1. Revising The 1985 EPA Purple Book

2. History / Timeline of the Purple Book 1.Published 1985 2.Immediately outdated 1.1986 OSHA Const. Std. 2.1987 AHERA 3.1990 NESHAP 4.1994 MAP (ASHARA) 5.1994 OSHA Const. Std. 3.GETF convened EPA “Blue Ribbon Committee” 10/02 1.Asbestos Strategies Report 4/03 2.#1 recommendation: Revise & update the Purple Book 4.EPA started “revision” of Purple Book 2005 5.Letter to EIA 6/09 Knowledge, control concepts, ways of doing business, analytical procedures, have all changed

3. 6/1/09 Brent Kynoch received a request from U.S. EPA to have EIA review the 1985 “Purple Book” for accuracy, and provide comments on needed revisions

4. After discussion with the Board of Directors, Brent contacted the asbestos committee chair, to organize a Purple Book Review Committee, and start the project.

5. The committee would be formed around the following disciplines: Consulting / Specifications Training / General Information Analytical Regulations Health Effects / Asbestos Disease ASTM / Outside Resources Construction EIA Purple Book Committee

6. Bill Cavness (Chair) TAI, AZ Brent Kynoch (Coordinator), EIA, MD Kevin Cannan, AAC, NY Dr. Ron Dodson, TX Bill Ewing, Compass Environmental, GA Steve Hayes, Gobbell Hayes Partners, TN Dave Hogue, TEI, GA Dave Kahane, Forensic Analytical, CA Tom Laubenthaul, TEI, GA Dr. Jim Millette, MVA, GA Andy Oberta, Environmental Consultancy, TX Mike Schrum, Terracon, NC Dr. Jim Webber, Wadsworth Center, NY

7. The proposed committee members were unanimous in their agreement to serve. Amazing… To get that many KEY people together from all parts of the country, to immediately volunteer for this project… And all are committed to not only making recommendations, but to do the entire re-write if necessary.

8. Brent and the EIA staff set up an interactive website with the entire text of the Purple Book, so that all could participate, and make notes and revisions for all to see. If it comes to an actual re-write of the book, this will be invaluable.

9. Face – to – face - meeting Meeting scheduled for July 20 th in the Atlanta area The Environmental Institute facilities in Marietta, GA Most members made it, others participated by teleconference, along with EPA Tom Laubenthaul volunteered to transcribe the notes as they are discussed and display them on an overhead screen

10. After The Meeting Tom emailed notes to members Comments / revisions / additions Tom writes the submittals EIA office does final revisions Submitted to EPA 9/1/09 A lot of effort by some very busy people

11. The Recommendations The Purple Book is still needed. It should address all types of buildings, public, commercial and industrial. It should be a “Best Work Practice” guide, not merely a regulatory guide. Outside resources should be referenced, such as ASTM, ISO, HSE, others.

12. It should address all types of asbestos, not only the basic 6, and all common media, not only ACM in buildings (NOA, soil, dust) that affect an owners site. All vermiculite in buildings should be addressed, not only VAI. Analytical methods must be updated. The Recommendations

13. Health effects information MUST be updated. Basic personal safety and PPE must be addressed. O&M (Green Book) issues need to be addressed. Almost all photographs and graphs need to be replaced. The Recommendations

14. The finished product should be reviewed by a panel of “practicing, recognized, asbestos control industry experts”, and their comments considered. The Recommendations

15. EIA Purple Book Timeline 6/1/09 Request from EPA 6/10/09 Committee agreed on 6/15/09 Committee unanimous on serving 7/20/09 Atlanta meeting 8/31/09 Final revision of “proceedings” 9/1/09 Submitted recommendations to EPA

16. The Submittals A submittal letter, an Executive Summary, and the detailed Summary of Proceedings (detailed notes by chapter, paragraph and appendix) were all drafted by Tom Laubenthaul, refined by Brent Kynoch and submitted to EPA on 9/1/09. About 30 pages in all.

17. Where does it go from here? 1.EPA does nothing 2.EPA re-writes in-house 1.Uses EIA recommendations 2.Ignores EIA recommendations 3.EPA has EIA undertake re-write BUT The committee has determined not to let it drop. One of the first items agreed on was the need for the document.

18. If EPA does nothing, or decides to produce a purely EPA regulatory document …… (A sobering time of decision early in the meeting)

19. The EIA Purple Book Committee is committed to produce the very best asbestos guidance document possible, that can be used here at home or internationally. We have the right people and the expertise. EIA can publish electronically. If necessary, EIA can do it all!

20. If EIA writes it’s own book It probably won’t be purple. It will be international in scope / use. It will include other resources (ASTM, ISO, HSE, etc.). The committee is only the nucleus of the resources that EIA has. But we have the right people, all together, right now. An exciting prospect!