Managing Asbestos in California
I’m constantly having to remind myself of the progression of training and certification required in California to do any kind of consulting related to asbestos, so I thought I’d capture it in a blog post.
The regulations for asbestos consultants are found in Title 8 of the California Code of Regulations, Section 341.15. They are based on federal AHERA requirements are found in Title 40 of the Code of Federal Regulations, Part 763, Subpart E, Appedix C.
The federal training and certification program includes:
In order to be certified to consult about asbestos issues in California, there is a progression of training and experience:
Step 1: Federal AHERA inspector training. Requires three day course and passing a test. Once you become a building inspector, you can conduct asbestos inspections and collect samples, but you must work under the supervision of a Certified Asbestos Consultant.
Step 2: Federal AHERA Abatement Contractor/Supervisor training. Five more days of training is required, focusing on the practicalities of doing abatement work.
Step 3: Six months of supervised experience under the direction of a certified asbestos consultant.
Step 4: California Site Surveillance Technician exam and registration. An application is submitted, the exam taken, and then you’re certified to perform site inspection independently.
Step 5. Federal AHERA Management/Planner training. Two more days of training on how to prepare operations and maintenance programs and plan for abatement projects.
Step 6. Federal AHERA Project Designer training prepares you for responding to incidents involving releases of asbestos fibers, conducting abatement projects in schools and public buildings, and understanding in detail the health risk aspects of asbestos abatement.
Step 7. Additional year of experience.
Step 8. California Asbestos Consultant exam and registration. Another application is submitted to document and verify all your credentials and experience, and once you pass the exam you’re certified to perform all aspects of asbestos management and planning.
The state issues official ID cards for each certification. The certifications are good for one year, and must be renewed annually after completing 3 days of refresher training.
New categories of Recognized Environmental Conditions mean that financial institutions must adjust their risk appetites
It’s been several months since ASTM released its new standard for Phase I environmental site assessments, E1527-13, and most consulting firms have completed their transition to the 2013 standard that replaces the 2005 version. How are things going so far?
On December 30, 2013, U.S. EPA issued a federal register notice (hyperlink http://www.epa.gov/brownfields/pdfs/fr-notice-recognize-astme.pdf), formally recognizing this standard to meet its All Appropriate Inquiries regulatory rule that provides liability protection from federal Superfund cleanup programs when an innocent landowner conducts the appropriate due diligence prior to acquiring a property. EPA intends to update its All Appropriate Inquiries rule in the near future to formally recognize the E1527-13 standard, but in the meantime both the 2005 and 2013 standards are acceptable.