How to Create an
Asbestos Management Plan

1 Building Information

The foundation of your plan starts with identifying every building in scope. For each building, document:

• Building name, address, and unique identifier
• Year of construction (buildings constructed after October 12, 1988 are generally exempt from AHERA, though they may still contain asbestos from imported materials)
• Building type and use (school, administrative, maintenance, etc.)
• Total square footage and number of floors
• Date of original asbestos inspection
• Name of the LEA or responsible organization

2 Inspection and Sampling Records

The plan must contain a complete record of all asbestos inspections performed in each building. This includes:

• Original inspection report with inspector name, credentials, and date
• All 3-year reinspection reports in chronological order
• Bulk sampling locations and laboratory analysis results
• Name and accreditation of the laboratory that analyzed samples
• Classification of each material as confirmed ACM, presumed ACM (PACM), or non-ACM
• Areas that were inaccessible during inspection and are assumed to contain ACM
• Accreditation certificates for inspectors and management planners

3 Material Inventory

The material inventory is the core data set of your plan. For every asbestos-containing or presumed asbestos-containing material, record:

• Material type (e.g., floor tile, pipe insulation, ceiling tile, spray-applied fireproofing, transite siding)
• Asbestos fiber type if known (chrysotile, amosite, crocidolite)
• Friability classification (friable vs. non-friable)
• Location by building, floor, room, and functional area
• Estimated quantity (linear feet, square feet, or cubic feet)
• Current condition assessment (good, fair, poor, significantly damaged)
• Risk score or priority rating based on condition, accessibility, and activity level
• Homogeneous area grouping

4 Floor Plans and Diagrams

Visual documentation is essential for helping maintenance staff, contractors, and inspectors quickly identify where ACM is located. Your plan should include:

• Floor plans for each building showing the location of all ACM and PACM
• Color coding or symbols to distinguish material types and condition categories
• Identification of inaccessible areas assumed to contain ACM
• Updated diagrams that reflect abatement work and building modifications

5 Operations and Maintenance (O&M) Procedures

The O&M section defines the day-to-day work practices that prevent accidental disturbance of ACM. This is one of the most important sections because it directly protects the people who work in your buildings every day.

• General work practice rules for activities near ACM (no drilling, cutting, sanding, or demolishing without prior authorization and asbestos review)
• Specific procedures for common maintenance tasks: plumbing work near pipe insulation, electrical work in ceilings with ACM, HVAC maintenance around duct insulation, floor work on vinyl asbestos tile
• Cleaning procedures that avoid disturbing friable materials (wet methods, HEPA vacuuming, no dry sweeping)
• Small-scale O&M repair procedures for minor damage (glove bag removal, encapsulation, wet wipe-down)
• Emergency response procedures for accidental fiber release (isolate area, restrict access, notify Designated Person, arrange for professional assessment)
• Contractor notification requirements (all outside contractors must be informed of ACM locations before beginning work)
• Work permit or clearance process for any activity that may disturb ACM

6 Periodic Surveillance Records

Six-month periodic surveillance between 3-year reinspections provides ongoing monitoring of ACM condition. Your plan must include documented surveillance records:

• Date of each surveillance activity
• Name of the person conducting surveillance
• Buildings, rooms, and materials inspected
• Observations on material condition (any changes from previous surveillance)
• Actions taken or recommended in response to findings
• Confirmation that warning labels are intact

7 Response Action Records

When ACM is damaged, deteriorated, or will be disturbed by renovation or demolition, a response action is required. The plan must document all past and planned response actions:

• Description of the response action (removal, encapsulation, enclosure, repair, or operations and maintenance)
• Recommendation from an accredited management planner
• Name and credentials of the abatement contractor
• Project design by an accredited project designer (when required)
• NESHAP notification filed with the appropriate regulatory agency
• Air monitoring data collected during and after abatement
• Final clearance sampling results
• Waste disposal documentation and manifest records
• Date of completion and updated material inventory reflecting the work

8 Training Records

The plan must document all asbestos-related training for staff who work in buildings containing ACM:

• Names of all staff who have completed asbestos awareness training (minimum 2 hours)
• Names of staff who have completed additional O&M training (14 hours)
• Training dates, topics covered, and instructor credentials
• Refresher training dates and schedules
• Accreditation records for inspectors, management planners, project designers, and abatement workers

9 Notification Records

Under AHERA, schools must notify parents, teachers, and employees annually about the management plan. Your plan should include:

• Copies of each annual notification sent
• Dates notifications were distributed
• Method of delivery (mail, email, newsletter, posted notice)
• Recipient groups (parent organizations, teacher unions, employee groups)
• Documentation confirming the management plan was made available for review

10 Designated Person Information

The plan must clearly identify who is responsible for overseeing the asbestos management program:

• Name, title, and contact information of the current Designated Person
• Date of appointment
• Documentation of authority and responsibilities
• History of previous Designated Persons (for continuity)

Step 1: Conduct or Verify the Building Inspection

Everything starts with knowing what you have. If your buildings have never been inspected, or if the original inspection is significantly outdated, engage an EPA-accredited inspector to perform a comprehensive survey. If inspections exist, verify that they cover all buildings and all accessible areas, and that laboratory results are on file for all sampled materials.

Step 2: Build the Material Inventory

Using inspection data, create a structured inventory of every ACM and PACM in every building. Organize by building, floor, and room. Assign condition assessments and risk scores to each material. This inventory is the data backbone of your entire plan.

Step 3: Create Floor Plans

Develop or update floor plans for each building showing the locations of all inventoried materials. These diagrams are essential for maintenance staff and contractors who need to know where ACM is located before performing any work.

Step 4: Establish O&M Procedures

Write clear, practical operations and maintenance procedures that your staff can actually follow. Focus on the specific maintenance activities that occur in your buildings and the specific types of ACM present. Generic O&M templates are a starting point, but your procedures should be tailored to your facilities.

Step 5: Set Up Inspection and Surveillance Schedules

Calculate and schedule the next 3-year reinspection date for each building. Set up a 6-month periodic surveillance calendar. Assign responsibility for each surveillance event and establish a documentation process for recording findings.

Step 6: Train Staff

Ensure all custodial and maintenance staff receive the required awareness training before they work in buildings with ACM. Provide additional O&M training for staff who may perform work that could disturb materials. Document all training and schedule refreshers.

Step 7: Assemble, Distribute, and Maintain

Compile all components into a complete management plan. Ensure copies are available at each building and at the central administrative office. Establish a process for ongoing updates as inspections occur, conditions change, response actions are completed, and training is delivered. Send the first annual notification to required parties.

What is an asbestos management plan?

An asbestos management plan is a written document that describes the location, condition, and management procedures for asbestos-containing materials in a building or group of buildings. It includes inspection results, material inventories, risk assessments, operations and maintenance procedures, training records, notification documentation, and response action plans. Under AHERA, every public and non-profit K-12 school must maintain an asbestos management plan.

Who is responsible for creating the asbestos management plan?

Under AHERA, the Local Education Agency (LEA) is responsible for developing and maintaining the asbestos management plan for each school building. The LEA appoints a Designated Person to oversee this process. Response action recommendations within the plan must be made by an EPA-accredited management planner based on inspection findings. For commercial and industrial buildings, the building owner or duty holder is responsible under applicable state and federal regulations.

How often should an asbestos management plan be updated?

The plan should be updated after every 3-year reinspection, after any response action or abatement work, when new asbestos-containing materials are discovered, when material conditions change significantly, and when training or notification records need to be added. In practice, this means the plan is a living document that should be reviewed and updated at least annually.

What happens if a building does not have an asbestos management plan?

For schools, the absence of an asbestos management plan is a violation of AHERA and can result in EPA civil penalties of up to $51,744 per day per violation. Beyond fines, lacking a management plan means there is no documented record of where asbestos materials are located, creating a serious risk of accidental disturbance during maintenance or renovation work.

Can I use software to maintain my asbestos management plan?

Yes. Cloud-based asbestos management software replaces paper binders with a centralized digital platform that stores material inventories, inspection reports, surveillance logs, training records, and notification documentation. Software automates scheduling for reinspections and surveillance, provides real-time compliance dashboards, and ensures the plan is always current and accessible from any location.

Does AHERA require a separate management plan for each building?

AHERA requires that the management plan include information for each school building under the LEA. While this can be organized as one comprehensive district plan with building-level sections, each building must have its own inspection results, material inventory, floor plans, surveillance records, and response action documentation. A copy of the management plan must be available at each school building and at the LEA administrative office.