Recordkeeping for Asbestos Operation and Management (O&M) Plans
You should store all the building asbestos management documents in permanent files, including:
- Inspection and assessment reports
- The O&M program plan
- Work practices and procedures
- Respirator use procedures
- Fiber release reports
- Application for maintenance work and work approval forms
- Evaluations of work affecting ACM
- Reinspections/surveillance of ACM
Recommendations
EPA recommends that building owners make available all written elements of the O&M program to the building’s O&M staff as well as to tenants and other building occupants, if applicable. Building owners are also encouraged to consult with their legal counsel concerning appropriate recordkeeping strategies as a standard part of their O&M programs.
Federal Requirements
Occupational Safety and Health Administration (OSHA) standards require that employers with employees engaged in asbestos-related work retain:
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Personal air sampling records, for at least 30 years; personal air samples are those collected in the worker's breathing zone during performance of work involving asbestos exposures.
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The data used to qualify for exemptions from OSHA's initial monitoring requirements for the duration of the exemption.
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Medical records for each employee subject to the medical surveillance program for the duration of their employment plus 30 years.
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All employee training records for one year beyond the last date of each worker's employment.
Additional OSHA recordkeeping requirements:
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Access to employee exposure and medical records (29 CFR 1910.1020)
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Hazard Communication (29 CFR 1910.1200).
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Also see the OSHA Construction Rule (29 CFR 1926.1101) or the EPA Worker Protection Rule (40 CFR 763 Subpart G) which incorporates the OSHA regulations by reference for certain state and local employees.
EPA's Asbestos in Schools regulations require that Local Education Agencies (LEAs), or school districts, maintain asbestos management plans for all of their school buildings.
Additionally, state and local regulations may also require additional recordkeeping procedures.
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