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Eric Allen Senior Industrial Hygienist MIOSHA CSHD & Asbestos Division.

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Presentation on theme: "Eric Allen Senior Industrial Hygienist MIOSHA CSHD & Asbestos Division."— Presentation transcript:

1 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 Paint Disturbance

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 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  Fireproofing

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

42 P.A. 440 – Asbestos Worker Accreditation Act

43 Questions?


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