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Displaying 1 - 15 of 149 results
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If an Asbestos Hazard Emergency Response Act (AHERA) accredited-training course is taught by someone other than instructors certified by the state or the Environmental Protection Agency (EPA), can an approved contractor/instructor sign certificates?
No. An EPA Asbestos Hazard Emergency Response Act (AHERA) accredited training course must be taught by EPA/state approved instructors and only those approved instructors may issue AHERA approved training course certificates. Other Frequent Questions about Asbestos Learn About Asbestos Asbestos and School Buildings Information for Owners and Managers of Buildings…
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Is there a formal requirement that an Asbestos Model Accreditation Plan (MAP) asbestos training course must have a training manual?
Accredited trainers are not required to have a formal training manual, per se. According to the Asbestos Model Accreditation Plan (MAP), at Unit III, (A)(3), (A)(4)(d) and (A)(5) of appendix C to 40 CFR part 763, subpart E, a trainer’s application for course approval must include the course curriculum, a…
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Why are industries exempt under OSHA's PSM subject to RMP?
The Program 3 prevention program requirements under 40 CFR Part 68 are almost identical to the requirements of OSHA's process safety management (PSM) standard. OSHA exempts certain industries from the PSM standard. Why does EPA not exempt those same industries from the CAA §112(r) risk management program requirements? EPA and…
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What if the quantity in the process fluctuates?
What if the quantity in the process fluctuates? I may not have a threshold quantity now, but I will intermittently exceed the threshold quantity. You do not need to comply with the rule and file an RMP unless you have more than threshold quantity in a process; however, once you…
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What are the requirements under the Asbestos Hazard Emergency Response Act (AHERA) for refresher training for a person who wants to "step down" his/her certification from contractor/supervisor status to worker status?
If such a person takes contractor/supervisor refresher courses on an annual basis, that person may perform in both the contractor/supervisor and worker roles. If, however, the person chooses only to take annual worker refresher courses, that person may continue to act in the role of an accredited worker but loses…
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What is the applicability of Federal asbestos inspector accreditation requirements under the Asbestos Hazard Emergency Response Act (AHERA) to real estate appraisers?
Real estate appraisers may not assess the suspected presence, location, or condition of asbestos in a school building or a public and commercial building during an appraisal unless they are accredited pursuant to the Toxic Substances Control Act (TSCA) and the Asbestos Model Accreditation Plan (MAP), as conducting an examination…
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When would a conflict of interest exist among Asbestos Model Accreditation Plan (MAP)-accredited personnel?
A conflict of interest with respect to Asbestos Model Accreditation Plan (MAP)-accredited personnel would exist if, for example, the management planner and abatement contractor worked for the same firm. The planner might recommend to the LEA more expensive response actions than are necessary in the management plan. Other Frequent Questions…
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Change of owner and RMP facility ID number
If a facility is sold to a new owner, does it keep its' original RMP Facility ID number? Yes. The facility will keep the ID number assigned by EPA.
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Facility ID number and re-registering a facility
If a facility deregisters, then reregisters, should the facility use the original RMP Facility ID or will it be assigned a new ID? The facility should use the original ID assigned by EPA.
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Resubmission of RMP for a facility that previously deregistered
A covered facility deregisters its RMP because it no longer has more than a threshold quantity of a regulated substance in a covered process. If the facility becomes subject to the CAA §112(r) risk management program regulations at a later date and submits a new RMP, should the facility submit…
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RMP Records Maintained Onsite
Pursuant to 40 CFR Part 68, Subpart G, the owner or operator of a stationary source subject to the risk management program regulations in Part 68 must develop and submit a risk management plan (RMP). Does the owner or operator have to maintain a written copy of the RMP on…
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Process identification and distance between vessels
How far apart do separate vessels have to be to be considered different processes? There is no hard and fast rule for how great this distance should be before you do not need to consider the vessels as part of one process. Two vessels at opposite ends of a large…
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What does "same industrial group" mean?
Operations at a site that belong to the same three-digit North American Industry Classification System (NAICS) code prefix (which has replaced the old SIC codes) belong to the “same industrial group. In addition, where one or more operations at the site serve primarily as support facilities for the main operation…
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Updating RMP if EPA lists a new substance
What if EPA lists a new substance? You will have three years from the date on which the new listing is effective to come into compliance for any process that is covered because EPA has listed a new substance.
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Should tank capacity be considered when determining thresholds?
When determining whether a threshold amount of a regulated substance is present in a process (e.g., a tank), must the owner or operator of a stationary source consider the total capacity of the process, or the actual amount of regulated substance contained in the process? The threshold determination is based…
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