3 SCOPE OF FEDERAL REGULATIONS OSHA: Work Site Procedures For Worker ProtectionNESHAP: Waste Generation and ManagementAHERA: Identification and Management in BuildingsMAP: Certification of Persons
4 SCOPE & APPLICABILITY OF OSHAApplies wherever a worker works who may be exposed to asbestosRequires employers to protect employeesThe building owner is an employerA notification regulation for building ownersA specification regulation for contractorsGenerally applies even when EPA does notOSHA DOES NOT REQUIRE THE WORK TO BE DONE, BUT REGULATES THE WORK PROCEDURES IF AN EMPLOYEE DISTURBS OR CONTACTS ASBESTOS. OSHA GIVES US WORK PRACTICES!
5 CLASSES OF WORK DEFINITIONS Class I Work The removal of TSI, fireproofing or popcornClass II Work The removal of anything elseClass III Work The small scale, short duration disturbance of ACMClass IV Work Contact, but no disturbance, or cleanup of previously generated debris
6 CLASSES OF WORK APPLICATION Class I Work Requires NPE, shower decon, full PPE, certified people, air monitoring, NEAClass II Work No initial NPE, NEA exemptions for shower decon, PPE, certified workers, air monitoring. One day training.Class III Work Requires PPE for TSI & Surfacing, NEA exemptions for all other ACM Two day training. SS, SD only.Class IV Work Requires NEA, all exemptions allowed, 2 hour training required.
7 SCOPE & APPLICABILITY OF NESHAPApplies to all facilities except single residential buildings having 4 living units or less.REQUIRES A THOROUGH INSPECTION BEFORE DISTURBANCERequires controlled removal of RACM about to be disturbed by DEMOLITION or RENOVATIONRequires prior notification to EPARequires proper management thru & after disposalNo visible emissionsNESHAP REQUIRES CONTROLLED REMOVAL OF ASBESTOS, BY REGULATING THE GENERATION, MANAGEMENT AND DISPOSAL OF THE WASTE. NESHAP IS ASBESTOS WASTE MANAGEMENT!
8 Applicability (a) 61.145 Standard for Demolition and Renovation (a) Applicability. To determine which requirements of paragraphs (a), (b) and (c) of this section apply to the owner or operator of a demolition or renovation activity and prior to the commencement of the demolition or renovation, thoroughly inspect the affected facility or part of the facility where the demolition or renovation operation will occur for the presence of asbestos, including Category I and Category II nonfriable ACM.ApplicabilityNotification RequirementsProcedures for Asbestos Emission Control
9 Definitions (cont.) e) EPA says that the material is RACM Regulated Asbestos Containing Material (RACM)Friable asbestos containing materialb) Category I nonfriable ACM that has become friablec) Category I nonfriable ACM that will be or has beensubjected to sanding, grinding, cutting or abradingd) Category II nonfriable ACM that has a highprobability of becoming or has become crumbled,pulverized, or reduced to powder by the forcesexpected to act on the material in the course ofdemolition or renovation operationse) EPA says that the material is RACM
10 Definitions (cont.) Nonfriable ACM Categories Category I nonfriable ACM: asbestos-containing packings, gaskets, resilient floor covering and asphalt roofing products containing more than 1% asbestos. IN GOOD CONDITION.Category II nonfriable ACM: any material, excluding Category I nonfriable ACM, containing more than 1% asbestos that when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure. IN GOOD CONDITION.Rule of Thumb: a material would not be Category I or II non-friableACM if it cannot be removed without significant breakage(i.e. rendered friable). The material would be RACM.
11 SCOPE & APPLICABILITY OF AHERAApplies in schoolsRequires identification of all ACBMRequires safe management of ACBMIndustry standards for identification & managementContains the Model Accreditation Plan (appendix C)AHERA TELLS US WHAT IS ASBESTOS AND WHAT IS NOT, AND REQUIRES THAT ACBM BE MANAGED SAFELY IN OCCUPIED SCHOOL BUILDINGS. AHERA DOES NOT REQUIRE REMOVAL !
12 MAJOR OBJECTIVES OF AHERA IDENTIFICATION OF ALL ACBMEVALUATION OF HAZARDSSAFE MANAGEMENT OF ACBM
13 AHERA FACILITIES SCHOOLS KINDERGARTEN - 12PUBLIC AND PRIVATENOT FOR PROFIT
14 AHERA CONCEPTS USED UNIVERSALLY ACCREDITATIONASBESTOS INSPECTION PROTOCOLNVLAP CERTIFIED LABORATORIESRESPONSE ACTIONSO & M PROGRAMSFORMAL PROJECT DESIGNFINAL CLEARANCE.
15 MAP SCOPE & APPLICABILITY OF Requires certification of inspectors Applies in all buildings except residential housing through 10 unitsRequires certification of inspectorsRequires certification of persons who design or conduct response actions:Project DesignersContractor/SupervisorsWorkersRequires certified specificationsThe Model Accreditation Plan is an EPA regulation that came out of AHERA, and as such, it applies to Response Actions (friable abatement), inside buildings.
16 SCOPE of the MAP Requires accreditation of training curriculums. Requires certification of people who design and conduct response actions.Requires certification of asbestos inspectors.
17 DEFINITIONS RESPONSE ACTION: A response to Friable ACM Inside the buildingBigger than SS/SD
18 Application of the MAPWhen addressing a Response Action, the following is required:Formal specs done by a certified Project DesignerContractor/Supervisor certification of the competent personWorker certification of all workers