Compliance Advisory Managing Asbestos in Schools June 2019

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20460
OFFICE OF ENFORCEMENT AND
COMPLIANCE ASSURANCE
COMPLIANCE ADVISORY
Managing Asbestos in Schools
June 2019
This advisory is intended to help Local Education Agencies (LEAs) comply with federal laws for
managing asbestos-containing materials in schools. Compliance with the key requirements of
this law will help schools provide a safe environment for children and employees.
Students and school employees may be at risk from exposure to asbestos via fibers released into the air
by the disturbance or damage of asbestos-containing material. Most asbestos-containing material can
be properly managed where it is. Intact and undisturbed asbestos materials generally do not pose a
health risk. Accordingly, the Asbestos Hazard Emergency Response Act (AHERA) schools rule rarely
requires the removal of asbestos materials. The information below provides a short overview of the
requirements. More detailed information can be found on the EPA's Asbestos and School Buildings
Website at https://www.epa.gov/asbestos/asbestos-and-school-buildings.
What is a Local Education Agency (LEA)?
An LEA can be a public-school district or non-profit private elementary and secondary schools, including
charter schools and schools affiliated with religious institutions.
What are the responsibilities of an LEA?
1. Designate a point person who will be responsible for the:
Basic knowledge of the health effects of asbestos, detection, identification and assessment of
asbestos-containing material, options for controlling asbestos-containing material, asbestos
management programs, and relevant federal and state regulations concerning asbestos.
S A study guide has been developed to help you "AHERA Designated Person's Self-Study
2. Complete an Initial Inspection and Periodic Surveillance
For each building leased, owned or otherwise used as a school building, LEAs must:
S Conduct an initial inspection to determine whether asbestos-containing materials are
present and then re-inspect every three years in each school that is not certified asbestos-
free.
S Perform surveillance of known or suspected asbestos-containing building materials every six
months to note any changes in the material.
S Ensure that trained and licensed professionals perform all of the inspections and take
appropriate response actions, when necessary. Surveillance does not need to be conducted
by a licensed consultant; it is often conducted by custodial or maintenance personnel.
Guide." The study guide can be found on the Asbestos and Schools website.

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3. Establish a School Asbestos Management Plan
Develop, maintain, and update an asbestos management plan and keep a copy at each individual
school and in the LEA's administrative office. The requirement to maintain an asbestos management
plan applies, even where the LEA has an "exclusion statement." To learn more about exclusions,
please refer to the regulation, 40 C.F.R. section 763.99, which is available by visiting the Electronic
Code of Federal Regulations.
4. Provide Written Notification Regarding Availability of the Asbestos Management Plan
At least once each school year, LEAs must provide a written notification to parent, teacher, and
employee organizations (such as PTAs) regarding the availability of the asbestos management plan
and any response actions taken or planned.
5. Inform Short-Term Workers and Provide Training to Custodial & Maintenance Workers
Short-term workers (e.g., utility repair workers) who may encounter asbestos, must be informed of
the location of the asbestos. Warning labels must be posted in all routine maintenance areas where
asbestos is found. Maintenance and custodial staff need training:
S If the building contains asbestos, two hours of asbestos awareness training whether or not
they are required to work with asbestos containing building material.
S If worker activities will result in the disturbance to asbestos containing materials, an
additional fourteen hours of training.
S Training must be provided within sixty days after commencement of employment.
6. Comply with the Record-Keeping Requirements
LEAs must maintain:
S A copy of the updated asbestos management plan in each school;
S A copy of all inspection and/or reinspection reports;
S A copy of the annual notice of the management plan availability;
S A copy of all reports on response actions taken;
S Dated statements regarding operations and maintenance activities;
S Periodic surveillance forms; and
S Documentation related to the training provided to custodial and maintenance employees.
Disclaimer
This Compliance Advisory addresses select provisions of EPA regulatory requirements using plain
language. Nothing in this Compliance Advisory is meant to replace or revise any EPA regulatory
provisions or any other part of the Code of Federal Regulations, the Federal Register, or the Asbestos
Hazard Emergency Response Act.
Where Can I Get More Information?
For more information, please visit EPA's Asbestos and School Buildings Website at
https://www.epa.gov/asbestos/asbestos-and-school-buildings and
https://www.epa.gov/asbestos/asbestos-training.
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