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Under the Asbestos Hazard Emergency Response Act (AHERA), do you have to label enclosed or encapsulated asbestos-containing building material ACBM in routine maintenance areas?

Yes. 40 CFR part 763.95(a) of the asbestos in schools rule states that “[t]he local education agency shall attach a warning label immediately adjacent to any friable and non-friable ACBM and suspected ACBM assumed to be ACM located in routine maintenance areas (such as boiler rooms) at each school building. This shall include:

Friable ACBM that was responded to by a means other than removal; and
ACBM for which no response action was carried out.”