AHERA re-inspections and periodic surveillance
Every three years, every building. Public districts and non-profit private schools carry permanent asbestos duties under 40 CFR Part 763 Subpart E — and they arrive on a calendar whether or not anything has changed.
What the rule requires
Once a management plan is in effect, a local education agency carries three recurring obligations. They don't expire, and they apply to every building with known or assumed asbestos-containing material.
| Duty | Frequency | Cite |
|---|---|---|
| Re-inspection | At least every 3 years, by an accredited inspector | 763.85(b) |
| Periodic surveillance | At least every 6 months | 763.92(b) |
| Management plan | Maintained current, by an accredited management planner | 763.93(e) |
What a re-inspection actually involves
It isn't a walk-through. A re-inspection requires visual inspection and physical assessment of all friable and non-friable known or assumed asbestos-containing material — touching previously identified non-friable material to determine whether it has become friable, and identifying any homogeneous area that has become friable since the last inspection.
Findings go to the designated person within 30 days. The record needs to be complete enough that a compliance review years from now can follow what was assessed and why.
Periodic surveillance
Every six months, visual inspection of all known or assumed asbestos-containing material, with the condition recorded. Straightforward work, but it has to happen on schedule and it has to be documented — and it is the obligation most often discovered to be missing.
Portfolio scheduling
A district is rarely one building. Re-inspection dates drift apart over the years, surveillance falls due in different months, and tracking it across a dozen sites becomes its own job. I'll map the whole portfolio to a calendar and work it, so compliance stops being something somebody has to remember.
Where my accreditation sits
I hold EPA AHERA Building Inspector accreditation — the accreditation 763.85(b) requires for re-inspections. I can perform three-year re-inspections and periodic surveillance.
I am not currently accredited as a Management Planner, so I do not develop or update management plans. 763.93(e) reserves that to an accredited management planner, and I'd rather tell you that up front than have you find out later.
Who this is for
Public school district facilities and maintenance directors, AHERA designated persons, and business managers at non-profit private schools.
Also available
Pre-renovation surveys when a building project starts, abatement oversight and clearance when removal is scheduled, and mold and moisture assessment.
All services →
When were your buildings last re-inspected?
If the answer is "we'd have to check," that's worth a conversation. Send a building list and I'll tell you where the portfolio stands.