We recently had a dissatisfied customer who didn't understand the training requirements under the Environmental Protection Agency's (EPA's) Model Accredited Plan (MAP) and the New York State Department of Health's (NYSDOH's) 10 New York Code of Rules and Regulations (NYCRR) Part 73. The customer registered for an asbestos management planner refresher course when his asbestos inspector training was in the grace period. We had to explain that he couldn't take the asbestos management planner refresher course until he refreshed his asbestos inspector training.
We are writing a blog post because many people remain unclear about expiration dates. Expiration dates are the most frequent question we receive at Future Environment Designs, Inc. (FEDTC). “When does my asbestos training expire?” And, just as importantly: “What happens if my training certificate expires?”
The confusion is understandable because there are multiple agencies involved in asbestos accreditation and certification in New York, and they do not all use the same expiration dates. There is the New York State Department of Labor (NYSDOL), which issues the asbestos handling certificate—what most people in the industry call the “hard card.” This card's expiration date is based on the last day of your birth month in relation to when you took your initial training. NYSDOL may give you a hard card with an expiration date that may be over a year from your initial training expiration date. This is not allowed under the EPA MAP.
Then there is the New York State Department of Health (NYSDOH), which oversees asbestos safety training providers and the training certificate, DOH-2832 form. This form follows the requirements for EPA's MAP and 10 NYCRR Part 73, requiring annual training based on the training completion date.
And, for those working in New York City, there is the New York City Department of Environmental Protection (NYCDEP), which has its own certification requirements. NYCDEP certificates are valid for two years from the date of issuance, which is also based on birth month. This, too, is not allowed under the EPA MAP. So let's break this down.
First, Let's Talk About the NYSDOL Hard Card
NYSDOL oversees asbestos licensing and certification in New York State. The company receives an asbestos handling license, while the individual receives an asbestos certificate, the hard card.
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| NYSDOL License and hard card |
The important thing to remember is that the hard card and the training certificate (DOH-2832) are not the same thing.
Your NYSDOL asbestos certificate has its own expiration date based on the birth month. NYSDOL's current information should be checked when determining the status of an individual certificate because the Department's certification requirements and administrative procedures can change. And this is where people sometimes get themselves into trouble. They look at the expiration date on their hard card and think: “I'm good until this date.”
Not necessarily. Let's look at how that can get you in trouble federally.
EPA's 12-Month Grace Period Recommendation
An important piece of this discussion goes back to the EPA's asbestos accreditation requirements. The EPA Model Accreditation Plan specifically recommends that states establish a 12-month grace period that allows formerly accredited individuals whose certificates have expired to complete refresher training and have their accreditation reinstated without having to retake the initial course.
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| Asbestos Pipe Insulation |
That is important because the whole concept behind refresher training is to maintain competency. The idea is not that someone suddenly forgets everything they learned the day their certificate expires. The purpose of the refresher is to keep the individual current with regulations, procedures, technology, and changes in the industry. And NYSDOH's current rules reflect that basic concept by providing the one-year grace period for completing refresher training after the expiration date of the training certificate; after that year you must take the initial course over again. However, NYSDOL's current rules do not comply with the MAP, giving you a hard card expiration date based on the last day of your birth month. That expiration date can be after the expiration date of your DOH-2832 form.
A grace period does not equal authorization to perform asbestos work. That is where we think some of the confusion comes from.
The DOH-2832 Is a Different Certificate
NYSDOH regulates the asbestos safety training providers and the training programs through 10 NYCRR Part 73. The DOH-2832 is the official NYSDOH certificate of asbestos safety training completion. This certificate has an expiration period of one year from the date you successfully completed the training and examination. NYSDOH specifically states that asbestos workers must maintain current training by completing annual refresher training. There is a one-year grace period based on the DOH-2832 form's expiration date.
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| DOH-2832 Training Certificate |
NYSDOH training providers are required to verify initial and refresher training credentials submitted by individuals before their enrollment in a refresher program. Verification of training credentials to ensure valid accredited training is a prerequisite for admittance into a NYSDOH-approved refresher training course. What is valid accredited training? The DOH-2832 form expiration date. In other words, as long as you are in your grace period, you can take a refresher course based on a year from the DOH-2832 expiration date.
So, essentially: Training expires → one-year grace period → refresher training must be completed → after the grace period, initial training is required. That is a very important distinction. The grace period does not mean you can continue performing asbestos work for another year. EPA specifically states that once the training expires, the individual cannot be actively engaged in asbestos work during the grace period.
The Consequences of Birthdate versus Course Completion Date
According to EPA, you cannot do asbestos work in the grace period. So if NYSDOL's hard card expires after your training expiration date, you are technically in a grace period for the purposes of EPA and should not be doing asbestos work. It means you are in violation of EPA's MAP. The problem can come if, for some reason, you go past one year after the expiration date of the DOH-2832. If that should happen, you would need to take an initial training even if your hard card happened to be current or in its grace period.
There Is Another Important Requirement: Management Planners
There is also a reason we emphasize keeping your training current. If you are an inspector and want to move into the management planner discipline, you cannot simply show up for management planner training after your inspector credentials have expired. NYSDOH Part 73 specifically states: “Possession of current and valid inspector accreditation shall be a prerequisite” for admission to the management planner initial or refresher training program.
That means your inspector accreditation needs to be current. This is another reason why waiting until the last minute—or allowing your credentials to expire—can create problems.
What About New York City?
If you work in New York City, you have another layer to consider. The NYCDEP has its own asbestos certification program under Title 15, Chapter 1 of the Rules of the City of New York. NYCDEP certifies asbestos handlers, restricted handlers, handler supervisors, and asbestos investigators. NYCDEP currently states that these certificates are valid for two years.
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| Ancient NYCDEP hard card (new ones look similar to NYSDOL hard cards) |
But here's the important part: A two-year NYCDEP hard card does not mean you only need asbestos training every two years. EPA's and New York State's annual training requirements still apply. So someone working in New York City may have:
- NYSDOL certificate: its own expiration date based on birth month.
- NYSDOH training: annual refresher requirement based on training date.
- NYCDEP certificate: generally two-year certification based on birth month
Three different things. Three different requirements. And this is why we continue to get questions about expiration dates.
Don't Wait Until Your Card Expires
Here's our advice after all these years in the asbestos training business: Don't wait until your expiration date to start looking for a refresher course. Check both your hard card and your DOH-2832. Put the expiration dates on your calendar. Talk to your employer. And schedule your refresher training before you have a problem.
At FEDTC, we have always believed that training never ends. A refresher course shouldn't be viewed as just another regulatory requirement that has to be checked off a list. It is an opportunity to review what has changed, revisit what may have been forgotten, discuss what we are seeing in the field, and learn from the experiences of other professionals in class.
The asbestos regulations continue to evolve. Sampling practices change. Analytical technology changes. Work practices change. And, as we have been discussing in our recent classes, even something as seemingly simple as determining whether a material needs to be sampled can become complicated very quickly. That is why staying current matters.
The Bottom Line
If you take only one thing away from this article, let it be this: Don't confuse your NYSDOL hard card with your NYSDOH training certificate. They are separate requirements.
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| Asbestos O&M Initial Course |
Your NYSDOL certificate has its own expiration requirements based on birth month, while NYSDOH asbestos safety training is required annually based on training date. NYSDOH provides a one-year grace period after training expires, but individuals cannot actively perform asbestos work during that grace period. If the grace period expires without completing the required refresher, the individual must repeat the initial training.
And if you are an inspector planning to become a management planner, remember that current and valid inspector accreditation is required for admission to management planner training. There is really no reason to let your training lapse.
Know your dates. Know which credential is expiring. Know what agency issued it. And, most importantly, don't wait until you are standing at the job site to find out that your credentials are no longer current.
At FEDTC, we would much rather see you in class for your refresher before there is a problem than have you calling us because you just discovered your training expired. Hence the reason we send out reminders (snail mail & email) for refresher training based on the training date.
Training never ends—and neither should your commitment to staying current.
