TN930
.A823
1988
OOOR88103
ASBESTOS-IN-SCHOOLS: A GUIDE TO
NEW FEDERAL REQUIREMENTS FOR
LOCAL EDUCATION AGENCIES
Office of Toxic Substances
Office of Pesticides and Toxic Substances
US. Environmental Protection Agency
Washington, D.C. 20460
February 1988
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TABLE OF CONTENTS
Page
Introduction i
CHAPTER 1 - MAJOR ELEMENTS OF THE NEW RULE 1
CHAPTER 2 - APPOINT A DESIGNATED PERSON 3
CHAPTER 3 - USE ACCREDITED PERSONS 5
CHAPTER 4 - CONDUCT INITIAL INSPECTIONS 7
CHAPTER 5 - DEVELOP A MANAGEMENT PLAN 13
CHAPTER 6 - IMPLEMENT APPROPRIATE RESPONSE ACTIONS 19
CHAPTER 7 - CONDUCT PERIODIC SURVEILLANCE AND REINSPECTIONS 23
CHAPTER 8 - ASSURE PROPER TRAINING AND AWARENESS 24
CHAPTER 9 - MAINTAIN RECORDS 26
CHAPTER 10 - COMPLY WITH THE NEW RULE 29
APPENDIX A - EPA-Funded Training Programs 31
APPENDIX B - Regional Asbestos Coordinators 32
APPENDIX C - AHERA State Designated Contacts 33
APPENDIX D - Sample Form 41
U.S. Environmental Protection Agency
Region 5, Library (5PL-16)
2TO S. Dearborn St'-eet, Room 1670
Chicago, IL 60604
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INTRODUCTION
INTRODUCTION TO AHERA
On October 22, 1986, President Reagan signed into law the Asbestos Hazard
Emergency Response Act (AHERA, Public Law 99-519). The law required EPA to
develop regulations which provide a comprehensive framework for addressing
asbestos problems in public and private elementary and secondary schools. On
October 30, 1987, EPA published the Asbestos-Containing Materials in Schools
Rule [40 CFR Part 763 Subpart E] . This New Rule requires all public and
private elementary and secondary schools to inspect for friable and non-friable
asbestos, develop asbestos management plans that address asbestos hazards in
school buildings, and implement response actions in a timely fashion.
References to the New Rule are provided throughout this Guide in brackets
(e.g., [Section 763.85] and always refer to a section of Title 40 of the Code
of Federal Regulations (40 CFR)).
To carry out the above activities, involving inspections, management
plans, and response actions, schools must use accredited persons. On April 30,
1987, EPA published the Model Accreditation Plan [40 CFR Part 763 Appendix C to
Subpart E] required by AHERA, which specifies training, examination, and other
requirements for persons who inspect, develop management plans, and design or
conduct response actions in schools. The Model Plan became effective on June
1, 1987.
PURPOSE OF THIS GUIDE
This Guide provides practical information to help Local Education Agencies
(LEAs) meet the requirements of the new Asbestos-Containing Materials in
Schools Rule. In 1982, EPA published an asbestos-in-schools rule that required
the identification of friable asbestos-containing materials in schools. The
1982 Asbestos-in-Schools rule also included notification requirements.
The new 1987 Asbestos-Containing Materials in Schools rule, written under
the authority of AHERA, took effect on December 14, 1987. Compared to the 1982
rule, the New Rule's requirements are much more comprehensive in scope. LEAs
that met the requirements of EPA's 1982 rule will have to accomplish a variety
of new tasks mandated by Congress to comply with EPA's 1987 Asbestos-Containing
Materials in Schools rule. This Guide will assist LEAs in meeting these new
requirements. Most chapters include checklists that are designed to help LEAs
comply with the New Rule.
KEY DATES AND PROVISIONS
LEAs should be aware of the dates when key provisions in the New Rule take
effect. The New Rule has three key dates:
• As of December 14, 1987, LEAs mist:
Use accredited personnel to design and carry out
response actions other than operations and
maintenance,
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a
a
a
a
a
a
Have custodial and maintenance staff members
receive training prior to conducting activities
that may disturb asbestos,
Post warning labels in routine maintenance areas
where asbestos was previously identified,
Abide by the operations and maintenance
requirements whenever these activities need to be
performed,
Comply with response action clearance
requirements of the New Rule,
Transport and dispose of asbestos waste as
required by the New Rule, and
Maintain the records necessary to verify
compliance with each of the above requirements.
By October 12, 1988, LEAs nust:
a
a
Complete an initial inspection to locate all
asbestos-containing building materials (ACBM),
and
Develop and submit to the State an asbestos
management plan that includes the results of the
inspection.
No later than July 9, 1989, LEAs nust:
Begin to implement their management plan.
Each LEA must also select and train an LEA Designated Person as soon as
possible. This person is responsible for ensuring that a variety of activities
-- including the initial inspection, operations and maintenance activities, and
other response actions -- are properly conducted. If an LEA has not done so
already, designating and training such a person is the first step to take to
comply with the New Rule.
ii
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CHAPTER 1 - MAJOR ELEMENTS OF THE NEW RULE
The New Rule includes a variety of requirements that an LEA must meet.
This Guide will assist LEAs in understanding the New Rule; each LEA, however,
must closely review the regulatory language in the New Rule to fully understand
its requirements.
Throughout this Guide, the term LEA is used to refer to the administrative
body that directs any public or private non-profit elementary or secondary
school. For example, an LEA would include an entire city or county public
school system consisting of multiple elementary and secondary schools, as well
as one private, non-profit elementary school (e.g., a private school admin-
istered by a religious group). The New Rule applies to all LEAs, regardless of
size. The definition of LEA in the New Rule should be consulted if any
uncertainty exists about a school's status [Section 763.83].
This chapter provides LEAs with an overview of the major requirements of
the New Rule. Exhibit 1-1 summarizes the key areas that LEAs must understand
in order to meet the New Rule's requirements. The chapters that follow
describe in greater detail the New Rule's major requirements and the steps LEAs
must take to comply. Sections of the New Rule are referenced throughout the
Guide to assist LEAs.
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EXHIBIT 1-1
MAJOR REQUIREMENTS FOR LEAs
APPOINT A DESIGNATED PERSON Chapter 2
LEAs must appoint a designated person and ensure that
he/she is adequately trained.
USE ACCREDITED PERSONS Chapter 3
LEAs must use properly accredited persons to conduct
initial inspections, develop management plans, design and
carry out response actions, and conduct reinspections.
CONDUCT INITIAL INSPECTIONS Chapter 4
LEAs must use an accredited inspector to conduct
inspections and must keep records of all activities.
DEVELOP A MANAGEMENT PLAN Chapter 5
LEAs must use an accredited management planner to develop
the management plan, submit the plan to the appropriate
State agency, and maintain an updated copy of the plan.
These plans must be made available to the public.
IMPLEMENT APPROPRIATE RESPONSE ACTIONS Chapter 6
LEAs must use an accredited management planner to recommend
response actions, and must select an accredited person to
design and conduct these response actions.
CONDUCT PERIODIC SURVEILLANCE AND REINSPECTION Chapter 7
LEAs must conduct periodic surveillance, use an accredited
inspector to conduct reinspections, and keep records of all
activities.
ASSURE PROPER TRAINING AND AWARENESS Chapter 8
LEAs must provide necessary training to maintenance and
custodial staff, provide short-term workers with
information about the location of any asbestos-containing
building material, and post necessary warning labels.
MAINTAIN RECORDS Chapter 9
LEAs must update the management plan as appropriate, retain
an updated version of the plan, make all records available
upon request, and notify affected parties of the
availability of the plan.
COMPLY WITH THE NEW RULE Chapter 10
LEAs must follow the requirements according to the time
schedule set forth in the New Rule.
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CHAPTER 2 - APPOINT A DESIGNATED PERSON
APPOINTING THE LEA'S DESIGNATED PERSON
Each LEA must have a designated person who is trained to oversee asbestos
activities and ensure compliance with the New Rule. The LEA's Designated
Person must be appointed as soon as possible to oversee the initial inspection
and management plan development, implementation of any operations and
maintenance activities (including training of custodial and maintenance
personnel), preventive measures, posting of warning labels, and any response
actions that may be necessary.
The LEA's Designated Person does not have to be an LEA employee. An
outside consultant is acceptable. In addition, two or more LEAs may choose to
have the same individual serve as the Designated Person for each LEA.
TRAINING OF THE LEA'S DESIGNATED PERSON
It is important for each LEA to make sure that its Designated Person
receives the training needed to oversee the completion of all the actions
required under'the New Rule. This training must provide basic knowledge of: 1)
health effects of asbestos exposure; 2) detection, identification, and
assessment of ACBM; 3) options for controlling ACBM; 4) asbestos management
programs; and 5) relevant Federal and State regulations [Section 763.84(g)].
Eight EPA-funded university training programs provide appropriate training (see
Appendix A). The LEA's Designated Person can receive this type of training
from one of the EPA centers, or any other training provider, as long as the
course covers the required subjects.
DUTIES OF THE LEA'S DESIGNATED PERSON
Among other tasks, the LEA's Designated Person is responsible for ensuring
that the LEA follows the correct procedures for inspection, management plan
development and submission, implementation of response actions, and
recordkeeping. In addition, he or she will provide a single contact for the
public to obtain information about asbestos-related activities in the LEA. The
Rule requires the LEA's Designated Person to ensure that the following actions
are performed properly:
• Inspections, reinspections, and periodic sur- I I
veillance are conducted (see Chapters 4 and 7); L«J
• Management plans are developed, submitted to the I I
State, and updated (see Chapter 5);
• Workers and building occupants, or their legal II
guardians, are informed at least once each school year
about inspections, response actions, and post-response
activities (see Chapters 5);
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Response actions are developed and implemented (in- I I
eluding operations and maintenance) (see Chapter 6); "•«•
Custodial and maintenance employees are trained (see I I
Chapter 8); ^""^
Short-term workers (e.g., telephone repair workers, I I
utility workers, or exterminators) who may come in ^"^
contact with asbestos in a school are given
information regarding the locations of ACBM (see
Chapter 8);
Warning labels are posted as needed (see Chapter 8); II
The potential for conflict of interest that may arise I
between accredited personnel to be hired by the school *"•
is considered by the LEA (see Chapter 3); and
Management plans are available for inspection, and I
proper notification of management plan availability ^"^
has been provided (see Chapter 9).
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CHAPTER 3 - USE ACCREDITED PERSONS
Persons who are to conduct certain asbestos-related work in schools must
be accredited. On April 30, 1987, EPA published its Model Accreditation Plan
[40 CFR Part 763 Appendix C to Subpart E], which specifies training,
examination and other requirements for persons requiring accreditation. The
Model Plan also includes provisions for "grandfathering" persons who have
received suitable training since January 1, 1985.
Persons can be accredited by States, which are required to adopt
contractor accreditation plans that are at least as stringent as the EPA Model
Accreditation Plan, or by completing an EPA-approved training course and
passing an examination for this course, LEAs should check with their EPA
Regional Asbestos Coordinator (RAC) (see Appendix B) to determine whether their
State has an approved State contractor' accreditation program that meets the
requirements of the Model Plan. States have the authority to develop
accreditation programs that are more stringent than the EPA Model Plan; thus,
an LEA should check with either the State AHERA designee (see Appendix C) or
the Regional Asbestos Coordinator to determine if there are any additional
State requirements.
LEAs should realize that accreditation alone does not guarantee the
quality of performance. When selecting an accredited person, LEAs should
closely examine the qualifications and experience of that person. In addition,
before hiring a person to perform a task requiring accreditation, LEAs should
check with the EPA-approved State program or training course to verify
accreditation credentials.
The following activities require the use of accredited persons:
• Initial Inspections (inspectors conduct initial
inspections to identify and assess ACBM),
• Management Plan Development (management planners
use the data gathered by inspectors to determine
the ACBM's hazard, select the appropriate
response actions, and develop a schedule for
implementing response actions),
• Response Action Design, Supervision, and
Implementation (abatement project designers
determine how the asbestos abatement work should
be conducted, and asbestos abatement contractors,
supervisors, and workers carry out the abatement
work), and
• Reinspections (inspectors conduct reinspection
and reassess ACBM).
The LEA may either hire an accredited consultant to perform the
inspections and prepare management plans or have a suitable school employee
complete an appropriate EPA-approved training course. It may be more
economical for a small school system with few buildings to hire an outside
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inspector and management planner. Large LEAs, however, may find that it is
more cost-effective to have a qualified staff member become accredited as an
inspector and management planner and have this person perform inspections and
develop management plans for all buildings. LEAs should carefully consider
which option is best for their situation. Regional Asbestos Coordinators may
be contacted to obtain a current list of EPA-approved training courses in the
area (see Appendix B). EPA plans to update this list periodically. The
training course organizers should be able to provide interested LEAs with a
list of those who are accredited.
Additionally, LEAs must have accredited personnel furnish proof of
accreditation. Proof could include a license from a State with an EPA-approved
accreditation program, or a training course certificate that indicates the
person successfully completed an EPA-approved course by passing the
examination. It is very inportant that LEAs keep a copy of all licenses and
certificates which denonstrate that the person selected to perform any of the
above tasks is accredited.
The following activities do not require accredited persons:
• Periodic Surveillance [Section 763.92(b)],
• Operations and Maintenance (although custodial
employees need training relative to their duties as
specified in the New Rule) [Section 763.92(a)], and
• Designated Person Activities (although this person
must receive specific training -- see Chapter 2)-
[Section 763.84(g)].
CONSIDERATION OF CONFLICT OF INTEREST
LEAs must consider the potential for conflicts of interest between
accredited inspectors, management planners, and persons who design or conduct
abatement actions for them. However, the resolution of such issues is at the
discretion of the LEA.
EPA recommends that LEAs consider requesting a full financial disclosure
from all accredited professionals they plan to hire. It may be more efficient
for LEAs to use the same firm to conduct the inspections and develop the
management plans in order to maintain continuity in the process. EPA
anticipates that many LEAs will find this alternative cost effective. However,
LEAs may not want to employ one firm to both develop the management plan and
conduct response actions, because in that situation the management planner's
recommendations about response actions could be influenced by the potential
profitability of the recommendations.
The only conflict of interest explicitly not permitted by the New Rule
involves the relationship between an accredited abatement contractor and
individuals selected to conduct certain air sampling operations for clearance
purposes. If the abatement contractor and the person conducting air sampling
operations were from the same firm, the air monitoring results could be
falsified to indicate a building is safe for re-occupancy and the abatement
contractor's work is complete.
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CHAPTER 4 - CONDUCT INITIAL INSPECTIONS
To determine if ACBM is present in school buildings, each LEA must use
accredited inspectors to conduct inspections of all school buildings, whether
owned or leased, for all friable and non-friable ACBM [Section 763.85(a)]. If
friable ACBM or thermal system insulation ACBM with potential for damage is
present, its condition must be assessed by the accredited inspector. The
appropriate response action for each category is discussed in Chapter 6.
WHAT BUILDINGS ARE SUBJECT TO THE RULE?
Any school building owned or leased by the LEA must have an initial
inspection conducted and a management plan developed and submitted to the State
by October 12, 1988. LEAs should schedule their inspections early in order to
be able to complete the management plan and submit the plan to the State by
this date.
LEAs should consult the definition of "school building" in Section 763.83
of the New Rule for a more precise definition. In general, the term "school
building" includes structures suitable for use as classrooms, laboratories,
libraries, school eating and kitchen facilities, gymnasiums, and student
dormitories. The term also includes administrative offices, and essential
maintenance, storage, and utility facilities.
If a building is acquired or leased on or after October 12, 1988, an
initial inspection must be conducted before the building is used as a school
building. In the event that emergency use of an uninspected building as a
school building is necessary, the LEA must conduct an inspection of the
building within 30 days after first using the building [Section 763.85(a)(2)].
IDENTIFICATION OF AN ACCREDITED INSPECTOR
Each inspector must be accredited. This means that the individual must be
trained and certified through an EPA-approved training course or an EPA-
approved State accreditation program.
PROCEDURES FOR THE INITIAL INSPECTION
The purpose of an initial inspection is to locate all friable and non-
friable ACBM in school buildings. Suspected ACBM includes surfacing material
on ceilings used for insulation, acoustical, or decorative purposes; thermal
system insulation on pipes and boilers; and miscellaneous materials such as
floor and ceiling tiles. Asbestos-containing material (ACM) is material that
has been tested by an accredited laboratory and found to contain more than one
percent asbestos. For the purpose of compliance, any suspected material may be
assumed to be ACBM. If the material is assumed to be ACBM, however, it must be
treated as ACBM for all purposes.
Exhibit 4-1 presents the LEA's major steps for completing an initial
inspection. Exhibit 4-2 summarizes the activities performed by accredited
inspectors as part of an inspection.
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EXHIBIT 4-1
THE LEA'S MAJOR STEPS TO COMPLETE AN INITIAL INSPECTION
Select an accredited inspector, I I
Have the accredited inspector conduct an initial inspection I I
of all areas of each school building, L^J
Record and keep information about the location of any ACBM I I
or assumed ACBM found by the accredited inspector (the LEA ^""
may keep information in a written description or in a
drawing on a building plan or diagram), and
Include inspection information in the management plan (the |
LEA's Designated Person must oversee this assignment). ^""
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EXHIBIT 4-2
ACTIVITIES PERFORMED BY ACCREDITED INSPECTORS
DURING INSPECTION FOR ASBESTOS-CONTAINING BUILDING MATERIAL
INSPECTION FOR ACBM
• Inspect school buildings for the presence of any ACBM. I
• Determine if suspected ACBM is friable, I
• Identify all homogeneous areas for purposes of sampling. |
SAMPLING OF BULK MATERIALS
Collect samples in each homogeneous area identified as suspected I
ACBM, unless the suspected material is assumed to be ACBM. ^"^
Submit samples to an accredited laboratory for analysis. I
Although not required, it is advisable to send a portion of I
samples to a second lab as a quality assurance/quality control ^""^
check.
ASSESSMENT
Evaluate all information to assess the physical condition of all I
friable ACBM and thermal system insulation ACBM with potential
for damage.
Classify all friable ACBM and thermal system insulation ACBM II
with potential for damage into categories of damage as ^™"
prescribed in the New Rule.
DOCUMENTATION
Document each step taken (a sample inspection form is found in I I
Appendix D. However, any other appropriate documentation form ^""
created by the LEA and/or accredited inspector is acceptable).
Describe or map the locations of all confirmed or assumed ACBM. I I
Submit documentation to the LEA's Designated Person. I
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Under certain conditions,, it may not be necessary to conduct all or part
of the initial inspection. An explanation of what areas of school buildings
may be excluded is provided later in this chapter.
The sample inspection form in Appendix D is intended to provide general
guidance regarding the content and format of inspection records and
reinspection records. The format and length of inspection forms are at the
discretion of the LEA. The sample form in Appendix D is used in one course
that trains inspectors. All completed inspection forms must be given to, and
maintained on file by, the LEA Designated Person, and incorporated into the
management plan.
Each time ACBM is found, the accredited inspector must determine whether
the ACBM is friable. Friable material may be crumbled, pulverized, or reduced
to powder by hand pressure. Friable ACBM is more hazardous than non-friable
ACBM because friable material can release airborne asbestos fibers more easily.
Determining friability is important because friable ACBM must be assessed for
damage and included in an operations and maintenance program.
ASSESSMENT OF ACBM
In order to help determine appropriate response actions, the accredited
inspector must perform an assessment by classifying all friable ACBM and
thermal system insulation ACBM with potential for damage into categories after
each inspection or reinspection [Section 763.88]. These categories are:
• Damaged or significantly damaged thermal system
insulation ACBM;
• Damaged friable surfacing ACBM;
• Significantly damaged friable surfacing ACBM;
• Damaged or significantly damaged friable miscel-
laneous ACBM;
• ACBM with potential for damage;
• ACBM with potential for significant damage; and
• Any remaining friable ACBM or friable assumed ACBM.
The inspector shall give reasons in the written assessment for classifying
the material into these categories. To assess a school building completely,
the inspector also must classify all friable ACBM identified in inspections
made prior to the inspection required by the New Rule. Records of all
inspection results must be maintained for inclusion in the management plan.
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REQUIREMENTS FOR SAMPLING AND ANALYSIS
When an accredited inspector identifies friable or non-friable suspected
ACBM during an inspection or reinspection, the LEA has the option to sample the
material or assume the material is ACBM. All samples must be taken by an
accredited inspector [Section 763.86]. LEAs must use accredited laboratories
to analyze the samples [Section 763.87] (for information on laboratories call
the appropriate EPA Regional Asbestos Coordinator listed in Appendix B or the
Office of Toxic Substances Hotline listed in Appendix A).
EXCLUSIONS
Under certain conditions, all or part of a school building may be excluded
from the initial inspection requirement. LEAs should realize that exclusion
fron an initial inspection in no way excludes them from the requirement to
submit a management plan. Exclusions are based on the judgement of an
accredited inspector who determines whether the results of previous inspections
and sampling were adequate to determine the presence or absence of asbestos in
specific areas of the school building [Section 763.99].
The accredited inspector generally is the key element in the exclusion
process. In some instances, however, architects, project engineers, and
employees of a State's lead agency responsible for asbestos inspection might be
involved in the exclusion process.
It is very important to note that the accredited inspector must perform an
assessment of areas that are excluded from an initial inspection if they
contain friable ACBM. For example, areas of a school that previously were
inspected and identified as containing friable ACBM under EPA's 1982 asbestos
inspection rule must be assessed by the accredited inspector. However, schools
may save on sampling costs if the accredited inspector certifies that an
exclusion is appropriate.
There are six ways in which an LEA may be excluded from all or part of the
requirement to conduct an initial inspection [Section 763.99]:
• LEAs do not need to have an initial inspection
conducted in specific areas of a school where
friable ACBM has already been identified.
However, the friable ACBM must be assessed.
• LEAs do not need to conduct an initial inspection
if sampling records show that non-friable ACBM
was identified. However, the inspector must
identify ACBM that has become friable. This
newly friable material must now be assessed.
• If previous sampling of a specific area of the
school indicated that no ACBM was present, and
the sampling was done in substantial compliance
with the New Rule, the LEA does not have to
perform an initial inspection of that area.
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• LEAs do not have to inspect specific areas of
schools where records indicate that all ACBM was
previously removed.
• LEAs can qualify for an inspection exclusion for
schools built after October 12, 1988 (the date
when management plans are to be submitted to
Governors), if no ACBM was specified for use in
the school.
• States that receive a waiver from the inspection
requirements of the New Rule can grant exclusions
to schools that have performed inspections in
substantial compliance with the New Rule and
found that no ACBM is present.
For most of these exclusions, the accredited inspector must review
sampling and inspection records before he/she can certify that a school can be
excluded from an initial inspection. If a representative of an LEA believes
that it qualifies for one of these exclusions, he/she should consult an
accredited inspector [Section 763.99]. Assistance on exclusions may be
obtained from EPA Regional Asbestos Coordinators (see Appendix B).
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CHAPTER 5 - DEVELOP A MANAGEMENT PLAN
IDENTIFICATION OF AN ACCREDITED MANAGEMENT PLANNER
The management planner must be accredited. The planner must be trained
and accredited through an EPA or State accreditation program (see Chapter 3).
LEAs may chose to use one person as both the accredited inspector and
accredited management planner.
DEADLINES
October 12, 1988 By this date each LEA must develop an asbestos
management plan for each school building under its
administrative control, and submit it to the Agency
designated by the State Governor [Section 763.93(a)]
(see Appendix C).
July 9, 1989 Implementation of the plan must begin on or before
this date and be completed in a timely fashion
[Section 763.93(c)]. Timely fashion is based upon the
schedule • developed by the accredited management
planner and the LEA.
MAJOR COMPONENTS OF THE MANAGEMENT PLAN
The following is a comprehensive checklist of the major elements of a
management plan. For each school building, LEAs must use an accredited
management planner to determine the specific format and content of that
school's management plan. Individual management plans may differ from the
checklist shown below. A checklist like this one may be used to help ensure
that the required information is included in the plan [Sections 763.93(e) to
763.93(i)].
1. Background infomation on the school
• Name and address of each school building II
• Whether the building contains friable ACBM, non- I|
friable ACBM, and friable and non-friable 1—J
suspected ACBM assumed to be ACM
2. Information on the LEA Designated Person
• Name, address, and telephone number of the LEA I I
Desi annt-erf Persrm ('ceo (Thfl-nl-ev 9^ ^"J
Designated Person (see Chapter 2)
The course name and date
the LEA Designated Person
The course name and dates of training taken by I I
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3. For all inspections and reinspections conducted after the
effective date of the regulations, i.e., December 14, 1987,
the following additional information must be included in
the management plan (for any inspections that were
conducted before December 14, 1987, refer to the .end of
this section):
• Background Data:
Date of the inspection or reinspection I I
Name, signature, accrediting agency, I I
and a copy of the State license or s«J
training course certificate that
includes the accreditation number of
the accredited inspector performing the
inspection or reinspection
• Sampling:
A blueprint, diagram, or written I I
description of each school building ^""
clearly identifying each location and
approximate square or linear footage of
any homogeneous area where material was
sampled for ACM
The exact description of the location I I
where each bulk sample was collected LJ
The dates of collection I I
The location of homogeneous areas where I I
friable suspected ACBM is assumed to be ^•~
ACM, and where non-friable suspected
ACBM is assumed to be ACM
A description of the manner used to I
determine sampling locations ^™"
The name, signature, accrediting I I
agency, and a copy of the State license
or training course certificate that
includes the accreditation number of
each accredited inspector collecting
samples
• Analyses:
A copy of the results of any bulk I I
samples analyzed ™"
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The name and address of any laboratory I I
that analyzed bulk samples "—J
An official statement from the I
laboratory that it meets the H^rf
accreditation requirements
Dates of any analyses I |
The name and signature of the person I |
performing laboratory analyses ^""
• Assessments:
A description of assessments (see I I
Chapter 4) of ACBM LJ
The name and signature, accrediting I
agency, and a copy of the State license ^""•"
or training course certificate that
includes the accreditation number of
each accredited person making
assessments
4. Managenent Plan Development
For each accredited management planner used to review the
results of inspections, reinspections, and assessments in
order to recommend response actions, the following
information must be included in the plan:
• Name and signature | j
• Accrediting agency and a copy of the State | |
license or training course certificate that
includes the accreditation number of the
management planner
5. Response actions
A detailed description of all response actions and
preventive measures to be taken must be incorporated in the
management plan (see Chapter 5), and should include the
following information:
• Methods to be used for response actions I I
• The locations where response actions will be II
taken WaJ
• Reasons for selecting the response action or II
preventive measure *^J
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• A schedule for beginning and completing each j I
preventive measure and response action '••I
• A detailed description in the form of a I I
blueprint, diagram, or in writing of the location ^"™"
of any ACBM or suspected ACBM assumed to be ACM
that remains in the school once response actions
are taken
• An update of the detailed description of I I
remaining ACBM as response actions are completed ^™"
6. Follow-up to response actions
• Plan for reinspection (see Chapter 7) J |
• Plan for periodic surveillance (see Chapter 7) jI
• Plan for operations and maintenance I I
• Description of tne recommendation by the I I
management planner regarding any additional •••»•
cleaning required for operations and maintenance,
and the response of the LEA to this
recommendation
• Evaluation of the resources needed to complete jI
response actions and carry out reinspection, *•"•
operations and maintenance activities, periodic
surveillance, and training
7. Statements of accreditation
Accreditation is required for all persons who conduct the
inspection, develop the management plan, or who will design or
carry out response actions with respect to ACBM, except for
operations and maintenance activities. One of the following
statements must be included in the management plan:
1. A statement that the person(s) is(are) accredited | |
under an EPA-approved State contractor
accreditation program in the State where the LEA
is located (if that State has adopted a program).
2. A statement that the LEA used, or will use, I I
persons who have been accredited by another State **•"
that has adopted a contractor accreditation
program or is accredited by an EPA-approved
course. This applies if the State in which the
LEA is located has not adopted its own EPA-
approved accreditation program.
16
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8. Notification
The plan must include a description of steps taken to
inform workers and building occupants, or their legal
guardians, about the inspections, response actions, and
post-response action activities, including periodic
surveillance and reinspection activities that are planned
or in progress.
9. Statement of Assurance
Statement of assurance, signed by the LEA Designated
Person, assuring that all school district responsibilities
have been or will be fulfilled.
Inspections conducted before December 14, 1987
For all inspections conducted before December 14, 1987, the effective
date of the Rule, the following information regarding the inspection
must be included in the management plan [Section 763.93(e)]:
Background Data:
a
Sampling:
Date of the inspection
A blueprint, diagram, or written
description of each school building
clearly identifying each location and
approximate square or linear footage of
any homogeneous or sampling area where
material was sampled for ACM
The locations of bulk sample collection
and the dates of collection
Analyses:
A copy of any analysis results of bulk
samples, including the dates of the
analysis and a copy of any other
laboratory reports pertaining to the
analysis
a
a
a
a
17
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Assessments:
A description of assessments (see II
Chapter 4) of material that was ™"
identified prior to December 14, 1987,
as friable ACBM or friable suspected
ACBM assumed to be ACM. This de-
scription should include the name and
signature, accrediting agency, and a
copy of the State license or training
course certificate that includes the
accreditation number of each accredited
person making the assessments
Response Actions:
• A description of any response actions I I
or preventive measures taken to reduce ^™
asbestos exposure, including the names
and addresses of all contractors
involved in such actions or measures,
the start and completion dates of the
contractors' work and, if possible, the
results of any air samples analyzed
during or upon completion of the work
NOTIFICATION OF MANAGEMENT PLAN AVAILABILITY
When submitting a management plan to the Agency designated by the State
Governor, and annually thereafter, the LEA shall notify in writing the parent,
teacher, and employee organizations of the availability of the plan. In the
absence of such organizations, the LEA must give annual written public notice
of the availability of the plan to the relevant groups. The LEA's management
plan shall include a dated copy of this notification and a description of the
steps taken to notify the appropriate groups [Section 763.93(g)].
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CHAPTER 6 - IMPLEMENT APPROPRIATE RESPONSE ACTIONS
With the guidance of the management planner, the LEA must select
appropriate response actions consistent with the assessment, and implement
these actions in a timely manner. It is important for the LEAs to understand
that the schedules which are developed for response actions, and included in
their management plans, are enforceable by EPA. The presence of friable ACBM,
or thermal system insulation ACBM with potential for damage, also requires the
initiation of an operations and maintenance (O&M) program. The response action
selected must protect human health and the environment, but the LEA may choose
to implement the least burdensome response action from those actions that
protect human health and the environment. LEAs may always choose to remove
ACBM. Guidelines specified in the New Rule [Section 763.90] for choosing
appropriate response actions are outlined below.
All supervisors, contractors, and workers who conduct response actions
must be accredited. For assistance in locating accredited personnel, contact
the nearest EPA Regional Asbestos Coordinator (see Appendix B).
RESPONSE ACTIONS
After assessments are made by an accredited inspector, the accredited
management planner will provide the LEA with written recommendations regarding
response actions. The LEA must select response actions and implement them in a
timely fashion [Section 763.90]. All response actions, including removal,
encapsulation, enclosure, or repair (other than small-scale, short-duration
repairs) must be designed and conducted by persons accredited to design and
conduct response actions. An LEA may draw upon its own personnel to carry out
response actions, but they must be individually accredited. Below are the
different categories of damage, each with its corresponding framework of
response actions.
• Damaged or significantly damaged thermal system insulation
ACBM:
Repair the damaged area and maintain all thermal
system insulation ACBM and its covering in an
intact state and undamaged condition;
Remove the damaged material if it is not
feasible, due to technological factors, to repair
the damage.
• Damaged friable surfacing ACBM or damaged friable
miscellaneous ACBM:
Encapsulate the ACBM (with a material that
surrounds or embeds the asbestos fibers in an
adhesive matrix to prevent the release of
fibers);
19
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Enclose the ACBM (with an airtight, impermeable,
and permanent barrier to prevent the release of
asbestos fibers into the air);
Remove the ACBM;
Repair the ACBM to an undamaged condition or to
an intact state so as to prevent fiber release.
Significantly damaged friable surfacing or miscellaneous
ACBM:
Immediately isolate the functional space and
restrict access, unless isolation is not
necessary to protect human health and the
environment;
Remove the material in the functional space or,
depending on whether enclosure or encapsulation
would be sufficient to protect human health and
the environment, enclose or encapsulate the
material.
Any friable surfacing ACBM, thermal system insulation ACBM,
or friable miscellaneous ACBM that has potential for
re:
Implement an operations and maintenance program.
• Any friable surfacing ACBM, thermal system insulation ACBM,
or friable miscellaneous ACBM that has potential for
significant damage:
Implement an operations and maintenance program;
Implement preventive measures appropriate to
eliminate the reasonable likelihood that the ACBM
or its covering will become significantly
damaged, deteriorated, or delaminated;
Remove the material as soon as possible if
appropriate preventive measures cannot be
implemented effectively, or unless other response
actions are determined to protect human health
and the environment. Immediately isolate the
area and restrict access if necessary to avoid an
imminent and substantial endangerment to human
health or the environment.
At the conclusion of any action to remove, encapsulate, or enclose ACBM, a
person designated by the LEA shall visually inspect each functional space where
20
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such actions were conducted to determine whether the action was completed
properly. In addition, the LEA must select a qualified person to collect air
samples to monitor air for residual asbestos levels. The requirements for air
sampling, including mandatory analysis methods, are explained in Section 763.90
of the New Rule. A list of laboratories which are certified to conduct this
testing can be obtained from the EPA Regional Asbestos Coordinators. (Air
sampling is not required for response actions that are of small-scale, short-
duration.) Because the LEA Designated Person is familiar with the asbestos
control program, it would be reasonable for this person to oversee these tasks.
Under the New Rule, LEAs are responsible for ensuring that asbestos waste
materials are transported and disposed of properly after response actions. The
transport and disposal of asbestos waste must meet the requirements in the EPA
publication "Asbestos Waste Management Guidance." Appendix D of the New Rule
covers the necessary requirements, as they had originally been described in the
Guidance publication. The Appendix requires schools to comply with the current
EPA and Department of Transportation regulations in this area.
EPA is in the process of revising the requirements governing the transport
and disposal of ACBM from schools. EPA expects to propose new regulations in
March 1988 and issue final regulations during fall 1988. When finalized, these
regulations will replace Appendix'D, discussed above.
It is important to reiterate that several key items under the New Rule
that relate to response actions are enforceable immediately. As of December
14, 1987, the following stipulations apply:
• Accredited persons must be used to design and
conduct response actions.
• Successful completion of response actions must be
verified by air monitoring [Section 763.90].
• Transportation and disposal of ACBM must be in
accordance with the requirements of Appendix D of
the New Rule.
OPERATIONS AMD MAINTENANCE (06M)
Whenever any friable ACBM or thermal system insulation ACBM with the
potential for damage is present in a school building, it is necessary for the
LEA to initiate O&M activities [Section 763.91]. Any material identified as
non-friable ACBM must be treated as friable ACBM for the purposes of operations
and maintenance when the material is about to become friable as a result of
activities performed in the school building (for example, non-friable ACBM that
is drilled or otherwise disturbed by remodeling, maintenance, or any other
activities that would cause the release of fibers).
Initial Gleaning
Unless the school building has been cleaned using equivalent methods
within the last six months, all areas of a school building where friable ACBM,
21
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damaged or significantly damaged thermal system insulation ACBM, or friable
assumed ACBM are present shall be cleaned at least once after the completion of
the initial inspection and before the initiation of any response action, other
than O&M activities and repair [Section 763.91(c) for specific procedures].
O&M Activities
Whenever an O&M activity disturbs friable ACBM, the LEA must protect
building occupants by enforcing the following procedures [Section 763.91]:
• Restrict entry into the area by persons other than
those necessary to perform the O&M action.
• Post signs to prevent entry into the area by I
unauthorized persons. ^""
• Shut off or temporarily modify the air-handling system |
and restrict other sources of air movement. ^™
• Use work practices or other controls to inhibit the I
spread of any released fibers. ^™"
• Clean all fixtures or other components in the I I
immediate work area. ^™"
• Seal the asbestos debris and other cleaning materials I I
in a leak-tight container and dispose of properly. ^™
Fiber Release Episodes
O&M activities resulting from minor fiber releases from friable ACBM
(falling or dislodging of 3 square or linear feet) require specific cleaning
and maintenance procedures [Section 763.91(f)].
Major fiber release episodes, those of more than three square or linear
feet of friable ACBM, or maintenance activities other than small-scale, short-
duration, are not considered O&M activities. These activities must be designed
and conducted by persons accredited to conduct response actions [Section
763.91(e)(f)].
Worker Protection
Employees of LEAs who perform O&M activities, but are not covered by the
Occupational Safety and Health Administration (OSHA) asbestos construction
standard [29 CFR 1926.58] or a State standard for asbestos worker protection,
are provided OSHA-type protection by EPA [Section 763.91(b)].
22
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CHAPTER 7 - CONDUCT PERIODIC SURVEILLANCE AND REINSPECTIONS
PERIODIC SURVEILLANCE
At least once every six months after a management plan is in effect, each
LEA must conduct periodic surveillance in each school building that contains
ACBM. The person conducting periodic surveillance, the monitor, does not have
to be an accredited inspector. However, the monitor should be familiar with
the school building in order to be able to accurately perceive any changes in
the condition of all ACBM that is identified in the management plan. A
custodian or maintenance worker may be a suitable monitor. The monitor must
record the date of the surveillance, his or her name, and any observable
changes in the condition of the material (e.g., water damage). The monitor
must submit a copy of this information to the LEA's Designated Person, who must
include these records in the management plan [Section 763.92(b)].
It would be very beneficial to have the .same individual conduct these
surveillance activities because the same person would be much more likely to
notice changes in the condition of ACBM. If a person who is unfamiliar with
the school building conducts periodic surveillance, he or she needs to look at
the records of the most recent periodic surveillance and the most recent
inspection or reinspection. This review will help the monitor detect any
changes in the condition of ACBM in the building that have occurred.
REINSPECTIONS
At least once every three years after a management plan is in effect, each
LEA must have an accredited inspector reinspect all friable and non-friable
ACBM, and have the accredited inspector reassess specific materials in each
school building [Section 763.85(b)]. Reinspections help keep track of the
physical condition of the ACBM. In the event that no asbestos was found in a
specific school building during the initial inspection, reinspection of that
building is not required.
As stated above, to ensure that the condition of ACBM is scrutinized
adequately, an accredited inspector must perform all reinspections and
reassessments. The primary purpose of the initial inspection is to locate all
ACBM. Each reinspection provides an opportunity to identify and respond to
changes in the condition of ACBM. Results of these reinspections must be
included in the school's management plan.
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CHAPTER 8 - ASSURE PROPER TRAINING AND AWARENESS
TRAINING OF CUSTODIAL AND MAINTENANCE WORKERS
Before implementing the operations, maintenance, and repair provisions of
the management plan, the LEA must ensure that all members of its maintenance
and custodial staff (custodians, electricians, heating/air conditioning
engineers, plumbers, etc.) who may work in a building that contains ACBM
receive general awareness training of at least 2 hours' duration, whether or
not they are required to work with ACBM. New custodial staff and maintenance
employees who are hired after the implementation of the management plan must be
trained within 60 days after commencement of employment [Section 763.92(a)].
Training must include at least these elements:
• Information regarding asbestos and its various uses
and forms;
• Information on health effects associated with asbestos
exposure;
• Locations of ACBM identified throughout each school
building in which they work;
• Recognition of damage, deterioration, and delamination
of ACBM;
• The name and telephone number of the LEA's Designated
Person; and
• The availability and location of the management plan.
The LEA must ensure that members of its maintenance and custodial staff
who conduct any activities that may result in the disturbance of ACBM receive
the awareness training outlined above, plus 14 hours of additional training
covering [Section 763.92(a)(2)]:
• proper methods of handling ACBM;
• the use of respiratory protection;
• other personal protection measures; and
• hands-on training in good work practices.
As of December 14, 1987, LEAs must ensure that their custodial and
maintenance staff members receive this training prior to conducting activities
that may disturb asbestos.
24
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LEA maintenance and custodial staff who have attended EPA-approved
asbestos training courses or received equivalent training for O&M and periodic
surveillance activities involving asbestos, are considered trained and do not
require any additional training.
PROVIDING INFORMATION REGARDING THE LOCATION OF AGBM TO SHORT-TERM WORKERS
It is the duty of the LEA's Designated Person to make sure that the LEA
provides information regarding the location(s) of ACBM and assumed ACBM in
school buildings to short-term workers such as telephone repair workers or
building repair contractors.
POSTING WARNING LABELS
The LEA Designated Person must make sure that warning labels are attached
immediately adjacent to any friable and non-friable ACBM in routine maintenance
areas (such as boiler rooms) of each school building. Such material includes
friable ACBM that was responded to by a means other than removal, for example,
encapsulation, and ACBM for which no response action was carried out.
Classrooms, libraries, and cafeterias are a few examples of rooms that are not
considered routine maintenance areas.
All labels must be displayed prominently in readily visible locations and
remain posted until the ACBM that is labeled is removed. Warning labels must
be made readily visible with large print or bright color, and shall read as
follows:
CAUTION: ASBESTOS. HAZARDOUS.
TRAINING AND EQUIPMENT.
DO NOT DISTURB WITHOUT PROPER
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CHAPTER 9 - MAINTAIN RECORDS
Each LEA is required to keep in its administrative office a copy of the
management plan that was submitted to the Agency designated by the State
Governor. If changes are made based on the State review, each LEA is required
to keep the revised management plan on file in the LEA office. In addition,
each school is required to keep a copy of its own management plan. Records of
all activities performed after the original plan was submitted to the Governor
must be collected and made available to the public for inspection.
The public may request the LEA to provide all information gathered during
inspections, reinspections, and periodic surveillance, as well as general
information regarding the LEA's asbestos control program [Section 763.93(g)].
RECORDKEEPING OF MANAGEMENT PLAN
• Each LEA must keep an updated copy of the management I
plan in its administrative office for each school ^™"
under its administrative control or direction. This
plan must be available, without restriction, to the
public, school personnel and their representatives,
parents, and representatives of EPA and the State, for
inspection during normal business hours.
• Each school must keep in its administrative office an I
updated copy of the management plan for that school.
The school must make the management plan available for
inspection.
• Each LEA and school must keep accurate records of I
relevant events with the management plan. '••••
RECORDKEEPING OF OTHER INFORMATION
Records must be kept of all relevant events occurring after submission of
the management plan. These records become part of the management plan. The
relevant events include:
1. Response actions and preventive measures.
2. Training of personnel.
3. Periodic surveillance.
4. Reinspection and assessments.
5. Cleaning activities.
6. Small-scale, short-duration operation and maintenance
activities.
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7. All operations and maintenance activities other than
small-scale and short duration activities.
8. Fiber release episodes.
All records shall be retained in the administrative offices of both the
LEA and the school as part of the management plan. For each area where ACBM
has been removed, the records must be kept for 3 years after the next required
reinspection [Section 763.94(a)]. The records that must be maintained are
presented in Exhibit 9-1 in the form of a checklist.
27
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EXHIBIT 9-1
RECORDKEEFING CHECKLIST
1. For any response action or preventive measures taken for I I
ACBM: a detailed description of the actions and information '•"
on sample analysis [see Section 763.94(b)].
2. For each person required to be trained: their name and job I
title, as well as information on their training. ^™"
3. For each periodic surveillance that is conducted: the name I
of each person performing the surveillance, the date of the ^™
surveillance, and any changes in the condition of the
materials.
4. For each reinspection: the name and accreditation | |
information of the inspector, the date of the reinspection,
and any changes noted in the condition of the material.
5. For each required cleaning: the name of the person | |
performing the cleaning, the date of the cleaning, the
locations cleaned, and the methods used.
6. For each small-scale and short-duration operation and
maintenance activity: the name and signature of the person
performing the activity, the activity start and completion
dates, the precise locations, a description of the activity
and any preventive measures taken, and if ACBM is removed,
the name and location of the storage or disposal site.
7. For maintenance activities other than small-scale and I |
short-duration activities: the name and signature of the V^J
person performing the activity; their State of
accreditation and, if applicable, the accreditation number
of each person doing the activity; the activity start and
completion dates; the precise locations; a description of
the activity and any preventive measures; and if ACBM is
removed, the name and location of the storage or disposal
site.
8. For each fiber release episode: the date and location of | |
the release, the method of repair, the preventive or
response actions taken, the name of each person performing
the work, and if ACBM is removed, the name and location of
the storage or disposal site.
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CHAPTER 10 - COMPLY WITH THE NEW RULE
DEADLINES
The introduction to this Guide outlines the major deadlines associated
with the New Rule. Figure 10-1 presents an overview of this information. As
this figure indicates, LEAs must take a number of steps this year to comply
with the New Rule.
PENALTIES
The Toxic Substances Control Act (TSCA) Title II, Section 207(a) provides
civil penalties of up to $5,000 per violation per day [Section 763.97(a)] when
an LEA:
• Fails to conduct inspections in a manner consistent
with this Rule.
• Knowingly submits false information to the designated
State Agency.
• Fails to develop a management plan in a manner
consistent with this Rule.
In the New Rule, a "violation" means a failure to comply with respect to a
single school building. TSCA Title I, Section 16 provides authority to issue
to persons other than LEAs civil penalties of up to $25,000 per day for each
violation of AHERA (TSCA Title II). Such persons may include those who design
and conduct response actions and are not accredited under AHERA, and
laboratories that perform air testing that are unaccredited or do not follow
the specified protocol.
Criminal penalties may be assessed if any violation committed by any
person (including an LEA) is knowing or willful [Section 763.97(c)].
NOTICE
Reading this Guide should not be considered a. substitute for reading the
New Rule (40 CFR Part 763 Subpart E); this Guide supplenents the Rule and LEAs
should refer to the Rule for specific details. Copies of the Rule are
available fro* the EPA Regional Asbestos Coordinator. LEAs are encouraged to
seek assistance fro» their EPA Regional Asbestos Coordinator and their
designated State agency (see Appendices B and C).
29
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FIGURE 10-1
SCHEDULE FOR MAJOR REQUIREMENTS OF THE NEW RULE
DEADLINES:
ASAP
Designate and train LEA Designated Person who has responsibility for
overseeing all asbestos activities, including compliance with the New Rule
Use accredited individuals for response actions,
aPProvec' a'r monit°rm9 methods after abatement,
approved waste disposal practices, and maintain
all records required under the New Rule
Prior to the initiation Train appropriate school district staff and
of any O&M activities abide by the O&M provisions of the New Rule
10/12/88 Conduct an
initial inspection
n/i 9/ftft Develop and submit a management
10/12/88 plan and notify the public
7/g/gg Initiate implementation of
management plan
"Timely manner" as pnitiate appropriate
approved in the | response actions
management plan
6 months after management Perform ic surveiMance
plan is in effect
3 years after management Conduc( a rein ,ion
plan is m effect
30
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APPENDIX A - EPA-FUNDED TRAINING PROGRAMS
ASBESTOS INFORMATION AND TRAINING CENTERS
Georgia Institute of Technology (404) 894-3806
University of Kansas (913) 491-0181
University of Illinois, Chicago (312) 996-5762
Tufts University (617) 381-3531 (x 5061)
University of California at Berkeley (415) 643-7143
University of Texas at Arlington (817) 273-2581
UMDNJ Robert Wood Johnson Medical School (201) 463-4500
(Rutgers)
Temple University (215) 787-6479
ADDITIONAL EPA-FUNDED TRAINING PROGRAMS
Texas A&M University (409) 845-6682
University of Cincinnati (513) 872-5733
University of Florida (904) 392-9570
University of Utah (801) 581-5710
National Asbestos Council (NAG) (404) 292-0629
Office of Toxic Substances HOTLINE
For information about other training programs and the New Rule in general,
call the Office of Toxic Substances HOTLINE at (202) 554-1404 or 554-1405
31
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APPENDIX B - REGIONAL ASBESTOS COORDINATORS
EPA Region 1 EPA Region 6
JFK Federal Building Allied Bank Tower
Boston, MA 02203 1445 Ross Avenue
(617) 565-3273 Dallas, TX 75202
(Connecticut, Maine, (214) 655-7244
Massachusetts, New Hampshire, (Arkansas, Louisiana, New
Rhode Island, and Vermont) Mexico, Oklahoma, and Texas)
EPA Region 2 EPA Region 7
Woodbridge Avenue 726 Minnesota Avenue
Edison, NJ 08837 Kansas City, KS 66101
(201) 321-6668 (913) 236-2835
(New Jersey, New York, Puerto (Iowa, Kansas, Missouri, and
Rico, and Virgin Islands) Nebraska)
EPA Region 3 EPA Region 8
841 Chestnut Street One Denver Place
Philadelphia, PA 19107 999 18th Street, Suite 500
(215) 597-9859 Denver, CO 80202-2405
(Delaware, District of (303) 293-1744
Columbia, Maryland, Pennsylvania, (Colorado, Montana, North
Virginia, and West Virginia) Dakota, South Dakota, Utah,
and Wyoming)
EPA Region 4
345 Cortland Street, N.E. EPA Region 9
Atlanta, GA 30365 215 Fremont Street
(404) 347-5053 San Francisco, CA 94105
(Alabama, Florida, Georgia, (415) 974-7290
Kentucky, Mississippi, North (Arizona, California, Hawaii,
Carolina, South Carolina, and Nevada, American Samoa, and
Tennessee) Guam)
EPA Region 5 EPA Region 10
230 S. Dearborn Street 1200 6th Avenue
Chicago, IL 60604 Seattle, WA 98101
(312) 886-6003 (206) 442-2870
(Illinois, Indiana, Michigan, (Alaska, Idaho, Oregon, and
Minnesota, Ohio, and Wisconsin) Washington)
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APPENDIX C - AHERA STATE DESIGNATED CONTACTS
(As of January 14, 1988)
State
Alabama
Alaska
American Samoa
Arizona
Arkansas
California
Colorado
Agency
Mr. William Weems, Director
Alabama Safe State Program
P.O. Box 2967
Tuscaloosa, Alabama 35486
(205) 348-7136
Sue Miller, Project Assistant
Department of Education
Goldbelt Building
P.O. Box F
Juneau, Alaska 99811
(907) 465-2865
David 0. Chelgren, Manager
Compliance Unit
Office of Air Quality
Department of Health Services
2005 North Central Avenue
Phoenix, Arizona 85004
(602) 251-2277
Dan Lovelady, Coordinator
School Plant Services
Department of Education
4 Capitol Mall
Room HOB
Little Rock, Arkansas 72201-1021
(501) 682-4261
John Jenkins
Office of Local Assistance
501 J Street, Suite 350
Sacramento, California 95814
(916) 445-9327
Dave Ouimette
Air Pollution Control Division
Colorado Department of Health
4210 East llth Avenue
Denver, Colorado 80220
(303) 331-8587
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Connecticut
Delaware
District of
Columbia
Florida
Georgia
Guam
Hawaii
Public Schools:
Nancy Harris, Chief
Bureau of Grants Processing
State Department of Education
165 Capitol Avenue
Hartford, Connecticut 06106
(203) 566-8204
Private Schools:
Paul Schur, Assistant Director
Preventable Diseases Division
State Department Health Services
150 Washington Street
Hartford, Connecticut 06106
(203) 566-3186
Robert Foster, Occupational Safety and Health
Administrator
Department of Administrative Services
Division of Facilities Management
P.O. Box 1401
O'Neill Building
Dover, DE 19903
(302) 736-5644
Robert Gordon
Department of Public Works
2000 14th Street, NW
Washington, D.C. 20009
(202) 939-8136
Bobby L. Johnson, Program Specialist
Florida Department of Education
W. V. Knott Building - 144 Collins
Tallahassee, Florida 32399
(904) 487-1130
Dr. Warner Rogers, Superintendent of Schools
Georgia State Department of Education
Office of Administrative Services
Division of Transportation Facilities & Asbestos
2066 Twin Towers East, 16th Floor
Atlanta, Georgia 30334
(404) 656-2438
James Ikeda
Department of Health
Environmental Protection and Health Services
P.O. Box 3378
Honolulu, Hawaii 96801
(808) 548-6455
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Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Don Anderson, Section Chief
Asbestos Abatement Section
Illinois Department of Environmental Management
525 West Jefferson - 3rd Floor
Springfield, Illinois 62671
(217) 782-3517
Andy Knott
Office of Air Management
Indiana Department of Environmental Management
P.O. Box 6015
Indianapolis, Indiana 46206
(317) 232-8416
C. Milton Wilson
Consultant, School Facilities, for
Department of Education
Bureau of Administration and Accreditation
Iowa Department of Education
Des Moines, Iowa 50319-0146
(515) 281-4743 or 281-3022
John Irwin, Chief
Environmental Toxicology Section
Kansas Department of Health & Environment
Forbes Field
Topeka, Kansas 66620
(913) 296-1500
Jim Judge, Assistant Director
Division of Buildings and Grounds
Kentucky Department of Education
1530 Capitol Plaza Tower
Frankfort, Kentucky 40601
(502) 564-4326
Bill Davis, Chief
NESHAPS Unit
P.O. Box 44096
Baton Rouge, Louisiana 70804
(504) 342-1209
Henry E. Warren, Director
Division of Asbestos Management Activities
Department of Administration
Bureau of Public Improvement
State House Station 77
Augusta, ME 04333
(207) 289-4511
35
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Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Dr. Katherine Farrell, Administrator
Center of Environmental Health
Department of the Environment
201 West Preston Street
Baltimore, MD 21201
(301) 225-5753
Dick Levine
Department of Labor and Industries
Division of Occupational Hygiene
1001 Watertown Street
West Newton, MA 02165
(617) 969-7177
Bill De Liefde, Asbestos Coordinator
Michigan Department of Public Health
Division of Occupational Health
P.O. Box 30035
Lansing, Michigan 48909
(517) 335-8250
Len Nachman, Director
District Financial Management & Transportation
Minnesota Department of Education
550 Cedar Street
St. Paul, Minnesota 55101
(612) 296-5032
Governor Ray Mabus
P.O. Box 139
Jackson, Mississippi
(601) 359-3100
39205
(Note: no State designee)
Erol Roberts
Division of Environmental Health
Missouri Department of Health
1730 East Elm Street
P.O. Box 750
Jefferson City, Missouri 65102
(314) 751-6102
Larry Lloyd, Administrator
Environmental Sciences Division
Department of Health and Environmental Sciences
Helena, Montana 59620
(406) 444-3111
36
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Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
Jacqueline M. Fiedler
Industrial Hygienist Coordinator
Nebraska Department of Health - EHHS
301 Centennial Mall South
Lincoln, Nebraska 68509
(402) 471-0519
Doug Stoker
Nevada Department of Education
4045 South Spencer - Suite A47
Las Vegas, Nevada 89158
(702) 486-6455
Douglas Brown
Department of Education
State Office Park South
101 Pleasant Street
Concord, New Hampshire 03301
(603) 271-3620
James A. Brownlee, Director
AHERA Implementation Section
New Jersey Department of Health
CN 360
Trenton, NJ 08625-0360
(609) 984-2193
State Department of Education
School Finance Division
Education Building
Sante Fe, New Mexico 87503
(505) 827-3848
Dr. Brian Walsh, Administrator
Facilities & Management Services
State Education Department, Room 3071
Albany, New York 12330
(518) 474-4383
Howard Bridges, Program Manager
North Carolina Division of Health Services
Occupational Health Branch
P.O. Box 2091
Raleigh, North Carolina 27602
(919) 733-3680
37
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North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Mr. Dana Mount, Director
Division of Environmental Engineering
North Dakota State Health Department
State Capitol
Bismark, North Dakota 58501
(701) 224-2348
(co-designee)
Mr. Alton Koppang, Director
Finance and Reorganization
Department of Public Instruction
State Capitol
Bismark, North Dakota 58501
(701) 224-2267
(co-designee)
Martin L. King, Program Director
Indoor Environmental Management Program
Bureau of Environmental Health
Ohio Department of Health
P.O. Box 118
Columbus, Ohio 43266-0118
(614) 466-1450
J. Dale McHard, Chief
Emily Allen
Bill Kemp
Radiation and Special Hazards
State Department of Health
N.E. 10th and Stonewall
Oklahoma City, Oklahoma 73152
(405) 271-5221
Al Shannon
Oregon Department of Education
700 Pringle Parkway, S.E.
Salem, Oregon 97310
(503) 378-6964
Gerald Grove, P.E.
Division of Physical Plant and Construction
Department of Education
333 Market Street
Harrisburg, PA 17126-0333
(717) 787-5480
Mr. Santos Rohena Betancourt, Chairman
Puerto Rico Environmental Quality Board
Box 1148
San Juan, Puerto Rico 00910
(809) 722-1174 or 722-2173
38
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Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
James Hickey, Chief
or
William Dundulis
Supervisor Asbestos Section
Department of Health
Division of Occupational Health and
Radiation Control
206 Cannon Building
75 Davis Street
Providence, Rhode Island 02908-5097
(401) 277-3601
Denard Harris, Director
Governor's Division of Education
1205 Pendleton Street
Columbia, South Carolina 29201
(803) 734-0448
Leonard Powell
Education Program Specialist
Kneip Building
700 North Governor's Drive
Pierre, South Dakota 57501
(605) 773-3553
Governor Ned Ray McWherter
Tennessee State Capitol Building
Nashville, Tennessee 37219
(615) 741-2001
Jerry Lauderdale, Chief
Joel Smith
Occupational Safety and Health Division
Texas Department of Health
1100 West 49th Street
Austin, Texas 78756
(512) 458-7254
Mr. Kenneth L. Alkema, Director
Division of Environmental Health
Bureau of Air Quality
288 North 1460 West
P.O. Box 16690
Salt Lake City, Utah 84116-0690
(801) 538-6121
39
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Vermont
Virgin Islands
Virginia
West Virginia
Wisconsin
Wyoming
Thomas J. Broido
Asbestos Program Manager
or
Todd Hobson
Vermont Department of Health
Division of Environmental Health
60 Main Street
P.O. Box 70
Burlington, Vermont 05402
(802) 863-7220
Commissioner of Department of Planning and
National Resources
179 Altona and Welgunst
St. Thomas, Virgin Islands 00802
David Boddy, Associate Director
Energy and Facilities Services
Department of Education
P.O. Box 6Q
Richmond, Virginia 23216
(804) 225-2035
Roy Blizzard, Director of School Facilities
Department of Education
Building 6 Room 264
Capitol Complex
1900 Washington Street, East
Charleston, West Virginia 25305
(304) 348-3569
Mr. William Otto, Public Health Educator
Wisconsin Division of Health
P.O. Box 309
Madison, Wisconsin 53701
(608) 266-9337
Roger Hammer
Wyoming State Department of Education
Hathaway Building
Cheyenne, Wyoming 82002
(307) 777-6198
No State designee at this time.
40
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APPENDIX D - SAMPLE FORM
The sample inspection form in this appendix is intended to provide general
guidance regarding the content and format of inspection records and
reinspection records. The format and length of inspection forms are at the
discretion of the LEA. The sample form presented here is similar to inspection
forms used to teach inspectors at some accreditation training courses.
Ideally, an inspection form would also include a category that
differentiates friable suspected ACBM from non-friable suspected ACBM. In
addition, the form would include the damage categories stipulated in the New
Rule (e.g., significant damage). Despite its limitations, the sample
inspection form does provide LEAs with an idea of the type of information an
accredited inspector gathers during an inspection.
' it's
41 U.S. Environmental Protection
Region 5, Library (5PL-16)
?. 0 G. Dearborn Street, Room 1670
CMcago. IL 60604
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SAMPLE INSPECTION FORM
RECORDING FORM FOR PHYSICAL ASSESSMENT DATA
Building:
Functional Area No.
Type:
Location:
Type of Suspect Material:
Description :
Surfacing,
TSI,
Overall Rating:
Good,
Fair,
Poor
Potential for Disturbance
Potential for Contact:
Description :
High,
Moderate,
Low
Effect of Vibration:
Description :
High,
Moderate,
Low
Misc.
Approximate Amount of Material (linear or square ft.):
Condition
Percent Damage: %, Localized, Distributed
Type of Damage: Deterioration, Water,
Description :
Physical
Potential for Air Erosion:
Description :
High,
Moderate,
Low
Overall Rating:
Comments:
Signed
Good,
Fair,
Poor
Date
42
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