The following items are required components of the asbestos management plan.
REGULATORY CORRESPONDENCE
Any correspondence with the Texas Department of State Health Services (Notice of Noncompliance letters) should be maintained in the plan.
OPERATIONS & MAINTENANCE PLAN (O&M PLAN)
An Operations and Maintenance (O&M) program is a formulated plan of training, cleaning, work practices, and surveillance to maintain asbestos-containing materials within buildings in good condition. The goal is to minimize the exposure of all building occupants to asbestos fibers.
ASBESTOS DESIGNATED PERSON
Every district must appoint an Asbestos Designated Person who will be responsible for the school’s asbestos program. Per AHERA regulations, this individual must be trained on the health effects of asbestos; identification, detection, and assessment of ACM; options for controlling ACBM; asbestos management plans; and relevant federal and state regulations concerning asbestos. Our accredited Asbestos Designated Person training course meets these requirements. The training certificate and a signed verification statement should be included in the plan.
Although refresher training is not currently required, we recommend taking this course every few years to stay informed about asbestos-related requirements and best practices. View the training schedule and register here.
ASBESTOS AWARENESS TRAINING FOR EMPLOYEES
This training is to be administered to all maintenance and custodial staff who may work in a building that contains Asbestos Containing Building Materials (ACBM). This includes part-time and contracted staff, as well as any other employees who may encounter ACBM in the routine course of their work or have cleaning in their job description (electricians, heating/air conditioning engineers, IT staff, plumbers, kitchen staff, etc).
New employees must be trained within 60 days of hire. There are no refresher requirements for this training.
PUBLIC NOTICE
A copy of the annual public notice regarding the condition of asbestos materials needs to be included in the management plan. A recommended location for this statement is in the Student and Employee Handbooks. Each year, add a dated copy of the notice to the plan.
A Short Term Worker Notification should also be made available to all outside contractors working at the district.
BUILDING INVENTORY LIST
A list of all buildings owned, leased, or operated by the district must be included in the plan.
HOMOGENEOUS AREAS LIST
A list of all materials that have been tested for the presence of asbestos.
BUILDING SUMMARIES/HOMOGENEOUS AREA REPORTS
These documents contain detailed building information and sampling information for the materials listed on the Homogeneous Areas list.
6-MONTH PERIODIC SURVEILLANCE
The 6-Month Surveillance is conducted by the Asbestos Designated Person every June and December and is simply a visual observation of the known or assumed asbestos-containing material in the district.
3-YEAR REINSPECTIONS
Like the 6-Month Surveillance, the 3-Year Reinspection is a visual observation and assessment of the known or assumed asbestos-containing material in the district. Unlike the 6-Month Surveillance, the 3-Year Reinspection must be conducted by a licensed asbestos inspector every three years.
LABORATORY ANALYTICAL RESULTS
Copies of all sample reports/lab results for materials tested throughout the district should be maintained in the plan.
ORIGINAL 1988 AHERA PLAN
All districts were required to have an original Asbestos Management Plan created around 1988. A copy of this original inspection report should be maintained in your plan.
RESPONSE ACTIONS
Copies of abatement records or any other response actions for asbestos-containing building material that may have been removed, repaired, enclosed, or encapsulated should be included in the plan.
INSPECTION REQUIREMENTS
All buildings owned, occupied, or leased by the district should be surveyed for the presence of asbestos-containing materials. Federal and state regulations (AHERA & TAHPA) require that all suspected building materials (anything other than wood, metal, or glass) must be presumed to contain asbestos unless proven otherwise by laboratory analysis. This includes materials such as mastics, cove base, floor tile, linoleum, sheetrock, joint compound, wall texture, ceiling material (tiles and spray-on), sink coatings, window glazing/caulking, HVAC duct insulation, duct mastic, thermal system (pipe) insulation, acoustical and decorative plaster, etc. Even new materials installed in the present day are considered “suspect materials” and could contain asbestos. The only way to verify a material does not contain asbestos is to have a licensed asbestos inspector sample it for laboratory analysis.
NEW CONSTRUCTION
Proper documentation should be included in the management plan on all new buildings, portables, additions, and renovations.
The district may obtain an exclusion letter signed by the architect or project engineer responsible for the construction of the school building in lieu of sampling materials. This letter will suffice for federal AHERA regulations; however, the materials must be sampled prior to renovation/demolition per state TAHPA regulations.
