Recordkeeping for the Management Plan

 INTRODUCTION

An effective management plan is key to a comprehensive record keeping system.  The Management Planner develops a report which is submitted to the Local Education Agency (LEA).  The report presents the results of the building inspection, the assessment of the ACBM found in the building, a discussion of recommended response options the LEA should implement to manage the ACBM, recommendations regarding prioritization of those response actions, and guidance concerning the cost of various options.

Upon receiving the Management Planner’s report, the LEA is responsible for developing the asbestos management plan.  The Planner’s report essentially becomes the LEA’s management plan and is submitted to the state for approval.

 

BENEFITS

The purpose of the record keeping process is to establish and maintain a standardized system which clearly documents implementation of an asbestos control program.  The steps taken be the LEA/building owner identify asbestos materials and associated hazards, and minimize the potential exposure to employees and building occupants must be recorded for the future reference.  AHERA is specific concerning the carious records and documentary information to be maintained.  It is the LEA’s responsibility to establish a recordkeeping system and maintain the required records as part of its management plan.

 

ELEMENTS OF RECORDKEEPING

In general, the recordkeeping system must track three types of data:  data on the physical condition of the ACBM, actions taken on the ACBM, and the data associated with the personnel involved with the asbestos management program.

The tracking of the ACBM’s may be thought of as the tracking of a business’s physical inventory requiring that the condition of the materials be recorded at intervals (record of the surveillance), the recording of the substantive changes in material status (removal, enclosure, encapsulation, or repair), various required reports to governing bodies (notices of abatement and disposal actions to the EPA), and the recording of an up-to-date inventory on a periodic basis (re-inspections).

Required recordkeeping for personnel includes the identity, training, medical monitoring and exposure of persons.  This information should be recorded in a form which will be available for a period of at least 30 years.

Despite the fact that the Management Planner does not set up, or maintain LEA records, (except in the instance that the LEA contracts for such services), the Planner should be certain that the LEA is aware of the AHERA recordkeeping requirements.

The various types of documents and records to be included in the recordkeeping system are outlined below.

For each preventative measure and/or response action taken:

  • Detailed written description of the measure or action
  • Methods used
  • Location
  • Justification for why a specific measure or action was selected
  • Start and completion of dates of all work
  • Names and addresses of all contractor involved and accreditation information
  • If ACM was removed, name and location of storage or disposal sites

For any air sampling conducted:

  • Name and signature of person collecting samples
  • Date and location where samples were collected
  • Name and address of laboratory analyzing samples
  • Date and method of analysis
  • Results of analysis
  • Name and signature of analyst

For persons required to be trained for maintenance and repair operations, training records must be maintained:

  • Employee’s name and job title
  • Date training completed
  • Location of training and training organization’s name
  • Number of hours of training

For each time periodic surveillance is performed:

  • Inspector’s name
  • Date of the surveillance
  • Notation of changes (or lack of ) in the condition of the ACBM

For each time that cleaning is performed:

  • Name of person(s) doing cleaning
  • Date of cleaning
  • Locations cleaned
  • Methods used in cleaning

For each time operations and maintenance activities are performed:

  • Name of person(s) performing activities
  • Start of completion dates of action
  • Locations
  • Description of activity, including preventative measures taken
  • If ACBM removed, name and location of storage/disposal site

Each time maintenance activities other than small-scale, short duration activities are undertaken.

  • Name, signature and state of accreditation for each person involved in activity
  • Start and completion date of project
  • Location(s)
  • Description of project, including preventative measures taken
  • If ACBM removed, name and location of storage/disposal site

For each fiber release episode:

  • Date of episode
  • Location
  • Method of repair
  • Preventative measures or response action taken
  • Name(s) of person(s) performing work
  • If ACBM is removed, name and location of storage/disposal site

Suggested documentation but not required:

  • Complete historical blueprint of facility, if available
  • Documentation on materials/products used in construction or renovation of the facility that may asbestos (include any correspondence with manufacturers)
  • Location and photographs of warning signs and barriers placed to prevent unauthorized access to areas of ACBM
  • Required state and federal forms dealing with notification and compliance
  • All correspondence pertaining to asbestos in the facility
  • Copies of notification statement, press releases, meeting agendas (with attendance rosters)

The reasons for maintaining complete and detailed records of asbestos management are many.  Documentation can expedite response action and make future renovation in any facility easier.  The legal liabilities involved with asbestos are another reason to maintain thorough records.  The more thorough the documentation is, the more defensible the actions taken.  Further, poor or sloppy recordkeeping could imply callousness toward employees, building occupants, and the public.  In the case of LEA’s, records are kept because they are required by AHERA.