AHERA Inspector cheat sheet

Subpart E applies to local education agencies (LEAs) that own, lease, or otherwise use a school building; coverage turns on use of the building for school purposes, not ownership alone.

A school building is any structure used for student instruction or support services, including administrative and maintenance buildings used by the LEA.

LEAs must inspect each school building for friable and nonfriable asbestos-containing building material (ACBM) and for assumed ACBM; sampling is done by an accredited inspector.

ACBM is any building material that contains more than 1 percent asbestos by weight, determined by Polarized Light Microscopy (PLM) per the prescribed method.

Material must be assumed ACBM if it is friable and has not been sampled, or if the LEA lacks reliable information that it is not ACBM; assumed material is managed as ACBM.

A management plan must be prepared for each school building and submitted to the state governor (or designee) and made available to parents, teachers, and employee organizations.

Reinspections of ACBM must occur at least once every 3 years by an accredited inspector, with surveillance every 6 months by a designated person.

Recordkeeping: inspection reports, management plans, and periodic surveillance records must be retained for the life of the building and made available for review.

AHERA (Title II of TSCA, 15 U.S.C. 2641 et seq.) mandates accreditation of inspectors, management planners, project designers, abatement contractors/supervisors, and workers.

NESHAP (40 CFR Part 61, Subpart M) governs asbestos emissions during demolition and renovation, including notification and work practice standards for regulated asbestos-containing material (RACM).

OSHA 29 CFR 1926.1101 covers construction asbestos work; 29 CFR 1910.1001 covers general industry; both set permissible exposure limits and worker protection requirements.

OSHA permissible exposure limit is 0.1 fiber per cubic centimeter (f/cc) as an 8-hour time-weighted average; excursion limit is 1.0 f/cc over 30 minutes.

The Asbestos School Hazard Abatement Act (ASHAA) and related programs provided federal loan/grant authority for school abatement; AHERA is the primary school regulatory statute.

EPA Model Accreditation Plan (MAP) sets training hour requirements and refresher intervals for each discipline; inspector initial training is 24 hours with annual refresher.

NESHAP defines RACM partly as friable material with more than 1 percent asbestos; Category I and II nonfriable definitions affect notification and handling.

Worker and occupant notification, medical surveillance, and respiratory protection requirements flow from OSHA when employees perform or disturb asbestos.

Inspection requires a walk-through of all building areas, including concealed spaces, mechanical systems, and areas that may be entered by maintenance staff.

Bulk samples are collected in a statistically random manner; a minimum number of samples per homogeneous area is required (commonly 3 for most materials, up to 7 for certain surfacing).

Homogeneous areas are materials that are uniform in color, texture, and date of application; each is sampled and assessed separately.

Assessment categories: friable, nonfriable, and significantly damaged; friable material that is damaged or likely to become damaged is a priority concern.

Assessment factors include accessibility, potential for disturbance, amount of damage, water damage, and air plenum location.

Sampling must not create a hazard; wet methods, proper tools, and containment of sample locations are used to minimize fiber release.

PLM is the standard analytical method for bulk samples; point counting may be used when results are near the 1 percent threshold.

Inspection reports must document sample locations, material descriptions, condition, assessment, and laboratory results for each homogeneous area.

Management plans must include inspection results, a description of response actions, a schedule for implementation, and a plan for periodic surveillance and reinspection.

Response actions include operations and maintenance (O&M), repair, enclosure, encapsulation, and removal; selection depends on condition, accessibility, and disturbance potential.

O&M programs are appropriate for ACBM that is in good condition and not likely to be disturbed; they include work practices, cleaning, and worker training.

Removal is required when material is significantly damaged and cannot be repaired, or when renovation/demolition will disturb it; removal must follow work practice standards.

Enclosure and encapsulation are acceptable where material is intact and the space is accessible for future inspection; encapsulated material must still be managed as ACBM.

The management plan must designate a person responsible for plan implementation and for ensuring periodic surveillance is performed.

Plans must be updated when response actions are completed, when new ACBM is identified, or when building use changes significantly.

Abatement projects require accredited project designers and contractors, and clearance air monitoring may be required depending on the response action and jurisdiction.