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K-12 Schools: A List of Potential Federal Environmental Regulation Violations

Environtmental Risk Management - School Mold Testing 2Environmental Risk Management has been keeping Ohio, Kentucky, and Indiana schools clean, safe, and compliant with federal environmental regulations for years.  Below is a list of some of the most common laws that apply to K–12 schools.   It’s not the full list but a list of what schools have the highest potential for concerning possible violations.

Asbestos violations include failure to…

  • Prepare and maintain an Asbestos Management Plan, maintain copies of the Plan in offices of the school and the local education agency, and at least annually notify parents, teachers, and employee organizations that the Plan is available for review.
  • Describe in the Asbestos Management Plan steps taken for annual notification of workers, building occupants, or their legal guardians about asbestos-related activities.
  • Appoint a designated person to oversee and ensure compliance with the Asbestos Hazardous Emergency Response Act (AHERA), and provide asbestos training to custodial and maintenance staff.
  • Identify all locations of suspected asbestos-containing building materials.
  • Take and analyze bulk samples, conduct six-month periodic surveillance and triennial re-inspections, and post warning labels in routine maintenance areas.
  • Notify the EPA of plans for renovation/demolition involving removal or disturbance of asbestos-containing materials greater than 160 square feet or 260 linear feet. Use trained and accredited asbestos personnel.

Hazardous waste violations include failure to…

  • Make proper hazardous waste determinations.
  • Label hazardous waste containers properly.
  • Close hazardous waste containers when not in use.
  • Segregate incompatible hazardous wastes.
  • Properly manage and dispose of hazardous wastes.
  • Use hazardous waste manifests.

Oil storage tank violations include failure to…

  • Monitor underground storage tanks (USTs)
  • Upgrade/replace/close USTs by December 22, 1998
  • Provide secondary containment for regulated aboveground storage tanks (ASTs) and develop and maintain a Spill Prevention, Control, and Countermeasure Plan (SPCC)
  • File annual Emergency Planning and Community Right-to-Know Act (EPCRA) Tier 2 chemical inventory information with the local fire department, Local Emergency Planning Commission, and State Emergency Response Commission (for USTs and ASTs holding more than 1,320 gallons).

Underground injection control violations include failure to…

  • Comply with the ban on cesspools (no septic, leaching pit only) serving 20 or more persons.
  • Inventory and obtain authorization for septic systems serving 20 or more persons and discharge to a leach field or cesspool/leaching pit.
  • Inventory and obtain authorization for outdoor stormwater drain discharges to a dry well(s).
  • Inventory and obtain any required permits for shop or laboratory drain discharging to a dry well, septic system, or leach field.
  • Potential pesticide violations include failure to:
  • Apply pesticides according to label instructions, including commercial pesticides requiring application by a certified applicator.
  • Potential chlorofluorocarbon (CFC) violations include failure to:
  • Ensure that all refrigeration air-conditioning equipment is serviced by personnel certified to handle and recover CFC refrigerants.

Combustion source violations include failure to…

  • Obtain applicable permit(s) for combustion products from boilers.
  • Notify and report the installation of new boilers greater than 10 million BTUs/hour.

Polychlorinated biphenyls (PCBs) violations include failure to…

  • Properly manage PCB oil and/or PCB-contaminated wastes, including (but not limited to) marking, record keeping, storage, inspection, and disposal requirements.

Need someone to help your school stay compliant? We work with these regulations everyday and know how to handle it for you, so you can focus on your students.  

Contact Us (859-689-9222 – KY, 513-367-4100 – OH) to get more information about how we can help your business.

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