MS Asbestos Abatement cheat sheet

Under TSCA Title II (AHERA), a person must be accredited before contracting to inspect for asbestos, design or conduct response actions, or supervise such work in a school or public/commercial building.

Five accreditation disciplines exist: inspector, management planner, project designer, contractor/supervisor, and worker; each has its own training hours and exam requirements.

Initial training hours: worker 4 days, contractor/supervisor 5 days, inspector 3 days, management planner 2 days (prerequisite: inspector), project designer 3 days.

Annual refresher is required to maintain accreditation; refresher courses are half the initial course length (worker 2 days, contractor/supervisor 1 day, inspector 1 day, management planner half day, project designer 1 day).

A worker refresher may be taken as an 8-hour annual refresher; a contractor/supervisor refresher is 8 hours and includes hands-on and exam.

Accreditation is issued by the state or EPA-approved program where the work occurs; a certificate from one state does not automatically authorize work in another.

Notification to the state or EPA regional office is generally required at least 10 working days before certain abatement or demolition/renovation projects begin, depending on the rule.

Respirator medical evaluation, fit testing, and training under OSHA 29 CFR 1910.134 are separate from AHERA accreditation and both are required for abatement work.

The certification portal is the state or program online system used to submit accreditation applications, renewals, refresher course completions, and fee payments.

Common portal fields include legal name, discipline, training provider, course date, certificate number, and expiration date.

Most portals require uploading a course completion certificate issued by an accredited training provider before the application is reviewed.

Renewal windows vary; many programs require refresher completion and renewal submission before the expiration date to avoid a lapse or late fee.

Portal records typically link to the individual's accreditation number, which employers and regulators use to verify current status.

A lapsed accreditation usually requires retaking the full initial course rather than only the refresher, depending on the program's rules.

Data corrections (name changes, discipline additions, duplicate records) are handled through the portal's amendment or support request process.

Keep portal confirmation numbers and submitted documents; they serve as evidence of timely renewal during inspections.

AHERA requires every local education agency (LEA) to inspect its school buildings for asbestos-containing building materials (ACBM) and to develop a management plan.

The management plan must be available at each school and at the LEA office; the LEA must notify parents, teachers, and employee organizations annually about its availability.

A designated person must be appointed by the LEA to ensure the management plan is implemented and updated.

Reinspection of all ACBM must occur every 3 years by an accredited inspector; periodic surveillance must occur every 6 months.

Response actions include repair, encapsulation, enclosure, removal, and operations and maintenance (O&M); O&M is often chosen when material is in good condition.

A management planner accredited under AHERA develops the management plan and recommends response actions based on inspection findings.

Short-term workers (custodial, maintenance) who may disturb ACBM must receive awareness training at least every 12 months.

The management plan must be updated when significant changes occur, such as a new response action, a reinspection finding, or a change in the designated person.

NESHAP (40 CFR Part 61, Subpart M) regulates asbestos during demolition and renovation of institutional, commercial, and industrial buildings, including schools.

A thorough inspection for asbestos must be conducted before demolition or renovation, and the owner/operator must keep the inspection report.

Notification to the EPA (or delegated state) is required at least 10 working days before demolition, and before renovation that will disturb threshold amounts of regulated asbestos-containing material (RACM).

Regulated asbestos-containing material (RACM) includes friable asbestos material and nonfriable material that will be crumbled, pulverized, or reduced to powder during the project.

Removal of RACM must occur before demolition, and the RACM must be kept adequately wet until collected and contained for disposal.

Waste must be transported in leak-tight containers labeled as asbestos waste and disposed of at a site permitted to accept it.

A demolition order or emergency renovation may allow reduced notification time, but the operator must still notify as soon as possible and document the emergency.

Wet methods, local exhaust ventilation with HEPA filtration, and proper containment are standard controls to prevent fiber release during abatement and demolition.