- Review your management plans and data, and determine if the ceiling tile results were obtained through an appropriate test, ELAP items 198.6 or 198.4. If the tiles were correctly tested in accordance with the current protocols and the data are available, no additional testing is required. If that information is not available, or if the results were not obtained in accordance with ELAP items 198.6 or 198.4, school districts should consider testing as either part of an existing or planned capital improvement or as an independent analysis prior to disturbance.
- Be aware that ceiling tiles and other products purchased today can still contain asbestos, but many manufacturers offer documentation as to the asbestos free nature of their products. Some manufacturers date stamp ceiling tiles. If you can provide documentation of when and where the tiles were purchased and installed, the manufacturer should be able to provide documentation or certification that they do not contain ACM, and your management plan should be updated accordingly.
- If you have documentation that your ceiling tiles or other materials are non-ACM, additional testing is not required, however, as in any investigation, actual bulk sample results would supersede documentation in an analysis of the situation.
- Check the ELAP list, contained in the web links above, to see if any other materials in your school that may be disturbed such as vinyl tile, mastic, caulking, etc, were tested under the correct protocol, and the results are available. If these items were not tested properly under the current protocol with negative results they should be considered for additional sampling prior to any disturbance.
- If ceiling tiles and other materials are found to be asbestos containing under the current analysis method, the schools asbestos management plan must be updated in accordance with AHERA regulations. Areas with significantly damaged ceiling tiles must be isolated and the damaged areas removed in accordance with AHERA and code rule 56. Districts should consider whether to undertake capital projects if certain ceilings must be accessed on a regular basis.
Considering my reccent article in Future Focus, it seems like someone else is thinking along the same lines as myself.