Are the school district's administrative offices (such as the Board of Education or the Superintendent's Office) covered by the Asbestos Hazard Emergency Response Act (AHERA), even if students never attend classes in these buildings?
Yes. Among the structures covered in the definition of “school building” in AHERA (section 202) and in the asbestos in schools rule (40 CFR part 763.83) are "... any other facility used for the instruction or housing of students or for the administration of education or research programs."