Sciences, support EPA's more protective
regulatory approach.
It is important to stress that the mere presence of a
hazardous substance, such as asbestos on an auditorium ceiling,
no more implies that an asbestos-related disease will develop
than a poisonous substance in a medicine cabinet or under a
kitchen sink implies that a poisoning will occur. Asbestos
fibers must be released from the material in which they are
contained, and an individual must breathe those fibers in order
to incur any chance of disease.
41 PROltV
H-2
Printed on Recycled Paper
-------
2
While scientists have been unable to agree on a level of
asbestos exposure at which we, as public policy makers, can
confidently say, "there is nfi risk," this does not mean that all
or any exposure is inherently dangerous. To the contrary, almost
every day we are exposed to some level of asbestos fibers in
buildings or in the outdoor air. Based upon available data, very
few among us, given existing regulatory controls, have contracted
or will ever contract an asbestos-related disease from these
relatively low levels of airborne fibers found in buildings. The
present scientific evidence will not allow us to state
unequivocally that there is a level of exposure below which there
is a zero risk, but the risk at these low levels in fact could be
negligible or even zero. The risks of asbestos disease can be
higher from exposures that occur during mining, manufacturing,
and use of some remaining asbestos products, for example, in the
repair of automotive brakes.
FACT TWO: Prevailing asbestos levels in buildings —
the levels that school children and you and I
face as building occupants — seem to be very
low, based upon available data. Accordingly,
the health risk we face as building occupants
also appears to be very low.
Indeed, a 1987 EPA study found that airborne fiber levels in
a segment of Federal buildings with asbestos management programs
were so low that the levels were in a range comparable to levels
outside these buildings. While the data are not conclusive and
we are seeking more information through a major research effort,
the 1987 study appears to suggest that building occupants face
only a minimal risk when their buildings have active asbestos
management programs. Severe health problems attributed to
asbestos exposure have generally been experienced by workers in
industries such as shipbuilding, where they were constantly
exposed to very high fiber levels in the air, often without any
of the worker protections now afforded to them under the law.
Of course, some building workers, if they are not properly
trained and protected, may disturb asbestos-containing materials
and, in so doing, increase the risk to themselves and others.
FACT THREE: Removal is often not a school district's or
other 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.
H-3
-------
3
It is important to understand that, for most situations,
EPA's asbestos regulations for schools under the Asbestos Hazard
Emergency Response Act (AHERA) do not require removal of
asbestos. These regulations allow the school to decide whether
asbestos removal, or some other response action, is the best
option to protect the health of school students and employees.
In general, asbestos removal is most appropriate when asbestos
materials, such as pipe or boiler insulation, are damaged beyond
repair.
Although we believe most asbestos removals are being
conducted properly, asbestos removal practices by their very
nature disturb the material and significantly elevate airborne
fiber levels. Unless all safeguards are properly applied and
strictly followed, exposure in the building can rise, perhaps to
levels where we know disease can occur. Consequently, an ill-
conceived or poorly conducted removal project can actually
increase rather than eliminate risk.
FACT FOUR: EPA only requires asbestos removal in order
to prevent significant public exposure to
asbestos, such as during building renovation
or demolition.
Prior to a major renovation or demolition, asbestos material
that is likely to be disturbed or damaged to the extent that
significant amounts of asbestos would be released must be removed
using approved practices under EPA's asbestos National Emission
Standard for Hazardous Air Pollutants (NESHAP) regulation.
Demolishing a building containing large amounts of asbestos, for
example, would likely result in significantly increased exposure
and could create an imminent hazard. Clearly, asbestos removal
before the wrecking ball swings into action is appropriate to
protect public health. However, this cannot be said of arbitrary
asbestos removal projects, which, as noted above, can actually
increase health risk unless properly performed. This, in part,
is why EPA has not mandated asbestos removal from schools or
other buildings beyond the NESHAP requirement, which has the
effect of gradually and rationally taking all remaining asbestos
building materials out of the inventory.
FACT FIVE: EPA does recommend in-place management
whenever asbestos is discovered.
Instead of removal, a conscientious in-place management
program will usually control fiber releases, particularly when
the materials are not significantly damaged and are not likely to
be disturbed. That is why Congress mandated such a program in
schools through AHERA.
H-4
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4
In-place management, of course, does not mean "do nothing."
It means, first, that the building owner or manager should
identify asbestos. through a building-wide inventory or on a
case-by-case basis before suspect materials are disturbed by
renovations or other actions. The AHERA program requires an
inventory of all asbestos materials in schools by properly
accredited individuals.
After the material is identified, the school's personnel,
building owner or manager can then institute controls to ensure
that the day-to-day management of the building is carried out in
a manner that prevents or minimizes the release of asbestos
fibers into the air. These controls will ensure that when
asbestos fibers are released, either accidentally or
intentionally, proper management and cleanup procedures are
implemented.
Another concern of EPA and other Federal, State and local
agencies which regulate asbestos is to ensure proper worker
training and protection. Maintenance and service workers in
buildings, in the course of their daily activities, may disturb
materials and can thereby elevate asbestos fiber levels,
especially for themselves, if they are not properly trained and
protected. For these persons, risk may be significantly higher
than for other building occupants. Proper worker training and
protection, as part of an active in-place management program, can
reduce any unnecessary asbestos exposure for these workers and
others. AHERA requires this training for school employees whose
job activities may result in asbestos disturbances.
In addition to the steps outlined above, an in-place
management program will usually include notification to workers
and occupants of the existence of asbestos in their building,
periodic surveillance of the material, and proper recordkeeping.
EPA requires all of these activities for schools and strongly
recommends that other building owners also establish
comprehensive asbestos management programs. Without such
programs, asbestos materials could be damaged or deteriorate,
which may result in elevated levels of airborne asbestos fibers.
While the management costs of all the above activities will
depend upon the amount, condition, and location of the materials,
such a program need not be expensive. In many instances, an in-
place management program may be all that is necessary to control
the release of asbestos fibers, until the asbestos-containing
material in a building is scheduled for removal because of
renovation or demolition activities.
H-5
-------
5
In summary, EPA's best advice on asbestos is neither to rip
it all out in a panic nor to ignore the problem under the false
presumption that asbestos is "risk free." Rather, we recommend a
practical approach that protects public health by emphasizing
that asbestos material in buildings should be located, that it
should be appropriately managed, and that those workers who may
disturb it should be properly trained and protected. That has
been, and continues to be, EPA's position.
If you have questions or need additional information about
asbestos in schools and other buildings, please call EPA's Toxics
Hotline at (202) 554-1404 or write the Environmental Assistance
Division (TS-799), Office of Pesticides and Toxics Substances,
401 M Street, Washington, DC 20460.
William K. Rei
H-6
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APPENDIX I
POINTS OF CONTACTS
1-1
-------
Regional Asbestos Groups
CT, MA,
ME, NH,
Rl. VT
DC, DE, MD,
PA, VA, WV
W
*
HI
Guam ^
Am. Samoa f\
CNMI
Virgin Is. *
PR a
CD °
Regional Asbestos Coordinators
Mr. James M. Bryson
EPA, Region I. (ATC-111)
Asbestos Coordinator
JFK Federal BIdg.
Boston, MA 02203-2211
(617) 565-3836 — (FTS) 835-3836
Mr. Louis Bevilacqua
EPA, Region II, (MS-500)
Asbestos Coordinator
2890 Woodbridge Ave.
Raritan Depot, BIdg. 5
Edison, NJ 08837
(908) 321-6671 — (FTS) 340-6671
Ms. Carole Dougherty
EPA, Region III, (3AT-33)
Asbestos Coordinator
841 Chestnut BkJg.
Philadelphia, PA 19107
(215) 597-3160 — (FTS) 597-3160
Ms. Rhonda Evans
EPA, Region IV
Asbestos Coordinator
345 Courtland St., N.E.
Atlanta, GA 30365
(404) 347-5014 — (FTS) 257-5014
Mr. Terence W. Stanuch
EPA, Region V, (SP-14J)
Acting Asbestos Coordinator
77 W. Jackson Blvd.
Chicago, IL 60604
(312) 353-5590 — (FTS) 886-5590
Mr. Steve Vargo
EPA, Region VI, (6T-PT)
Asbestos Coordinator
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-7244 — (FTS) 255-7244
Mr. Wolfgang Brandner
EPA, Region VH, (ARTX)
Asbestos Coordinator
726 Minnesota Ave.
Kansas City, KS 66101
(913) 551-7020 — (FTS) 276-7020
Mr. David Combs
EPA, Region VIII, (8AT-TS)
Asbestos Coordinator
Denver Place, Suite 500
999 ~ 18th Street
Denver, CO 80202-2405
(303) 293-1442 — (FTS) 330-1442
Ms. Jo Ann Semones
EPA, Region IX, (A-4-4)
Asbestos Coordinator
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1128 — (FTS) 484-1128
Mr. Matt Wilkenlng
EPA, Region X, (AT-083)
Asbestos Coordinator
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-4762 — (FTS) 399-4762
11/27/91
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AHERA State Designees
ALABAMA
William Weems
AL Safe State Program
College of Continuing Studies
University of Alabama
PO Box 870388
Tuscaloosa, AL 35487-0388
Phone: (205)348-3033
ALABAMA
Office of the Governor
AL Safe State Program
11 South Union Street, Room 217
Montgomery, AL 36104
Phone: (205)242-7100
ALASKA
Susan Miller
AK Dept of Education (Facilities)
801 West 10th Goldbelt Bldg
PO Box F
Juneau, AK 99811-0500
Phone: (907)465-2865
AMERICAN SAMOA
Pati Faiai
American Samoa EPA
Office of the Governor
Pago Pago, AS 96799
Phone: (684)633-2304
ARIZONA
Yvette David
Dept of Environmental Quality
Office of Air Quality
PO Box 600
Phoenix, AZ 85001-0600
Phone: (602)257-2287
ARKANSAS
Dan Lovelady
AR Dept of Education
School Plant Services
Arch Ford Education Bldg
#4 Capitol Mall, Room 110B
Little Rock, AR 72201-1071
Phone: (501)682-4261
BUREAU OF INDIAN AFFAIRS
Herman Fisher
Bureau of Indian Affairs
FMCC
PO Box 1248
Albuquerque, NM 87103
Phone: (505)766-2454
CALIFORNIA
Sandra Proctor
School Facilities Program Analyst
Office of Local Assistance
501 J Street Suite 350
Sacramento, CA 95814
Phone: (916)322-0948
COLORADO
Dave Ouimette
CO Dept of Health
Air Pollution Control Div
4210 E 11th Avenue
Denver, CO 80220
Phone: (303)331-8587
CONNECTICUT
William Sawicki
Environ'l Health Services Div
CT Dept of Health Service
150 Washington Street
Hartford, CT 06106-4474
Phone: (203)566-1260
CONNECTICUT
Michael Ruggles
Dept of Education
Plan Review Unit
Cromwell Commons Bldg
136 Berlin Road, Suite 203
Cromwell, CT 06416
Phone: (203)635-1148
DELAWARE
Robert Foster
Dept of Administrative Services
Div of Facilities Mgmt
Short Bldg
21 The Green
Dover, DE 19901
Phone: (302)739-3045
DISTRICT OF COLUMBIA
Edgar Kennedy
Love Joy Administration Bldg
12th &DNE
Washington, DC 20002
Phone: (202)724-4706
FLORIDA
Hal Thomas
FL Dept of Education
Fl Education Center
Plant Mgmt & Insurance
Rm 1032, 325 West Gains Street
Tallahassee, FL 32399-0400
Phone: (904)487-1130
GEORGIA
Don Elam
GA Dept of Education
School Safety & Environ'l Services
1662 Twin Towers East
Atlanta, GA 30334-5050
Phone: (404)656-7059
GEORGIA
Don Thornhill
Trans Fac & Asbestos Div
GA Dept of Education
1670 Twin Towers East
Atlanta, GA 30334
Phone: (404)656-2446
GUAM
Fred M. Castro
GU Environ'l Protection Agency
D-107 Harmon Plaza
130 Rojas Street
Harmon, GU 96911
Phone: (671)646-8863
HAWAII
Ken Hall
Clean Air Branch
PO Box 3378
Honolulu, HI 96801
Phone: (808)586-4200
IDAHO
Gary Barnes
Dept of Labor & Industrial Services
State House Mail
Boise, ID 83720
Phone: (208)334-3896
ILLINOIS
R. Kent Cook
IL Dept of Public Health
525 West Jefferson Street
3rd Floor
Springfield, IL 62761
Phone: (217)782-3517
INDIANA
Debbie Dubenetzky
Office of Air Mgmt
Dept of Environ'l Mgmt
105 South Meridian Street
Indianapolis, IN 46225
Phone: (317)232-8373
IOWA
C. Milton Wilson
School Plant & Facilities Unit
Dept of Education
Grimes State Office Bldg
Des Moines, IA 50319-0146
Phone: (515)281-4743
KANSAS
Gary Miller
Dept of Health & Environment
Forbes Field Bldg 740
Topeka, KS 66620
Phone: (913)296-1547
KENTUCKY
Jim Judge
KY Dept of Education
Div of Bldgs & Grounds
1530 Capitol Plaza Tower
15th Floor
Frankfort, KY 40601
Phone: (502)564-4326
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LOUISIANA
Chris Roberie
Enforcement Program Manager
Office of Air Quality
7290 Bluebonnet Road
Baton Rouge, LA 70810
Phone: (504)765-0110
MAINE
Gene Kaler
Bureau of General Services
Asbestos Coordinator
State House Station 77
Augusta, ME 04333
Phone: (207)289-4000
MARYLAND
Mardel Knight
MD Dept of the Environment
Industrial Operations Program
2500 Broening Hwy
Baltimore, MD 21224
Phone: (410)631-3846
MASSACHUSETTS
Paul Aboody
Div of Occupational Hygiene
MA Dept of Labor & Industry
1001 Watertown Street
West Newton, MA 02165
Phone: (617)969-7177
MICHIGAN
George Howard
Dept of Public Health
Attn: Asbestos Program
3423 North Logan Street
PO Box 30195
Lansing, Ml 48909
Phone: (517)335-8246
MINNESOTA
Kerry Leider
MN Dept of Education
563 Capitol Square Bldg
550 Cedar Street
St. Paul, MN 55101
Phone: (612)296-9786
MISSISSIPPI
Gerald Pevey
MS State Dept of Education
Bureau of Sch Bldg & Trans
501 North West Street
Suite 1205 Woollolk Bldg
Jackson, MS 39201
Phone: (601)359-1028
MISSOURI
Daryl W. Roberts
Bureau of Environ'l Epidemiology
Health Dept
1730 East Elm Street
PO Box 570
Jefferson City, MO 65102
Phone: (314)751-6102
MONTANA
Andrea Guthrie
Dept of Health & Environ'l Science
Cogswell Bldg, Room A107
Helena, MT 59620
Phone: (406)444-2690
NEBRASKA
John Hall
NE Dept of Health - EHHS
301 Centenial Mall South
PO Box 95007
Lincoln, NE 68509
Phone: (402)471-2541
NEVADA
Douglas M. Stoker
NV Dept of Education
1850 E Sahara Ave
Suite 200 State Mail Room
Las Vegas, NV 89158
Phone: (702)486-6455
NEW HAMPSHIRE
Doug Brown
Dept of Education
State Office Park South
101 Pleasant Street
Concord, NH 03301
Phone: (603)271-4609
NEW JERSEY
James A. Brownlee
NJ Dept of Health
Environ'l Health Services
CN 360, 210 S Broad Street
Trenton, NJ 08625-0360
Phone: (609)984-2193
NEW MEXICO
Dr. Ed Tangman
State Dept of Education
Education Bldg
300 Don Gaspar Street
Santa Fe, NM 87501-2786
Phone: (505)827-6670
NEW YORK
Dr. Mae Timer
Bureau of Educational Mgmt Svcs
NY State Education Dept
Room 510
Education Bldg, West Wing
Albany, NY 12234
Phone: (518)474-3911
NORTH CAROLINA
John J. "Pat" Curran
Asbestos Hazard Mgmt Branch
441 N Harrington
Raleigh, NC 27603
Phone: (919)733-0820
NORTH DAKOTA
Dana Mount
ND Health Dept & Consolidated
Laboratories
1200 Missouri Ave, Box 5520
Bismarck, ND 58502-5520
Phone: (701)221-5188
NORTH DAKOTA
Ken Wangler
Dept of Public Instruction
600 E Blvd Ave
Bismarck, ND 58505-0440
Phone: (701)224-2267
NORTHERN MARIANAS
F. Russell Mechem, II
Div of Environ'l Quality
Dr. Torres Hospital
PO Box 1304
Saipan, MP 96950
Phone: ( )
OHIO
Marty King
OH Dept of Health
35 E Chestnut
7th Floor
Columbus, OH 43266-0588
Phone: (614)466-1450
OKLAHOMA
Emily Allen
OK State Dept of Health
Special Hazards Div
Consumer Protection Service 0202
1000 NE 10th
Oklahoma City, OK 73117-1299
Phone: (405)271-5221
OREGON
Al Shannon
OR Dept of Education
700 Pringle Parkway SE
Salem, OR 97310-0290
Phone: (503)378-8142
PENNSYLVANIA
Dean Van Orden
Dept of Environment Resources
101 South 2nd Street
PO Box 2357
Harrisburg, PA 17105
Phone: (717)787-9257
PUERTO RICO
Jesus Santa
Environ'l Quality Bldg 6
PO Box 11488 HatoRey
431 Ponce De Leon Ave
San Juan, PR 00910
Phone: (809)767-8071
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REPUBLIC OF PALAU
Executive Officer
Palau Env Qual Proj Bd
PO Box 100
Koror, PW 96940
Phone: ( )
RHODE ISLAND
Roger P. Marinelli
Dept of Health
Div of Occupation and Radiological
Health
206 Cannon Bldg
3 Capitol Hill
Providence, Rl 02908-5097
Phone: (401)277-3601
SOUTH CAROUNA
G. Stuart Clarkson
SC Dept of Education, School
Planning & Bldg
Rutledge Bldg
1429 Senate Street
Columbia, SC 29210
Phone: (803)734-8823
SOUTH DAKOTA
Bob McDonald
Dept of Environment & Natural
Resources
319 S Coteau
c/o 500 E Capital Ave
Pierre, SD 57501
Phone: (605)773-3153
TENNESSEE
George Brumett, Jr.
Office of Special Initiatives
Div of Facilities Mgmt
Dept of Finance and Admin
Suite 500
Nashville Ctr 511 Union Street
Nashville, TN 37243-0300
Phone: (615)741-6319
TEXAS
Peter M. Tadin
TX Dept of Health
Div of Occupational Health
1100 West 49th Street
Austin, TX 78756
Phone: (512)834-6600
UTAH
Joan Thalmann
Dept of Environ'l Quality
Div of Air Quality
1950 West North Temple
Salt Lake City, UT 84114-4820
Phone: (801)536-4084
VERMONT
Alayne Senior
VT Dept of Health
Asbestos Program
60 Main Street
PO Box 70
Burlington, VT 05402
Phone: (802)863-7231
VIRGIN ISLANDS
Hugh M. Smith, Jr.
Dept of Education USVI
44-46 Kongens
Gade, Charlotte Amelia
St. Thomas, VI 00801
Phone: (809)774-8315
VIRGIN ISLANDS
Leonard Reid
Dept of Planning & Natural
Resources Environ'l Protection
458 Nisky Center Suite 231
St. Thomas, VI 00802
Phone: (809)774-1320
VIRGINIA
David Boddy
Dept Of Education
James Monroe Bldg, 24th Floor
101 N 14th Street, PO Box 6Q
Richmond, VA 23216
Phone: (804)225-2035
WASHINGTON
Terry Michalson
Superintendent of Public
Instruction
Old Capitol Bldg, FG-11
Olympia, WA 98504
Phone: (206)753-6729
WEST VIRGINIA
Joseph P. Schock
Office of Environ'l Health Services
Capitol Complex Bldg 3
1900 Kanawha Blvd E, Room 550
Charleston, WV 25305
Phone: (304)348-2981
WISCONSIN
Gina Cowell
Wl Div of Health
Asbestos Unit
1414 E Washington Ave, Rm 117
Madison, Wl 53703
Phone: (608)267-2289
WYOMING
Dr. Roger Hammer
WY Dept of Education
Hathaway Bldg, 2nd Floor
2300 Capitol Ave
Cheyenne, WY 82002-0050
Phone: (307)777-6198
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