Presentation on theme: "Eric Allen Senior Industrial Hygienist MIOSHA CSHD & Asbestos Division."— Presentation transcript:
Eric Allen Senior Industrial Hygienist MIOSHA CSHD & Asbestos Division
MIOSHA Consultation, Education, and Training Division (CET)
Disclaimer The asbestos regulations are very complex. Each scenario is individually unique. Each inspection is based on a case by case scenario.
Overview Other Construction Rules Other Occ. Health Standards Asbestos - General Industry (Part 305) Asbestos - Construction (Part 602) Public Act 135 – Asbestos Abatement Contractors Licensing Act Public Act 440 – Asbestos Worker Accreditation Act
Common MIOSHA Construction Safety Rules Part 1 – General Rules Part 6 – Personal Protective Equipment Part 11 – Ladders Part 20 – Demolition Part 45 – Fall Protection
Common Occupational Health Rules Part 309 – Cadmium Paint Disturbance Part 430 – Hazard Communication (Global Harmonized System) Part 451 – Respiratory Protection All aspects Part 601 – Air Contaminants for Construction Part 603 – Lead in Construction Paint Disturbance
General Industry Asbestos Regulations Applies more to the Facility / Property Owner than the Abatement Contractor Schools / Factories / Commercial Buildings Asbestos Survey Informing custodial staff, custodial employers of the Asbestos Survey Labeling Jurisdiction - Homeowners
General Industry Asbestos Regulations Air Monitoring – Appendix A (Later) Air Monitoring only – GI work
Part 602 – Asbestos in Construction Standard Scope :
Responsibilities for all Employers
Responsibilities for General Contractor A General Contractor cannot absolve themselves of asbestos hazards on the site. Overall authority over the jobsite Typical scenarios for asbestos ○ Have the asbestos abatement work completely separate from the other “regular” construction activities
General Contractor – (d)(5)
Abatement Work under 602
Regulated Area Asbestos Tape – Red Note* = Change in 2015/2016 for signage
Competent Person Must be up-to-date on Contractor/Supervisor Training and Licensing (PA 440)
Competent Person - Continued
Air Monitoring Negative Exposure Assessment Must be “apples to apples” Closely resembling Initial Determination 8-hour samples and 30-minute samples are required
Classes of Asbestos Work
Class I Work Thermal System Insulation Plaster – Skim and/or Base Fireproofing
Typical Items to be asked for during a Class I MIOSHA Inspection Manometric Pressure Readings – NPE Manometer Smoke Tubes – Glove Bags HEPA Vacuum – Glove Box Water Spray Process System – Special Training License 6 Mil plastic – HVAC jobs
Class II Work Floor Tile* Roofing Materials* Siding / Shingles / Transite Panels Gaskets * Settlement Agreements with OSHA
Typical Items to be asked for during a Class II MIOSHA Inspection Floor Tile* Manometric Readings/ Manometer for Mechanical Chipping Roofing Materials* How was it done? * Settlement Agreements with OSHA
Class III Work Mini Enclosure 60” x 60” glove bag See Class I Work
Class IV Work
Other Work (g)(11) Asphaltic Pipelines Roof Flashing These have specific rules contained in the Roofing Industry Settlement with OSHA
Part 451- Respiratory Protection Program
Respiratory Protection An Assigned Protection Factor cannot be established unless the following have been established; 1. Fit Test 2. Medical Evaluation 3. Written Program 4. Training 5. Maintenance 6. Use Requirements
Protective Clothing Protective clothing Tyvek Spun Bound Paper Undergarments ○ Class I – No street clothes on underneath Laundering
Decontamination – Class I Equipment Room Shower Room Hot and Cold Water from a common stream Clean Room Very Rare – Remote Decon There is no “It’s below freezing” rule!
Decontamination - Continued Requirements for Class I work involving less than 25 linear or 10 square feet of TSI or surfacing ACM and PACM, and for Class II and Class III asbestos work operations where exposures exceed a PEL or where there is no negative exposure assessment produced before the operation. Plastic dropcloth beneath HEPA Vacuum
Do I need an asbestos survey? Yes. The facility / property owner or employer must conduct an asbestos survey. Can I claim everything as asbestos? Yes! But, it must be in writing!
How can I rebut a material?
Proper Laboratories for Rebuttal Sample collection by an accredited inspector or a CIH Sample must be submitted to: NVLAP NIST Round Robin for Bulk Samples (AIHA) Or an equivalent recognized round robin testing facility Must follow EPA AHERA – 40 CFR criteria for number of samples
Training Make Sure all employees are up-to-date on their annual license and training requirement.
Medical Surveillance Maintain your paperwork through the medical provider or the company!
Appendix A - Sampling and Analytical Procedure Air Monitoring HSE Phase Shift Test Slide
Appendix A – Quality Control Procedures Intralaboratory – Statistically designed QA Program involving blind recounts and comparisons between microscopists Interlaboratory – QA Program with at least 2 other independent laboratories Proficiency Analytical Testing Program (PAT) or the Asbestos Registry (AIHA) NIOSH Course 582 – Equivalency Course