Background and Regulatory Framework
The statutory skeleton
AHERA (40 CFR Part 763) is the parent statute; the Project Designer operates inside a web of rules that each govern a different moment of a project. Know which rule answers which question: NESHAP (40 CFR Part 61, Subpart M) governs how regulated asbestos-containing material (RACM) is handled, stripped, and disposed of, and sets the threshold categories (e.g., a facility being demolished or renovated, quantity thresholds, and the 7-day notice to the delegated agency before demolition or certain renovations). OSHA (29 CFR 1926.1101 for construction; 1910.1001 for general industry) governs worker protection and exposure limits. AHERA governs identification in schools, accreditation of inspectors/designers/workers, and recordkeeping. State programs may be stricter and may hold delegation for NESHAP; when a question offers a state requirement that is stricter than federal, the stricter rule controls.
Traps
Questions love to blur the boundary between classification (NESHAP: is it RACM?) and protection (OSHA: what PPE and monitoring?). A material can be non-RACM under NESHAP yet still require OSHA protections. Another trap: the Project Designer is a defined accredited discipline under AHERA - do not confuse it with a licensed architect or engineer, though many designers hold those credentials. Also watch the distinction between friable and RACM: RACM includes category I nonfriable that will be sanded, ground, cut, or abraded.
Rule of thumb
When a stem asks "who requires...", name the agency first (EPA/NESHAP, OSHA, or AHERA/state), then the obligation. Worked example: a renovation will remove 200 linear feet of friable pipe insulation - that is RACM, so NESHAP handling and disposal rules apply; OSHA still sets the PEL and requires exposure assessment for the workers doing it.