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How should the periodic surveillance results be documented pursuant to the Asbestos Hazard Emergency Response Act (AHERA)? How detailed does the information have to be and what constitutes adequate records?

40 CFR part 763.94(d) of the asbestos in schools rule pursuant to the Asbestos Hazard Emergency Response Act (AHERA) requires local education agencies (LEAs) to “record the name of each person performing the [periodic] surveillance, the date of the surveillance, and any changes in the conditions of the materials.” A one-page checklist (i.e., change/no change) with sufficient room for comments by the person conducting the surveillance would be adequate, although other methods that record this information also would be acceptable. If changes are noticed, the comments must describe each change clearly.