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Frequent Questions

Asbestos in Schools

  1. General
  2. Are schools supposed to notify parents if their child attends a school that has asbestos in it? .
  3. Does my school district know where the asbestos in its school buildings is located?
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  1. Applicability of AHERA
  2. Are vocational schools covered under the Asbestos Hazard Emergency Response Act (AHERA)?
  3. A school building includes a “covered exterior hallway or walkway.” Is this covered exterior hallway or walkway covered by the asbestos in schools rule? If so, does this include both the underside and roof of these areas?
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  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. 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?
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  1. Asbestos Sampling and Testing
  2. Are there criteria under the Asbestos Hazard Emergency Response Act (AHERA) for doing aggressive asbestos air monitoring?
  3. How many samples do you have to take for friable miscellaneous material under the Asbestos Hazard Emergency Response Act (AHERA)?
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  1. Inspections and Reinspections
  2. A school building burns down. A local education agency (LEA) wants to use a local community center under the authority of an LEA for 6 months due to the emergency. Does this temporary school building have to be inspected?
  3. Are local education agencies relieved of the requirement of reinspections once every 3 years for schools which are asbestos-free, either because they were constructed without asbestos-containing building material (ACBM) or because all ACBM has been removed?
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  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?
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  1. Recordkeeping and Asbestos Management Plans
  2. 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)?
  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?
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  1. Small-Scale and Short-Duration Projects
  2. 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)?
  3. 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?
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  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), 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?
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  1. Operations and Maintenance
  2. 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?
  3. 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?
  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?

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