Management Plan

The asbestos management plan is made up of much more than just triennial re-inspection reports ("the binder").

[Note: This is a long page with many sections. Keep scrolling down to see all the content.]

Tab 1 includes a List of School Buildings, which indicates whether buildings contain any ACBMs. Tab 1 also includes general School Information, such as grades serves, number of students and staff, and contact information. Tab 1 also includes a school map which shows all of the school buildings located on campus.

The LEA-DP information is required to be kept in the management plan. This has contact information for the LEA-DP, in case you need to contact them (such as when there is a fiber release episode). LEA-DP packet is available in Google Docs. It is updated as the LEA-DP asbestos building inspector and asbestos management plan certifications are renewed, annually.

Click on the images, below, to view a copy of HAR 11-502 or the Department of Health Asbestos Rule Guide

An initial inspection of all school buildings is required prior to occupancy. This includes new construction, moved buildings (portables) and renovation. An exclusion statement can substitute for a physical inspection for HAR 11-502 purposes.

Exclusion Statement: An architect or project engineer responsible for the construction of a new school building built after October 12, 1988, or a certified inspector signs a statement that no ACBM was specified as a building material in any construction document for the building, or, to the best of that person's knowledge, no ACBM was used as a building material in the building. The local education agency shall submit a copy of the signed statement of the architect, project engineer, or certified inspector to the director and shall include the statement in the management plan for that school.

The exclusion statement exempts a school from periodic surveillance and re-inspection of excluded suspect ACBMs (per HAR 11-502). However, HAR 11-501 requires physical sampling before renovation and demolition. Therefore, any suspect ACBM will be sampled and tested prior to its removal.

Documentation of response actions is required under HAR 11-502. Abatement documents demonstrate that all necessary precautions were taken during abatement activities. Failure to include complete abatement documentation in the management plan can create the perception that required procedures were not followed (whether true or not). The Environmental Services Unit usually receives environmental reports for CIP and Major R&M jobs. Jobs initiated by schools or the community are not exempt from HAR 11-501 and HAR 11-502. All abatement activities must be properly designed, executed and documented. ESU should receive copies of all abatement documentation.

HAR 11-502 requires response action documents to be kept in the management plan for 3 years after the most recent re-inspection (equivalent to a maximum of 6 years).

Response Action:

• A method, including removal, encapsulation, enclosure, repair, operations and maintenance that protects human health and the environment from friable asbestos.

• Removal actions are typically called asbestos abatement.

R&M Projects:

• Often include removal of ACBM (abatement).

• Greater than 3 square feet qualifies as “other than small scale, short-duration”

• Thorough documentation essential for compliance, safety & health

• All abatement documents become part of the asbestos management plan

Required Response Action Documentation (for jobs > 3 square feet)

• Abatement work plan (prepared by certified Asbestos Project Designer)

• Project monitoring (by certified Asbestos Project Monitor)

• Air monitoring report (during project and at close**)

• Details of the location, duration and timing of the abatement

• Visual clearance and air clearance (Required prior to re-occupancy for each functional space undergoing abatement)

• Waste Disposal records

• Certifications for all Designers, Monitors, Abatement Workers & Supervisors

The Annual Notification Letter notifies parents, teacher and employee organizations that an asbestos management plan is available for review in the school's administrative office. The letter may also indicate when periodic surveillance was done and if there have been any response actions or fiber release episodes.

HAR §11-502-11(a) requires school custodial and maintenance staff to receive 2 hours of asbestos awareness training within 60 days of hire. 2 hour asbestos awareness training satisfies the training requirement for staff that encounter but does not disturb asbestos-containing building materials (ACBMs). Although the EPA/DOH training requirement is for a 1-time training, OSHA/HIOSH have an ANNUAL retraining requirement of the same 2 hour asbestos awareness training curriculum.

Three ways to get trained:

1. This website.

2. Video training: https://sites.google.com/k12.hi.us/asbestos-training-videos.

3. In person training by LEA-DP. Usually arranged by Administrative Services Assistants.

Regardless of which method you use to get trained, it is important that you complete the TRAINING RECORD and keep a copy in the asbestos management plan, as well as send a PDF copy to gary.bignami@k12.hi.us.

What is Periodic Surveillance?

• Periodic Surveillance Reports (PSRs) are an essential component of a school’s asbestos Operations and Maintenance program.

• Periodic surveillance involves visual inspection of all areas that are identified in the management plan as ACBM or assumed ACBM. It is not necessary to touch ACBMs.

• Periodic surveillance looks for damage to ACBM such as:

  • Delamination

  • Flaking

  • Blistering

  • Crumbling

  • Scrapes, gouges, mars

  • Asbestos debris

  • Torn, crushed, or missing TSI

Why is Periodic Surveillance Necessary?

• Safety: Primary means to ensure that existing ACBM is in good condition.

• Identify areas requiring a “response action” (repair, replacement, encapsulation or enclosure).

• Required by law to be conducted every six months, if the school has any assumed or known ACM. DOE does this in June and December.

• Hawaii Administrative Rules (HAR) 11-502-11(d):

“At least once very six months after a management plan is in effect, the local education agency shall conduct periodic surveillance in each building that it leases, owns, or otherwise uses as a school building that contains ACBM or is assumed to contain ACBM.”

Who can Perform Periodic Surveillance?

• Anyone who has received 2 hour asbestos awareness training.

  • Head Custodian, Principal or Vice Principal, ASA

• Periodic surveillance includes a visual inspection of the previously identified confirmed and assumed ACBMs to detect any changes in the conditions of the materials.

  • Surveyor should be familiar with the management plan including most recent re-inspection report.

  • Surveyor should be familiar with and have access throughout campus.

• You do not have to touch ACBMs during periodic surveillance.

• Periodic Surveillance Report must be submitted to the Designated Person (currently via Lotus Notes application).

Once the top portion of the form is complete, assess the condition changes of the listed ACBMs.

1. Print a copy of the PSR form for annotating during the survey.**

2. Conduct the survey, taking note of any changes in condition to ACBM or assumed ACBM materials.

3. Add comments, as needed, to note specifics of damage (location, amount of material involved) and possible remedy (e.g. submit work order for floor tile replacement).

4. Enter the data into the Lotus Notes PSR database using the annotated printed copy for reference.

5. CALL THE ESU for assistance if significantly damaged, friable ACBM is found!

** Be sure to use “Print Preview” to select how many pages to print; default is 12 pages!

Examples of How ACBMs Can Be Damaged

Submitting the PSR

Once the condition of the various homogeneous materials (also called Uniform Sampling Areas "USA") has been assessed and entered into the form, the following options are available:

Create a Follow on Report

To create a follow on report, highlight your most recent completed submission, go to the menu at the top of the page and click "Create Follow up Report".

Note that ESU has been creating follow up reports for schools and you should not have to do this; an up to date template will be available for the next surveillance period.

The short term worker notification is used to inform outside workers (telephone, termite, plumbers, etc.) that ACBMs are present at the school and they are entitled to review the asbestos management plan.

It is recommended that the most recent triennial re-inspection report be made available, upon request. Most outside workers will not be qualified to properly disturb ACBMs, so if ACBM is present where work needs to be performed, they may need to consider a "work around." The goal is to prevent outside workers from causing fiber release episodes that expose themselves and school students and staff.

Correspondence with the Hawaii Department of Health should be kept in the asbestos management plan. Examples shown below include a Notice of Inspection, an Advisory Notice, an Advisory Notice Response from HIDOE, and a No Further Action letter, indicating the "case has been closed."