ASBESTOS ABATEMENT ACTIVITIES
The school system is licensed by the State of Maryland to remove and/or encapsulate asbestos materials. Maryland regulates all friable materials and any non-friable materials which may become friable during renovation, demolition or asbestos removal projects. Asbestos Hazard Emergency Response Act (A.H.E.R.A.) regulations require school systems to identify all asbestos containing materials (ACM) and to track activities performed on them. This includes ensuring that any work performed is done by accredited workers as well as having clearance air sampling reports and disposal manifests for the material(s) removed. Basically we have to account for all ACM identified when the buildings were inspected.
We are required to notify the State and the Maryland Department of Energy 10 working days prior to starting a NESHAP size project. This includes non-friable materials that may become friable. The form is self explanatory. The original goes to the Maryland Department of the Environment and a copy to the United States Environmental Protection Agency Via the mail. Faxing copies is frowned on. The addresses are:
Maryland Department of the Environment U. S. E. P. A.
Air & Radiation Management Administration Region III
Division of Asbestos Licensing & Enforcement 841 Chestnut Building
1800 Washington Blvd. Philadelphia, PA 19107
Baltimore, Maryland 21230
Click Here to see Asbestos Management Plans Information
On NESHAP sized projects, we usually meet with the building's principal and/or staff to discuss the project prior to beginning any work. We prepare a draft "Dear Parent/Guardian/Staff Member" letter (site & project specific) for the notification purposes. Every effort is made to have our in-house crew perform work in occupied buildings.
We also prepare specifications and evaluate bids for contracted asbestos work. Environmental Office personnel monitor all asbestos abatement activities.
Copies of clearance sampling reports and waste disposal manifests for in-house projects must be sent to the MDE as soon as they are available. Contractors are responsible for submitting these documents for projects they perform. We provide copies of clearance sampling reports to the contractor, and he/she must submit a waste manifest before final payment is authorized. Copies of all air testing and disposal manifests are required to be inserted in the Building's Asbestos Management Plan.
On smaller sized jobs (less than NESHAP), crews are supposed to submit an ASBESTOS WORK NOTIFICATION/AUTHORIZATION form to the Environmental Office prior to working on more than 3 square or 3 linear feet of asbestos containing material. Environmental Office personnel verify the submitted information and permission to proceed is given as long as the work can be accomplished safely. Emergency jobs in this category must be called into the Environmental Office prior to beginning work. The above mentioned paper work is to be completed and sent as soon as possible. Maintenance employees are allowed to do jobs consisting of less than 3 square or 3 linear feet without prior authorization as long as they follow the Maintenance Department Asbestos Work Policy and Procedures document. All required paperwork must be submitted after the work is completed.
ASBESTOS TRAINING OF EMPLOYEES
We solicit prices for all regulated classes as part of our yearly Industrial Hygienist Services account. Most training occurs in January. Abatement workers can not perform any removal activities if their certification lapses. There is a one-year grace period for retraining without the affected person having to retake the complete class. However that individual is prohibited from removing materials other than small scale, short duration type of work.
Operational and maintenance activities (normal work around asbestos materials) can be done by anyone who has received 16 hours of asbestos training. The State requires yearly re-certification for O & M workers; however, our employees do not fall under that prerequisite since all removal of friable asbestos material is undertaken by the Abatement Crew. Additionally, our maintenance employees deal mostly with non-friable materials that aren't regulated in Maryland (unless rendered friable). A price for this class is solicited with the In House Services Contract.
ASBESTOS (A.H.E.R.A.) INSPECTIONS
Mandated (A.H.E.R.A.) asbestos inspections are performed by the inspectors assigned to the Environmental Office. The law requires all facilities to be reinspected once, every three years. We perform the required inspection in one third of the systems' buildings each year. The Asbestos Management Plans are updated accordingly.
SIX MONTH SURVEILLANCE ACTIVITIES
The (A.H.E.R.A.) mandated six month surveillance activities are performed by the inspectors assigned to the Environmental Office.
The Environmental Office telephone number is (301) 952-6539