Asbestos Management
for Facility Managers

1. Building Inventory and Survey Status

Start by inventorying every building in your portfolio with its construction date, square footage, and current asbestos survey status. For buildings constructed before 1980 (or before your state's cutoff date), determine whether a comprehensive asbestos survey has been conducted. Prioritize surveys for buildings that have never been inspected, that are scheduled for renovation, or where maintenance work regularly occurs in areas with suspect materials.

• Create a master list of all buildings with year built and survey status
• Classify buildings as surveyed, partially surveyed, unsurveyed, or post-cutoff
• For unsurveyed pre-1980 buildings, treat all suspect materials as presumed ACM (PACM) until surveyed
• Prioritize survey scheduling based on renovation plans, material risk, and occupancy

2. Centralized Material Inventory

Once surveys are conducted, consolidate all material data into a centralized inventory. For each identified ACM or PACM, record the building, floor, room, material type, quantity, friability, condition, and risk assessment. This inventory is the foundation for every other element of your program.

• Include all confirmed ACM and all presumed ACM from partial surveys
• Record quantities in linear feet, square feet, or cubic feet for NESHAP threshold planning
• Assign condition ratings (good, fair, poor, significantly damaged) to each material
• Link each material to the survey report and laboratory results that identified it

3. Operations and Maintenance Program

An O&M program is the operational core of your asbestos management. It defines how your maintenance staff, contractors, and building operations teams work safely in buildings with ACM. Key elements include:

• Work practice rules for routine maintenance activities near ACM (plumbing, electrical, HVAC, flooring, ceiling work)
• A work permit or clearance process requiring asbestos review before any work that could disturb suspect materials
• Cleaning procedures that prevent fiber disturbance (wet methods, HEPA vacuuming, no dry sweeping of debris near ACM)
• Emergency response procedures for accidental ACM disturbance or damage
• Contractor notification procedures ensuring all outside workers are informed of ACM locations before starting work

4. Periodic Condition Monitoring

ACM conditions change over time due to deterioration, building vibration, water damage, accidental contact, and normal wear. Regular visual monitoring catches damage before it becomes a safety hazard:

• Establish a periodic surveillance schedule (every 6 months is best practice, matching the AHERA standard)
• Train maintenance or facility staff to recognize ACM damage and know what to report
• Document each surveillance with date, observer, materials checked, and findings
• Use mobile inspection tools to streamline field data collection and photo documentation
• Schedule formal reinspections by an accredited inspector every 3 to 5 years

5. Renovation and Demolition Planning

Every renovation or demolition project in a building with known or suspected ACM requires asbestos planning before work begins. This is where NESHAP compliance becomes critical:

• Require a pre-renovation asbestos survey of the affected areas before any project is scoped or bid
• Compare the ACM quantities in the project area against NESHAP threshold amounts (260 LF / 160 SF / 35 CF)
• Build asbestos abatement costs and timelines into the project budget and schedule from the start
• Submit NESHAP notification at least 10 working days before asbestos removal begins
• Ensure abatement contractors are properly licensed and accredited
• Track air monitoring, clearance results, and waste disposal documentation for each project

6. Training Program

All staff who work in buildings containing ACM need appropriate training:

• Asbestos awareness training (2 hours minimum): Required for all custodial, maintenance, and facility staff who work in buildings with ACM. Covers what asbestos is, where it is found, health effects, recognition of damage, and what to do if ACM is disturbed.
• O&M training (16 hours): Required for staff who perform maintenance activities that could disturb small amounts of ACM. Covers work practices, personal protective equipment, and small-scale O&M repair techniques.
• Contractor awareness: Ensure all contractors receive site-specific information about ACM locations before beginning work, and verify their workers have appropriate asbestos training for the work being performed.

7. Recordkeeping

Comprehensive recordkeeping protects your organization during regulatory inspections, litigation, property transactions, and insurance claims:

• Building survey reports and laboratory analytical results
• Material inventory with condition assessment history
• Periodic surveillance and reinspection records
• O&M program documentation and work permit records
• Training records for all staff and contractor notification records
• NESHAP notifications and abatement project documentation
• Air monitoring data and clearance results
• Waste disposal manifests and transporter records

Records should be retained for the life of the building plus any applicable regulatory retention period. Best practice is indefinite retention, since asbestos-related health claims can surface decades after exposure.

Centralized Building and Material Inventory

Every building, floor, room, and material in your portfolio is tracked in one system. You can see the survey status of every building, the condition of every material, and the compliance status of your entire program from a single dashboard. When a new survey is conducted, the data goes directly into the system rather than into a binder on a shelf.

Building Diagrams and Floor Plans

Interactive floor plans show the location of all ACM and PACM in each building. Maintenance staff and contractors can view diagrams from any device to see exactly where asbestos materials are before they start work. Diagrams are automatically updated when materials are abated or conditions change.

Automated Scheduling

Set up surveillance and reinspection schedules once, and the system handles reminders, assignments, and deadline tracking. No more relying on someone to remember to check the calendar. Task management ensures nothing falls through the cracks.

Mobile Field Inspections

Your field staff can perform periodic surveillance and inspections from a phone or tablet, with offline support for areas without connectivity. Data syncs directly to the central system with no transcription required. Photos are attached to specific materials and timestamped for audit purposes.

Renovation Project Integration

When a renovation is planned, query the material inventory for all ACM in the affected areas. Assess NESHAP notification requirements, track abatement contractor credentials, and document the entire project from pre-renovation survey through clearance and waste disposal, all linked to the materials and building records in the system.

Compliance Documentation on Demand

When a regulator requests your asbestos program documentation, when a property transaction requires environmental due diligence, or when a legal matter requires records of past asbestos activities, you can produce the information in minutes from a searchable, centralized system.

What asbestos regulations apply to commercial and government buildings?

Commercial and government buildings are primarily regulated under OSHA standards 1926.1101 (construction) and 1910.1001 (general industry), which require building owners to identify and communicate the presence and location of ACM to employees and contractors. The asbestos NESHAP applies when renovation or demolition will disturb ACM. Most states also have additional asbestos regulations that may require building surveys, management plans, contractor licensing, and notifications.

Is an asbestos management plan required for commercial buildings?

While AHERA specifically requires management plans only for K-12 schools, OSHA requires building owners to inform employers and employees about ACM locations. Many states require formal asbestos management plans for public buildings, and industry best practice strongly recommends maintaining a comprehensive asbestos management plan for any building with known or presumed ACM.

How do I know if my building contains asbestos?

Any building constructed before 1980 is highly likely to contain ACM. Buildings constructed between 1980 and the late 1990s may also contain asbestos in certain products. The only way to confirm is through a building survey conducted by a qualified inspector with bulk sampling and laboratory analysis. Without a survey, all suspect materials in pre-1980 buildings should be presumed to contain asbestos.

What is an asbestos operations and maintenance (O&M) program?

An O&M program is a set of documented procedures to manage ACM in place and prevent accidental disturbance during routine building operations. It includes work practice rules, cleaning procedures, minor repair methods, emergency response protocols, contractor notification requirements, and a permit or clearance process for work near asbestos materials.

Do I need to notify contractors about asbestos in my building?

Yes. Under OSHA 1926.1101, building owners must notify employers and their employees who will perform work in areas where ACM or PACM is present. Under NESHAP, the building owner must ensure contractors are aware of asbestos locations before renovation or demolition work. Failure to notify is one of the most common and costly compliance violations.

How often should asbestos in commercial buildings be reinspected?

Most best practices recommend periodic reinspection at least every 3 to 5 years, or more frequently for materials in poor or fair condition. Many states require periodic reinspections for public buildings. Between formal reinspections, regular visual surveillance should be conducted to monitor material conditions.