AHERA Designated Person Training Course
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Preview of EPA-mandated Designated Person Training Course (Three-Hour)
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AHERA Designated Person Training Course
- 1. Welcome to AHERA Designated Person Training Course Preview and Training Sample Presented by: Joseph Burley Freelance Enviro-Tech Services
- 2. Congratulations DP Candidates upon completion of this training you will… understand asbestos regulations for schools be able to effectively implement them and help maintain your school in compliance assure teachers, co-workers, parents, students and contractors that your school’s is safe from asbestos
- 3. Being a D.P. is a thankless job! DESIGNATED PERSON!
- 4. What are Your Responsibilities? (see AHERA 763.84) (a) ensure inspections, MPs, responses and O&M carried out (b) custodial and maintenance personnel trained (60 days) (c) annual notification to parents/workers (d) contractor notification (e) posted signage (f) MPs available
- 5. Asbestos-Containing Building Materials (ACBM) ACM found in or on interior structural portions of a school building interpretations include some “facility components” • firedoors • underground cement pipe • fume hoods • boiler gasket
- 6. Examples of non-AHERA materials • exterior window materials/roofing • room dividers • bunsen burner pads/lab gloves etc. • kiln bricks • blackboards (and glue) • auto brake dust • box of spare 9x9 floor tiles • electrical insulation
- 7. What is a Management Plan? 1. LEA/DP and Building Summaries (A-1 to A-2) 2. Inspections 3. Operations and Maintenance Plan 4. Response Action Records forms for in-house (f1a-f1b, f2a-f2b) minor fiber release (f-8) consultant report for large abatements and major fiber releases
- 8. Other Records to be Kept Worker/Parent notifications (A-3) pre-AHERA records? State acceptance letter training documentation (including yours!) exclusionary documentation for ACBM-free buildings (10/12/1988+) Your signed statement that the LEA’s general responsibilities have been or will be met
- 9. How do you facilitate contractor notifications?
- 11. Code Red Circumstances (AHERA Score 3 or “4 SD”) • SD surfacing (e.g. acoustic spray-on) • SD friable MM (e.g. ceiling panels) (1) Isolate the space and restrict access. (2) Remove…enclose or encapsulate. (3) No further discussion of the matter!
- 12. A Pounce on Prevention is Almost Worth a Sound Cure • prevent door strikes • protect ACBM from students • encapsulate and use shielding • protect SM and TSI in gyms • keep floors waxed • roof maintenance • consider vibration sources (music, mechanical, shop class, road traffic etc.)
- 13. Fate of Airborne Asbestos carpeting electronics (monitors etc.) drop ceiling and ductwork dust return air filter media ventilation exhaust air
- 14. Dust Control Under the General Industry standard, no visible dust should be present in spaces with asbestos • Wet hand cleaning or HEPA vacuum only • don’t confuse with “debris” Northern Dust Hare photo credit: NRDC
- 15. VAT Floor Stripping- Class IV if done right! • once per year • verify there is wax to strip • apply chemical stripper • keep floor wet • use white/light colored pads (darker more abrasive) • run stripping machines at low speed • wet mop or vacuum (HEPA ideal)
- 16. Sources of Regulator Referrals disgruntled employees error in State notification bidding contractor “sour grapes” asbestos litigation concerned parents reportable worker injury incidental regulator drive-by fires/catastrophic events
- 17. Renovations EPA NESHAP Regulation requires inspection by Accredited Michigan Building Inspector can use but can’t rely solely on AHERA data
- 18. Remodeling… “something less than a renovation” a t th “no structural alteration” e d s rn tor single tasks such as painting and wallpapering a w ula as a general rule of thumb- something you can do t yourself without being “handy or trade-skilled” or, B e g re e rp y! something that can be handled by one skilled R te trade i n ictl s tr
- 19. Can you remove asbestos just because you want to? ASBESTOS IN EDUCATIONAL FACILITIES (Mich. Act 51 of 1993) Asbestos shall not be removed unless : (a) Required under Section 112 … of Clean Air Act (NESHAP) (b) Required under Title II of the Toxic Substances Control Act (AHERA) (c) The exposure level of asbestos fibers exceeds 0.01 f/cc. (d) The cost of … operations and maintenance … exceeds the cost of removal (e) Removal of the material is incidental to normal maintenance or repair.
- 21. Asbestos rope, packings, gloves, cloth and floor tile now on sale! See your local Golden Resources distributer for one of these quality Chinese products
- 22. To Schedule a Designated Person Class please contact: Joseph Burley Freelance Enviro-Tech Services Oak Park, Michigan Phone (248) 721-8574 freelance.enviro.tech (at) gmail.com
Editor's Notes
- I would like everyone to go around the room and introduce themselves—tell what school you are from, what your job title is , tell us if you have any other asbestos training (eg Competent Person) and I want you to finish this sentence—the worst thing about being my school’s Designated Person is… (and if there is an upside mention that too!); mention any previous training or exp with asbestos (military etc)
- Its how the (AOD) recognizes their best people
- (e) “maint and regulated areas only required—advisory helpful (f) front office and duplicate at school district office—electronic ok (except signature pgs) (g) e.g. parent complained about damage in schools was a bidding contractor; MP bias (AKT) stands to benefit from recommendations
- a poorly worded and broad definition there are some grey areas—these regulations were implemented before they knew Asbestos was in such things as firehose, urinal caulk, window glazing etc.
- comment on canopy exception one of the inconsistencies in the regs--- kiln brick is excluded although boiler firebrick isn’t; also wall and ceiling carpet excluded
- response actions—3 yrs after last amount removed of each HA
- most schools pretty good about parent notifications but what about workers? When you had ABC Computer Networks come through your school and string ethernet cable through your ceilings do you have documentation that you gave them proper notice? Just askin’ don’t confuse ACBM-free with ACM-free
- see suggested generic attachment to request for proposal THIS INCLUDES COMPUTER SERVICE PERSONNEL—CAN YOU GUESS WHY? keep them in suspense and answer later?
- since the days of H-K we have gone from one or two listings per page to a data table format we hope you can read and understand the data tables
- here is what I call the code red circumstances “wahp wahp” interestingly TSI is omitted from this regulatory requirement in the words of the famous SNL economist Oscar Rogers “Just fix it!”
- you’ve heard the old saying… I know its lame to use old cliches light bulb analogy—consult the MP’er for major changes such as music rooms, shop class etc.
- so you have asbestos in your air (where does it go? besides what you filter out with your lungs) electronics act as electrostatic precipitators (air filters)—this is why in my opinion you need to provide notice to computer service techs the overall point being is once it settles to remove and avoid re-suspending : wet dusting and other careful cleaning methods called for (amosite=amended water)
- I think that’s might be the one with sharp pointy teeth
- so what is the most common Class IV-prob. FT
- anyone have renovations coming up? I have some ideas for you—just bulldoze the cafeteria—you don’t really need it do you? maybe install a helicopter pad instead…. maybe a trap door in your office? what? no room in your school budgets for stuff like that?
- for example: repainting a wall that is or might be asbestos doesn’t require a survey warning—refer back to case study
- EPA says yes go for it—legal challenges upheld; however Mi says uh-uh-uh not so fast! 1993 law limits (no fines or teeth) (d) is your loophole since it doesn’t say how you figure the costs over what period of time just wondering if there are any AOD schools close enough to go for it—my local public school is hanging on with just several hundred sq ft of FT
- this product was in the news about the same time as it was found in crayons—this MSDS was still current –pulled it off the internet in May of this yr
- see you next year or in school