Yes. Custodial and maintenance staff who conduct any activity that results in the disturbance of ACBM must receive the 14-hour training in addition to the 2-hour awareness training. (40 CFR part 763.92(a)(2)). Only custodial or maintenance staff that have had 16 total hours of training can pick-up and dispose of unattached floor tiles. Note that if the material is friable and left over from a response action, then only asbestos model accreditation plan (MAP)-accredited personnel may perform the work. However, if the removal of the material is required in the performance of an emergency or routine maintenance activity, not intended solely as asbestos abatement, then operations and maintenance personnel may remove small amounts of friable asbestos-containing material (ACM). The LEA must ensure that any disposal of asbestos is in accordance with Appendix D of 40 CFR part 763, subpart E or the applicable National Emission Standards for Hazardous Air Pollutants (NESHAP) disposal requirements under 40 CFR part 61.
Under AHERA, does picking up nonfriable asbestos-containing floor tiles for the purposes of disposal constitute "disturbance" of asbestos-containing building material (ACBM) and therefore would require 14-hour training?
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