Operations & Maintenance Plan Requirements for Schools with Asbestos

The Maine Department of Environmental Protection (DEP) has been delegated by the U.S. Environmental Protection Agency to conduct periodic Asbestos Hazard Emergency Response Act (AHERA) compliance inspections in Maine 's non-profit school systems. AHERA requirements are designed to prevent asbestos hazards in schools. The purpose of the DEP's program is to monitor Local Education Agency (LEAs) compliance with AHERA requirements, and to provide compliance assistance to LEAs where necessary.

AHERA Background

AHERA was enacted in 1986. The regulation requires LEAs to identify the location of asbestos-containing materials, to develop Management Plans to manage properly these materials, and to take appropriate actions to control the release of asbestos fibers in their buildings. In addition to the original inspection, the regulation requires that LEAs conduct both 6-month periodic and 3-year annual re-inspections to reassess the condition of the asbestos-containing materials. Other requirements include providing asbestos awareness training to school staff, designating and training an individual (the Designated Person) to ensure that the LEA's AHERA requirements, including an Operations and Maintenance Plan (O&M), are implemented properly for each school.

Department Compliance Program

The Department conducts approximately 45 AHERA-related compliance inspections in schools annually. Specifically, these compliance inspections include a review of the following:

• Name of Designated Person;
• Date and name of the inspector conducting/developing the original AHERA Inspection/Management Plan;
• Whether 6-month periodic and 3-year annual re-inspections were conducted;
• Whether asbestos awareness training was provided to school staff;
• Whether accredited persons designed and conducted asbestos response actions; and
• Whether the LEA has implemented an Operation and Maintenance program.

When non-compliance with the AHERA-requirements are noted, the Department will issue a Notice of Non-Compliance (NON) to the LEA. A common Notice of Non-Compliance that the Department has issued pertains to a failure to implement or develop an O&M Plan.

Operations and Maintenance Plan Requirements 

It is important that each LEA implement an O&M Plan in each school. It documents that the LEA has in place a system that ensures that daily activities that have the potential to impact asbestos-containing materials are done safely. It also sets forth the training requirements for maintenance personnel that conduct small-scale short duration activities and establishes a protocol for responding to uncontrolled or unintentional disturbances of friable asbestos-containing materials. Implementing an O&M Plan will help ensure that the LEA has in place a program of work practices that will maintain asbestos-containing materials in good condition and prevent further release by minimizing and controlling asbestos-containing material disturbance or damage. Your LEA may elect to develop its own O&M Plan, or may choose to hire an accredited asbestos professional to provide this service for you.

Elements of an Operations & Maintenance Plan

The Asbestos in Schools Rule, commonly referred to as AHERA, requires that whenever friable asbestos is present in a school building, the Local Education Agency (LEA) must develop and implement an Operations and Maintenance (O&M) Plan. An O&M Plan is comprised of the following elements:

I. Worker Protection Program

LEA's are required to ensure prior to the implementation of an O&M Plan that all members of its maintenance and custodial staff who may work in a building that contains asbestos receive training. New custodial and maintenance employees have to receive training within 60 days of their employment.

The worker protection training program contains two components:

• 2 hr general awareness training for all maintenance and custodial staff; and
• 14 hr additional training for all maintenance and custodial staff who conduct activities that result in the disturbance of asbestos-containing material (acm).

2-hour Awareness Training

This training is required for all maintenance and custodial staff whether or not they are required to work with asbestos. It covers the following topics:

• General information regarding asbestos and its uses
• Information on health effect associated with asbestos
• Locations of asbestos within each school building they work in
• The name and telephone number of the LEAs Designated Person
• How to recognize damaged, deteriorated, delaminated asbestos

14-hour Additional Training

This training is required for all maintenance and custodial staff who conduct activities that result in the disturbance of acm. These activities, referred to as small-scale, short-duration activities generally involve the repair, or sometimes the removal (using the glove bag methods) of, no more than 3 feet of friable acm. It is important to understand that this training is only required if your LEA intends to have its maintenance staff perform small-scale, short-duration activities , ie activities that result in the disturbance of acm. This additional training is intended to meet the requirements of 40 CFR Subpart G, Asbestos Abatement Projects, Worker Protection, and covers the following topics:

• Proper handling of asbestos;
• Information on the use of respiratory protection;
• Information on federal asbestos regulations that apply to schools; and
• Hands on training in the use of respiratory protections and good work practices.

It is important to note that the federal regulation referred to above requires that any individual who performs O&M activities that disturb asbestos must be monitored under medical surveillance program.

II. Cleaning Program

Initial Cleaning

Following the completion of the original AHERA inspection, all areas of a school building where friable asbestos or damaged thermal system insulation was identified are required to be cleaned at least once. This cleaning must happen after the completion of the inspection and before the implementation of a response action other than O&M activities.

Additional cleanings

It is appropriate to implement an ongoing cleaning program in all areas of a school where asbestos is present; this helps reduce dust levels that may concentrate asbestos buildup. Use the following procedures:

• HEPA vacuum or steam clean all carpets;
• HEPA vacuum or wet-clean all other floors;
• Wet-clean all other horizontal surfaces, including window and door trim, baseboards, desks, shelves, bookcases, etc; and
• Use good cleaning practices such as always use separate buckets for cleaner and rinse water, change your rinse water often.
  

III. O&M Activities (small-scale short-duration)

Whenever a maintenance activity is performed that will disturb friable asbestos the following procedure must be implemented to protect building occupants:

• Restrict access into the area where the activity will occur either through scheduling or by physically isolating the work site;
• Post signs to prevent entry by unauthorized personnel;
• Shutoff any air handling systems and restrict other sources of air movement;
• Use work practices (wet methods, HEPA vacuuming, mini-enclosures, glove bags) to inhibit the spread of any released asbestos fibers;
• Clean all fixtures/components in the work area when done; and
• Place debris in a sealed leak-tight container.

Contact your Designated Person who will arrange to have the material disposed of properly through a licensed asbestos abatement contractor.

Please note that this activity is limited to less than 3 feet of asbestos. Any individual performing this activity must have received the specialized 14 hrs additional training referred to above.

IV. Maintenance activities other than small-scale short-duration activities

It is also important to note that any maintenance-related activity that involves disturbing greater than 3 feet of asbestos material must be designed by persons accredited to design response actions and conducted by persons accredited to conduct response action.

V. Fiber Release Episodes

Fiber release episodes, the falling or dislodging of friable asbestos, are divided into Minor Fiber Release Episodes (episodes involving less than 3 feet of acm), and Major Fiber Release Episodes (episodes involving greater than 3 feet of acm). Each requires a different response from the LEA as follows:

Minor Fiber Release Episodes

In case of a Minor Fiber Release Episode the LEA must:

• Restrict access into the area where the clean up will occur;
• Thoroughly wet the debris;
• Clean all surfaces, fixtures/components in the area; and
• Carefully repair the area of damaged acm with an appropriate compound such as plaster, spackling or fiberglass pipe insulation.

Major Fiber Release Episodes

In the case of a Major Fiber Release Episode the LEA must:

• Restrict access into the area where the clean up will occur; and
• The clean up/response action for any Major Fiber Release Episode must be designed by persons accredited to design response actions and conducted by persons accredited to conduct response action. Contact your Designated Person who will arrange for the clean up to occur.

If you have any questions on AHERA requirements for schools, please contact the MEDEP Asbestos Unit at (207) 287-7688 for assistance.