Asbestos Hazard Emergency Response Act Warning Label Requirements
This is the third article in a series dealing with the Federal Asbestos Hazard Emergency Response Act (AHERA) requirements for public and nonpublic elementary and secondary schools (40 CFR Part 763).
A review of Environmental Protection Agency (EPA) issued AHERA citations of noncompliance, identifies asbestos warning labels as an area of concern.
Asbestos warning labels in schools are often missing, incomplete, or sometimes placed erroneously in unnecessary locations within school buildings. AHERA 763.95, Warning Labels, specifies that schools must "attach a warning label immediately adjacent to any friable and nonfriable asbestos containing building material (ACBM) and suspected ACBM assumed to be asbestos containing material (ACM) located in routine maintenance areas (such as boiler rooms) at each school building." Specifically, warning labels must be affixed in routine maintenance areas adjacent to:
friable ACBM that was responded to by means other than removal; and
ACBM for which no response action was carried out.
Asbestos warning labels must be large and/or printed with a bright color. AHERA requires that the sign be worded as follows:
CAUTION: ASBESTOS. HAZARDOUS. DO NOT DISTURB WITHOUT PROPER TRAINING AND EQUIPMENT.
During each six month periodic surveillance (763.92(3)(b)), school officials should check to see that warning labels are still properly posted and in place.
IMPORTANT NOTE: AHERA only requires that asbestos warning labels be displayed in "routine maintenance areas". These are locations such as boiler rooms and maintenance workshops. It is not necessary or recommended to post warning labels in public areas, such as cafeterias, auditoriums, or even in classrooms and corridors.
While the location of all ACBM throughout the building must be known to all custodial and maintenance employees (including any short-term workers; ie: telephone and utility workers 763.84(d)), it is only necessary to prominently display warning labels in the routine maintenance areas.
As always, the AHERA management plan must be made available during normal business hours, without cost or restriction, for public inspection by parents, teachers, and other interested persons (763.93(g)(3)). Through this review, the public may learn of exact locations of ACBM throughout the building.