Procedures for School Inspections and Reinspections

Section 855 Section 855.310  Procedures for School Inspections and Reinspections a)         The Department shall prepare and maintain a list of licensed inspectors. All inspections and sampling of school buildings for the presence of ACBM and all assessments of the condition of ACBM in schools shall be done by a Department licensed asbestos inspector. b)         School Building Inspections. 1)         Inspections shall be conducted only during non-school hours.  Samples shall not be collected in areas where, and at times when, students or school personnel are present. 2)         All areas of the school building shall be inspected including classrooms, cafeterias, auditoriums, gymnasiums, locker rooms, offices, hallways, tunnels, boiler rooms, mechanical rooms, above drop ceilings, crawl spaces, ventilation ducts, attics, basements, etc. 3)         For initial inspections, the inspector shall identify and establish homogeneous sampling areas for friable and nonfriable materials. 4)         The inspector shall photograph materials sampled and damaged areas found and identify locations where pictures were taken. 5)         The inspector shall complete the form "Building Inspection for Friable and Nonfriable Materials" for each school or facility.  (See Appendix B, Illustration A of this Part.) c)         Sampling Friable and Nonfriable Materials. 1)         The area of each homogeneous friable and nonfriable surface shall be calculated (allow for beams, vaulted ceilings, etc.).  If materials appearing uniform were installed at different times, two materials shall be designated as distinct homogeneous areas. 2)         A diagram shall be drawn for each homogeneous sampling area as described in subsections (g), (h), (i), and (j) of this Section. 3)         Random sample points shall be determined using the method described in subsection (l) of this Section. 4)         The following requirements shall apply to all sampling of surfacing material: A)        For each homogeneous sampling area of less than 1,000 square feet, a minimum of 3 samples shall be collected; B)        For areas from 1,000 to 5,000 square feet, a minimum of 5 samples shall be collected; C)        For homogeneous areas greater than 5,000 square feet, a minimum of 7 samples shall be collected. 5)         If pipe and boiler insulation are in good condition (not friable), sampling shall not be conducted.  It shall be assumed that these areas are asbestos containing and recorded as such.  The Superintendent of the school district may request a variance (see Section 855.25) for the inspectors to sample material that is in good condition.  However, damaged pipe and boiler insulation are considered distinct sample areas, and three samples must be collected for each such homogeneous material found.  Pipe, pipe joints and boiler insulation are all different homogeneous areas and shall not be sampled as one homogeneous area. 6)         Wall and ceiling tiles must also be sampled.  Three samples shall be collected from each homogeneous type of wall and ceiling tile found. 7)         At least one bulk sample shall be collected from each homogeneous area of patched thermal system insulation that is not assumed to be ACBM if the patched section is less than six linear or square feet. 8)         Bulk samples are not required to be collected from any homogeneous area where the accredited inspector has determined that the thermal system insulation is fiberglass, foam glass, rubber, or other non-asbestos-containing building materials. 9)         Miscellaneous materials shall be collected in a manner sufficient to determine whether material is asbestos-containing building materials (ACBM). Bulk samples shall be collected from each homogeneous area of friable miscellaneous material that is not assumed to be asbestos-containing materials. 10)       Nonfriable suspected asbestos-containing building materials (ACBM).  If any homogeneous area of nonfriable suspected ACBM is not assumed to be ACBM, then a licensed inspector shall collect, in a manner sufficient to determine whether the material is ACBM, bulk samples from the homogeneous area. d)         Sampling Precautions. 1)         Disturbed materials shall only be sampled with necessary personnel present.  Materials shall not be disturbed any more than necessary. 2)         A NIOSH approved respirator equipped with HEPA filters shall be worn when sampling friable materials or when moving ceiling tiles to access friable materials. 3)         Disturbed materials shall be sealed with a clear, nonflammable encapsulant. 4)         Any visible materials shall be cleaned by wet mopping or by wiping with a damp cloth. 5)         When carpet is present, a plastic drop cloth shall be placed under the sample point to facilitate easy clean up. 6)         Contaminated materials (e.g., wiping cloths, mop heads) shall be disposed of in sealed, labeled six mil plastic bags. e)         Sampling Procedures. 1)         Materials shall be sprayed with a light mist of water to reduce fiber release during sampling. 2)         A small core of the material penetrating all layers including any paint or protective coating shall be gently cut and removed.  Any reusable instrument shall be wet-wiped before reuse. 3)         The sample shall be placed in a zip top plastic bag.  The bag shall be sealed and  the exterior wiped with a damp cloth to remove any materials. 4)         Each bag shall be labeled with a sample I.D. number. 5)         The samples for each school shall be sealed in a second plastic bag. 6)         Information to be recorded for each sample collected includes the date, sampling location and ID number.  The form "Asbestos Bulk Analysis" shall be completed and samples submitted to a laboratory accredited under the National Voluntary Laboratory Accreditation Program (NVLAP) administered by the National Institute for Standards and Technology (NIST). f)         Reporting.  The Management Plan referenced in Section 855.325 shall be submitted to the Department along with one copy of the inspection report which shall include a narrative description of building components and a completed "Building Inspection for Friable and Nonfriable Materials" form for each school inspected.  Photographs and sample area diagrams shall be included with sample locations.  All photographs must be reproduced from negatives.  Photocopies of photographs shall not be sent.  Each sample must have a photograph to show condition of the material. 1)         To expedite the efficient review of the inspection reports, they shall be organized and submitted in the following order: A)        Each report shall be put in a three hole report cover.  (Not a three ring binder.) B)        The school district, school name, and the complete address of school building where inspection was conducted, city and county shall be identified on the front cover. C)        The report shall be assembled in the following order: i)          Appendix B, Illustration A ii)         Narrative Report iii)        Each sample area:  Appendix B, Illustration B (2 pages) Identifying sample area; Drawing to scale or dimension; Indicating on plan where samples were taken; Including photographs of material from which samples were taken; Indicating the sample number which applies to each photo.  The reference material should be used to determine the number of samples required based on the square footage in the sampling area. 2)         The inspection report will not be considered complete until bulk samples are received by an approved laboratory. A copy of the laboratory submission sheets shall be included with the inspection report. g)         For each sampling area, diagram shall be prepared showing all friable and nonfriable materials in the sampling area.  Construct the diagram on graph paper as follows: 1)         The approximate dimensions of all rooms, corridors, or other school building areas included in the diagram shall be clearly indicated.  If these measurements are not readily available, rooms will need to be measured. Prepare the diagram approximately to scale.  (See Appendix B, Illustration C.) 2)         The diagram shall distinguish between friable and nonfriable material areas of the sampling area, and areas in the diagram that are not contained in the sampling area. 3)         Any of the following features that are found within the sampling area shall be drawn on the diagram approximately to scale: A)        Damage caused by water or high humidity. B)        Damage due to vandalism, rough use, or other factors. C)        Patched or repaired material. D)        Areas that are inaccessible for the purpose of sampling the friable or nonfriable material. h)         If one sampling area contains friable or nonfriable material areas that are not adjacent (for example, areas on different floors of the school building where the material is the same), each separate area shall be sketched according to the above instructions.  Place all sketches on the same graph, as closely together as possible.  The sampling area may contain areas that are not in the same plane (for example, a ceiling and a wall with the same type of friable or nonfriable material).  In this case, each flat surface shall be sketched according to the above instructions and these sketches placed on the same graph, as close together as possible. i)          On each sampling area diagram, the following information shall be recorded: 1)         Sampling area identification number that distinguishes the sampling area from all others of the school building. 2)         Brief description of the sampling area. 3)         Area dimensions and scale. 4)         Name and address of the school. 5)         Name and telephone number of the school official contacted. 6)         Name of inspector and date of inspection. 7)         Name of person preparing the diagram and date prepared. j)          For piping, vent and boiler diagrams: 1)         A diagram shall be drawn which includes room dimensions and sample locations.  (See Appendix B, Illustration D.) 2)         Sample locations shall be described. k)         These diagrams shall be included with the "Building Inspection" form. l)          Sampling Procedure 1)         The sampling area shall be divided into nine equally sized subareas.  This shall be done by dividing the length and width of the sampling area into three equal lengths and three equal widths and drawing a grid over the diagram (see Appendix B, Illustrations C through G). 2)         The diagrams in Appendix B, Illustration E show which subareas to use in order to follow a random sampling scheme.  For the first area to be sampled, the nine subareas shall be numbered as shown for sampling area #1 in  Appendix B, Illustration E.  If three samples are needed, they shall be taken from the subareas marked 1, 2 and 3.  If 5 samples are needed, they shall be taken from the subareas marked 1, 2, 3, 4 and 5, and so on.  Samples shall be taken from approximately the center of a subarea, or as close as possible to the center if inaccessibility, presence of light fixtures, etc., make the center location impractical.  If a subarea is specified that falls entirely outside the sampling area, the next specified subarea shall be used.  For example, if subarea 3 falls outside the sampling area, the third sample from subarea 4 shall be taken. 3)         For very irregularly shaped areas, the sampling area may be divided into nine approximately equally sized subareas that do not necessarily form a rectangular grid.  The diagrams in Appendix B, Illustration E will then need to be adapted to the specific situation.  Appendix B, Illustration F shows an example of a Y-shaped sampling area that is divided into nine equally sized subareas.  The first diagram of Appendix B, Illustration E was adapted accordingly to number the subareas.  When adapting sampling diagrams, the order of the numbered subareas from left to right and top to bottom shall be retained wherever possible. 4)         For each sampling area, a new diagram in accordance with Appendix B, Illustration E shall be used.  If there are more than 18 sampling areas, a new diagram shall be used, starting again at the top (Sampling Area #1) of Illustration E to determine sampling locations for sampling area 19 and higher. m)        The following shall be required for reinspections: 1)         All items included in Section 855.Appendix B, Illustration H. 2)         Any additional suspect ACBM found during the reinspection, that was not included in the original management plan or previous reinspection report, shall be sampled according to procedures in Section 855.310(d) or listed as assumed ACBM and added to the management plan. 3)         Inspections shall be conducted only during non-school hours when students or school personnel are not present.  Samples shall not be collected in areas when and where students or school personnel are present. 4)         Within 30 days after the reinspection, the Department-licensed inspector shall submit to the LEA the following: A)        The date of the reinspection. B)        The name and signature of the Department-licensed inspector performing the reinspection and the licensed management planner. C)        The current Department-issued license number of the inspector/management planner and the current training course certificate at the time of the inspection. D)        Any changes in condition of known or assumed ACBM. E)        Any changes in the classification of an assumed ACBM to a non-ACBM shall be performed in accordance with the requirements of this Section. F)         If the LEA chooses to resample known ACBM, the results of the new sampling shall use TEM to prove that the material is not ACBM. G)        Any changes in the response action recommendations.