AHERA Management Planner cheat sheet
AHERA Management Planner · Keep the key ideas within reach.
Asbestos Inspection and Assessment Findings
Inspection findings must identify the material, its location, quantity (square or linear feet), accessibility, condition, and type (surfacing, thermal system insulation, or miscellaneous).
Assessment categories: damaged or significantly damaged TSI, damaged friable surfacing, damaged friable miscellaneous, and nonfriable materials that may become friable.
Friability is the ability of a material to be crumbled, pulverized, or reduced to powder by hand pressure.
Homogeneous areas group materials of similar composition applied at the same time; sampling is performed by homogeneous area, not by individual room.
A management planner relies on the inspector's written assessment; the planner does not re-sample or re-assess materials.
Seven assessment ratings commonly recorded: none, minor damage, significant damage, potential for damage, potential for significant damage, and undetermined.
Quantities are reported in square feet for surfacing materials and linear feet for TSI and some miscellaneous materials.
Reinspection/reassessment is required at least once every three years in schools under AHERA.
Evaluation of Asbestos Hazards and Exposure Potential
Potential for fiber release depends on friability, condition, accessibility, activity level, air movement, and vibration in the area.
Airborne fiber concentration is expressed in fibers per cubic centimeter (f/cc); phase contrast microscopy is the standard method for routine air samples.
Exposure potential rises when damaged friable material is in a high-traffic area, near air-handling equipment, or subject to disturbance.
A hazard assessment weighs damage state against likelihood of disturbance; intact material in a sealed area presents lower potential.
Occupancy and use of the space (children, frequent maintenance, cleaning methods) modify the exposure estimate.
Deterioration can be accelerated by water damage, vibration, and physical contact; these factors should be documented in the assessment.
Risk is evaluated per homogeneous area and per location, not only building-wide, because exposure varies by room function.
Selection and Prioritization of Response Actions
Response actions: operations and maintenance, repair, enclosure, encapsulation, and removal.
Removal is generally reserved for significantly damaged friable material, material that will be disturbed by renovation or demolition, or material that cannot be controlled by other means.
Enclosure and encapsulation are interim controls; they require ongoing surveillance and do not eliminate the hazard.
Repair is used for limited damage, such as patching TSI or sealing small tears, and is typically paired with O&M.
Prioritize actions by hazard: significantly damaged friable material in occupied or high-traffic areas first, then lesser damage, then intact material under O&M.
Encapsulation is not appropriate for materials subject to water damage or for TSI that may need future access.
The management planner selects response actions and sets a schedule; the plan must state what will be done, where, and when.
Cost, effectiveness, durability, and potential for fiber release during the action itself are weighed when choosing among options.
Management Plan Development and Required Content
An AHERA management plan must include the inspection and assessment results, response actions, a schedule, and the O&M plan.
Required elements include a list of homogeneous areas, location and quantity of materials, and the assessment of condition.
The plan must describe response actions for each material, including who will perform them and the timetable.
A plan must identify the steps taken to inform workers, building occupants, and guardians of the plan's availability.
The plan must include a procedure for periodic surveillance (every six months) and reinspection (every three years).
The plan must address how records are maintained and made available for public inspection.
Plans are prepared by an accredited management planner based on an accredited inspector's findings.
The plan should include a statement of the building's asbestos-related goals and the rationale for chosen actions.
O&M Programs and Operations and Maintenance Plans
An O&M program addresses activities that may disturb asbestos, such as maintenance, repair, cleaning, and minor renovation.
O&M provisions include work practices, worker training, respiratory protection, cleaning procedures, and waste handling.
Specialized cleaning (HEPA vacuuming, wet wiping) is used where friable material has shed fibers; dry sweeping and dusting are prohibited.
Employees whose duties may disturb asbestos receive asbestos awareness training; O&M work requires more detailed training.
The O&M plan specifies safe work practices for each material type and location, and prohibits activities that would disturb ACM.
Minor maintenance that disturbs ACM follows prescribed work practices; larger disturbances require abatement by a contractor.
Warning labels or signage identify asbestos-containing materials and areas where access is restricted.
O&M is appropriate for material in good condition that is not likely to be significantly disturbed.
Regulatory Requirements and Recordkeeping
AHERA requires inspection of school buildings by accredited inspectors and management plans by accredited management planners.
Accreditation requires completion of an EPA-approved course and passing an examination; refresher training is required annually for management planners.
Local education agencies must maintain records of inspections, assessments, response actions, and periodic surveillance.
Records must be made available to the EPA, state agencies, and the public; the plan is kept on site.
Notification to parents, teachers, and employee organizations is required annually and whenever the plan is updated.
Abatement contractors and workers must be accredited or certified; abatement is regulated under NESHAP and applicable OSHA standards.
Waste containing asbestos is handled as regulated waste and transported and disposed of per NESHAP requirements.
Recordkeeping must document training, surveillance, reinspection, and any response actions performed.
Communication, Notification, and Plan Updates
The management plan must be available for inspection by parents, teachers, and the public during normal school hours.
Annual written notification informs parents, teachers, and employee organizations of the plan's availability and any updates.
Notification is required when response actions are performed or when the plan is revised.
Periodic surveillance occurs every six months to check material condition and note changes.
Reinspection by an accredited inspector occurs at least every three years and triggers plan revision if conditions change.
Plan updates must reflect new findings, completed response actions, and revised schedules.
Communication should describe the location of ACM, its condition, and the actions being taken, in plain language.
Records of notifications and updates are retained with the management plan.