On September 30, 2004 a Consent Agreement and Final Order (CAFO) was filed resolving violations of the Asbestos Hazards Emergency Response Act (���AHERA���) under the Toxic Substances Control Act (���TSCA���). Upper Moreland School District (���District���) located in Willow Grove, Pennsylvania owns and operates four schools. The District failed to ensure that short term workers were notified concerning locations of asbestos material in the schools. The District also failed to perform periodic surveillance, ensure that the Round Meadow Elementary School and the Upper Moreland Middle School maintain in its administrative office a complete, updated copy of the management plan, provide training to all members of its maintenance and custodial staff, and annually notify in writing, parents teachers, and employees organizations of the availability of the management plan. Upper Moreland School District contains more than 1000 linear feet and more than 3000 square feet of asbestos-containing material. There are four schools operated under the Upper Moreland School District ranging from kindergarten to twelfth grades with approximately 11,920 students and 400 employees. Management plans are used to note the location and condition of asbestos-containing materials (ACM) through-out the school. It is the responsibility of the designated person to ensure that the management plan is maintained and updated as required by AHERA. A management plan