AHERA Inspections in Schools

Schools are required to maintain asbestos-containing materials in good condition, in accordance with the EPA’s Asbestos-Containing Materials in Schools Rule, 40 CFR 763.80 through 763.99. This regulation is commonly known as “AHERA.”  The Massachusetts Department of Labor Standards administers and enforces AHERA for all K-12 schools in Massachusetts.  

 

Scope

AHERA applies to public and private not-for-profit elementary and secondary schools, K-12, including charter schools and schools with religious affiliation.

 

General AHERA Requirements

Schools are required to 1) identify asbestos-containing materials in their buildings; 2) maintain asbestos-containing materials in good condition; 3) notify occupants; and 4) maintain records.  This bulletin highlights the major requirements of the regulation. For specific details, refer to http://www2.epa.gov/asbestos/school-buildings#resources.

 

Identify Asbestos-containing materials:

Inspection:

Schools must be inspected by a licensed Asbestos Inspector to identify the presence and condition of any asbestos-containing materials (ACM).    For new construction the requirement for an initial asbestos inspection may be waived if a certification statement is available that documents there were no asbestos-containing materials specified or used in the building. The certification statement may be made by the architect, project engineer responsible for the construction of the new building, or by a licensed Asbestos Inspector after a review of construction documents.  If no certification is available, a full AHERA inspection is required.

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Reinspection:

A reinspection is required every three years. The inspection must be conducted by an accredited Asbestos Inspector.  The school must maintain inspection and reinspection reports, including supporting laboratory reports.

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Description of Asbestos-Containing Materials:

The school’s Asbestos Management Plan must maintain a floorplan, diagram or written description of all asbestos-containing materials in a school.

• Identity and description of material;

• Whether the material is confirmed by testing, or assumed to contain asbestos;

• Location and quantity of material;

• Condition of material; and

• Recommendations by a licensed Management Planner for maintenance or abatement of material.

 

Maintain Asbestos-Containing Materials in Good Condition:

Materials must be maintained in good condition to prevent occupant and worker exposure to asbestos.

• Appoint a Designated Person to oversee that the AHERA requirements are met. The Designated Person must receive training

• Repair or Remove Damaged ACM. Damaged ACM may be identified during a reinspection or periodic surveillance.  Follow recommendations provided by your licensed Management Planner after each 3-year reinspection.

• Implement an Asbestos Management Plan. A Management Plan must be developed by a Massachusetts licensed Management Planner, and is based on the inspection conducted by a licensed Asbestos Inspector. If there is no ACM present in your building, a Management Plan is still required.  o Implement an Operations and Maintenance Program. The O&M program provides specific procedures and work practices for routine maintenance and repair operations which may disturb asbestos and for the clean-up of minor asbestos spills.

• Provide O&M Equipment. Depending upon the type of ACM in your school, HEPA vacuums, wet mopping, and other equipment may be required

• Train Custodians and Maintenance Staff:  a 2-hour Asbestos Awareness training is required for custodians who work in the vicinity of ACM; a 16-hour Operations and Maintenance training is required for maintenance and trades personnel who may disturb asbestos.

• Conduct periodic surveillance every six months to monitor condition of ACM.

• Hire licensed Asbestos Contractors and Consultants.

 

Notify Occupants:

• Post warning signs in custodial and maintenance areas where ACM is present.

• Notify custodians and maintenance staff of the types and locations of ACM.

• Notify vendors and contractors who may disturb ACM, of the presence of ACM in their work area (i.e. Plumbers, heating contractors, computer contractors). A sample is enclosed and posted at www.mass.gov/dols/ahera.

• Distribute an annual notification to all building occupants regarding the availability of the management plan. (a sample notification is enclosed and posted at www.mass.gov/dols/ahera).

 

Maintain Records:

The school shall maintain and update its Management Plan to keep it current, including:

• Asbestos Abatement records and clearance air sampling reports.

• O&M Activities: maintain documentation in the Management Plan.

• Periodic Surveillance: maintain documentation in the Management Plan.

• Bulk Sampling Reports.