Environmental Engineering Reference
In-Depth Information
(3) visual inspection and assessment of the physical condition of friable
ACM; (4) development and implementation of asbestos management plans;
(5) identification of a designated person in an LEA responsible for the
implementation of asbestos management plans; and (6) minimum training
requirements for custodial staff and maintenance workers who might dis-
turb asbestos.
AHERA required all schools K-12 to be inspected by an accredited
inspector. It also required the preparation and submission of an asbestos
management plan for each building to an authorized state agency by October
2, 1988 (postponed to May 1989).
It was widely assumed in the late 1980s that USEPA would subsequently
develop and promulgate rules requiring the inspection of other nonresiden-
tial, nonindustrial buildings for asbestos. USEPA evaluated the much larger
problem (in terms of the number of buildings that would be involved) of
asbestos in public-access buildings. The review indicated that ACM was
present in such buildings, but was less prevalent than in schools. USEPA
officials, for a variety of reasons, deferred action on requiring AHERA-type
inspections and management plans in nonresidential, non-school buildings
indefinitely.
Under authority granted under AHERA, USEPA extended OSHA asbes-
tos worker protection rules (which are limited to construction and general
industry) to public employees. As a consequence, school employees were
provided OSHA worker protection for the first time.
Under AHERA, USEPA required that all major abatement projects that
disturb ACM must be visually inspected and pass a clearance standard of
0.01 f/cc (fibers per cubic centimeter) based on aggressive sampling prior
to the completion of asbestos abatement projects. Though only required for
schools, these clearance standards have become the accepted practice in
asbestos abatement activities in buildings subject to subsequent use.
In 1988, more than a decade after the promulgation of the USEPA
NESHAP, which required removal of friable ACM before renovation or
demolition, OSHA promulgated a construction industry standard for asbes-
tos. It was designed to protect asbestos abatement workers as well as work-
ers in other asbestos-related construction trades. Covered activities included
removal, encapsulation, enclosure, repair/maintenance, transportation, dis-
posal, and storage of ACM. This standard required use of administrative
and engineering controls and respiratory protection to protect workers from
excessive asbestos exposures. Administrative controls included the demar-
cation of regulated areas where abatement activities were to occur and
access restriction for nonabatement personnel. Abatement activities
required a “competent person” who was capable of identifying asbestos
hazards and selecting appropriate control strategies for reducing asbestos
exposure, and who had the authority to take prompt corrective measures
to eliminate asbestos hazards to workers and building occupants. Engineer-
ing controls included use of negatively pressurized enclosures/contain-
