Do You Have Time to Convert Your Asbestos Management Plans to the AAC-8 Format?
The AAC-8 (Required Elements for Asbestos Management Plans for School and State Buildings) takes some getting used to.
Last week, we visited the Louisiana School Facility Managers Association meeting in Marksville. We got to talk with school personnel from all across the state about what’s going well for them, and also what’s giving them trouble. Since we’re primarily known for asbestos inspections, asbestos management plans, helping Owners get their asbestos abatement projects done, we ended up talking about – you guessed it, asbestos. Many facility managers have the same difficulties, and meetings like these are great for sharing tips for problem solving.
Inevitably, asbestos management plan compliance comes up. The Louisiana Department of Environmental Quality has stepped up efforts to ensure school systems comply with state and federal asbestos regulations. They’re really focused on the AAC-8 (Required Elements for Asbestos Management Plans for School and State Buildings).
DEQ created the AAC-8 in order to make asbestos management plans uniform and easy to read and review, especially for concerned citizens (like parents). At first, I wasn’t a fan of the AAC-8 at all. I have to admit that I think our in-house asbestos management plans were fine as they were. But after working with the AAC-8 form for a while now, it’s grown on me.
Switching from your old asbestos management plan format is a challenge, but look at moving to the AAC-8 as an opportunity.
Without a doubt, developing an asbestos management plan using the AAC-8 form is easiest when you’re starting from scratch. One thing the AAC-8 makes difficult is taking existing data, probably from multiple reports and documents (like abatement plans & specifications) and jamming them in the various AAC-8 sections to make the asbestos management plan format what DEQ wants.
Try moving data from an almost 30 year old asbestos management plan to the AAC-8 and you’ll see what I mean. But it can be done. You’ll need some time, coffee, a good scanner, and pdf software. That’s because the AAC-8 form starts out as 31 pages with no data. By the time you cram everything in there that’s required, you’ll likely end up with 300-400 pages.
Better still, each subsequent change you make to the asbestos management plan means you’ll need to edit at least one page in the AAC-8. That means each six month periodic surveillance, custodial training session, anything.
If you haven’t started moving your old asbestos management plans to the AAC-8 version, now is the time to get started. DEQ has visited some school systems and have issued Notices of Deficiency, requiring school systems to complete AAC-8.
To be fair to the DEQ folks, they have a job to do, and that includes reviewing asbestos management plans across 64 parishes. That’s a lot of field and office work. Much of the focus on this particular information comes from EPA – so we’re all in the same boat with DEQ on this one. DEQ will work with you, give you additional time (but not forever!), and help where needed to get the AAC-8 done.
The AAC-8 form isn’t perfect, and at some point you’ll likely hit a road block (like what if you can’t get the old reports or signatures the AAC-8 requires?). Or what if you’ve lost data as a result of a fire, flood, or storm? After Katrina and Rita, some schools experienced exactly that.
DEQ will help you – I know this because they’ve helped me get some of the more difficult to complete AAC-8 files done. The DEQ folks don’t like writing those letters that you and your superintendent don’t like reading.
Another funny wrinkle to this is the fact that you have to complete an AAC-8 form for any new school facility (even though you may be 100% certain the building doesn’t contain asbestos). The good news there is filling out the AAC-8 and creating a one-off asbestos management plan takes much less time than other AAC-8 forms. But there are a few interesting things to note:
You’ll need proof the new buildings don’t contain asbestos. We call it the “no asbestos” letter. The letter has specific language from the architect or engineer saying no asbestos was used or specified. Sometimes though, design professionals don’t want to write those letters.
Strange, I know, since your school system hired them to design a new building that contains no asbestos, but you may have a tough time getting that. Ask me how I know. It’s taken me several months to get letters like these from design professionals – and I sent them a letter template to use!
If you can’t get a “no asbestos” letter from the professional(s) of record, an accredited asbestos inspector can write the letter. But they’ll need something stronger than someone’s assurance that the building has no asbestos. I’ve done this for clients before, but I have some tricks that I use to help me. If you’re interested, email me.
You’ll need proof of Designated Person training. Most school systems won’t have a problem with this, since they have other schools with asbestos, so they have a trained Designated Person. But what if you have all brand new schools, or you’ve finally completed removal of all asbestos from your schools? Do they mean you’d still have to get training for something you probably don’t need?
Looks like it. I can only guess DEQ wants to make sure each school system has an asbestos point man in case something ever comes up. But this will be tough for small systems or single campus schools. I know this because I’ve seen many small and private school systems that have operated for years without ever having a trained Designated Person.
You’ll also need a management planner to help complete the AAC-8 for new schools with no asbestos. So you’ll need to engage a firm (unless you’re lucky enough to have an in-house asbestos management planner) to help with this. Either way, you still have time and money involved in this step. Make sense? In this case I suppose the intent is to make sure the information DEQ wants is there, and reviewed by an asbestos management planner.
There are other things you have to do for new schools. If you’re interested in finding out exactly what those are, email me.
You’re probably thinking, “Man, we’ve built 10 schools over the last 20 years, and we don’t have any of this stuff.”. You’re not alone. But you can get all the data together and get this done. As luck would have it, we have a checklist for these types of asbestos management plans. If you’d like to learn more, email me.
If DEQ hasn’t visited some (or all!) of your facilities in a while, I’d act now to make sure DEQ will be happy with your asbestos management plans as you move to the AAC-8.
A few quick tips:
1. Visit your sites to make sure your onsite files are accessible – and complete.
2. Make sure your Six Month Periodic Surveillances and Asbestos Management Plan Updates are complete.
3. Make sure your custodial and maintenance staff have received training.
4. Start work to complete the AAC-8 forms.
5. Make sure the facility’s staff can locate your asbestos management plan binder – you probably won’t be there when DEQ stops by.
If you’ve been visited recently, I wouldn’t let my guard down.
If you need help getting your AAC-8 asbestos management plans in order (or help checking to make sure you’re in good shape), please call or email me.