Asbestos Hazard Emergency Response Act (AHERA), 40 CFR Part 763, Subpart E — specifically focused on K-12 schools.
Every Local Education Agency (LEA) must ensure that an accredited asbestos inspector inspects all school buildings.
Inspections determine the presence, location, and condition of any Asbestos-Containing Material (ACM) or Presumed Asbestos-Containing Material (PACM).
These inspections form the baseline of the school’s Asbestos Management Plan.
Each school must maintain an AHERA Asbestos Management Plan (AMP) at both:
The school building itself, and
The LEA administrative office.
Plans must:
Include results of inspections and assessments.
Outline how asbestos hazards will be managed (e.g., removal, encapsulation, enclosure, O&M programs).
Contain response actions and a schedule for implementation.
List names/qualifications of persons conducting inspection, sampling, and response actions.
Document annual notifications to parents, teachers, and staff.
Schools must perform periodic surveillance every 6 months of all known or assumed ACM.
Surveillance must be conducted by a trained person (not necessarily accredited inspector).
Findings are logged in the AMP to show whether ACM condition has changed.
A full re-inspection is required every 3 years by an accredited inspector.
The inspector reassesses the condition of ACM and updates the risk assessment and recommendations.
Each LEA must appoint a Designated Person responsible for ensuring compliance with AHERA requirements.
Responsibilities include maintaining records, coordinating training, and ensuring contractors are properly accredited.
Custodial and maintenance staff with potential to disturb ACM must receive:
2-hour Asbestos Awareness Training initially.
Additional 14 hours if they will conduct O&M activities that may disturb ACM.
Training must cover asbestos hazards, locations, proper work practices, and emergency response.
Annual written notice must be provided to parents, teachers, and staff about:
The availability of the AMP.
Any asbestos-related activities conducted during the year.
Schools must keep detailed records of:
Inspections, re-inspections, surveillance, training, response actions, and clearance results.
These records must remain for the life of the building.
If asbestos is damaged or poses a risk, schools must implement one of the following:
Repair damaged ACM.
Encapsulate or enclose ACM.
Remove ACM if required by regulation (e.g., before major renovations/demolition under EPA NESHAP).
Response actions must be conducted by accredited contractors and overseen by accredited management planners/project designers.
AHERA compliance reporting with ispecX means schools can easily inspect, document, notify, and maintain — with inspections every 3 years, 6-month surveillance, annual notifications, and strict recordkeeping. All Live and Up-to-date!
Asbestos Hazard Emergency Response Act (40 CFR Part 763, Subpart E)
☐ Has the school building been inspected by an EPA-accredited asbestos inspector?
☐ Are all ACM and PACM locations identified and documented?
☐ Are sampling and analysis results (PLM/TEM) included in the files?
☐ Is an AMP available at the school building?
☐ Is a copy also available at the LEA (district) office?
☐ Does the AMP include:
Results of inspections & assessments
Response actions & schedules
Custodial/maintenance training records
Names/qualifications of inspectors, planners, contractors
Annual notification letters to staff and parents
Surveillance & re-inspection records
☐ Has 6-month surveillance of ACM been performed?
☐ Were observations documented in the AMP?
☐ Have changes in ACM condition been noted and acted upon?
☐ Was the 3-year re-inspection completed by an accredited inspector?
☐ Are updated risk assessments and recommendations documented?
☐ Has the school/LEA appointed a Designated Person responsible for AHERA compliance?
☐ Is contact information documented in the AMP?
☐ Have custodial and maintenance staff received 2-hour asbestos awareness training?
☐ Have staff performing O&M activities completed the additional 14-hour training?
☐ Are training certificates/records kept in the AMP?
☐ Has an annual written notice been provided to parents, teachers, and staff regarding the availability of the AMP?
☐ Are copies of these notices maintained in the AMP?
☐ Are damaged ACM properly repaired, encapsulated, enclosed, or removed by accredited contractors?
☐ Are clearance results documented for response actions involving removal?
☐ Were accredited project designers/management planners involved where required?
☐ Are all AHERA records retained for the life of the building?
☐ Are documents accessible for staff, parents, and regulators upon request?
☐ Does the AMP include documentation of all inspections, re-inspections, surveillance, training, and response actions?
✅ Compliant schools should be able to check every item above.
⚠️ Any unchecked box may represent an AHERA compliance gap requiring corrective action.
AHERA stands for the Asbestos Hazard Emergency Response Act (40 CFR Part 763, Subpart E). It requires all K-12 schools in the U.S. to inspect for asbestos-containing materials (ACM), develop a management plan, and ensure ongoing monitoring and notification.
All public and private, non-profit elementary and secondary schools (K–12) must comply. Colleges and universities are not covered under AHERA, but OSHA and EPA asbestos regulations still apply to them.
No. AHERA does not mandate removal of asbestos unless it is severely damaged or will be disturbed during renovation or demolition. Instead, schools must safely manage ACM through inspections, monitoring, and response actions.
Initial inspection: Required for all school buildings.
Re-inspection: Every 3 years by an accredited asbestos inspector.
Periodic surveillance: Every 6 months by trained staff.
An AMP is a school’s asbestos “roadmap.” It documents the location and condition of ACM, outlines response actions, and records ongoing monitoring, training, and notifications. A copy must be kept at the school and the LEA office.
Every school district (LEA) must appoint a Designated Person responsible for ensuring AHERA compliance. This person oversees inspections, recordkeeping, notifications, and contractor accreditation.
Custodial/Maintenance staff receive at least 2 hours of asbestos awareness training.
Staff who perform work that may disturb ACM need an additional 14 hours of O&M training.
Records of training must be kept in the AMP.
Schools must provide annual written notification to parents, teachers, and employees informing them of the availability of the AMP and any asbestos-related actions taken during the year.
The EPA (or state delegated authority) may issue notices of non-compliance, assess civil penalties, and require corrective action. Non-compliance can also result in liability for exposure claims.
All records (inspection reports, re-inspections, surveillance logs, training records, response action reports) must be retained for the life of the building and kept accessible for review by staff, parents, and regulators.