Laschone P. Garrison

State of Connecticut, Department of Public Health

QualificationsCT DPH Asbestos Program- 8 years

BS/MS BiologyOSHA HAZWOPER-(40 hour initial training & 8 hour yearly training)United States Environmental Protection Agency State Inspector Enforcement Awareness (10hours)Asbestos Inspector/Management Planner Training (40 hour initial training & 8 hour yearly training)Asbestos Project Monitor Training (40 hour initial training & 8 hour yearly training)Asbestos Project Designer Training (40 hour initial and 8 hour yearly training)

Applicable State RegulationsStandards for Asbestos Abatement§§ 19a-332a-1 through 19a-332a-16

Licensure and Training Requirements§§ 20-440-1 through 20-441-1

Asbestos-Containing Materials in Schools§§ 19a-333-1 through 19a-333-13

Applicable Federal RegulationsAsbestos-Containing Materials in Schools40 C.F.R., Part 763 *(AHERA)

EPA Clean Air Act, National Emissions Standard for Hazardous Air Pollutants (NESHAP)40 C.F.R. , Part 61 Subpart M, asbestos

Current Status of Asbestos IndustryApproximately 250 licensed asbestos abatement

contractorsApproximately 3,300 certified asbestos workers

and supervisorsApproximately 600 licensed asbestos

consultantsEach year there are approximately 3500 notified

asbestos abatement projects in ConnecticutEach year there are approximately 200 to 300

notifiable school projects in Connecticut.

How is Asbestos Regulated in Schools? “AHERA” (Asbestos Hazard

Emergency Response Act), requires all K-12 schools to inspect for the presence of asbestos; to develop plans to manage asbestos in schools; and to carry out necessary response actions in a timely fashion.

CT is a waiver state and enforces AHERA with its own regulations.

Asbestos Management PlanThe Local Education

Agency (LEA) shall develop, maintain, and update an Asbestos Management Plan (AMP) and keep a copy at the school;

AMP must be submitted to DPH for review and approval

Asbestos Management PlanCommon AMP

implementation ViolationsNo AMP update for

new buildings at existing schools

No implementation of AMP before school opens

No approval of new/newly constructed buildings by DPH

Not the same as environmental survey

Designated PersonEach school system shall

assign a “Designated Person” to ensure the responsibilities of the LEA are properly implemented.

Common ViolationsNo DPNo statement of assuranceNo DP trainingNo replacement DP

InspectionsSchools must initially be

inspected for the presence of asbestos materials by a DPH licensed inspector.

All school buildings are inspected for friable and non-friable asbestos-containing building materials (ACBM).

Samples are analyzed by DPH approved environmental laboratories.

ReinspectionsAll known and suspected

ACBM must be reinspected at least once every 3 years

Results are used to implement response actions

Common ViolationsLate 3-yearsFailure to note change in

condition/failure to implement response action in timely manner

Periodic SurveillanceThe LEA must conduct

periodic surveillance in each building under its authority at least once every six months after a management plan is in effect.

This periodic surveillance must be documented in the management plan.

Common Periodic Surveillance ViolationsNot being conducted

every six monthsPeriodic surveillance

forms not accurate/up to date.

Periodic surveillance not reflecting O&M activities performed

Awareness TrainingThe LEA shall

provide the custodial staff with asbestos awareness training.

Common ViolationsNot trained w/in 60

days of hireOutsourced

custodians not trained

No 16 hour training if conducting SSSD

NotificationThe LEA shall provide yearly notification to parent, teacher, and employee organizations regarding the availability of the school’s AMP and any asbestos abatement actions taken or planned in the school

Common Annual Notification ViolationsNot being conducted

on a yearly basisCopies not located in

the AMPNotification located

onlineNotification in

handbookNot updated with

most current information

Proper Methods for Managing AsbestosMost ACBM that is

maintained in good condition does not pose an exposure risk and can be managed in place.

The EPA recommends proper maintenance rather than removal in most cases.

Green Floor TileGreen Floor Tile

Response ActionsResponse actions are

based upon an assessment of the ACBM.

The DPH must grant written approval to conduct abatement while school is in session.

Typically 30 to 40 AAWSIS projects per year (partial/Full)

Letter to confirm not students in building to be sent to DPH.

Common Response Action ViolationsNo record of SSSD

projects in AMPWhoWhat Where WhenWaste manifest

Response action records not on file for three years after the next three year reinspection. All files to be kept for 30 years.

CT Department of Public HealthRegulatory Services Branch

Environmental Health Section

Asbestos Program

Tel: 860-509-7367

Fax: 860-509-7378http://www.ct.gov/dph/