What specifically must be inspected in a school building subject to the Asbestos Hazard Emergency Response Act (AHERA)? How far does an inspector have to go to inspect for asbestos?
The asbestos-containing materials in schools rule requires local education agencies (LEAs) to ensure that accredited inspectors conduct a thorough and complete inspection. This includes all of the steps listed in 40 CFR part 763.85(a)(4) of the asbestos-containing materials in schools rule. However, in most cases, EPA does not intend that the accredited inspector undertake destructive steps (e.g., tearing down a wall) in an attempt to locate asbestos-containing building material (ACBM). Instead, an accredited inspector is expected to take reasonable steps to locate ACBM. Specifically, an accredited inspector should conduct a thorough visual inspection, including, among other things, an examination of areas not immediately visible but that can be accessed (e.g., above drop ceilings, inside ventilation shafts, etc.), carefully reviewing building plans and using his or her own knowledge to determine if ACBM was used in areas that cannot be accessed (See 40 CFR part763.85(a)(4)). While building plans may provide some helpful information about where to look for ACBM, they are not a substitute for a thorough inspection.