TSCA 206(A) REQUIRES THAT ASBESTOS WORKERS MUST BE ACCREDITED TO CONDUCT RESPONSE ACTIONS INVOLVING FRIABLE ASBESTOS-CONTAINING MATERIALS. THE COMPLAINT ALLEGED THAT MR. HAD RECEIVED CERTIFICATION OF WORKER TRAINING IN COMPLIANCE WITH TSCA, BUT HAD NOT IN FACT ATTENDED SUCH TRAINING. THE COMPLAINT FURTHER ALLEGED THAT MR. JOACHIN HAD PARTICIPATED IN A RESPONSE INVOLVING FRIABLE ASBESTOS DURING THE TIME PERIOD COVERED BY THIS CERTIFICATE.