laschone p. garrison state of connecticut, department of public health
TRANSCRIPT
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Laschone P. Garrison
State of Connecticut, Department of Public Health
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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)
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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
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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
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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.
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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.
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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
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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
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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
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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.
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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
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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.
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Common Periodic Surveillance ViolationsNot being conducted
every six monthsPeriodic surveillance
forms not accurate/up to date.
Periodic surveillance not reflecting O&M activities performed
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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
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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
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Common Annual Notification ViolationsNot being conducted
on a yearly basisCopies not located in
the AMPNotification located
onlineNotification in
handbookNot updated with
most current information
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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
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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.
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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.
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CT Department of Public HealthRegulatory Services Branch
Environmental Health Section
Asbestos Program
Tel: 860-509-7367
Fax: 860-509-7378http://www.ct.gov/dph/