On November 28, 1990, Asbestos School Hazard Abatement Reauthorization Act (ASHARA) was enacted. The EPA regulations for implementing ASHARA are under the Model Accreditation Plan (MAP) contained in the Federal Register, dated February 3, 1994 (40 CFR 763 Appendix C to Subpart E). The MAP went into effect October 4, 1994, and require that training be conducted by organizations approved by the state.

• Under the EPA standards implementing ASHARA: 
  • Abatement Worker training requires a 4 day course 
  • Abatement Supervisor training requires a 5 day course
  • Building Inspector training requires a 3 day course
  • Management Planner training requires a 2 day course
  • Class I Worker training requires a 4 day course - (Class I asbestos work means activities involving the removal of asbestos containing material (ACM) and presumed asbestos containing material (PACM) which is "high risk.")
  • Class II Worker training requires a 4 day course - (Class II asbestos work means activities involving the removal of ACM and PACM which is not "high risk.")
  • Class III Worker training requires a 2 day course - (Class III asbestos work means activities involving repair and maintenance where ACM and PACM is disturbed.)
  • Class IV Worker training requires a 2 hour awareness training - (Class IV asbestos work means maintenance and custodial activities during which employees contact ACM and PACM and activities to clean up waste and debris containing ACM and PACM.)

  Note: Individuals providing awareness training to staff, e.g., custodial, must have AHERA training or be a Certified Industrial Hygienist.

• Under OSHA 
  • A competent person as defined in the general construction standards, must supervise all work under the asbestos construction standard. That person must be "capable of identifying existing asbestos * * * hazards in the workplace, and has the authority to take prompt corrective measures to eliminate them * * *" 29 CFR 1926.58[b]. 
    • All workers performing Class I construction work must have continuous access to an on-site supervisor, who meets the training requirements for designation as a "competent person" under this standard.
    • Supervision for Class II and III work does not always require a continuous on-site "competent person," therefore the standard requires inspections at "sufficient" intervals and at employee request.
    • Supervision of installation of asbestos containing construction materials and Class IV work must also be accomplished by complying with the "generic" requirement for "frequent and regular" inspection [Paragraph (0)(2)].
  • Training for the competent person (OSHA interpretation) can be accomplished in a number of ways and meet the standard's performance requirements:
    • For Class I, II and III work, the "competent person" must take a course such as a course under the EPA Model Accreditation Plan for accredited contractor/supervisor, project designer or management planner course, or their equivalent in content, duration, and criteria for success. OSHA interpretation - When pounding a nail or installing a molly anchor into wall materials, such as, joint compound, finishing/texture material, wall plaster, or paint, that contain more than 1% asbestos, to hang a picture, bulletin board, or clock, etc, requires a Class III worker. Surfacing material is defined.
    • Class IV work may be part of larger construction projects, in which case the competent person trained to supervise the project should supervise the on-site cleanup activities which constitute the Class IV work.
  • Duties: OSHA has also expanded the scope of the competent person's duties so that a competent person must supervise all asbestos activities under the construction standard.
• Project Designer: In addition to competent person supervision, the revised standard requires that the person evaluating compliance methods that are alternatives to those in 29 1926.58 (g) Methods of compliance, be qualified as a project designer [1926.58(g)(6)(ii)]. Removal projects which employ sanding, grinding, mechanical chipping, drilling, cutting or abrading the material (other than small-scale-short-duration) must be conducted as response actions, including use of a project designer, accredited persons, and air clearance (55 FR 48409).
  • "Project Designer" means a person who has successfully completed the training requirements for an abatement project designer established by 40 U.S.C. Sec. 763.90(g).

Additional details concerning Occupational Exposure to Asbestos