EPA ICR No. 1365.08; OMB Control No. 2070-0091

Attachment D

Model Accreditation Plan

40 CFR 763, Subpart E, Appendix C

       Appendix C to Subpart E--Asbestos Model Accreditation Plan

             I. Asbestos Model Accreditation Plan for States

    The Asbestos Model Accreditation Plan (MAP) for States has eight 

components:

    (A) Definitions

    (B) Initial Training

    (C) Examinations

    (D) Continuing Education

    (E) Qualifications

    (F) Recordkeeping Requirements for Training Providers

    (G) Deaccreditation

    (H) Reciprocity

A. Definitions

    For purposes of Appendix C:

    1. ''Friable asbestos-containing material (ACM)'' means any material
containing more than one percent asbestos which has been applied on
ceilings, walls, structural members, piping, duct work, or any other
part of a building, which when dry, may be crumbled, pulverized, or
reduced to powder by hand pressure. The term includes non-friable
asbestos-containing material after such previously non-friable material
becomes damaged to the extent that when dry it may be crumbled,
pulverized, or reduced to powder by hand pressure.

    2. ''Friable asbestos-containing building material (ACBM)'' means
any friable ACM that is in or on interior structural members or other
parts of a school or public and commercial building.

    3. ''Inspection'' means an activity undertaken in a school building,
or a public and commercial building, to determine the presence or
location, or to assess the condition of, friable or non-friable
asbestos-containing building material (ACBM) or suspected ACBM, whether
by visual or physical examination, or by collecting samples of such
material. This term includes reinspections of friable and non-friable
known or assumed ACBM which has been previously identified. The term
does not include the following:

    a. Periodic surveillance of the type described in 40 CFR 763.92(b)
solely for the purpose of recording or reporting a change in the
condition of known or assumed ACBM;

    b. Inspections performed by employees or agents of Federal, State,
or local government solely for the purpose of determining compliance
with applicable statutes or regulations; or

    c. visual inspections of the type described in 40 CFR 763.90(i)
solely for the purpose of determining completion of response actions.

    4. ''Major fiber release episode'' means any uncontrolled or
unintentional disturbance of ACBM, resulting in a visible emission,
which involves the falling or dislodging of more than 3 square or linear
feet of friable ACBM.

    5. ''Minor fiber release episode'' means any uncontrolled or
unintentional disturbance of ACBM, resulting in a visible emission,
which involves the falling or dislodging of 3 square or linear feet or
less of friable ACBM.

    6. ''Public and commercial building'' means the interior space of
any building which is not a school building, except that the term does
not include any residential apartment building of fewer than 10 units or
detached single-family homes. The term includes, but is not limited to:
industrial and office buildings, residential apartment buildings and
condominiums of 10 or more dwelling units, government-owned buildings,
colleges, museums, airports, hospitals, churches, preschools, stores,
warehouses and factories. Interior space includes exterior hallways
connecting buildings, porticos, and mechanical systems used to condition
interior space.

    7. ''Response action'' means a method, including removal,
encapsulation, enclosure, repair, and operation and maintenance, that
protects human health and the environment from friable ACBM.

    8. ''Small-scale, short-duration activities (SSSD)'' are tasks such
as, but not limited to:

    a. Removal of asbestos-containing insulation on pipes.

    b. Removal of small quantities of asbestos-containing insulation on
beams or above ceilings.

    c. Replacement of an asbestos-containing gasket on a valve.

    d. Installation or removal of a small section of drywall.

    e. Installation of electrical conduits through or proximate to
asbestos-containing materials.

    SSSD can be further defined by the following considerations:

    f. Removal of small quantities of ACM only if required in the
performance of another maintenance activity not intended as asbestos
abatement.

    g. Removal of asbestos-containing thermal system insulation not to
exceed amounts greater than those which can be contained in a single
glove bag.

    h. Minor repairs to damaged thermal system insulation which do not
require removal.

    i. Repairs to a piece of asbestos-containing wallboard.

    j. Repairs, involving encapsulation, enclosure, or removal, to small
amounts of friable ACM only if required in the performance of emergency
or routine maintenance activity and not intended solely as asbestos
abatement. Such work may not exceed amounts greater than those which can
be contained in a single prefabricated mini-enclosure. Such an enclosure
shall conform spatially and geometrically to the localized work area, in
order to perform its intended containment function.

B. Initial Training

    Training requirements for purposes of accreditation are specified
both in terms of required subjects of instruction and in terms of length
of training. Each initial training course has a prescribed curriculum
and number of days of training. One day of training equals 8 hours,
including breaks and lunch. Course instruction must be provided by EPA
or State-approved instructors. EPA or State instructor approval shall be
based upon a review of the instructor's academic credentials and/or
field experience in asbestos abatement.

    Beyond the initial training requirements, individual States may wish
to consider requiring additional days of training for purposes of
supplementing hands-on activities or for reviewing relevant state
regulations. States also may wish to consider the relative merits of a
worker 

apprenticeship program. Further, they might consider more stringent
minimum qualification standards for the approval of training
instructors. EPA recommends that the enrollment in any given course be
limited to 25 students so that adequate opportunities exist for
individual hands-on experience.

    States have the option to provide initial training directly or
approve other entities to offer training. The following requirements are
for the initial training of persons required to have accreditation under
TSCA Title II.

    Training requirements for each of the five accredited disciplines
are outlined below. Persons in each discipline perform a different job
function and distinct role. Inspectors identify and assess the condition
of ACBM, or suspect ACBM. Management planners use data gathered by
inspectors to assess the degree of hazard posed by ACBM in schools to
determine the scope and timing of appropriate response actions needed
for schools. Project designers determine how asbestos abatement work
should be conducted. Lastly, workers and contractor/supervisors carry 

out and oversee abatement work. In addition, a recommended training
curriculum is also presented for a sixth discipline, which is not
federally-accredited, that of ''Project Monitor.'' Each accredited
discipline and training curriculum is separate and distinct from the
others. A person seeking accreditation in any of the five accredited MAP
disciplines cannot attend two or more courses concurrently, but may
attend such courses sequentially.

    In several instances, initial training courses for a specific
discipline (e.g., workers, inspectors) require hands-on training. For
asbestos abatement contractor/supervisors and workers, hands-on training
should include working with asbestos-substitute materials, fitting and
using respirators, use of glovebags, donning protective clothing, and
constructing a decontamination unit as well as other abatement work
activities.

	1. Workers

    A person must be accredited as a worker to carry out any of the
following activities with respect to friable ACBM in a school or public
and commercial building: (1) A response action other than a SSSD
activity, (2) a maintenance activity that disturbs friable ACBM other
than a SSSD activity, or (3) a response action for a major fiber release
episode. All persons seeking accreditation as asbestos abatement workers
shall complete at least a 4-day training course as outlined below. The
4-day worker training course shall include lectures, demonstrations, at 

least 14 hours of hands-on training, individual respirator fit testing,
course review, and an examination. Hands-on training must permit workers
to have actual experience performing tasks associated with asbestos
abatement. A person who is otherwise accredited as a contractor/

supervisor may perform in the role of a worker without possessing
separate accreditation as a worker.

    Because of cultural diversity associated with the asbestos
workforce, EPA recommends that States adopt specific standards for the
approval of foreign language courses for abatement workers. EPA further
recommends the use of audio-visual materials to complement lectures, 

where appropriate.

    The training course shall adequately address the following topics:

    (a) Physical characteristics of asbestos. Identification of
asbestos, aerodynamic characteristics, typical uses, and physical
appearance, and a summary of abatement control options.

    (b) Potential health effects related to asbestos exposure. The
nature of asbestos-related diseases; routes of exposure; dose-response
relationships and the lack of a safe exposure level; the synergistic
effect between cigarette smoking and asbestos exposure; the latency
periods for asbestos-related diseases; a discussion of the relationship
of asbestos exposure to asbestosis, lung cancer, mesothelioma, and
cancers of other organs.

    (c) Employee personal protective equipment. Classes and
characteristics of respirator types; limitations of respirators; proper
selection, inspection; donning, use, maintenance, and storage procedures
for respirators; methods for field testing of the facepiece-to-face seal
(positive and negative-pressure fit checks); qualitative and
quantitative fit testing procedures; variability between field and
laboratory protection factors that alter respiratory fit (e.g., facial
hair); the components of a proper respiratory protection program;
selection and use of personal protective clothing; use, storage, and
handling of non-disposable clothing; and regulations covering personal
protective equipment.

    (d) State-of-the-art work practices. Proper work practices for
asbestos abatement activities, including descriptions of proper
construction; maintenance of barriers and decontamination enclosure
systems; positioning of warning signs; lock-out of electrical and
ventilation systems; proper working techniques for minimizing fiber
release; use of wet methods; use of negative pressure exhaust
ventilation equipment; use of high-efficiency particulate air (HEPA)
vacuums; proper clean-up and disposal procedures; work practices for
removal, encapsulation, enclosure, and repair of ACM; emergency
procedures for sudden releases; potential exposure situations; transport
and disposal procedures; and recommended and prohibited work practices.

    (e) Personal hygiene. Entry and exit procedures for the work area;
use of showers; avoidance of eating, drinking, smoking, and chewing (gum
or tobacco) in the work area; and potential exposures, such as family
exposure.

    (f) Additional safety hazards. Hazards encountered during abatement
activities and how to deal with them, including electrical hazards, heat
stress, air contaminants other than asbestos, fire and explosion
hazards, scaffold and ladder hazards, slips, trips, and falls, and
confined spaces.

    (g) Medical monitoring. OSHA and EPA Worker Protection Rule
requirements for physical examinations, including a pulmonary function
test, chest X-rays, and a medical history for each employee.

    (h) Air monitoring. Procedures to determine airborne concentrations
of asbestos fibers, focusing on how personal air sampling is performed
and the reasons for it.

    (i) Relevant Federal, State, and local regulatory requirements,
procedures, and standards. With particular attention directed at
relevant EPA, OSHA, and State regulations concerning asbestos abatement
workers.

    (j) Establishment of respiratory protection programs.

    (k) Course review. A review of key aspects of the training course.

	2. Contractor/Supervisors

    A person must be accredited as a contractor/supervisor to supervise
any of the following activities with respect to friable ACBM in a school
or public and commercial building: (1) A response action other than a
SSSD activity, (2) a maintenance activity that disturbs friable ACBM
other than a SSSD activity, or (3) a response action for a major fiber
release episode. All persons seeking accreditation as asbestos abatement
contractor/supervisors shall complete at least a 5-day training course
as outlined below. The training course must include lectures,
demonstrations, at least 14 hours of hands-on training, individual
respirator fit testing, course review, and a written examination.
Hands-on training must permit supervisors to have actual experience
performing tasks associated with asbestos abatement.

    EPA recommends the use of audiovisual materials to complement
lectures, where appropriate.

    Asbestos abatement supervisors include those persons who provide
supervision and direction to workers performing response actions.
Supervisors may include those individuals with the position title of
foreman, working foreman, or leadman pursuant to collective bargaining
agreements. At least one supervisor is required to be at the worksite at
all times while response actions are being conducted. Asbestos workers
must have access to accredited supervisors throughout the duration of
the project.

    The contractor/supervisor training course shall adequately address
the following topics:

    (a) The physical characteristics of asbestos and asbestos-containing
materials. Identification of asbestos, aerodynamic characteristics,
typical uses, physical appearance, a review of hazard assessment
considerations, and a summary of abatement control options.

    (b) Potential health effects related to asbestos exposure. The
nature of asbestos-related diseases; routes of exposure; dose-response
relationships and the lack of a safe exposure level; synergism between
cigarette smoking and asbestos exposure; and latency period for
diseases.

    (c) Employee personal protective equipment. Classes and
characteristics of respirator types; limitations of respirators; proper
selection, inspection, donning, use, maintenance, and storage procedures
for respirators; methods for field testing of the facepiece-to-face seal
(positive and negative-pressure fit checks); qualitative and
quantitative fit testing procedures; variability between field and
laboratory protection factors that alter respiratory fit (e.g., facial
hair); the components of a proper respiratory protection program;
selection and use of personal protective clothing; and use, storage, and
handling of non-disposable clothing; and regulations covering personal
protective equipment.

    (d) State-of-the-art work practices. Proper work practices for
asbestos abatement activities, including descriptions of proper
construction and maintenance of barriers and decontamination enclosure
systems; positioning of warning signs; lock-out of electrical and
ventilation systems; proper working techniques for minimizing fiber
release; use of wet methods; use of negative pressure exhaust
ventilation equipment; use of HEPA vacuums; and proper clean-up and 

disposal procedures. Work practices for removal, encapsulation,
enclosure, and repair of ACM; emergency procedures for unplanned
releases; potential exposure situations; transport and disposal
procedures; and recommended and prohibited work practices. New
abatement-related techniques and methodologies may be discussed.

    (e) Personal hygiene. Entry and exit procedures for the work area;
use of showers; and avoidance of eating, drinking, smoking, and chewing
(gum or tobacco) in the work area. Potential exposures, such as family
exposure, shall also be included.

    (f) Additional safety hazards. Hazards encountered during abatement
activities and how to deal with them, including electrical hazards, heat
stress, air contaminants other than asbestos, fire and explosion
hazards, scaffold and ladder hazards, slips, trips, and falls, and
confined spaces.

    (g) Medical monitoring. OSHA and EPA Worker Protection Rule
requirements for physical examinations, including a pulmonary function
test, chest X-rays and a medical history for each employee.

    (h) Air monitoring. Procedures to determine airborne concentrations
of asbestos fibers, including descriptions of aggressive air sampling,
sampling equipment and methods, reasons for air monitoring, types of
samples and interpretation of results.

    EPA recommends that transmission electron microscopy (TEM) be used
for analysis of final air clearance samples, and that sample analyses be
performed by laboratories accredited by the National Institute of
Standards and Technology's (NIST) National Voluntary Laboratory
Accreditation Program (NVLAP).

    (i) Relevant Federal, State, and local regulatory requirements,
procedures, and standards, including:

    (i) Requirements of TSCA Title II.

    (ii) National Emission Standards for Hazardous Air Pollutants (40
CFR part 61), Subparts A (General Provisions) and M (National Emission
Standard for Asbestos).

    (iii) OSHA standards for permissible exposure to airborne
concentrations of asbestos fibers and respiratory protection (29 CFR
1910.134).

    (iv) OSHA Asbestos Construction Standard (29 CFR 1926.58).

    (v) EPA Worker Protection Rule, (40 CFR part 763, Subpart G).

    (j) Respiratory Protection Programs and Medical Monitoring Programs.

    (k) Insurance and liability issues. Contractor issues; worker's
compensation coverage and exclusions; third-party liabilities and
defenses; insurance coverage and exclusions.

    (l) Recordkeeping for asbestos abatement projects. Records required
by Federal, State, and local regulations; records recommended for legal
and insurance purposes.

    (m) Supervisory techniques for asbestos abatement activities.
Supervisory practices to enforce and reinforce the required work
practices and discourage unsafe work practices.

    (n) Contract specifications. Discussions of key elements that are
included in contract specifications.

    (o) Course review. A review of key aspects of the training course.

	3. Inspector

    All persons who inspect for ACBM in schools or public and commercial
buildings must be accredited. All persons seeking accreditation as an
inspector shall complete at least a 3-day training course as outlined
below. The course shall include lectures, demonstrations, 4 hours of 

hands-on training, individual respirator fit-testing, course review, and
a written examination.

    EPA recommends the use of audiovisual materials to complement
lectures, where appropriate. Hands-on training should include conducting
a simulated building walk-through inspection and respirator fit testing.
The inspector training course shall adequately address the following 

topics:

    (a) Background information on asbestos. Identification of asbestos,
and examples and discussion of the uses and locations of asbestos in
buildings; physical appearance of asbestos.

    (b) Potential health effects related to asbestos exposure. The
nature of asbestos-related diseases; routes of exposure; dose-response
relationships and the lack of a safe exposure level; the synergistic
effect between cigarette smoking and asbestos exposure; the latency
periods for asbestos-related diseases; a discussion of the relationship
of asbestos exposure to asbestosis, lung cancer, mesothelioma, and
cancers of other organs.

    (c) Functions/qualifications and role of inspectors. Discussions of
prior experience and qualifications for inspectors and management
planners; discussions of the functions of an accredited inspector as
compared to those of an accredited management planner; discussion of 

inspection process including inventory of ACM and physical assessment.

    (d) Legal liabilities and defenses. Responsibilities of the
inspector and management planner; a discussion of comprehensive general
liability policies, claims-made, and occurrence policies, environmental
and pollution liability policy clauses; state liability insurance
requirements; bonding and the relationship of insurance availability to
bond availability.

    (e) Understanding building systems. The interrelationship between
building systems, including: an overview of common building physical
plan layout; heat, ventilation, and air conditioning (HVAC) system
types, physical organization, and where asbestos is found on HVAC
components; building mechanical systems, their types and organization,
and where to look for asbestos on such systems; inspecting electrical
systems, including appropriate safety precautions; reading blueprints
and as-built drawings.

    (f) Public/employee/building occupant relations. Notifying employee
organizations about the inspection; signs to warn building occupants;
tact in dealing with occupants and the press; scheduling of inspections
to minimize disruptions; and education of building occupants about 

actions being taken.

    (g) Pre-inspection planning and review of previous inspection
records. Scheduling the inspection and obtaining access; building record
review; identification of probable homogeneous areas from blueprints or
as-built drawings; consultation with maintenance or building personnel; 

review of previous inspection, sampling, and abatement records of a
building; the role of the inspector in exclusions for previously
performed inspections.

    (h) Inspecting for friable and non-friable ACM and assessing the
condition of friable ACM. Procedures to follow in conducting visual
inspections for friable and non-friable ACM; types of building materials
that may contain asbestos; touching materials to determine friability;
open return air plenums and their importance in HVAC systems; assessing
damage, significant damage, potential damage, and potential significant
damage; amount of suspected ACM, both in total quantity and as a
percentage of the total area; type of damage; accessibility; material's 

potential for disturbance; known or suspected causes of damage or
significant damage; and deterioration as assessment factors.

    (i) Bulk sampling/documentation of asbestos. Detailed discussion of
the ''Simplified Sampling Scheme for Friable Surfacing Materials (EPA
560/5-85-030a October 1985)''; techniques to ensure sampling in a
randomly distributed manner for other than friable surfacing materials; 

sampling of non-friable materials; techniques for bulk sampling;
inspector's sampling and repair equipment; patching or repair of damage
from sampling; discussion of polarized light microscopy; choosing an
accredited laboratory to analyze bulk samples; quality control and 

quality assurance procedures. EPA's recommendation that all bulk samples
collected from school or public and commercial buildings be analyzed by
a laboratory accredited under the NVLAP administered by NIST.

    (j) Inspector respiratory protection and personal protective
equipment. Classes and characteristics of respirator types; limitations
of respirators; proper selection, inspection; donning, use, maintenance,
and storage procedures for respirators; methods for field testing of the
facepiece-to-face seal (positive and negative-pressure fit checks);
qualitative and quantitative fit testing procedures; variability between
field and laboratory protection factors that alter respiratory fit
(e.g., facial hair); the components of a proper respiratory protection
program; selection and use of personal protective clothing; use,
storage, and handling of non-disposable clothing.

    (k) Recordkeeping and writing the inspection report. Labeling of
samples and keying sample identification to sampling location;
recommendations on sample labeling; detailing of ACM inventory;
photographs of selected sampling areas and examples of ACM condition;
information required for inclusion in the management plan required for
school buildings under TSCA Title II, section 203 (i)(1). EPA recommends
that States develop and require the use of standardized forms for
recording the results of inspections in schools or public or commercial
buildings, and that the use of these forms be incorporated into the
curriculum of training conducted for accreditation.

    (l) Regulatory review. The following topics should be covered:
National Emission Standards for Hazardous Air Pollutants (NESHAP; 40 CFR
part 61, Subparts A and M); EPA Worker Protection Rule (40 CFR part 763,
Subpart G); OSHA Asbestos Construction Standard (29 CFR 1926.58); OSHA
respirator requirements (29 CFR 1910.134); the Asbestos-Containing
Materials in School Rule (40 CFR part 763, Subpart E; applicable State
and local regulations, and differences between Federal and State
requirements where they apply, and the effects, if any, on public and
nonpublic schools or commercial or public buildings.

    (m) Field trip. This includes a field exercise, including a
walk-through inspection; on-site discussion about information gathering
and the determination of sampling locations; on-site practice in
physical assessment; classroom discussion of field exercise.

    (n) Course review. A review of key aspects of the training course.

	4. Management Planner

    All persons who prepare management plans for schools must be
accredited. All persons seeking accreditation as management planners
shall complete a 3-day inspector training course as outlined above and a
2-day management planner training course. Possession of current and
valid inspector accreditation shall be a prerequisite for admission to
the management planner training course. The management planner course
shall include lectures, demonstrations, course review, and a written
examination.

    EPA recommends the use of audiovisual materials to complement
lectures, where appropriate.

    TSCA Title II does not require accreditation for persons performing
the management planner role in public and commercial buildings.
Nevertheless, such persons may find this training and accreditation
helpful in preparing them to design or administer asbestos operations
and maintenance programs for public and commercial buildings.

    The management planner training course shall adequately address the
following topics:

    (a) Course overview. The role and responsibilities of the management
planner; operations and maintenance programs; setting work priorities;
protection of building occupants.

    (b) Evaluation/interpretation of survey results. Review of TSCA
Title II requirements for inspection and management plans for school
buildings as given in section 203(i)(1) of TSCA Title II; interpretation
of field data and laboratory results; comparison of field inspector's
data sheet with laboratory results and site survey.

    (c) Hazard assessment. Amplification of the difference between
physical assessment and hazard assessment; the role of the management
planner in hazard assessment; explanation of significant damage, damage,
potential damage, and potential significant damage; use of a description
(or decision tree) code for assessment of ACM; assessment of friable
ACM; 

relationship of accessibility, vibration sources, use of adjoining
space, and air plenums and other factors to hazard assessment.

    (d) Legal implications. Liability; insurance issues specific to
planners; liabilities associated with interim control measures, in-house
maintenance, repair, and removal; use of results from previously
performed inspections.

    (e) Evaluation and selection of control options. Overview of
encapsulation, enclosure, interim operations and maintenance, and
removal; advantages and disadvantages of each method; response actions
described via a decision tree or other appropriate method; work
practices for each response action; staging and prioritizing of work in
both vacant and occupied buildings; the need for containment barriers
and decontamination in response actions.

    (f) Role of other professionals. Use of industrial hygienists,
engineers, and architects in developing technical specifications for
response actions; any requirements that may exist for architect sign-off
of plans; team approach to design of high-quality job specifications.

    (g) Developing an operations and maintenance (O&M) plan. Purpose of
the plan; discussion of applicable EPA guidance documents; what actions
should be taken by custodial staff; proper cleaning procedures; steam
cleaning and HEPA vacuuming; reducing disturbance of ACM; scheduling O&M
for off-hours; rescheduling or canceling renovation in areas with ACM; 

boiler room maintenance; disposal of ACM; in-house procedures for
ACM--bridging and penetrating encapsulants; pipe fittings; metal
sleeves; polyvinyl chloride (PVC), canvas, and wet wraps; muslin with
straps, fiber mesh cloth; mineral wool, and insulating cement;
discussion of 

employee protection programs and staff training; case study in
developing an O&M plan (development, implementation process, and
problems that have been experienced).

    (h) Regulatory review. Focusing on the OSHA Asbestos Construction
Standard found at 29 CFR 1926.58; the National Emission Standard for
Hazardous Air Pollutants (NESHAP) found at 40 CFR part 61, Subparts A
(General Provisions) and M (National Emission Standard for Asbestos);
EPA Worker Protection Rule found at 40 CFR part 763, Subpart G; TSCA
Title II; applicable State regulations.

    (i) Recordkeeping for the management planner. Use of field
inspector's data sheet along with laboratory results; on-going
recordkeeping as a means to track asbestos disturbance; procedures for
recordkeeping. EPA recommends that States require the use of
standardized forms for purposes of management plans and incorporate the
use of such forms into the initial training course for management
planners.

    (j) Assembling and submitting the management plan. Plan requirements
for schools in TSCA Title II section 203(i)(1); the management plan as a
planning tool.

    (k) Financing abatement actions. Economic analysis and cost
estimates; development of cost estimates; present costs of abatement
versus future operation and maintenance costs; Asbestos School Hazard
Abatement Act grants and loans.

    (l) Course review. A review of key aspects of the training course.

	5. Project Designer

    A person must be accredited as a project designer to design any of
the following activities with respect to friable ACBM in a school or
public and commercial building: (1) A response action other than a SSSD
maintenance activity, (2) a maintenance activity that disturbs friable
ACBM other than a SSSD maintenance activity, or (3) a response action
for a major fiber release episode. All persons seeking accreditation as
a project designer shall complete at least a minimum 3-day training
course as outlined below. The project designer course shall include 

lectures, demonstrations, a field trip, course review and a written
examination.

    EPA recommends the use of audiovisual materials to complement
lectures, where appropriate.

    The abatement project designer training course shall adequately
address the following topics:         (a) Background information on
asbestos. Identification of asbestos; examples and discussion of the
uses and locations of asbestos in buildings; physical appearance of
asbestos.

    (b) Potential health effects related to asbestos exposure. Nature of
asbestos-related diseases; routes of exposure; dose-response
relationships and the lack of a safe exposure level; the synergistic
effect between cigarette smoking and asbestos exposure; the latency
period of asbestos-related diseases; a discussion of the relationship
between asbestos exposure and asbestosis, lung cancer, mesothelioma, and
cancers of other organs.

    (c) Overview of abatement construction projects. Abatement as a
portion of a renovation project; OSHA requirements for notification of
other contractors on a multi-employer site (29 CFR 1926.58).

    (d) Safety system design specifications. Design, construction, and
maintenance of containment barriers and decontamination enclosure
systems; positioning of warning signs; electrical and ventilation system
lock-out; proper working techniques for minimizing fiber release; entry
and 

exit procedures for the work area; use of wet methods; proper techniques
for initial cleaning; use of negative-pressure exhaust ventilation
equipment; use of HEPA vacuums; proper clean-up and disposal of
asbestos; work practices as they apply to encapsulation, enclosure, and
repair; use of glove bags and a demonstration of glove bag use.

    (e) Field trip. A visit to an abatement site or other suitable
building site, including on-site discussions of abatement design and
building walk-through inspection. Include discussion of rationale for
the concept of functional spaces during the walk-through.

    (f) Employee personal protective equipment. Classes and
characteristics of respirator types; limitations of respirators; proper
selection, inspection; donning, use, maintenance, and storage procedures
for respirators; methods for field testing of the facepiece-to-face seal
(positive and negative-pressure fit checks); qualitative and
quantitative fit testing procedures; variability between field and
laboratory protection factors that alter respiratory fit (e.g., facial
hair); the components of a proper respiratory protection program;
selection and use of personal protective clothing; use, storage, and
handling of non-disposable clothing.

    (g) Additional safety hazards. Hazards encountered during abatement
activities and how to deal with them, including electrical hazards, heat
stress, air contaminants other than asbestos, fire, and explosion
hazards.

    (h) Fiber aerodynamics and control. Aerodynamic characteristics of
asbestos fibers; importance of proper containment barriers; settling
time for asbestos fibers; wet methods in abatement; aggressive air
monitoring following abatement; aggressive air movement and
negative-pressure exhaust ventilation as a clean-up method.

    (i) Designing abatement solutions. Discussions of removal,
enclosure, and encapsulation methods; asbestos waste disposal.

    (j) Final clearance process. Discussion of the need for a written
sampling rationale for aggressive final air clearance; requirements of a
complete visual inspection; and the relationship of the visual
inspection to final air clearance.

    EPA recommends the use of TEM for analysis of final air clearance
samples. These samples should be analyzed by laboratories accredited
under the NIST NVLAP.

    (k) Budgeting/cost estimating. Development of cost estimates;
present costs of abatement versus future operation and maintenance
costs; setting priorities for abatement jobs to reduce costs.

    (l) Writing abatement specifications. Preparation of and need for a
written project design; means and methods specifications versus
performance specifications; design of abatement in occupied buildings;
modification of guide specifications for a particular building; worker 

and building occupant health/medical considerations; replacement of ACM
with non-asbestos substitutes.

    (m) Preparing abatement drawings. Significance and need for
drawings, use of as-built drawings as base drawings; use of inspection
photographs and on-site reports; methods of preparing abatement
drawings; diagraming containment barriers; relationship of drawings to 

design specifications; particular problems related to abatement
drawings.

    (n) Contract preparation and administration.

    (o) Legal/liabilities/defenses. Insurance considerations; bonding;
hold-harmless clauses; use of abatement contractor's liability
insurance; claims made versus occurrence policies.

    (p) Replacement. Replacement of asbestos with asbestos-free
substitutes.

    (q) Role of other consultants. Development of technical
specification sections by industrial hygienists or engineers; the
multi-disciplinary team approach to abatement design.

    (r) Occupied buildings. Special design procedures required in
occupied buildings; education of occupants; extra monitoring
recommendations; staging of work to minimize occupant exposure; 

scheduling of renovation to minimize exposure.

    (s) Relevant Federal, State, and local regulatory requirements,
procedures and standards, including, but not limited to:

    (i) Requirements of TSCA Title II.

    (ii) National Emission Standards for Hazardous Air Pollutants, (40
CFR part 61) subparts A (General Provisions) and M (National Emission
Standard for Asbestos).

    (iii) OSHA Respirator Standard found at 29 CFR 1910.134.

    (iv) EPA Worker Protection Rule found at 40 CFR part 763, subpart G.

    (v) OSHA Asbestos Construction Standard found at 29 CFR 1926.58.

    (vi) OSHA Hazard Communication Standard found at 29 CFR 1926.59.

    (t) Course review. A review of key aspects of the training course.

	6. Project Monitor

    EPA recommends that States adopt training and accreditation
requirements for persons seeking to perform work as project monitors.
Project monitors observe abatement activities performed by contractors
and generally serve as a building owner's representative to ensure that
abatement work is completed according to specification and in compliance
with all relevant statutes and regulations. They may also perform the
vital role of air monitoring for purposes of determining final
clearance. EPA recommends that a State seeking to accredit individuals
as project monitors consider adopting a minimum 5-day training course
covering the topics outlined below. The course outlined below consists
of lectures and demonstrations, at least 6 hours of hands-on training,
course review, and a written examination. The hands-on training
component might be satisfied by having the student simulate
participation in or performance of any of the relevant job 

functions or activities (or by incorporation of the workshop component
described in item ''n'' below of this unit).

    EPA recommends that the project monitor training course adequately
address the following topics:

    (a) Roles and responsibilities of the project monitor. Definition
and responsibilities of the project monitor, including
regulatory/specification compliance monitoring, air monitoring,
conducting visual inspections, and final clearance monitoring.

    (b) Characteristics of asbestos and asbestos-containing materials.
Typical uses of asbestos; physical appearance of asbestos; review of
asbestos abatement and control techniques; presentation of the health
effects of asbestos exposure, including routes of exposure, dose-

response relationships, and latency periods for asbestos-related
diseases.

    (c) Federal asbestos regulations. Overview of pertinent EPA
regulations, including: NESHAP, 40 CFR part 61, subparts A and M; AHERA,
40 CFR part 763, subpart E; and the EPA Worker Protection Rule, 40 CFR
part 763, subpart G. Overview of pertinent OSHA regulations, including:
Construction Industry Standard for Asbestos, 29 CFR 1926.58; Respirator
Standard, 29 CFR 1910.134; and the Hazard Communication Standard, 29 CFR
1926.59. Applicable State and local asbestos regulations; regulatory
interrelationships.

    (d) Understanding building construction and building systems.
Building construction basics, building physical plan layout;
understanding building systems (HVAC, electrical, etc.); layout and
organization, where asbestos is likely to be found on building systems;
renovations and the effect of asbestos abatement on building systems.

    (e) Asbestos abatement contracts, specifications, and drawings.
Basic provisions of the contract; relationships between principle
parties, establishing chain of command; types of specifications,
including means and methods, performance, and proprietary and
nonproprietary; reading and interpreting records and abatement drawings;
discussion of change orders; common enforcement responsibilities and
authority of project monitor.

    (f) Response actions and abatement practices. Pre-work inspections;
pre-work considerations, precleaning of the work area, removal of
furniture, fixtures, and equipment; shutdown/ modification of building
systems; construction and maintenance of containment barriers, proper 

demarcation of work areas; work area entry/exit, hygiene practices;
determining the effectiveness of air filtration equipment; techniques
for minimizing fiber release, wet methods, continuous cleaning;
abatement methods other than removal; abatement area clean-up
procedures; waste transport and disposal procedures; contingency
planning for emergency response.

    (g) Asbestos abatement equipment. Typical equipment found on an
abatement project; air filtration devices, vacuum systems, negative
pressure differential monitoring; HEPA filtration units, theory of
filtration, design/construction of HEPA filtration units, qualitative
and quantitative performance of HEPA filtration units, sizing the
ventilation requirements, location of HEPA filtration units, qualitative
and quantitative tests of containment barrier integrity; best available
technology.

    (h) Personal protective equipment. Proper selection of respiratory
protection; classes and characteristics of respirator types, limitations
of respirators; proper use of other safety equipment, protective
clothing selection, use, and proper handling, hard/bump hats, safety
shoes; breathing air systems, high pressure v. low pressure, testing for
Grade D air, determining proper backup air volumes.

    (i) Air monitoring strategies. Sampling equipment, sampling pumps
(low v. high volume), flow regulating devices (critical and limiting
orifices), use of fibrous aerosol monitors on abatement projects;
sampling media, types of filters, types of cassettes, filter
orientation, storage and shipment of filters; calibration techniques,
primary calibration standards, secondary calibration standards,
temperature/pressure effects, frequency of calibration, recordkeeping
and field work documentation, calculations; air sample analysis,
techniques available and limitations of AHERA on their use, transmission
electron microscopy (background to sample preparation and analysis, air
sample conditions which prohibit analysis, EPA's recommended technique 

for analysis of final air clearance samples), phase contrast microscopy
(background to sample preparation, and AHERA's limits on the use of
phase contrast microscopy), what each technique measures; analytical
methodologies, AHERA TEM protocol, NIOSH 7400, OSHA reference method
(non clearance), EPA recommendation for clearance (TEM); sampling
strategies for clearance monitoring, types of air samples (personal
breathing zone v. fixed-station area) sampling location and objectives
(pre-abatement, during abatement, and clearance monitoring), number of
samples to be collected, minimum and maximum air volumes, clearance
monitoring (post-visual-inspection) (number of samples required,
selection of sampling locations, period of sampling, aggressive
sampling, interpretations of sampling results, calculations), quality
assurance; special sampling problems, crawl spaces, acceptable samples
for laboratory analysis, sampling in occupied buildings (barrier
monitoring).

    (j) Safety and health issues other than asbestos. Confined-space
entry, electrical hazards, fire and explosion concerns, ladders and
scaffolding, heat stress, air contaminants other than asbestos, fall
hazards, hazardous materials on abatement projects.

    (k) Conducting visual inspections. Inspections during abatement,
visual inspections using the ASTM E1368 document; conducting inspections
for completeness of removal; discussion of ''how clean is clean?''

    (l) Legal responsibilities and liabilities of project monitors.
Specification enforcement capabilities; regulatory enforcement;
licensing; powers delegated to project monitors through contract
documents.

    (m) Recordkeeping and report writing. Developing project logs/daily
logs (what should be included, who sees them); final report preparation;
recordkeeping under Federal regulations.

    (n) Workshops (6 hours spread over 3 days). Contracts,
specifications, and drawings: This workshop could consist of each
participant being issued a set of contracts, specifications, and 

drawings and then being asked to answer questions and make
recommendations to a project architect, engineer or to the building
owner based on given conditions and these documents.

    Air monitoring strategies/asbestos abatement equipment: This
workshop could consist of simulated abatement sites for which sampling
strategies would have to be developed (i.e., occupied buildings,
industrial situations). Through demonstrations and exhibition, the
project monitor may also be able to gain a better understanding of the
function of various pieces of equipment used on abatement projects (air
filtration units, water filtration units, negative pressure monitoring
devices, sampling pump calibration devices, etc.).

    Conducting visual inspections: This workshop could consist, ideally,
of an interactive video in which a participant is ''taken through'' a
work area and asked to make notes of what is seen. A series of questions
will be asked which are designed to stimulate a person's recall of the
area. This workshop could consist of a series of two or three videos
with different site conditions and different degrees of cleanliness.

C. Examinations

    1. Each State shall administer a closed book examination or
designate other entities such as State-approved providers of training
courses to administer the closed-book examination to persons seeking
accreditation who have completed an initial training course.
Demonstration testing may also be included as part of the examination. A
person seeking initial accreditation in a specific discipline must pass
the examination for that discipline in order to receive accreditation. 

For example, a person seeking accreditation as an abatement project
designer must pass the State's examination for abatement project
designer.

    States may develop their own examinations, have providers of
training courses develop examinations, or use standardized examinations
developed for purposes of accreditation under TSCA Title II. In
addition, States may supplement standardized examinations with questions


about State regulations. States may obtain commercially developed
standardized examinations, develop standardized examinations
independently, or do so in cooperation with other States, or with
commercial or non-profit providers on a regional or national basis. EPA
recommends the use of standardized, scientifically-validated testing
instruments, which may be beneficial in terms of both promoting
competency and in fostering accreditation reciprocity between States.

    Each examination shall adequately cover the topics included in the
training course for that discipline. Each person who completes a
training course, passes the required examination, and fulfills whatever
other requirements the State imposes must receive an accreditation
certificate in a specific discipline. Whether a State directly issues
accreditation certificates, or authorizes training providers to issue
accreditation certificates, each certificate issued to an accredited 

person must contain the following minimum information:

    a. A unique certificate number

    b. Name of accredited person

    c. Discipline of the training course completed.

    d. Dates of the training course.

    e. Date of the examination.

    f. An expiration date of 1 year after the date upon which the person
successfully completed the course and examination.

    g. The name, address, and telephone number of the training provider
that issued the certificate.

    h. A statement that the person receiving the certificate has
completed the requisite training for asbestos accreditation under TSCA
Title II.

    States or training providers who reaccredit persons based upon
completion of required refresher training must also provide
accreditation certificates with all of the above information, except the
examination date may be omitted if a State does not require a refresher
examination for reaccreditation.

    Where a State licenses accredited persons but has authorized
training providers to issue accreditation certificates, the State may
issue licenses in the form of photo-identification cards. Where this
applies, EPA recommends that the State licenses should include all of
the same information required for the accreditation certificates. A
State may also choose to issue photo-identification cards in addition to
the required accreditation certificates.

    Accredited persons must have their initial and current accreditation
certificates at the location where they are conducting work.

    2. The following are the requirements for examination in each
discipline:

    a. Worker:

    i. 50 multiple-choice questions

    ii. Passing score: 70 percent correct

    b. Contractor/Supervisor:

    i. 100 multiple-choice questions

    ii. Passing score: 70 percent correct

    c. Inspector:

    i. 50 Multiple-choice questions

    ii. Passing score: 70 percent correct

    d. Management Planner:

    i. 50 Multiple-choice questions

    ii. Passing score: 70 percent correct

    e. Project Designer:

    i. 100 multiple-choice questions

    ii. Passing score: 70 percent correct

D. Continuing Education

    For all disciplines, a State's accreditation program shall include
annual refresher training as a requirement for reaccreditation as
indicated below:

    1. Workers: One full day of refresher training.

    2. Contractor/Supervisors: One full day of refresher training.

    3. Inspectors: One half-day of refresher training.

    4. Management Planners: One half-day of inspector refresher training
and one half-day of refresher training for management planners.

    5. Project Designers: One full day of refresher training.

    The refresher courses shall be specific to each discipline.
Refresher courses shall be conducted as separate and distinct courses
and not combined with any other training during the period of the 

refresher course. For each discipline, the refresher course shall review
and discuss changes in Federal, State, and local regulations,
developments in state-of-the-art procedures, and a review of key aspects
of the initial training course as determined by the State. After
completing the annual refresher course, persons shall have their
accreditation extended for an additional year from the date of the
refresher course. A State may consider requiring persons to pass
reaccreditation examinations at specific intervals (for example, every 3
years).

    EPA recommends that States formally establish a 12-month grace
period to enable formerly accredited persons with expired certificates
to complete refresher training and have their accreditation status
reinstated without having to re-take the initial training course.

E. Qualifications

    In addition to requiring training and an examination, a State may
require candidates for accreditation to meet other qualification and/or
experience standards that the State considers appropriate for some or
all disciplines. States may choose to consider requiring qualifications 

similar to the examples outlined below for inspectors, management
planners and project designers. States may modify these examples as
appropriate. In addition, States may want to include some requirements
based on experience in performing a task directly as a part of a job or 

in an apprenticeship role. They may also wish to consider additional
criteria for the approval of training course instructors beyond those
prescribed by EPA.

    1. Inspectors: Qualifications - possess a high school diploma.
States may want to require an Associate's Degree in specific fields
(e.g., environmental or physical sciences).

    2. Management Planners: Qualifications - Registered architect,
engineer, or certified industrial hygienist or related scientific field.

    3. Project Designers: Qualifications - registered architect,
engineer, or certified industrial hygienist.

    4. Asbestos Training Course Instructor: Qualifications - academic
credentials and/or field experience in asbestos abatement.

    EPA recommends that States prescribe minimum qualification standards
for training instructors employed by training providers.

F. Recordkeeping Requirements for Training Providers

    All approved providers of accredited asbestos training courses must
comply with the following minimum recordkeeping requirements.

    1. Training course materials. A training provider must retain copies
of all instructional materials used in the delivery of the classroom
training such as student manuals, instructor notebooks and handouts.

    2. Instructor qualifications. A training provider must retain copies
of all instructors' resumes, and the documents approving each instructor
issued by either EPA or a State. Instructors must be approved by either
EPA or a State before teaching courses for accreditation purposes. A
training provider must notify EPA or the State, as appropriate, in
advance whenever it changes course instructors. Records must accurately
identify the instructors that taught each particular course for each
date that a course is offered.

    3. Examinations. A training provider must document that each person
who receives an accreditation certificate for an initial training course
has achieved a passing score on the examination. These records must
clearly indicate the date upon which the exam was administered, the
training course and discipline for which the exam was given, the name of
the person who proctored the exam, a copy of the exam, and the name and
test score of each person taking the exam. The topic and dates of the
training course must correspond to those listed on that person's
accreditation certificate. States may choose to apply these same
requirements to examinations for refresher training courses.

    4. Accreditation certificates. The training providers or States,
whichever issues the accreditation certificate, shall maintain records
that document the names of all persons who have been awarded
certificates, their certificate numbers, the disciplines for which
accreditation was conferred, training and expiration dates, and the
training location. The training provider or State shall maintain the
records in a manner that allows verification by telephone of the
required information.

    5. Verification of certificate information. EPA recommends that
training providers of refresher training courses confirm that their
students possess valid accreditation before granting course admission.
EPA further recommends that training providers offering the initial
management planner training course verify that students have met the
prerequisite of possessing valid inspector accreditation at the time of
course admission.

    6. Records retention and access.

    (a) The training provider shall maintain all required records for a
minimum of 3 years. The training provider, however, may find it
advantageous to retain these records for a longer period of time.

    (b) The training provider must allow reasonable access to all of the
records required by the MAP, and to any other records which may be
required by States for the approval of asbestos training providers or
the accreditation of asbestos training courses, to both EPA and to State


Agencies, on request. EPA encourages training providers to make this
information equally accessible to the general public.

    (c) If a training provider ceases to conduct training, the training
provider shall notify the approving government body (EPA or the State)
and give it the opportunity to take possession of that provider’s
asbestos training records.

G. Deaccreditation

    1. States must establish criteria and procedures for deaccrediting
persons accredited as workers, contractor/supervisors, inspectors,
management planners, and project designers. States must follow their own
administrative procedures in pursuing deaccreditation actions. At a 

minimum, the criteria shall include:

    (a) Performing work requiring accreditation at a job site without
being in physical possession of initial and current accreditation
certificates;

    (b) Permitting the duplication or use of one's own accreditation
certificate by another;

    (c) Performing work for which accreditation has not been received;
or

    (d) Obtaining accreditation from a training provider that does not
have approval to offer training for the particular discipline from
either EPA or from a State that has a contractor accreditation plan at
least as stringent as the EPA MAP.

    EPA may directly pursue deaccreditation actions without reliance on
State deaccreditation or enforcement authority or actions. In addition
to the above-listed situations, the Administrator may suspend or revoke
the accreditation of persons who have been subject to a final order 

imposing a civil penalty or convicted under section 16 of TSCA, 15
U.S.C. 2615 or 2647, for violations of 40 CFR part 763, or section 113
of the Clean Air Act, 42 U.S.C. 7413, for violations of 40 CFR part 61,
subpart M.

    2. Any person who performs asbestos work requiring accreditation
under section 206(a) of TSCA, 15 U.S.C. 2646(a), without such
accreditation is in violation of TSCA. The following persons are not
accredited for purposes of section 206(a) of TSCA:

    (a) Any person who obtains accreditation through fraudulent
representation of training or examination documents;

    (b) Any person who obtains training documentation through fraudulent
means;

    (c) Any person who gains admission to and completes refresher
training through fraudulent representation of initial or previous
refresher training documentation; or

    (d) Any person who obtains accreditation through fraudulent
representation of accreditation requirements such as education,
training, professional registration, or experience.

H. Reciprocity

    EPA recommends that each State establish reciprocal arrangements
with other States that have established accreditation programs that meet
or exceed the requirements of the MAP. Such arrangements might address
cooperation in licensing determinations, the review and approval of 

training programs and/or instructors, candidate testing and exam
administration, curriculum development, policy formulation, compliance
monitoring, and the exchange of information and data. The benefits to be
derived from these arrangements include a potential cost-savings from 

the reduction of duplicative activity and the attainment of a more
professional accredited workforce as States are able to refine and
improve the effectiveness of their programs based upon the experience
and methods of other States.

	II. EPA Approval Process for State Accreditation Programs

    A. States may seek approval for a single discipline or all
disciplines as specified in the MAP. For example, a State that currently
only requires worker accreditation may receive EPA approval for that
discipline alone. EPA encourages States that currently do not have
accreditation requirements for all disciplines required under section
206(b)(2) of TSCA, 15 U.S.C. 2646(b)(2), to seek EPA approval for those
disciplines the State does accredit. As States establish accreditation
requirements for the remaining disciplines, the requested information
outlined below should be submitted to EPA as soon as possible. Any State
that had an accreditation program approved by EPA under an earlier
version of the MAP may follow the same procedures to obtain EPA approval
of their accreditation program under this MAP.

    B. Partial approval of a State Program for the accreditation of one
or more disciplines does not mean that the State is in full compliance
with TSCA where the deadline for that State to have adopted a State Plan
no less stringent than the MAP has already passed. State Programs which 

are at least as stringent as the MAP for one or more of the accredited
disciplines may, however, accredit persons in those disciplines only.

    C. States seeking EPA approval or reapproval of accreditation
programs shall submit the following information to the Regional Asbestos
Coordinator at their EPA Regional office:

    1. A copy of the legislation establishing or upgrading the State's
accreditation program (if applicable).

    2. A copy of the State's accreditation regulations or revised
regulations.

    3. A letter to the Regional Asbestos Coordinator that clearly
indicates how the State meets the program requirements of this MAP.
Addresses for each of the Regional Asbestos Coordinators are shown
below:

EPA, Region I, (ATC-111) Asbestos Coordinator, JFK Federal Bldg.,
Boston, MA 02203-2211, (617) 565-3836.

EPA, Region II, (MS-500), Asbestos Coordinator, 2890 Woodbridge Ave.,
Edison, NJ 08837-3679, (908) 321-6671.

EPA, Region III, (3AT-33), Asbestos Coordinator, 841 Chestnut Bldg.,
Philadelphia, PA 19107, (215) 597-3160.

EPA, Region IV, Asbestos Coordinator, 345 Courtland St., N.E., Atlanta,
GA 30365, (404) 347-5014.

EPA, Region V, (SP-14J), Asbestos Coordinator, 77 W. Jackson Blvd.,
Chicago, IL 60604-3590, (312) 886-6003.

EPA, Region VI, (6T-PT), Asbestos Coordinator, 1445 Ross Ave. Dallas, TX
75202-2744, (214) 655-7244.

EPA, Region VII, (ARTX/ASBS), Asbestos Coordinator, 726 Minnesota Ave.,
Kansas City, KS 66101, (913) 551-7020.

EPA, Region VIII, (8AT-TS), Asbestos Coordinator, 1 Denver Place, Suite
500 999 - 18th St., Denver, CO 80202-2405, (303) 293-1442.

EPA, Region IX, (A-4-4), Asbestos Coordinator, 75 Hawthorne St., San
Francisco, CA 94105, (415) 744-1128.

EPA, Region X, (AT-083), Asbestos Coordinator, 1200 Sixth Ave., Seattle,
WA 98101, (206) 553-4762.

    EPA maintains a listing of all those States that have applied for
and received EPA approval for having accreditation requirements that are
at least as stringent as the MAP for one or more disciplines. Any
training courses approved by an EPA-approved State Program are
considered to be EPA-approved for purposes of accreditation.

	III. Approval of Training Courses

    Individuals or groups wishing to sponsor training courses for
disciplines required to be accredited under section 206(b)(1)(A) of
TSCA, 15 U.S.C. 2646(b)(1)(A), may apply for approval from States that
have accreditation program requirements that are at least as stringent
as this MAP. For a course to receive approval, it must meet the
requirements for the course as outlined in this MAP, and any other
requirements imposed by the State from which approval is being sought.
Courses that have been approved by a State with an accreditation program
at least as stringent as this MAP are approved under section 206(a) of
TSCA, 15 U.S.C. 2646(a), for that particular State, and also for any
other State that does not have an accreditation program as stringent as
this MAP.

A. Initial Training Course Approval

    A training provider must submit the following minimum information to
a State as part of its application for the approval of each training
course:

    1. The course provider's name, address, and telephone number.

    2. A list of any other States that currently approve the training
course.

    3. The course curriculum.

    4. A letter from the provider of the training course that clearly
indicates how the course meets the MAP requirements for:

    a. Length of training in days.

    b. Amount and type of hands-on training.

    c. Examination (length, format, and passing score).

    d. Topics covered in the course.

    5. A copy of all course materials (student manuals, instructor
notebooks, handouts, etc.).

    6. A detailed statement about the development of the examination
used in the course.

    7. Names and qualifications of all course instructors. Instructors
must have academic and/or field experience in asbestos abatement.

    8. A description of and an example of the numbered certificates
issued to students who attend the course and pass the examination.

B. Refresher Training Course Approval

    The following minimum information is required for approval of
refresher training courses by States:

    1. The length of training in half-days or days.

    2. The topics covered in the course.

    3. A copy of all course materials (student manuals, instructor
notebooks, handouts, etc.).

    4. The names and qualifications of all course instructors.
Instructors must have academic and/or field experience in asbestos
abatement.

    5. A description of and an example of the numbered certificates
issued to students who complete the refresher course and pass the
examination, if required.

C. Withdrawal of Training Course Approval

    States must establish criteria and procedures for suspending or
withdrawing approval from accredited training programs. States should
follow their own administrative procedures in pursuing actions for
suspension or withdrawal of approval of training programs. At a minimum,


the criteria shall include:

    (1) Misrepresentation of the extent of a training course's approval
by a State or EPA;

    (2) Failure to submit required information or notifications in a
timely manner;

    (3) Failure to maintain requisite records;

    (4) Falsification of accreditation records, instructor
qualifications, or other accreditation information; or

    (5) Failure to adhere to the training standards and requirements of
the EPA MAP or State Accreditation Program, as appropriate.

    In addition to the criteria listed above, EPA may also suspend or
withdraw a training course's approval where an approved training course
instructor, or other person with supervisory authority over the delivery
of training has been found in violation of other asbestos regulations
administered by EPA. An administrative or judicial finding of violation,
or execution of a consent agreement and order under 40 CFR 22.18,
constitutes evidence of a failure to comply with relevant statutes or
regulations. States may wish to adopt this criterion modified to include


their own asbestos statutes or regulations. EPA may also suspend or
withdraw approval of training programs where a training provider has
submitted false information as a part of the self-certification required
under Unit V.B. of the revised MAP.

    Training course providers shall permit representatives of EPA or the
State which approved their training courses to attend, evaluate, and
monitor any training course without charge. EPA or State compliance
inspection staff are not required to give advance notice of their
inspections. EPA may suspend or withdraw State or EPA approval of a
training course based upon the criteria specified in this Unit III.C.

IV. EPA Procedures for Suspension or Revocation of Accreditation or
Training Course Approval.

    A. If the Administrator decides to suspend or revoke the
accreditation of any person or suspend or withdraw the approval of a
training course, the Administrator will notify the affected entity of
the following:

    1. The grounds upon which the suspension, revocation, or withdrawal
is based.

    2. The time period during which the suspension, revocation, or
withdrawal is effective, whether permanent or otherwise.

    3. The conditions, if any, under which the affected entity may
receive accreditation or approval in the future.

    4. Any additional conditions which the Administrator may impose.

    5. The opportunity to request a hearing prior to final Agency action
to suspend or revoke accreditation or suspend or withdraw approval.

    B. If a hearing is requested by the accredited person or training
course provider pursuant to the preceding paragraph, the Administrator
will:

    1. Notify the affected entity of those assertions of law and fact
upon which the action to suspend, revoke, or withdraw is based.

    2. Provide the affected entity an opportunity to offer written
statements of facts, explanations, comments, and arguments relevant to
the proposed action.

    3. Provide the affected entity such other procedural opportunities
as the Administrator may deem appropriate to ensure a fair and impartial
hearing.

    4. Appoint an EPA attorney as Presiding Officer to conduct the
hearing. No person shall serve as Presiding Officer if he or she has had
any prior connection with the specific case.

    C. The Presiding Officer appointed pursuant to the preceding
paragraph shall:

    1. Conduct a fair, orderly, and impartial hearing, without
unnecessary delay.

    2. Consider all relevant evidence, explanation, comment, and
argument submitted pursuant to the preceding paragraph.

    3. Promptly notify the affected entity of his or her decision and
order. Such an order is a final Agency action.

    D. If the Administrator determines that the public health, interest,
or welfare warrants immediate action to suspend the accreditation of any
person or the approval of any training course provider, the
Administrator will:

    1. Notify the affected entity of the grounds upon which the
emergency suspension is based;

    2. Notify the affected entity of the time period during which the
emergency suspension is effective.

    3. Notify the affected entity of the Administrator's intent to
suspend or revoke accreditation or suspend or withdraw training course
approval, as appropriate, in accordance with Unit IV.A. above. If such
suspension, revocation, or withdrawal notice has not previously been
issued, it will be issued at the same time the emergency suspension
notice is issued.

    E. Any notice, decision, or order issued by the Administrator under
this section, and any documents filed by an accredited person or
approved training course provider in a hearing under this section, shall
be available to the public except as otherwise provided by section 14 of


TSCA or by 40 CFR part 2. Any such hearing at which oral testimony is
presented shall be open to the public, except that the Presiding Officer
may exclude the public to the extent necessary to allow presentation of
information which may be entitled to confidential treatment under
section 14 of TSCA or 40 CFR part 2.

	V. Implementation Schedule

    The various requirements of this MAP become effective in accordance
with the following schedules:

A. Requirements applicable to State Programs

    1. Each State shall adopt an accreditation plan that is at least as
stringent as this MAP within 180 days after the commencement of the
first regular session of the legislature of the State that is convened
on or after April 4, 1994.

    2. If a State has adopted an accreditation plan at least as
stringent as this MAP as of April 4, 1994, the State may continue to:

    a. Conduct TSCA training pursuant to this MAP.

    b. Approve training course providers to conduct training and to
issue accreditation that satisfies the requirements for TSCA
accreditation under this MAP.

    c. Issue accreditation that satisfies the requirements for TSCA
accreditation under this MAP.

    3. A State that had complied with an earlier version of the MAP, but
has not adopted an accreditation plan at least as stringent as this MAP
by April 4, 1994, may:

    a. Conduct TSCA training which remains in compliance with the
requirements of Unit V.B. of this MAP. After such training has been
self-certified in accordance with Unit V.B. of this MAP, the State may
issue accreditation that satisfies the requirement for TSCA
accreditation under this MAP.

    b. Sustain its approval for any training course providers to conduct
training and issue TSCA accreditation that the State had approved before
April 4, 1994, and that remain in compliance with Unit V.B. of this MAP.

    c. Issue accreditation pursuant to an earlier version of the MAP
that provisionally satisfies the requirement for TSCA accreditation
until October 4, 1994.

    Such a State may not approve new TSCA training course providers to
conduct training or to issue TSCA accreditation that satisfies the
requirements of this MAP until the State adopts an accreditation plan
that is at least as stringent as this MAP.

    4. A State that had complied with an earlier version of the MAP, but
fails to adopt a plan as stringent as this MAP by the deadline
established in Unit V.A.1., is subject to the following after that
deadline date:

    a. The State loses any status it may have held as an EPA-approved
State for accreditation purposes under section 206 of TSCA, 15 U.S.C.
2646.

    b. All training course providers approved by the State lose State
approval to conduct training and issue accreditation that satisfies the
requirements for TSCA accreditation under this MAP.

    c. The State may not:

    i. Conduct training for accreditation purposes under section 206 of
TSCA, 15 U.S.C. 2646.

    ii. Approve training course providers to conduct training or issue
accreditation that satisfies the requirements for TSCA accreditation; or

    iii. Issue accreditation that satisfies the requirement for TSCA
accreditation.

    EPA will extend EPA-approval to any training course provider that
loses State approval because the State does not comply with the
deadline, so long as the provider is in compliance with Unit V.B. of
this MAP, and the provider is approved by a State that had complied with
an earlier version of the MAP as of the day before the State loses its
EPA approval.

    5. A State that does not have an accreditation program that
satisfies the requirements for TSCA accreditation under either an
earlier version of the MAP or this MAP, may not:

    a. Conduct training for accreditation purposes under section 206 of
TSCA, 15 U.S.C. 2646;

    b. Approve training course providers to conduct training or issue
accreditation that satisfies the requirements for TSCA accreditation; or

    c. Issue accreditation that satisfies the requirement for TSCA
accreditation.

B. Requirements applicable to Training Courses and Providers

    As of October 4, 1994, an approved training provider must certify to
EPA and to any State that has approved the provider for TSCA
accreditation, that each of the provider's training courses complies
with the requirements of this MAP. The written submission must document
in specific detail the changes made to each training course in order to
comply with the requirements of this MAP and clearly state that the
provider is also in compliance with all other requirements of this MAP,
including the new recordkeeping and certificate provisions. Each
submission must include the following statement signed by an authorized
representative of the training provider: ``Under civil and criminal
penalties of law for the making or submission of false or fraudulent
statements or representations (18 U.S.C. 1001 and 15 U.S.C. 2615), I
certify that the training described in this submission complies with all
applicable requirements of Title II of TSCA, 40 CFR part 763, Appendix C
to Subpart E, as revised, and any other applicable Federal, state, or
local requirements.'' A consolidated self-certification submission from
each training provider that addresses all of its approved training
courses is permissible and encouraged.

    The self-certification must be sent via registered mail, to EPA
Headquarters at the following address: Attn. Self-Certification Program,
Field Programs Branch, Chemical Management Division (7404), Office of
Pollution Prevention and Toxics, Environmental Protection Agency, 401 M
St., SW., Washington, DC 20460. A duplicate copy of the complete
submission must also be sent to any States from which approval had been
obtained.

    The timely receipt of a complete self-certification by EPA and all
approving States shall have the effect of extending approval under this
MAP to the training courses offered by the submitting provider. If a
self-certification is not received by the approving government bodies on
or before the due date, the affected training course is not approved
under this MAP. Such training providers must then reapply for approval
of these training courses pursuant to the procedures outlined in Unit
III.

C. Requirements applicable to Accredited Persons.

    Persons accredited by a State with an accreditation program no less
stringent than an earlier version of the MAP or by an EPA-approved
training provider as of April 3, 1994, are accredited in accordance with
the requirements of this MAP, and are not required to retake initial
training. They must continue to comply with the requirements for annual
refresher training in Unit I.D. of the revised MAP.

D. Requirements applicable to Non-Accredited Persons.

    In order to perform work requiring accreditation under TSCA Title
II, persons who are not accredited by a State with an accreditation
program no less stringent than an earlier version of the MAP or by an
EPA-approved training provider as of April 3, 1994, must comply with the


upgraded training requirements of this MAP by no later than October 4,
1994. Non-accredited persons may obtain initial accreditation on a
provisional basis by successfully completing any of the training
programs approved under an earlier version of the MAP, and thereby
perform work during the first 6 months after this MAP takes effect.
However, by October 4, 1994, these persons must have successfully
completed an upgraded training program that fully complies with the
requirements of this MAP in order to continue to perform work requiring
accreditation under section 206 of TSCA, 15 U.S.C. 2646.

[59 FR 5251, Feb. 3, 1994, as amended at 60 FR 31922, June 19, 1995]

EPA ICR No. 1365.08; OMB Control No. 2070-0091

Attachment E

Worksheet A-1: Annual Recordkeeping Burden, by School Type and Asbestos
Type

Worksheet A-2:  Annual Recordkeeping Cost, by School Type and Asbestos
Type

	



Worksheet A-1.  Annual Recordkeeping Burden, by School Type and
Asbestos Type



Year	

ACM Type	Previous Year 

Removals	

School 

Counts	Public Primary	Public Secondary	Private	

Total

Hours	

Annual

Total Hours





No. of

 Schools	Hours/

School	No. of

 Schools 	Hours/

School	No. of

Schools	Hours/

School



17	SM & TSI	323	10,786	5,151	35	3,036	58	2,598	35	447,303



TSI	101	3,392	1,620	35	955	58	817	35	140,685



NFACM	424	106,319	59,412	15	23,099	28	23,808	15	      1,895,522
2,483,510

18	SM & TSI	323	10,464	4,997	35	2,946	58	2,520	35	433,963



TSI	101	3,290	1,571	35	926	58	792	35	136,413



NFACM	424	106,744	59,615	15	23,218	28	23,911	15	1,902,994	2,473,370

19	SM & TSI	323	10,141	4,843	35	2,855	58	2,442	35	420,565



TSI	101	3,189	1,523	35	898	58	768	35	132,269



NFACM	424	107,167	59,817	15	23,337	28	24,013	15	1,910.886	2,463,720

20	SM & TSI	323	9,819	4,689	35	2,764	58	2,365	35	407,202



TSI	101	3,087	1,474	35	869	58	744	35	128,032



NFACM	424	112,094	61,344	15	24,586	28	26,164	15	2,001,028	2,536,262 

21	SM & TSI	323	9,496	4,535	35	2,673	58	2,287	35	393,804



TSI	101	2,986	1,426	35	841	58	719	35	123,853



NFACM	424	112,518	61,546	15	24,705	28	26,267	15	2,008,935	2,526,592

22	SM & TSI	1,055	8,441	4,031	35	2,376	58	2,033	35	350,048



TSI	332	2,654	1,268	35	747	58	639	35	110,071



NFACM	1,387	113,905	62,208	15	25,096	28	26,601	15	2,034,823	2,494,942

23	SM & TSI	1,055	7,386	3,527	35	2,079	58	1,779	35	306,292



TSI	332	2,322	1,109	35	654	58	559	35	96,312



NFACM	1,387

	15

28

15



24	SM & TSI	1,055	6,331	3,023	35	1,782	58	1,525	35	262,536



TSI	332	1,991	951	35	560	58	479	35	82,530



NFACM	1,387

	15

28

15



25	SM & TSI	1,055	5,276	2,519	35	1,485	58	1,271	35	218,780



TSI	332	1,659	792	35	467	58	400	35	68,806



NFACM	1,387

	15

28

15



26	SM & TSI	1,055	4,220	2,016	35	1,188	58	1,016	35	175,024



TSI	332	1,327	634	35	374	58	320	35	55,082



NFACM



15

28

15



27	SM & TSI	1,055	3,165	1,512	35	891	58	762	35	131,268



TSI	332	995	475	35	280	58	240	35	41,265



NFACM	1,387

	15

28

15



28	SM & TSI	1,055	2,110	1,008	35	594	58	508	35	87,512



TSI	332	664	317	35	187	58	160	35	27,541



NFACM	1,387

	15

28

15



29	SM & TSI	1,055	1,055	504	35	297	58	254	35	43,756



TSI	332	332	158	35	93	58	80	35	13,724



NFACM	1,387

	15

28

15



30

	SM & TSI	1,055	0	0	35	0	58	0	35	0



TSI	332	0	0	35	0	58	0	35	0



NFACM	1,387

	15

28

15









Total Hours for Years 20 - 22



7,557,796

	Average Hours Per Year for Years 20-22



2,519,262

SM = surfacing material; TSI = thermal systems insulation.  Both are
friable ACM.  NFACM = nonfriable ACM.

Sources:  AHERA RIA (EPA, 1987c), Table 4 and Appendix G; Addendum to
ICR #2070-0091 Asbestos in Schools Rule (EPA, 1987a)



Worksheet A-2:  Annual Recordkeeping Cost, by School Type and Asbestos
Type



Year	

ACM Type	

School 

Counts	Public Primary	Public Secondary	Private	

Total

Cost ($)	

Annual

Total Cost ($)



	No. of

 Schools	$ per

School	No. of

 Schools	$ per

School	No. of Schools	$ per

School



17	SM & TSI	10,786	5,151	$858	3,036	$1,316	2,598	$938	10,851,858



TSI	3,392	1,620	$858	955	$1,316	817	$938	3,413,086



NFACM	106,319	59,412	$416	23,099	$682	23,808	$453	51,253,934	65,518,878

18	SM & TSI	10,464	4,997	$858	2,946	$1,316	2,520	$938	10,528,122



TSI	3,290	1,571	$858	926	$1,316	792	$938	3,309,430



NFACM	106,744	59,615	$416	23,218	$682	23,911	$453	51,466,199	65,303,751

19	SM & TSI	10,141	4,843	$858	2,855	$1,316	2,442	$938	10,203,070



TSI	3,189	1,523	$858	898	$1,316	768	$938	3,208,886



NFACM	107,167	59,817	$416	23,337	$682	24,013	$453	51,677,595	65,089,551

20	SM & TSI	9,819	4,689	$1,021	2,764	$1,586	2,365	$1,021	11,585,838



TSI	3,087	1,474	$1,021	869	$1,586	744	$1,021	3,642,812



NFACM	112,094	61,344	$475	24,586	$787	26,164	$475	60,915,482	76,144,132

21	SM & TSI	9,496	4,535	$1,021	2,673	$1,586	2,287	$1,021	11,204,640



TSI	2,986	1,426	$1,021	841	$1,586	719	$1,021	3,523,871



NFACM	112,518	61,546	$475	24,705	$787	26,267	$475	61,154,010	75,882,521

22	SM & TSI	8,441	4,031	$1,021	2,376	$1,586	2,033	$1,021	9,959,680



TSI	2,654	1,268	$1,021	747	$1,586	639	$1,021	1,837,161



NFACM	113,905	62,208	$475	25,096	$787	26,601	$475	61,934,827	73,731,668

23	SM & TSI	7,386	3,527	$858	2,079	$1,316	1,779	$938	7,430,832



TSI	2,322	1,109	$858	654	$1,316	559	$938	2,336,528



NFACM

	$416

$682

$453



24	SM & TSI	6,331	3,023	$858	1,782	$1,316	1,525	$938	6,369,296



TSI	1,991	951	$858	560	$1,316	479	$938	2,002,220



NFACM

	$416

$682

$453



25	SM & TSI	5,276	2,519	$858	1,485	$1,316	1,271	$938	5,307,760



TSI	1,659	792	$858	467	$1,316	400	$938	1,669,308



NFACM

	$416

$682

$453



26	SM & TSI	4,220	2,016	$858	1,188	$1,316	1,016	$938	4,246,144



TSI	1,327	634	$858	374	$1,316	320	$938	1,336,316



NFACM

	$416

$682

$453



27	SM & TSI	3,165	1,512	$858	891	$1,316	762	$938	3,184,608



TSI	995	475	$858	280	$1,316	240	$938	1,001,150



NFACM

	$416

$682

$453



28	SM & TSI	2,110	1,008	$858	594	$1,316	508	$938	2,123,072



TSI	664	317	$858	187	$1,316	160	$938	668,158



NFACM

	$416

$682

$453



29	SM & TSI	1,055	504	$858	297	$1,316	254	$938	1,061,536



TSI	332	158	$858	93	$1,316	80	$938	332,992



NFACM

	$416

$682

$453



30	SM & TSI	0	0	$858	0	$1,316	0	$938	0



TSI	0	0	$858	0	$1,316	0	$938	0



NFACM

	$416

$682

$453



Total Cost for Years 20-22



$225,758,321

Average Cost per Year for Years 20-22



$75,252,774

SM = surfacing material; TSI = thermal systems insulation.  Both are
friable ACM.  NFACM = non-friable ACM. 

Sources:  AHERA RIA (EPA, 1987c), Table 4 and Appendix G; Addendum to
ICR #2070-0091, Asbestos in Schools Rule (EPA, 1987a)

Wage rates have been updated as described in the text.



References

U.S. Bureau of Labor Statistics. 2005. Occupational Employment
Statistics: May 2005 National 

Industry-Specific Occupational Employment and Wage Estimates. Web site  
  HYPERLINK "http://www.bls.gov/oes/current/oes299011.htm" 
http://www.bls.gov/oes/current/oes299011.htm .  See same Occupational
Employment Statistics, Occupational Employment and Wages, website for
data for wage rates for occupation groups 299012, 370000, 430000,
110000, and 192041 used in the analysis.  

U.S. Bureau of Labor Statistics. 2006. Employment Cost Index, 2Q 2005 to
3Q 2006, 4Q 2005 = 

	100.  Series ID’s CIU3020000000000I, and CIU202S000200000I.  Website 
  HYPERLINK "http://www.bls.gov/web/echistry.pdf" 
http://www.bls.gov/web/echistry.pdf .

U.S. Bureau of Labor Statistics. 2006a. Employer Costs for Employee
Compensation 2Q 2005 to

3Q 2006.  Series ID’s CMU3010000000000D, CMU3020000000000D, and
CMU2010000000000D, CMU2020000000000D. Website     HYPERLINK
"http://www.bls.gov/news.release/pdf/ecec.pdf" 
http://www.bls.gov/news.release/pdf/ecec.pdf  .

U.S. Department of Commerce. 2006.  Bureau of Economic Analysis.  Gross
Domestic Product:

Implicit Price Deflator.  Series ID GDPDEF.  Index 2000=100.  
http://research.stlouisfed.org/fred2/data/GDPDEF.txt.

U.S. Department of Education.  2005.  National Center for Education
Statistics.  Digest of 

	Education Statistics: 2005.  Table 84.  Web site

http://nces.ed.gov/programs/digest/d05/tables/dt05_084.asp 

 

U.S. EPA. 1987a. Office of Toxic Substances, Economics and Technology
Division. Asbestos

Hazard Emergency Response Act Regulatory Impact Analysis. September,
1987.

U.S. EPA. 1987b. Office of Pesticides and Toxic Substances.  Addendum to
ICR #2070-0091 

	Asbestos-In-Schools Rule. October, 1987.

U.S. EPA. 1991. ICR Renewal for the Asbestos Hazard Emergency Response
Act (AHERA),

	Title II of the Toxic Substances Control Act (TSCA) -
Asbestos-Containing Materials in Schools Rule. OMB No. 2070-0091. EPA
ICR #1365.

U.S. EPA. 1993. Supplemental ICR for the Asbestos-Containing Materials
in Schools Rule. 

OMB No. 2070-0091. EPA ICR #1365.

U.S. EPA. 1994. Renewal ICR for the Asbestos-Containing Materials in
Schools Rule. OMB No.  	2070-0091. EPA ICR #1365.

U.S. EPA. 1997. Renewal ICR for the Asbestos-Containing Materials in
Schools Rule. OMB No.

	2070-0091. EPA ICR #1365.

U.S. EPA. 2001. Renewal ICR for the Asbestos-Containing Materials in
Schools Rule. OMB No.

2070-0091. EPA ICR #1365.

U.S. EPA. 2004.  Renewal ICR for the Asbestos-Containing Materials in
Schools Rule. OMB 

	No. 2070-0091. EPA ICR #1365.

U.S. EPA. 2005. Office of Pollution Prevention and Toxics. . National
Directory of AHERA

	Accredited Courses.  November, 2005. Website     HYPERLINK
"http://www.epa.gov/asbestos/ndaac.html" 
http://www.epa.gov/asbestos/ndaac.html .

U.S. Office of Personnel Management. 2006. Salary Table 2006-DCB. Web
Site

  HYPERLINK "http://www.opm.gov/oca/06tables/html/dcb.asp" 
http://www.opm.gov/oca/06tables/html/dcb.asp .



 This worksheet has been revised to include updated numbers of public
primary and secondary schools, and private schools from the Dept. of
Education’s National Center for Education Statistics (NCES) for both
the previous ICR period (years 17 through 19), and the current ICR
period (years 20 through 22).  NCES data used for years 17 through 19
were from 2000-2001, and were used in Section 6 of the previous ICR
renewal, but were not included previously in this worksheet.  NCES data
for 2003-2004 were used for the current ICR renewal.  These school
figures will be updated by NCES in future years of the ICR, so new
totals for both NFACM schools, and all schools, which are based on the
NCES data, are not calculated for the period beyond the current 3-year
period of this ICR renewal.  

 This worksheet has been revised to include updated numbers of public
primary and secondary schools, and private schools from the Dept. of
Education’s National Center for Education Statistics (NCES) for both
the previous ICR period (years 17 through 19), and the current ICR
period (years 20 through 22).  NCES data used for years 17 through 19
were from 2000-2001, and were used in Section 6 of the previous ICR
renewal, but were not included previously in this worksheet.  NCES data
for 2003-2004 were used for the current ICR renewal.  These school
figures will be updated by NCES in future years of the ICR, so new total
costs for both NFCAM schools, and all schools, which are based on the
NCES data, are not calculated for the period beyond the current 3-year
period of this ICR renewal. Totals may not match totals in Section 6
worksheets due to rounding.

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D-  PAGE   3 

