Asbestos consulting for church schools......

Statewide church school system

A school system operated by a Conference of churches is subject to the EPA AHERA requirements for asbestos management as well as the Texas Asbestos Health Protection Rules. Since 2008 I have provided consulting services to the Conference for the management of asbestos-containing building materials (ACBM) in these schools.

I have conducted initial inspections and three-year re-inspections in thirteen schools and am in the process of evaluating the remaining schools to ensure that the management plans reflect the facilities currently used for educational purposes. While complying with the AHERA assessment requirements, I also use the quantitative protocol in the ASTM E2356 Standard Practice for Comprehensive Building Asbestos Surveys. I document my findings in a narrative report, tables of inspection and sampling results, and floor plans. The management plans, inspection reports, Operations and Maintenance plans and supporting documentation are submitted as electronic files as well as the hard copy required by EPA and the Texas Department of State Health Services. For schools with ACBM, six-month periodic surveillance is an on-going process that is facilitated by forms that I have developed for use by school staff.

One of the school complexes consists of eleven high-school, elementary-school and administrative buildings. My findings included asbestos floor tile under carpet that had not been previously identified in two buildings and asbestos-containing textured finish on ceilings in two other buildings. The Conference accepted my recommendation, based on assessments according to the ASTM E2356 standard, to have the ceilings removed. I managed the abatement project as their representative, conducting the Project Design Survey, soliciting proposals and overseeing the work of the selected contractor. Because work was proceeding in both buildings simultaneously I retained the services of a licensed project monitor for on-site PCM analysis and assistance with visual inspections (according to ASTM E1368) and air sampling. Final clearance samples were analyzed by TEM as required by AHERA regulations and no asbestos structures were detected. Immediately prior to this project I managed an abatement project to remove carpet and underlying floor tile in another school operated by the Conference. ASTM E1368 visual inspections and TEM analysis of clearance samples were also used on this project.

Some of the buildings in the Conference school system are free-standing while others are physically attached to church buildings. Some of the spaces used by the school and therefore subject to AHERA are also used for church functions, and the school buildings are often cleaned, maintained and even renovated by church volunteers. This situation poses challenges to compliance with AHERA and the Texas regulations for the management plans, O&M plans and notification.


Non-asbestos plaster ceiling in classroom

Removing ceiling with asbestos-containing textured finish


Removing carpet, floor tile and mastic

Six-building church school complex

I assisted a church school with coming into compliance with the AHERA regulations by preparing management plans for their buildings. For five of the buildings I obtained “asbestos-free” certifications from the architects that comply with EPA requirements and therefore did not have to inspect the buildings or take samples. Because a certificate could not be obtained for the oldest building, I conducted an inspection that found no ACBM and referenced my report in the management plan.

Charter school in church building

I inspected a 45,000 ft² church building that was being renovated to provide space for a charter school, including an entire unfinished second floor. No ACBM was found and I prepared an inspection report based on my pre-renovation inspection. After the renovation was completed I obtained an “asbestos-free” certification from the architect who had designed the renovation and prepared a management plan referencing my pre-renovation inspection report and the architect’s certification.

Church building used as charter school