Jump to main content

Frequent Questions

Asbestos in Schools

  1. General
  2. What is an asbestos management plan?
  3. My child’s school has asbestos in it. Why aren't they taking it out?
  4. How can we have the air tested in my school?
  5. Is it dangerous to have asbestos containing material in my school?
  6. Is the school district required to do anything about asbestos in its school buildings?
  7. More...
  1. Applicability of AHERA
  2. A public school district leases space from a non-school group (e.g., corporation, YMCA, etc.) to use as a “school building.” Who is responsible, the school or the landlord, for complying with the asbestos in schools rule, pursuant to the Asbestos Hazard Emergency Response Act (AHERA) ?
  3. Is a nursery/daycare center subject to the Asbestos Hazard Emergency Response Act (AHERA)?
  4. Do the Asbestos Hazard Emergency Response Act (AHERA) requirements apply to charter schools that provide online elementary and secondary education through “learning centers” and/or directly in the home?
  5. Are churches that have Sunday school classes, daycare centers, or kindergartens regulated under the Asbestos Emergency Response Act (AHERA)?
  6. Are private for-profit schools included under the Asbestos Hazard Emergency Response Act (AHERA)?
  7. More...
  1. School Personnel Training
  2. 40 CFR part 763.92(a)(1) and (2) of the asbestos in schools rule refer to 2-hour training and 14-hour training. If an LEA's workers have not taken the 3-day course to ecome "accredited" abatement workers, and the LEA decides to have workers receive the 2-hour and 14-hour training, where should the workers go for the abbreviated training? How is this training documented?
  3. How often must school custodial staff complete the 2-hour or 14-hour asbestos awareness training under the Asbestos Hazard Emergency Response Act (AHERA)?
  4. What are the qualifications or exact training needed by an individual who conducts the 2-hour asbestos awareness training and the 14-hour additional training for the maintenance and/or custodial employees under the asbestos in schools rule pursuant to the Asbestos Hazard Emergency Response Act (AHERA) ?
  5. A local education agency (LEA) plans to contract all asbestos-related work (including minor repairs) to outside contractors. The LEA has provided 2-hour awareness training to all of their custodial and maintenance staff, but has not provided the 14-hour training. The LEA would like to have its custodial staff remove loose nonfriable vinyl floor tiles for disposal from the building after the accredited asbestos contractor has performed the removal work. Under AHERA, does picking up nonfriable floor tiles for the purposes of disposal constitute “disturbance” of asbestos-containing building material (ACBM) and therefore would require the 14-hour training?
  1. Asbestos Sampling and Testing
  2. How many samples of miscellaneous material or nonfriable suspected material must be taken to determine if the material is asbestos-containing material (ACM) under the Asbestos Hazard Emergency Response Act (AHERA)?
  3. Please clarify the use of the term “homogeneous area,” under the Asbestos Hazard Emergency Response Act (AHERA), which has a regulatory definition of being uniform in color or texture, when applied to thermal system insulation having pipe lagging that has either been discolored or applied differently to give the appearance of possessing a different texture.
  4. Is floor tile considered asbestos containing material (ACM) under the Asbestos Hazard Emergency Response Act (AHERA) if there are contradictory results after analysis of the material through polarized-light microscopy (PLM) and transmission electron microscopy (TEM)?
  5. If vermiculite insulation bulk samples analyzed by standard polarized-light microscopy (PLM) analysis is found to be negative for asbestos, can schools treat the vermiculite as a non-asbestos containing material under the Asbestos Hazard Emergency Response Act (AHERA)?
  6. Are there criteria under the Asbestos Hazard Emergency Response Act (AHERA) for doing aggressive asbestos air monitoring?
  7. More...
  1. Inspections and Reinspections
  2. If the architect or project engineer responsible for the construction of the building provides a statement indicating there is no asbestos-containing material in the school, does the local education agency (LEA) still have to submit an asbestos management plan or have the school building(s) inspected?
  3. How should the periodic surveillance results be documented pursuant to the Asbestos Hazard Emergency Response Act (AHERA)? How detailed does the information have to be and what constitutes adequate records?
  4. If my school does not have any known or assumed asbestos containing building materials (ACBM), do I need to reinspect?
  5. Could miscellaneous asbestos-containing building material (ACBM) on the floors of two identical classrooms on two separate floors be viewed as homogeneous areas?
  6. During an inspection, can a local education agency (LEA) just assume that some or all homogeneous areas of friable and nonfriable suspected ACBM are ACM rather than take samples?
  7. More...
  1. Annual Notification Requirements
  2. Are schools within a local education agency with no Asbestos-Containing Building Material (ACBM) relieved of the annual notification requirements at 40 CFR part 763.84(c)?
  3. Is the local education agency (LEA) required to provide a separate notification to non-short-time workers and building occupants (i.e. parents, teachers, and employees or their organizations) for each response action that is performed?
  1. Local Education Agency Designated Persons
  2. A local education agency (LEA) is required to “designate a person to ensure” that all LEA responsibilities and/or requirements “are properly implemented.” (40 CFR part 763.84(g)(1)) Such a designated person, in turn, is required to obtain “adequate training.” Does this mean that the designated person is required to be “accredited”? If not, what constitutes adequate training?
  3. Can a local education agency (LEA) designate a committee instead of one person to coordinate asbestos programs for an LEA?
  4. Does a local education agency (LEA) with all asbestos-free schools need a designated person pursuant to 40 CFR part 763.84(g)?
  5. Who is responsible for ensuring that a project has been reviewed by a project designer in order to ensure compliance with the Asbestos Hazard Emergency Response Act (AHERA)?
  6. Under the Asbestos Hazard Emergency Response Act (AHERA), must a local education agency’s (LEA’s) Designated Person be an employee of the LEA, or can this person be an outside consultant, available on a part-time basis? Does the Designated Person have to be "on-site" at the LEA, or can he/she be located at another location?
  7. More...
  1. Recordkeeping and Asbestos Management Plans
  2. Pursuant to the Asbestos Hazard Emergency Response Act (AHERA), can a local education agency (LEA) store a management plan in electronic format (e.g., CD ROM)?
  3. Is each individual school required to keep a complete updated copy of its asbestos management plan pursuant to the Asbestos Hazard Emergency Response Act (AHERA) in its administrative office?
  4. If a school has all asbestos-containing building material (ACBM) removed, how long do we need to keep records in the asbestos management plan pursuant to the Asbestos Hazard Emergency Response Act (AHERA)?
  1. Small-Scale and Short-Duration Projects
  2. Under the Asbestos Hazard Emergency Response Act (AHERA), are there any size or volume constraints on the amount of asbestos that can be disturbed or removed during any single small-scale, short-duration project?
  3. When the worker training requirements specified in the Asbestos Hazard Emergency Response Act (AHERA) standard (40 CFR part 763) were extended to abatement activities conducted in commercial, public, and some residential buildings, an exception was made for "small scale, short duration" projects. Specifically, the Environmental Protection Agency (EPA) did not appear to require "accredited" asbestos abatement professionals to be utilized for a "small scale, short duration" activities. Is this interpretation correct?
  4. Does cutting hatchways into ceilings where small amounts of asbestos is disturbed for purposes of mounting fire alarm components in a school fall within the scope of “small-scale, short-duration activities” under the Asbestos Model Accreditation Plan (MAP)?
  1. Determining Friability
  2. If a non-friable component such as a piece of floor tile is broken into small pieces (0.25 inch squares or smaller) in a removal process and the resulting pieces still can’t be reduced to powder by hand pressure, does the Environmental Protection Agency (EPA) still classify these pieces as non-friable and consider this removal process one that can be performed by unaccredited workers pursuant to the Asbestos Hazard Emergency Response Act (AHERA)?
  3. Under the Asbestos Hazard Emergency Response Act (AHERA),what criteria must be applied to determine when a non-friable asbestos containing material is made friable?
  1. Response Actions
  2. If, during a periodic surveillance check, a custodian finds damaged thermal system insulation, what must be done under the Asbestos Hazard Emergency Response Act (AHERA)?
  3. Under the Asbestos Hazard Emergency Response Act (AHERA), is the installation of carpet over damaged A/V floor tile an enclosure?
  4. Under the Asbestos Hazard Emergency Response Act (AHERA), what is meant by the phrase “at approximately the same time” in 40 CFR part 763.90(i)(6) as it relates to transmission electron microscopy (TEM_) clearance?
  5. Under the Asbestos Hazard Emergency Response Act (AHERA), must the accredited management planner review the inspector’s written assessment?
  6. Under the Asbestos Hazard Emergency Response Act (AHERA), does the recommendation that the management planner provides to the local education agency (LEA) need to include a date for implementation of the response action?
  1. Operations and Maintenance
  2. Will areas of newly friable asbestos-containing building material (ACBM) or newly friable assumed ACBM be required to undergo initial cleaning in accordance with 40 CFR part 763.91?
  3. Under the Asbestos Hazard Emergency Response Act (AHERA), Operations and Maintenance (O&M) is for friable asbestos-containing building material (ACBM), or non-friable ACBM and non-friable assumed ACBM when the material is about to become friable. What about non-friable ACBM with the potential for damage? Does this type of material need to be addressed in an O&M plan?
  1. Labeling of Asbestos-Containing Materials
  2. Under the Asbestos Hazard Emergency Response Act (AHERA), do you have to label enclosed or encapsulated asbestos-containing building material ACBM in routine maintenance areas?

Jump to main content.