Dale Wilson, CIH, LEED AP, Sr. Project ManagerSummer vacation is what every student dreams of...no school! While this may be true for the educational calendar, summer is the time of year when schools generally address their big asbestos issues. So instead of students and teachers filling the classrooms, they are replaced by a range of very specific professionals that are required to get the job done: the Local Education Agency (LEA), Designated Person, Inspectors, Management Planners, Remediation Contractors, and Asbestos Safety Technicians/Project Monitors.
Regulations for Asbestos in Schools
Asbestos in schools is regulated by the Asbestos Hazard Emergency Response Act (AHERA), promulgated by the US Environmental Protection Agency (EPA) in 1986. AHERA applies to all public and private elementary and secondary schools in the United States and requires LEA’s to identify, evaluate and control Asbestos Containing Building Materials (ACBM). At each school a “Designated Person” is given the responsibility to be in charge of the school's asbestos control program. The regulation is meant to protect children, as health issues from asbestos are not immediate, but can take decades to appear. The EPA explains on their website:
“Although asbestos is hazardous when inhaled, the risk of exposure to airborne fibers is very low. Therefore, removal of asbestos from schools is often not the best course of action. It may even create a dangerous situation when none previously existed. The Environmental Protection Agency (EPA) only requires removal of asbestos to prevent significant public exposure during demolition or renovation. EPA does, however, require an in-place, pro-active asbestos management program for all LEAs in order to ensure ACBM remains in good condition and is undisturbed by students, faculty, and staff.”
Identifying the Problem
The first task of managing asbestos correctly is identifying the location, quantity, and condition of ACBM. This responsibility is assigned to an AHERA-accredited Building Inspector. In addition to conducting the initial inspection, Building Inspectors must also re-inspect ACBM every three years. Six- month periodic surveillances are also conducted by a Building Inspector or other individual familiar with the inspection results, such as a member of the custodial staff. Collectively, the inspections and surveillances help maintain the accuracy of the inventory and identify any damage that requires a response action.
Developing a Plan
The inspection and surveillance results are used by AHERA-accredited Management Planners to develop an Asbestos Management Plan specific to each school. The Asbestos Management Plan uses the inventory to assess the likelihood of disturbance and recommend appropriate response actions.
Plan Implementation
Because children are not occupying the school in summer, it is the perfect time to implement response actions that would otherwise disrupt the educational process and present risk. Response Actions include the following activities:
- Removal
- Repair
- Encapsulation
- Enclosure
- Operations & Maintenance (O&M)
Response actions are undertaken by licensed firms who employ AHERA-accredited supervisors and abatement workers. Many states also require the companies to have a state-issued license for asbestos abatement work and supervisors and workers must carry performance identification permits. In many states, oversight of the work is done by a trained professional such as NJ’s Asbestos Safety Technician (AST)/Project Monitor who works for an independent firm (not the abatement company) to ensure that proper procedures are followed, and performs on-going air sampling and final clearance sampling to document that the response action does not release asbestos particles into the school. After all, the goal of the response action is to make conditions inside of the school safe!
The AHERA Regulations turned 25 this year. I f you want to find out more about asbestos and the regulations that control its presence in your local schools, visit the EPA website or review this list of FAQ. Asbestos Management Plans are required to be available to the public, and you can receive a copy from your school district just by asking.
Parents, have you heard about an asbestos removal or management plan in your school district? To learn more about Asbestos management in schools, the EPA publishes an informative “The ABCs about Asbestos in Schools” If you are part of an asbestos management team, do you have some reassuring information to share with concerned parents?