Laschone P. Garrison State of Connecticut, Department of Public Health

Qualifications CT DPH Asbestos Program- 8 years BS/MS Biology OSHA HAZWOPER-(40 hour initial training & 8 hour yearly training) United States Environmental Protection Agency State Inspector Enforcement Awareness (10hours) Asbestos Inspector/Management Planner Training (40 hour initial training & 8 hour yearly training) Asbestos Project Monitor Training (40 hour initial training & 8 hour yearly training) Asbestos Project Designer Training (40 hour initial and 8 hour yearly training)

Applicable State Regulations Standards for Asbestos Abatement §§ 19a-332a-1 through 19a-332a-16 Licensure and Training Requirements §§ through Asbestos-Containing Materials in Schools §§ 19a through 19a

Applicable Federal Regulations Asbestos-Containing Materials in Schools 40 C.F.R., Part 763 *(AHERA) EPA Clean Air Act, National Emissions Standard for Hazardous Air Pollutants (NESHAP) 40 C.F.R., Part 61 Subpart M, asbestos

Current Status of Asbestos Industry Approximately 250 licensed asbestos abatement contractors Approximately 3,300 certified asbestos workers and supervisors Approximately 600 licensed asbestos consultants Each year there are approximately 3500 notified asbestos abatement projects in Connecticut Each year there are approximately 200 to 300 notifiable school projects in Connecticut.

How is Asbestos Regulated in Schools? “AHERA” (Asbestos Hazard Emergency Response Act), requires all K-12 schools to inspect for the presence of asbestos; to develop plans to manage asbestos in schools; and to carry out necessary response actions in a timely fashion. CT is a waiver state and enforces AHERA with its own regulations.

Asbestos Management Plan The Local Education Agency (LEA) shall develop, maintain, and update an Asbestos Management Plan (AMP) and keep a copy at the school; AMP must be submitted to DPH for review and approval

Asbestos Management Plan Common AMP implementation Violations No AMP update for new buildings at existing schools No implementation of AMP before school opens No approval of new/newly constructed buildings by DPH Not the same as environmental survey

Designated Person Each school system shall assign a “Designated Person” to ensure the responsibilities of the LEA are properly implemented. Common Violations No DP No statement of assurance No DP training No replacement DP

Inspections Schools must initially be inspected for the presence of asbestos materials by a DPH licensed inspector. All school buildings are inspected for friable and non-friable asbestos- containing building materials (ACBM). Samples are analyzed by DPH approved environmental laboratories.

Reinspections All known and suspected ACBM must be reinspected at least once every 3 years Results are used to implement response actions Common Violations Late 3-years Failure to note change in condition/failure to implement response action in timely manner

Periodic Surveillance The LEA must conduct periodic surveillance in each building under its authority at least once every six months after a management plan is in effect. This periodic surveillance must be documented in the management plan.

Common Periodic Surveillance Violations Not being conducted every six months Periodic surveillance forms not accurate/up to date. Periodic surveillance not reflecting O&M activities performed

Awareness Training The LEA shall provide the custodial staff with asbestos awareness training. Common Violations Not trained w/in 60 days of hire Outsourced custodians not trained No 16 hour training if conducting SSSD

Notification The LEA shall provide yearly notification to parent, teacher, and employee organizations regarding the availability of the school’s AMP and any asbestos abatement actions taken or planned in the school

Common Annual Notification Violations Not being conducted on a yearly basis Copies not located in the AMP Notification located online Notification in handbook Not updated with most current information

Proper Methods for Managing Asbestos Most ACBM that is maintained in good condition does not pose an exposure risk and can be managed in place. The EPA recommends proper maintenance rather than removal in most cases. Green Floor Tile

Response Actions Response actions are based upon an assessment of the ACBM. The DPH must grant written approval to conduct abatement while school is in session. Typically 30 to 40 AAWSIS projects per year (partial/Full) Letter to confirm not students in building to be sent to DPH.

Common Response Action Violations No record of SSSD projects in AMP Who What Where When Waste manifest Response action records not on file for three years after the next three year reinspection. All files to be kept for 30 years.

CT Department of Public Health Regulatory Services Branch Environmental Health Section Asbestos Program Tel: Fax: