Electronic Asbestos Management Plan
Electronic Recordkeeping for Asbestos Management Plans Frequently Asked Questions
1. Can we keep our asbestos management plans (AMPs) in an electronic format?
Yes. Asbestos Hazard Emergency Response Act (AHERA) does not prohibit Local Education Agencies (LEAs) from maintaining records in an electronic format. Records must be available to the public upon request, without cost or restriction, at each school and the LEA's administrative office within 5 working days. An LEA may scan and store documents containing original signatures in electronic format. However, such documents must be available and accessible in their entirety (40 CFR part 763.93(g)(2) or (3)).
For accessibility, the electronic system must have the capability to print a hard copy of the AMP. Also, the LEA must ensure the availability of assistance for those wishing to review the AMP.
2. Do I need to have backup paper copies of our AMP?
No. AHERA does not require AMPs to be in paper format. However, LEAs should create a backup copy of the latest, updated version of the AMP (either electronic or hard copy). Also, it should be easily accessible if the primary electronic files become compromised.
3. Can we convert our paper files to an electronic format?
Yes. The AMP must include scanned documents that contain original signatures.
4. Can we maintain our electronic AMP using an internet cloud service (i.e. OneDrive, Google Drive, etc.)?
Yes. AHERA does not require an LEA to keep records in a specific format. Records must be available at each school and the LEA’s administrative office upon request.
5. Are we out of compliance if our AMPs get corrupted or lost?
Yes. AHERA requires AMPs to be available for review. Failure to meet this requirement is a violation of state and federal regulations. LEAs should keep backup records to ensure the AMP is always available for review.
6. Can a third party assist us with maintaining our AMP?
Yes. A third party may assist an LEA with keeping an electronic AMP. A third party should never own the AMP. The LEA should always be the true owner of the records.
7. Can we maintain our electronic AMP in a proprietary format?
Yes, but the LEA must have the ability to print or export the records to a non-proprietary format.
8. What documents in our AMP should we update regularly?
An AMP is a living document. LEAs should update AMPs regularly. The following is a list of common records that should receive updates:
- 6-month periodic surveillance reports
- 3-year reinspection reports
- Custodial and maintenance staff asbestos awareness training
- Designated person training
- Annual notifications to parents, teachers, and employee organizations
- Operations and Maintenance activity
- An inventory list for each school building that includes the:
- School building's name
- Whether the building contains friable/nonfriable ACBM
- Whether the building contains suspected friable/nonfriable ACBM assumed to be ACBM
This list only comprises commonly updated AHERA documents. It is not a comprehensive list of every record that may need updates.
9. Can we send our AMP for a new school or wing addition to the State electronically?
Yes. An LEA may submit AMPs to the State electronically. LEAs are not required to submit AMPs after converting to electronic copies. A plan submission to the State is only required for new school buildings under AHERA regulations in 40 CFR, Title 40, Section 763.98(a).
To submit a new plan electronically, please email a PDF copy to AHERA Help.
Please note, the method above is not for submitting AMPs related to non-compliance. If you received a notice of noncompliance from DSHS, please follow the directions in the notice to submit your AMP.