MassDEP Asbestos Regulation (310 CMR 7.15) 2-day Building Officials Educational Academy May 10, 2018 Taunton Holiday Inn, Taunton, MA

Asbestos Regulation Revisions (310 CMR 7.00 and 7.15) Took effect on June 20, 2014 Amended definitions (310 CMR 7.00) Replaced Asbestos Regulation (310 CMR 7.15) Goals: Clarify definitions and requirements Codify material-specific work practices Better align with EPA Asbestos-NESHAP After more than 10 years in the making, the MassDEP asbestos regulation were revised June 20, 2014. This represented the first major re-write in 30 years or so. The overarching goals of the MassDEP Asbestos Regulation revisions enacted in June 2014 were to clarify definitions and regulatory requirements; incorporate policies and guidelines that were previously outside the regulation; and better align the state program with the EPA Asbestos National Emissions Standards for Hazardous Air Pollutants (or NESHAPs). It is also worth noting that the overlap with the State Sanitary code affords an opportunity for inter-agency cooperation with local Boards of Health. State Sanitary Code requires owners of residential buildings to repair or remove damaged asbestos containing materials in accordance with MassDEP and DLS regulations.

What Stays the Same? Performance standards: Program structure: Prevent air emissions Protect public health, safety and environment Program structure: Notification prior to work Asbestos abatement work practice standards Asbestos-containing waste material must be properly managed DLS requirements have not changed: Worker qualifications/training Work practices/worker safety Final clearance monitoring The MassDEP asbestos regulation focuses on renovation and demolition work involving materials that contain asbestos. The regulation’s two fundamental performance standards for these activities have not changed. Whenever you need to disturb asbestos-containing material, you will still need to: Prevent releases of asbestos fibers to the air; and Protect public health, safety and the environment. The essential elements of the program remain unchanged. These elements reflect the typical life-cycle of an asbestos abatement project. Notify MassDEP and DLS before starting work. Notifications filed with MassDEP are shared with DLS so you only need to notify once Follow specified work practices when conducting the abatement activities Manage asbestos containing waste material properly Please note: DLS’s regulations have not changed. The graphic on the right side of the slide shows an image of the first page of the AQ-04 Asbestos Notification Form (ANF-001). This notification is required to be submitted 10 working-days prior to any asbestos abatement activities by both the MassDEP and DLS.

What’s New? (1 of 2) Pre-Demolition/Renovation Survey Identify all asbestos containing material (ACM) and Suspect ACM Notification Exemptions Small jobs on cement shingles & siding, floor tiles, and wallboard/joint compound (non-friable ACM only) Homeowner working on non-friable ACM in own home All jobs must follow applicable work practices Material-specific work practices Asphalt roofing, window caulking, cement shingles, floor tile, gypsum wall-board In the next two slides, I will highlight a few of the new elements of the revised regulation. Pre-Demo/Reno Survey: While the requirement to conduct a pre-demo/reno survey is new to the MassDEP regulation, it is not new to this type of work. Since 1990, EPA’s Asbestos NESHAP regulation has required a “thorough inspection” before starting any demolition or renovation activities. This inspection must identify all asbestos-containing material in the area that will be disturbed by the planned work. MassDEP’s regulation describes who can conduct the “pre-demo/reno” surveys and what needs to be documented in a written survey report. Notification Exemption for Small Jobs: The revised regulation provides notification exemptions for a limited universe of small jobs involving certain materials. Specifically, the following threshold quantities apply: < 100 sf of asbestos-cement shingles, siding, panels <100 sf of asbestos floor tile and related mastics, or < 32 sf of gypsum wallboard and related joint compound In addition, certain work on asbestos-containing material at an owner-occupied single family residence does not have to be reported to MassDEP. This exemption only applies if the owner is working exclusively on non-friable asbestos-containing material, does not cause it to become friable, and does the work himself/herself (does not engage a contractor). By “non-friable”, we mean material that when dry, cannot be crumbled, shattered, pulverized or reduced to powder by hand-pressure and that has not been subjected to sanding, grinding, cutting or abrading and has not been crumbles, shattered, or pulverized by mechanical means such as, but not limited to, the use of excavators, bulldozers, heavy equipment or power and/or hand tools. Aside from these limited notification exemptions, the notification requirements continue to apply as they always have in the past –that is - any activity that disturbs or removes any quantity of asbestos-containing material requires notification 10-working days prior to starting the job. Regardless of whether a job qualifies for one of the new notification exemptions, all asbestos abatement activities must be performed in a manner that is consistent with the applicable work practices specified in the regulation. Generally speaking, applicable work practices for the materials that are now exempt from notification include the following: Wetting work surfaces with amended water (which means water with soap/surfactant added) to prevent air emissions Carefully lowering roofing and siding shingles to the ground Spreading tarp or plastic sheeting where debris may fall and cleaning up at end of each shift Properly packaging waste material in leak-tight, sealed and labeled waste containers Disposing of waste material at a solid waste facility that has a “Special Waste” permit to accept asbestos waste. Material Specific Work Practices: As I mentioned at the outset, one of the goals of the revised regulation was to provide greater regulatory certainty by codifying established material specific work practices that were previously found either in policy or guidance. In this regard, new sections were added to the regulation to address the following material-specific work practices: Asphaltic roofing and siding materials Window glazing and/or caulking compounds Cement shingles, siding and panels Floor tile Gypsum wall-board and joint compound Asbestos-Cement Pipe is under consideration (Public comment period May – July, 2016)  

What’s New? (2 of 2) Non-Traditional Asbestos Abatement Work Practices (NTs) Permits Formal permit to conduct “alternative work practices” Only allowed in six specific scenarios Post-Abatement Visual Inspection Required at end of asbestos work Ensures that no visible ACM debris remains Waste Shipment Record (WSR) Forms Aligns with EPA NESHAP Record-keeping requirements Owner/operator to maintain pre-demo/reno survey and WSR for minimum of 2-years Non-Traditional Asbestos Abatement Work Practices: Non-Traditional Asbestos Abatement Work Practices were historically called Alternative Work Practices This now requires a formal permit application (“Application for Non-Traditional Asbestos Abatement Work Practice Approval” BWP AQ-36) and payment of a $600 fee, if applicable . Post-Abatement Visual Inspection The post-abatement visual inspection is required for all jobs; it comes at the end of the asbestos abatement activities. It ensures that no visible asbestos-containing debris remains on any of the work surfaces. Waste Shipment Record Forms The Waste Shipment Record is another example where the revised regulation incorporated an existing EPA NESHAP requirement. All shipments of Asbestos Containing Waste Material (or “ACWM”) must now be accompanied by a Waste Shipment Record that conforms to a template posted on the MassDEP Asbestos website. Record-keeping requirements The revised regulation requires that the owner/operator keep copies of the pre-demo/reno survey report and Waste shipment Record for at least 2 years. If MassDEP does a compliance inspection, the inspector is likely to ask to see these documents and will rely on them, in part, to determine that the asbestos-containing materials were properly managed.

Pre-Demo/Reno Survey Identify and properly manage materials that contain asbestos Required before ANY demolition/renovation project Exception: Owner of a single- family house conducting work on non-friable asbestos themselves in the home they live in DLS-certified Asbestos Inspector must conduct “thorough” inspection Identify all material containing asbestos in any amount (including <1%) in area to be worked on Destructive survey (wall cavities, floor layers, above ceilings) Use of approved analytical methods Keep the Survey Report for at least two years The requirement for a pre-demo/reno survey applies to ANY project (any structure or any age) with the potential to disturb suspect asbestos-containing material. Before disturbing the material, a DLS-certified asbestos inspector must conduct a “thorough inspection” – that is, to identify the presence, location and quantity of any ACM or Suspect ACM that contains asbestos in any amount. What passes as a “thorough inspection” could be one thing for a manufactured material where product content is fairly consistent (for example VAT tile, asphalt roofing material, cement shingles/siding, etc.);but, it could be different for a material with inconsistent levels of asbestos content caused by contamination with naturally occurring asbestos minerals (such as vermiculite insulation) or hand-mixed compounds (like plaster). In the former case: a limited number of random samples may suffice, But in the latter case: many more samples may be needed, particularly to target areas where asbestos is likely to have accumulated. To satisfy the requirement to “thoroughly inspect”, the survey must identify, representatively sample, and assess suspect ACM located in all accessible and inaccessible areas that will be breached or otherwise affected by demolition or renovation activities, including, but not limited to wall cavities, areas above ceilings and under/between multiple layers of flooring. Once enough samples have been collected, they will need to be analyzed by a qualified laboratory that follows an approved analytical method, to find out definitively whether the material contains asbestos or not. The only analytical method recognized by MassDEP is the EPA Method for the Determination of Asbestos in Bulk Building Materials which goes by the report number EPA/600/R-93/116.   Any Suspect ACM that is not sampled and analyzed MUST be presumed to be ACM, identified on the written survey report as ACM, and managed as ACM (i.e. it must be abated prior to demolition/renovation). The pre-demo/reno survey is central to assuring compliance with all federal, state and local regulations. The survey provides valuable information: It will determine whether notification to MassDEP/DLS is required; It will determine whether you will need to follow the applicable work practices to remove asbestos-containing material safely;; It will determine whether you will need to engage a licensed contractor It will help with sequencing project tasks ( by identifying which materials contain asbestos and need to be removed before your demolition or renovation can start);It provides a basis for developing a waste management plan that can help you minimize volume and cost of material that needs to be disposed of as ACWM; and, It provides the information you will need to comply with waste packaging, transportation and disposal requirements. The survey requirement is really for the best interest of all involved, including the owner/operator. The survey report must be maintained on file and redily available for at least 2 years.

“Suspect Asbestos-Containing Material” MassDEP Definition (310 CMR 7.15(1)) Products reasonably likely to contain asbestos based on appearance, composition, and use Includes (but is not limited to): Non-fiberglass insulation (e.g., pipe, boiler, duct work) Mastic (flooring or cove base adhesive or damp-proofing) Spray-on fire proofing Vinyl floor and wall tiles Asphalt roofing and siding (shingles, roofing felts, tars, etc.) Vinyl sheet flooring Cement/transite shingles Wallboard Joint Compound Cement/transite pipes Plaster Cement sheets (corrugated and decorative) Ceiling tiles Cloth vibration dampers or duct work There is a common misperception that structures built after 1980 are unlikely to contain any asbestos. Nothing could be further from the truth. This confusion likely stems from at least two separate sources: 1) the erroneous belief that all asbestos- containing materials were banned in the 1980s; 2) the OSHA definition of Presumed Asbestos Containing Material (PACM) for suspect materials in structures built prior to 1980. Asbestos-containing materials are routinely found in many buildings, even those built after 1980. The table in this slide provides a partial list of some of the suspect materials found in the home that may still contain asbestos. So contractors and homeowners doing demolition or renovation activities need to be attentive to the likelihood of coming across suspect asbestos-containing materials, no matter the age of the structure. Broadly speaking, the definition of “suspect asbestos- containing material” includes any product reasonably likely to contain asbestos based on its appearance, composition and use. This slide lists a few of the common types of suspect ACM that can be found in buildings.

This graphic illustrates some, but not all, of the typical locations where the most common asbestos-containing materials are found in a home. Some examples of materials not shown include: base cove adhesive, flooring mastic, foundation asphaltic damp-proofing material, wall-board /joint-compound systems, vermiculite attic insulation etc. MassDEP Reference: Public Health & Safety, Inc.

Asbestos Product Bans 1970’s EPA banned certain uses; and CPSC banned certain products: Spray applied fireproofing/insulation (NESHAP) Spray applied surfacing materials (NESHAP) Asbestos pipe insulation and asbestos block insulation on facility components, such as boilers and hot water tanks (NESHAP) Asbestos in artificial fireplace embers (CPSC) Asbestos in wall patching compounds (CPSC) 1989: TSCA banned manufacture, importation, processing and distribution in commerce of most asbestos products 1991: 5th Circuit Court of Appeals vacated TSCA Rule; most of original ban overturned, except Corrugated paper Rollboard Commercial paper Specialty paper Flooring felt New uses So let’s spend a little time to dispel the myth that all uses of asbestos have been banned… Regulatory history of asbestos bans In 1973, EPA banned spray-applied surfacing asbestos-containing material for fireproofing/insulating purposes. See National Emission Standards for Hazardous Air Pollutants (NESHAP) at 40 CFR Part 61, Subpart M In 1975, EPA banned installation of asbestos pipe insulation and asbestos block insulation on facility components, such as boilers and hot water tanks, if the materials are either pre-formed (molded) and friable or wet-applied and friable after drying. See National Emission Standards for Hazardous Air Pollutants (NESHAP) at 40 CFR Part 61, Subpart M In 1978, EPA banned spray-applied surfacing materials for purposes not already banned. See National Emission Standards for Hazardous Air Pollutants (NESHAP) at 40 CFR Part 61, Subpart M In 1977, the Consumer Product Safety Commission (CPSC) banned the use of asbestos in artificial fireplace embers and wall patching compounds. (See 16 CFR Part 1305 and 16 CFR 1304) In 1989, the EPA issued a final rule under Section 6 of Toxic Substances Control Act (TSCA) banning most asbestos-containing products. However, in 1991, this rule was vacated and remanded by the Fifth Circuit Court of Appeals. As a result, most of the original ban on the manufacture, importation, processing, or distribution in commerce for the majority of the asbestos-containing products originally covered in the 1989 final rule was overturned. (i.e, products no longer subject to the 1989 TSCA ban because it was overturned) In 1990, EPA prohibited spray-on application of materials containing more than 1% asbestos to buildings, structures, pipes, and conduits unless certain conditions specified. See National Emission Standards for Hazardous Air Pollutants (NESHAP) at 40 CFR 61, Subpart M are met. Reference: https://www.epa.gov/asbestos/us-federal-bans-asbestos

Asbestos products not banned The manufacture, importation, processing and distribution in commerce of these products are not banned (partial list): Cement corrugated sheet Clutch facings Cement flat sheet Friction materials Clothing Disk brake pads Pipeline wrap Drum brake linings Roofing felt Brake blocks Vinyl floor tile Gaskets Cement shingle Non-roofing coatings Millboard Roof coatings Cement pipe Adhesives/mastics Automatic transmission components In 1989, the EPA issued a final rule under Section 6 of Toxic Substances Control Act (TSCA) banning most asbestos-containing products. However, in 1991, this rule was vacated and remanded by the Fifth Circuit Court of Appeals. As a result, most of the original ban on the manufacture, importation, processing, or distribution in commerce for the majority of the asbestos-containing products originally covered in the 1989 final rule was overturned. See 40 CFR 763 Subpart I. Reference: https://www.epa.gov/asbestos/us-federal-bans-asbestos

Approved Analytical Method EPA Method for the Determination of Asbestos in Bulk Building Materials (EPA/600/R-93/116) specified by MassDEP to determine ACM (1% or more) Appendix D “Special-Case Building Materials” (e.g. cementitious products, viscous matrix products, vinyl materials, asphaltic roofing, miscellaneous [paints, coating, friction plates, gaskets, etc.]) May require additional sample treatment(s) and analysis beyond routine PLM AHERA survey allows older method – negative result may be suspect Once enough samples have been collected, they will need to be analyzed by a qualified laboratory that follows an approved analytical method, to find out definitively whether the material contains asbestos or not. The only analytical method recognized by MassDEP is the EPA Method for the Determination of Asbestos in Bulk Building Materials which goes by the report number EPA/600/R-93/116. Appendix D “Special-Case Building Materials” (e.g. cementitious products, viscous matrix products, vinyl materials, asphaltic roofing, miscellaneous [paints, coating, friction plates, gaskets, etc.]) Materials characterized by interfering binder/matrix, low asbestos content, and/or small fiber size may require that additional sample treatment(s) and analysis be performed beyond routine PLM analysis Appendix D of EPA/600/R-93/116 “Special Case Building Materials” suggests that for the dominantly non-friable materials covered by that Appendix, materials exhibiting characteristics of interfering binder/matrix, low asbestos content, or small fiber size may require additional sample treatment(s) and analysis beyond routine Polarized Light Microscopy (“PLM”). The Appendix provides examples of materials for which additional sample treatment and analysis should be considered: cementitious products (pipe, sheeting, etc.), viscous matrix products (adhesives, cements, coatings, etc.), vinyl materials (vinyl floor tile and sheeting), asphaltic roofing (shingles, roll roofing) and miscellaneous products (paints, coatings, friction plates, gaskets, etc).

Material Containing < 1% Asbestos Should be identified in the pre-demo/reno survey ACWM includes material containing any amount of asbestos (even <1%) If material with any asbestos gets mixed with non-asbestos C&D, all must be handled as ACWM Segregate, manage separately to reduce disposal costs e.g. for wallboard/joint compound removal; place poly on floor under work area; adequately wet material prior to, and all during removal; immediately package in sealed, leak-tight containers In Massachusetts, material that contains any amount of asbestos (even < 1%) is regulated. All materials that contain any amount of asbestos should have been identified during the pre-reno/demo survey. ACM identified by the survey needs to be abated before it is disturbed. Material containing less than 1% asbestos doesn’t need to be abated in accordance with work practices (and you don’t need to notify MassDEP before the abatement starts). But as concerns the waste material containing less than 1% asbestos, it is regulated and needs to be managed as ACWM. That means that the <1% material must be wetted from the moment you start to remove it and all during handling to minimize potential fiber release. Furthermore, we recommend the use of PPE. If you remove it carefully and keep it separated from your other non-asbestos construction or demolition waste, you can avoid contaminating your solid waste with asbestos, and can minimize the amount of material that has to be disposed of as ACWM. The MassDEP asbestos regulation requires that ALL ACWM is managed in accordance with the specified packaging, transportation, storage and disposal provisions. In simplest terms, material that contains asbestos in any amount (even < 1%): Has to be segregated and properly managed during demo/reno project It has to be packaged and labeled as ACWM And, it has to be disposed as “Special Waste” at a permitted solid waste management facility.  

“Spiral” of Non-compliance Failure to perform thorough asbestos survey is often first step down a path of non-compliance Cleanup of non-compliant activities requires NT Work Plan project delays and increased project costs All affected C&D debris must be disposed as ACWM Occupants often must be relocated during decon Civil administrative penalties may be imposed AG may seek civil or criminal charges

Liability extends to any and all parties who control activities OWNER/OPERATOR means any person who: (a) has legal title, alone or with others, of a facility or dumping ground; (b) has the care, charge, or control of a facility or dumping ground, or (c) has control of an asbestos abatement activity, including but not limited to contractors and subcontractors. (310 CMR 7.15(1) Definitions) Includes property owners, demolition/renovation contractors, insurance companies

Examples of Civil Administrative Penalties Assessed by MassDEP

Referral to Attorney General’s Office Certain cases are screened for referral to Attorney General's Office Criteria for referral to AGO: Magnitude of assessment Deliberate and/or willful intent Knowledge (i.e. party knows or should have known) AGO can pursue civil or criminal enforcement AGO not bound by MassDEP penalty assessment schedule Can assess penalties as allowed by statute – up to $25,000 per day per violation

Reminder of Construction/Demolition Notification Requirement Submit 10 working-days before start of construction or demolition of a building: Industrial/Commercial/Institutional Residential buildings with fewer than 20 units are exempt (EPA requires for demo of any residence >4 units) Use MassDEP form BWP AQ 06 Notification Prior to Construction or Demolition Prevent release of dust or other hazardous pollutants (e.g. asbestos) Notification form asks about: Asbestos survey Survey results Any asbestos abatement activities Helpful suggestions from regional asbestos program section chiefs: Requirement for a building construction/demolition project is pretty obvious. AQ06 needs to be specific to a single building location (i.e. address); the inspector needs to be able to identify which building is being worked on. When project involves an unoccupied, detached service structure, notification is required, but it can be included as part of the notification for the main building that it supports or is connected with. Requirement for renovation projects can be a bit more subjective and require one to apply the common sense rule – if the project is destructive in nature, involves large areas, or has the potential to liberate any dust or hazardous air pollutants, such as asbestos, notification is required. Examples include: Gutting a room Tearing down walls or ceiling Ripping up flooring NOT drilling holes to install fixtures, etc. Any time a project disturbs commercial or industrial facilities, there is the potential to liberate hazardous air pollutants, therefore AQ-06 notification is required. Concerning multi-family residential structures (e.g. triple deckers), no AQ-06 notification is required, but MassDEP Asbestos Regulation requires a Pre-Reno/Demo Survey. This is something Municipal Building official could ask about that would greatly benefit public health; Turn-over renovation of triple deckers without a pre-reno/demo survey that ends up disturbing asbestos has been a problem this year in parts of the state.

Checklist for MassDEP Asbestos Regulation Survey/Removal Requirements Was structure, or portion of structure where work will be performed, thoroughly surveyed by DLS-certified asbestos inspector prior to ANY demolition or renovation activity? Provide copy of survey report as proof of completion Survey requirements exemption: Owner of owner-occupied single family residence, doing work themselves and only on non-friable ACM. Did survey identify any ACM? If ACM identified, has it been removed? Provide copies of Asbestos Notification Form(s) (ANFs) and Waste Shipment Records (WSRs) as proof of abatement activity Notification exemptions: <100 s.f. of A-C shingles, siding, panels <100 s.f. of floor tile and related mastic <32 s.f. of gypsum wallboard/joint compound system Owner of owner-occupied single family residence, doing work themselves and only on non-friable ACM (except >100 s.f. of A-C shingles, siding or panels) Note that projects that qualify as exempt from notification still must: Follow applicable work practices Complete a WSR for any waste shipped for disposal (disposal only notification will apply)

Checklist for MassDEP AQ06 Notification Prior to Construction or Demolition Does the project involve an institutional, commercial or industrial structure, or any portion of such a structure? Does the project involve of a residential structure, or any portion of such a structure, with more than 20 dwelling units? Does the project involve the demolition of a residential structure with more than 4 dwelling units? If yes to any of the above questions, then the owner/operator is required to submit an AQ06 Notification Prior to Construction or Demolition (https://www.mass.gov/how-to/aq-06-constructiondemolition-notification). 10 working-days (two weeks) prior to start of any activity

Asbestos Project Look-up Tool The Asbestos Project Look-Up tool is a useful web resource that anyone can use to see whether a notification has been filed for an abatement project at any given address. Notifications filed through eDEP are added to the look-up tool automatically. Notifications filed on paper forms are added to the database within a day or two of their receipt by MassDEP. The look-up tool can be accessed from the MassDEP website at the links listed on the slide. https://eeaonline.eea.state.ma.us/portal#!/search/asbestos

For More Information: MassDEP Asbestos Regulation – June 2014: http://www.mass.gov/eea/docs/dep/air/laws/asbestosreg14.pdf Questions about Asbestos Regulations and Policy: Mike Elliott, email: michael.elliott@state.ma.us, telephone: 617/292-5575 Regional MassDEP Asbestos Contacts: Central: Gregg Levins (gregory.levins@state.ma.us, 508/767-2768) Northeast: John Macauley (john.macauley@state.ma.us, 978/694-3262) Southeast: Cynthia Baran (cynthia.baran@state.ma.us, 508/946-2887) Western: Marc Simpson (marc.simpson@state.ma.us, 413/755-2115) Find your region: https://www.mass.gov/service-details/massdep-regional-offices-by-community Asbestos Project Lookup Tool: https://eeaonline.eea.state.ma.us/portal#!/search/asbestos MassDEP Asbestos Website: http://mass.gov/dep/asbestos If you desire further detailed information, this slide provides links to relevant regulation and guidance documents. Or, you can always call one of us on the MassDEP program staff with specific questions by phone or email at the contact information listed on the slide; For information or help with filing asbestos forms, eDEP or the asbestos database, you can submit you question by email to the Bureau of Air & Waste eDEP mailbox. For questions about permits or compliance at a specific jobsite, feel free to contact one of the regional staff in the appropriate MassDEP region for the town in which the project is located. If you’re not sure which region of MassDEP your town is located in, you can click on the “Find Your Region” link. Thank you for your attention during this overview of the revised asbestos regulation. We hope this slide presentation was helpful, and we welcome your feedback.

Massachusetts Department of Labor Standards 2-day Building Officials Educational Academy May 10, 2018 Taunton Holiday Inn, Taunton, MA

Commonwealth of Massachusetts Department of Labor Standards The Department of Labor Standards (DLS) Asbestos Program is responsible for the regulation of occupational asbestos exposure in the Commonwealth. The Program works with employers, employees, unions and state and local agencies to create healthier and safer work conditions for Massachusetts workers through site visits, and technical information. The Program aids in the coordination of OSHA, EPA and Multi-State regulatory authorities along with the North Eastern U.S. States (CONES) in the common goal of protecting the public from long term damage from excessive asbestos exposure

DLS Asbestos Responsibilities Delegated from US EPA: Model Accreditation Plan (MAP) Licensing of : Training Providers Contractors Supervisors Workers Consultants Inspectors Management Planners Project Monitors Project Designers Asbestos Analytical Services (Labs) Asbestos Hazard Emergency Response Act (AHERA) Pursuant to the Asbestos Hazard Emergency Response Act (AHERA), the Asbestos-Containing Materials in Schools rule requires local education agencies to inspect their school buildings for asbestos-containing building material, prepare asbestos management plans and perform asbestos response actions to prevent or reduce asbestos hazards. Public school districts and non-profit private schools, including charter schools and schools affiliated with religious institutions (collectively called local education agencies) are subject to the rule’s requirements. Oversite Inspection of K-12 Schools in Mass.

The Removal Containment or Encapsulation of Asbestos 453 CMR 6.0

Asbestos Sampling Bulk Sampling Air Sampling Must be taken by an accredited certified inspector following approved methodology Must be analyzed by an accredited certified laboratory following approved methodology Air Sampling Final part of abatement, following thorough visual inspection to determine if the job is complete. Air sampling determines completeness of abatement activity before containment is removed

Air Sample (PCM) Slide Examples

Bulk Sample (PLM) Samples

www.mass.gov/dols Contact DLS: Patricia E. Sutliff, Industrial Safety & Health Inspector Investigations and Enforcement Unit Department of Labor Standards Charles F. Hurley Building 19 Staniford Street, 2nd Floor Boston, MA 02114 Tel: (617) 626-6979 Fax: (617) 626-6965