Presentation is loading. Please wait.

Presentation is loading. Please wait.

2014 Asbestos Symposium Enforcement overview

Similar presentations

Presentation on theme: "2014 Asbestos Symposium Enforcement overview"— Presentation transcript:

1 2014 Asbestos Symposium Enforcement overview
Eric Allen Senior Industrial Hygienist MIOSHA CSHD & Asbestos Division

2 MIOSHA Consultation, Education, and Training Division (CET)

3 Disclaimer The asbestos regulations are very complex. Each scenario is individually unique. Each inspection is based on a case by case scenario.

4 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

5 Common MIOSHA Construction Safety Rules
Part 1 – General Rules Part 6 – Personal Protective Equipment Part 11 – Ladders Part 20 – Demolition Part 45 – Fall Protection

6 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

7 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

8 General Industry Asbestos Regulations
Air Monitoring – Appendix A (Later) Air Monitoring only – GI work

9 Part 602 – Asbestos in Construction
Standard Scope :

10 Responsibilities for all Employers

11 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

12 General Contractor – (d)(5)

13 Abatement Work under 602

14 Regulated Area Asbestos Tape – Red
Note* = Change in 2015/2016 for signage

15 Competent Person Must be up-to-date on Contractor/Supervisor Training and Licensing (PA 440)

16 Competent Person - Continued

17 Air Monitoring Negative Exposure Assessment Initial Determination
Must be “apples to apples” Closely resembling Initial Determination 8-hour samples and 30-minute samples are required

18 Prohibited Activities

19 Classes of Asbestos Work

20 Class I Work Thermal System Insulation Plaster – Skim and/or Base

21 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

22 Class II Work Floor Tile* Roofing Materials*
Siding / Shingles / Transite Panels Gaskets * Settlement Agreements with OSHA

23 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

24 Class III Work Mini Enclosure 60” x 60” glove bag See Class I Work

25 Class IV Work

26 Other Work (g)(11) Asphaltic Pipelines Roof Flashing
These have specific rules contained in the Roofing Industry Settlement with OSHA

27 Part 451- Respiratory Protection Program

28 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

29 Protective Clothing Protective clothing Tyvek Spun Bound
Paper Undergarments Class I – No street clothes on underneath Laundering

30 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!

31 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

32 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!

33 How can I rebut a material?

34 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

35 Training Make Sure all employees are up-to-date on their annual license and training requirement.

36 Waste Disposal

37 Medical Surveillance Maintain your paperwork through the medical provider or the company!

38 Appendix A - Sampling and Analytical Procedure
Air Monitoring HSE Phase Shift Test Slide

39 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

40 P.A. 135 – Asbestos Abatement Contractors Licensing Act

41 P.A. 135 – Asbestos Abatement Contractors Licensing Act

42 P.A. 440 – Asbestos Worker Accreditation Act

43 Questions?

Download ppt "2014 Asbestos Symposium Enforcement overview"

Similar presentations

Ads by Google