2MIOSHA Consultation, Education, and Training Division (CET)
3DisclaimerThe asbestos regulations are very complex. Each scenario is individually unique. Each inspection is based on a case by case scenario.
4Overview Other Construction Rules Other Occ. Health Standards Asbestos - General Industry (Part 305)Asbestos - Construction (Part 602)Public Act 135 – Asbestos Abatement Contractors Licensing ActPublic Act 440 – Asbestos Worker Accreditation Act
5Common MIOSHA Construction Safety Rules Part 1 – General RulesPart 6 – Personal Protective EquipmentPart 11 – LaddersPart 20 – DemolitionPart 45 – Fall Protection
6Common Occupational Health Rules Part 309 – CadmiumPaint DisturbancePart 430 – Hazard Communication(Global Harmonized System)Part 451 – Respiratory ProtectionAll aspectsPart 601 – Air Contaminants for ConstructionPart 603 – Lead in Construction
7General Industry Asbestos Regulations Applies more to the Facility / Property Owner than the Abatement ContractorSchools / Factories / Commercial BuildingsAsbestos SurveyInforming custodial staff, custodial employers of the Asbestos SurveyLabelingJurisdiction - Homeowners
8General Industry Asbestos Regulations Air Monitoring – Appendix A (Later)Air Monitoring only – GI work
9Part 602 – Asbestos in Construction Standard Scope :
11Responsibilities for General Contractor A General Contractor cannot absolve themselves of asbestos hazards on the site.Overall authority over the jobsiteTypical scenarios for asbestosHave the asbestos abatement work completely separate from the other “regular” construction activities
20Class I Work Thermal System Insulation Plaster – Skim and/or Base Fireproofing
21Typical Items to be asked for during a Class I MIOSHA Inspection Manometric Pressure Readings – NPEManometerSmoke Tubes – Glove BagsHEPA Vacuum – Glove BoxWater Spray Process System – Special Training License6 Mil plastic – HVAC jobs
22Class II Work Floor Tile* Roofing Materials* Siding / Shingles / Transite PanelsGaskets* Settlement Agreements with OSHA
23Typical Items to be asked for during a Class II MIOSHA Inspection Floor Tile*Manometric Readings/ Manometer for Mechanical ChippingRoofing Materials*How was it done?* Settlement Agreements with OSHA
24Class III WorkMini Enclosure60” x 60” glove bagSee Class I Work
28Respiratory Protection An Assigned Protection Factor cannot be established unless the following have been established;1. Fit Test2. Medical Evaluation3. Written Program4. Training5. Maintenance6. Use Requirements
29Protective Clothing Protective clothing Tyvek Spun Bound Paper UndergarmentsClass I – No street clothes on underneathLaundering
30Decontamination – Class I Equipment RoomShower RoomHot and Cold Water from a common streamClean RoomVery Rare – Remote DeconThere is no “It’s below freezing” rule!
31Decontamination - 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 beneathHEPA Vacuum
32Do 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!
34Proper Laboratories for Rebuttal Sample collection by an accredited inspector or a CIHSample must be submitted to:NVLAPNISTRound Robin for Bulk Samples (AIHA)Or an equivalent recognized round robin testing facilityMust follow EPA AHERA – 40 CFR criteria for number of samples
35TrainingMake Sure all employees are up-to-date on their annual license and training requirement.
37Medical SurveillanceMaintain your paperwork through the medical provider or the company!
38Appendix A - Sampling and Analytical Procedure Air MonitoringHSE Phase Shift Test Slide
39Appendix A – Quality Control Procedures Intralaboratory – Statistically designed QA Program involving blind recounts and comparisons between microscopistsInterlaboratory –QA Program with at least 2 other independent laboratoriesProficiency Analytical Testing Program (PAT) or the Asbestos Registry (AIHA)NIOSH Course 582 – Equivalency Course