Why this matters
The Asbestos Hazard Emergency Response Act (AHERA) applies to every public and non-profit private K–12 school in Texas, regardless of whether asbestos has been found. Compliance is a calendar, not a one-time project — and the audits that catch districts almost always find a missed recurring item rather than a missing original inspection.
Every six months
- Periodic surveillance of every building with known or assumed asbestos-containing material (ACM), by trained staff — a visual check for damage or deterioration, documented and filed in the management plan.
- Confirm warning labels in routine maintenance areas are present and legible; replace any that are missing.
Every three years
- Reinspection of all known or assumed ACM by an accredited asbestos inspector (in Texas, a TDSHS-licensed inspector), with condition reassessment and updated response-action recommendations from a licensed management planner.
- Update the management plan with the reinspection report and any changes in response actions.
Every year
- Written notification to parent, teacher, and employee organizations that the management plan is available for review and describing any asbestos-related activity completed or planned.
- Confirm every custodial and maintenance employee has had the 2-hour awareness training, and that staff who perform O&M work on or near ACM have the additional 14-hour training. Add new hires as they arrive.
Ongoing
- A formally appointed designated person who has completed the required training and oversees the program.
- The management plan kept current and available in the district office and each campus, and producible within five working days of a request.
- Records retained for the life of each building: inspections, surveillance, response actions, training, notifications, and air sampling.
- Before any renovation or demolition, the AHERA plan is consulted and a licensed pre-renovation survey is performed as the Texas rules require — the AHERA inspection is not a substitute for a project-specific survey.
- Short-term workers (plumbers, electricians, telecom crews) are told where ACM is before they open walls or ceilings.
Where districts get caught
- Surveillance performed but not documented — if it isn't in the plan, it didn't happen.
- A three-year reinspection that lapsed by a few months when a facilities director changed.
- Annual notifications that went out to parents but not to employee organizations.
- New buildings or portables never added to the management plan (a new building needs either an inspection or an architect's statement that no ACM was specified).
- Renovations done from the AHERA inventory alone, without the pre-renovation survey Texas requires.
TSEC performs three-year reinspections, management plan updates, and pre-renovation surveys for Texas districts, and can train your staff for the six-month surveillance so it happens on time. Request a proposal for your district.