OSHA A GUIDE TO THE NEGATIVE EXPOSURE ASSESSMENT

Air Monitoring Data and The Negative Exposure Assessment First, a short explanation of air monitoring and the negative exposure assessment: As mentioned before, air monitoring and the air monitoring data is the most important compliance issue under the OSHA asbestos standard. You may not do any asbestos work without documenting the airborne exposure to the workers. This is done by either conducting initial personal air monitoring at the time of work, or by relying on acceptable previously generated air monitoring data in your possession at that time. This previous data represents your work on the current job and is referred to as “Negative Exposure Assessment”.

There are 4 terms relating to the air data used in the standard: 1.Initial Exposure Assessment: This means an assessment, or well thought out plan on how the work will be done so that there will be no exposure above the PEL. This is the first responsibility of the Competent Person for the employer. The assessment considers the Class of Work, the employees training, the material, the condition of the material, the controls to be used, work procedures, environmental conditions and any previous air monitoring. 2.Negative Exposure Assessment: This is conducting the work according to the Initial Exposure Assessment while collecting air samples verifying the negative result. The air monitoring is attached to the Assessment, which is then the Negative Exposure Assessment.

3. Negative Initial Exposure Assessment: This is starting the job with a verified Negative Exposure Assessment in hand. You should have more than 1 set of air data to be statistically reliable in making the prediction that there will be no exposure, although OSHA does not specify that in the regulation. The definition in paragraph (b) of the regulation reads: “a demonstration by the employer, which complies with the criteria in (f)(2)(iii) of this section, that employee exposure during an operation is expected to be consistently below the PELs”. 4. Initial Monitoring of the Current Job: This is simply doing the air monitoring on the current job. It is either the initial monitoring which is used to verify the Negative Exposure Assessment, or it is simply doing air monitoring every time, and not relying on previous data. Most abatement contractors do air monitoring every job. Most industry does class III or IV work with NEAs.

Generating A NEA Documented Negative Exposure Assessments are best accomplished with forms and lab results of analysis attached. The following are standard forms used in the industry, and meet compliance with 29 CFR (f).The first form of the 4 is always used, and is the Initial Exposure Assessment, or the description of the work. One of the other 3 is then used and air monitoring results are attached. If no NEA or air monitoring data exists, it is a serious violation. Exposure must be assumed.

NEA Forms The Objective Data form is used when relying on outside data that you did not generate. It may be available from a manufacturer of an ACM or of a proprietary procedure or even from OSHA (i.e. VAT removal). There is very little Objective Data in the industry. The advantage is that the data is good indefinitely, as long as the material and the procedures do not change. This exempts the employer from conducting ongoing air monitoring, and except for Class I Work, exempts respirators, protective clothing and any level of decontamination.

The Historical Data form is used when relying on air monitoring data generated in-house. This data is valid if generated within 1 year of the current job. It must be repeated annually. The jobs that it is used on must “closely resemble” the job on which the data was generated. It is good at any location in the U.S. Like the Objective Data, except for Class I Work, all the same regulatory exemptions apply. NEA Forms

The last form is the “Initial Monitoring Of This Job” form. It is merely designed as a cover sheet to the air monitoring data on the current job, where prior data is not being relied on. It makes the statement that the data was collected in compliance with the standard, and that the results are “Negative” (below the PELs). NEA Forms

INITIAL EXPOSURE ASSESSMENT Must be conducted by a Competent Person before the initiation of any work covered by 29 CFR Class of work: Class I Class II Class III Class IV Type of Asbestos Containing Material: ____________________________________ Condition of ACM: Intact Non-intact Type and percent of asbestos: __________________________________________ Indicate Specific or Alternative control Methods: Specific Control Methods Alternative Control Methods Describe Control Methods: _____________________________________________ ___________________________________________________________________ Employee’s Training: Class I Class II Class III Class IV Environmental Conditions: _____________________________________________ THIS ASSESSMENT IS: NEGATIVE POSITIVE COMPETENT PERSON: ______________________________________________ PROJECT: ____________________________________ DATE: ____________

NEGATIVE EXPOSURE ASSESSMENT OBJECTIVE DATA Who developed the objective data? ______________________________________ ___________________________________________________________________ When was the Objective Data developed? _________________________________ ___________________________________________________________________ Average monitoring results: TWA:________________ EL:________________ Is the Objective Data statistically reliable? _________________________________ Attach Objective Data including pump calibration data.

NEGATIVE EXPOSURE ASSESSMENT HISTORICAL DATA Was the data obtained within the last 12 months? Yes No Was the data for both the TWA and EL? Yes No Was prior monitoring and analysis performed correctly? Yes No Were work procedures and controls the same? Yes No Please describe: _____________________________________________________ Was the material the same? Yes No Please describe: _____________________________________________________ Were the environmental conditions the same? Yes No Please describe: _____________________________________________________ ___________________________________________________________________ Prior monitoring below the PEL’s? Yes No Worker training & experience the same? Yes No Document: _________________________________________________________ __________________________________________________________________ If you answered “no” to any question, you may not base your NEA on Historical Data.

NEGATIVE EXPOSURE ASSESSMENT INITIAL MONITORING OF THIS JOB Were air samples taken from the workers breathing zone, representative of an 8- hour time weighted average and including a 30 minute exposure? Yes No Attach data. Were the operations most likely to cause exposure above a PEL monitored? Yes No Describe operations: __________________________________________________ ___________________________________________________________________ Were the samples analyzed according to the standard? Yes No Were the results below the PEL’s? Yes No Note results here:_____________________________________________________ ___________________________________________________________________ TWA: ________________ EL: __________________ Date(s) of air monitoring: _______________________________________________ If you answered “no” to any question, you may not base your NEA on Air Monitoring Data.