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What is the applicability of Federal asbestos inspector accreditation requirements under the Asbestos Hazard Emergency Response Act (AHERA) to real estate appraisers?

Real estate appraisers may not assess the suspected presence, location, or condition of asbestos in a school building or a public and commercial building during an appraisal unless they are accredited pursuant to the Toxic Substances Control Act (TSCA) and the Asbestos Model Accreditation Plan (MAP), as conducting an examination, either visual or physical, to determine whether a substance contains asbestos qualifies as an “inspection” as defined by the MAP.

EPA advises real estate appraisers to obtain asbestos inspector training and accreditation only if they determine that they will be undertaking inspections and examinations that would fall within the activities that trigger accreditation requirements under TSCA and the MAP. If an appraiser relies entirely upon an existing asbestos inspection report for a particular building that they are appraising, for purposes of estimating the impact of the presence or condition of asbestos on the value of the property, that appraiser would not need to be accredited.