2 Asbestos in UseThere are more the 3000 products that have contained asbestosSome were made in the US, some importedAlmost all building products contained asbestos at one time or anotherThere has never been a regulation that requires the removal of asbestos from buildings merely because it is presentNor have all asbestos-containing materials been banned in the US
3 6 Regulated Asbestos Minerals Chrysotile - most common – White>90% of products in USAmosite - less common - BrownCrocidolite - uncommon – BlueAmosite & crocidolite most common in pipe & boiler insulationOthers - Tremolite, Actinolite, Anthophyllite sometimes found as contaminants with other minerals such as talc and vermiculite
4 Asbestos Containing Materials (ACM) A material containing >1% asbestosA term global to EPA and OSHAAccredited Inspectors perform surveys and issue reportsSample AnalysisACM has to be determined using laboratory techniques, not by “naked” eye“Bulk” samples are analyzed by polarized light microscopy (PLM)Results contain type and percentage of asbestos and other fibrous material
5 Friable & Intact ACMFriable (EPA): material, that when dry, may be crumbled, pulverized or reduced to powder by hand pressureEX: Such pipe insulation or fireproofingIntact (OSHA): means that the ACM has not crumbled, been pulverized, or otherwise deteriorated so that the asbestos is no longer likely to be bound with its matrix.
6 Surfacing material (SM) Material that is spray or trowel applied; generally to ceilings and structural steel
7 Modern non-ACM Fireproofing Can look like older ACM fireproofing ACM fireproofing banned in 1973
8 Thermal System Insulation (TSI) Insulation materials on systems such as: boilers/steam delivery, chilled water, condensate returns and ductworkPrevents heat gain or loss
9 EPA & OSHA allow in-place management If undamaged..EPA & OSHA allow in-place managementUndamaged TSI
10 Badly Damaged TSIWorkers should inform building owners/managers of these situations…and should not be in these areas without PPE. This cannot be repaired, it would require immediate removal/clean up of the area.
19 Ceiling Tiles Some ceiling tiles do contain asbestos, but they are not common
20 Roof Felts, Coatings and Flashing Roof materials (flashing, cements and coatings) may STILL contain asbestos materials in new construction
21 Electrical Applications Asbestos cloth used to insulate electrical lines
22 Worker Protection Rule Classes of asbestos disturbing work (I-IV) Federal Asbestos RegulationsCommon to day-to-day asbestos control workEPAOSHANESHAP40 CFR Part 61Subpart MDemolition, renovation and waste issuesInspections prior to disruptionNotificationsRequired removalWaste packaging & approved landfillsWaste shipment recordsAHERA40 CFR Part 763K-12 schools, public and privateInspections & AssessmentsManagement PlansCommunicationTraining requirementsAbatement final clearance issuesWorker Protection Rule40 CFR Part 763 Subpart GOSHA protection for those in State/Municipal employmentGeneral Industry29 CFRPermissible exposure limits and exposure assessmentsInspection before exposuresWorker protection;Respiratory protection must meet29 CFRTrainingMandatory appendicesConstruction29 CFRClasses of asbestos disturbing work (I-IV)Significant work practice requirementsAlways check for State/Local program requirements!
23 OSHA – Definitions Presumed Asbestos Containing Material (PACM) Surfacing Materials and TSI in buildings constructed through 1980Also: (k)(1)(i) Flooring and Adhesives installed in buildings constructed through 1980This was not a ban!OSHA has not banned any ACMAlso of note: (k)(1)(1)(i) - Other materials that are known or should have known to contain asbestos; “due diligence” (simply; sample before exposure)
24 OSHA Communication Requirements of the Owner (k)(2)(ii)Inspect for ACM/PACM Prior to Disruption“Before work subject to this standard is begun, building and facility owners shall determine the presence, location, and quantity of ACM and/or PACM at the work site…”In most cases, this will require an accredited inspector following AHERA survey requirements
25 OSHA Communication Requirements of the Owner (k)(2)Notify the Following:Prospective Employers applying or bidding for workEmployees of the OwnerMulti-employer worksite employers and employeesTenantsApplies to commercial renters, not apartment dwellers etc.This applies to those in or adjacent to areas containing such material
26 OSHA Communication Requirements of the Owner Employers working at the Owner’s site have responsibilities, (k)(4)…all employers who discover ACM and or PACM…shall convey info concerning presence, location & quantity…newly discovered ACM/PACM to the owner, other employers of employees…within24 hoursGeneral contractors: have responsibility to assure that the abatement contractor is in compliance
27 EPA NESHAP Use/Installation Bans 1973 (fireproofing),1976 (TSI, spray/toweled acoustical) and1978 (decorative material),The following asbestos containing materials are banned:Corrugated PaperRollboardCommercial PaperSpecialty PaperFlooring FeltAny other new uses of asbestos1977 CPSC, asbestos tape & joint compoundHomes & schools, persisted commercially for some time, imports
28 ACM Not BannedThere are many products yet in the market place that can get into new constructionACM not subject to the current bans…a few:asbestos cementcorrugated and flat sheetasbestos cement pipeasbestos cement shinglepipeline wrapvinyl asbestos floor tilemillboardasbestos clothingFriction productsdisc brake padsdrum brake liningsautomatic transmission componentsclutch facingsbrake blocksgaskets & packingsroofing productstypically flashing & cementscaulks, putties, glues & mastics of all kinds
29 Asbestos Inspections The terms “survey” is most commonly used today Surveys are required by regulations under:AHERA – Schools K-12; requirements are well defined within the regulationNESHAP; Demo/Renovations, must inspect for all possible ACMs prior to disruption; notificationsOSHA; Worker protection; inspection and communication before disruption
30 Environmental Site Assessments (ESA) or “Phase I” These are NOT designed to meet regulatory requirements as an asbestos inspectionASTM E …asbestos is excludedDespite reporting language (caveats) in the ESA report…clients often believe they have an asbestos inspectionLimited asbestos surveys or “screens” (ASTM E-2308) are also NOT compliant with required regualtion-required sampling protocols
31 AHERA Requirements Must sample the following and categorize: Surfacing MaterialsFireproofing, textured ceilings etc.Thermal System InsulationPipe and boiler insulation etc.Miscellaneous MaterialsBasically everything else; floor tiles, ceiling tiles, wallboard joint compound, mastics, etc.Assess All Friable MaterialsAnd non-friable ACM which have become friableThis is to describe the condition of the friable ACMFor management purposes
32 OSHA RequirementsFor buildings constructed before 1981, suspect surfacing material and TSI must be assumed to be ACM or testedSheet flooring or floor tiles & mastics installed before 1981 must be assumed to be ACM or testedOSHA “due diligence” for any materialMust sample and communicate prior to disruptionSample BEFORE exposure; may be limited in scopeThe sampling and analytical portion of the survey must be conducted in accordance with AHERA
33 NESHAP RequirementsNational Emission Standard for Hazardous Air Pollutants (NESHAP)Demolition and renovation activities & wasteNESHAP requires:inspection prior to disturbanceA THOROUGH survey!NESHAP has no “end date” when surveys must be performedAn AHERA survey is often not adequate; usually do not sample exteriors or perform invasive sampling (walls, floors)categorize based on friability (NESHAP categories)removal of RACM prior to renovation or demolitionnotification for all demos and most renovation activities
34 Managing Survey DataAn asbestos survey acts as your inventory of what materials are ACM and where they are foundA survey is only useful in the long term IF that inventory is kept up to date!This requires management of when ACM is removed and to then update the survey info
35 Managing Survey Data The old school method: the file cabinet Can you or your staff access this when needed?The new school; electronic data management of this infoAllows for easier access to data and for updating as materials they are removedSpreadsheets or databases, CAD drawings, GIS system infoWhichever is chosen, it needs to be standardized across offices
36 Managing Survey Data The bottom line: Can you inform a staff member or contractor if a material that will be disturbed is ACM or not?!Can you plan for renovations or demo?Proactive vs. ReactiveEPA asbestos NESHAP requires a thorough survey before renovation or demo & removal of RACM as requiredCan you plan for operations & maintenance (O&M)Applies to in-house and subcontracted work
37 Types of Certifications EPA & OSHA require those that perform asbestos work are certifiedAsbestos Inspector; performs the surveyManagement Planner; write O&M plans etc.Certification a matter for school work (AHERA)Project Designer; those that write plans/specs for abatement activitiesSupervisor/Worker; those that perform/manage abatement activitiesProject Monitors; those that manage abatement activities and provide air sampling servicesCertification is by State/Local program hereState/Local program may also require licensing
38 In-house or Subcontracted ACM survey Depends on the scope of the surveyAHERA? NESHAP? OSHA?What is the purpose?If subcontracted remember to defineWhat will be sampled/assumed?EPA and OSHA allow “assume” ACMWhat will be quantified? How accurately?What will be accurately located on a floor plan?What is the deliverable; the final report?
39 In-house or Subcontracted Abatement? O&M or removalCan be performed in-houseTraining, medical monitoring, fit testing, waste issues, specialized equipment (HEPA vacuums, glovebags etc.)….SubcontractorAvailability of qualified, certified firmsIn some areas these are abundant, not allCostLevel of detail of work, location of client, State/Local regsFacility security issues; nights/weekends? badging?
40 OSHA Classes of Work Knowing these work classes is important Class IRemoval of surfacing material, TSI or PACMTraining: 4 day worker, 5 day supervisor (AHERA)Can perform all classes of workClass IIRemoval of other than surfacing and TSIEX: flooring, ACM cement siding, mastics, roofing, wallboardTraining same as Class I if all Class II performedSingle media (task) 8 hr min worker trainingIf trained to one type of work; roofers commonSupervisors: in most cases 5 day training
41 All work classes have annual refresher requirements OSHA Classes of WorkClass IIIAsbestos Surveys; Inspector is subject to Class III requirementsMaintenance & RepairNon-removal (same as AHERA O&M)1 glovebag, mini-enclosures (2 workers max.), 1 waste bag (1/3 – 1/2 full), 60”x60” bag max16 hour trainingClass IVMaintenance & custodial cleaning activities, incidental contact or incidental to construction (Class I, II, III)2 hour awareness trainingAll work classes have annual refresher requirements
42 Closing the LoopNo matter if the survey or abatement is completed by a vendor or in-house…If the data in not managed, the program will failCost of periodic re-inspectionsCost of reactive responses and OSHA mattersACM disturbance issuesA program must be managed or liabilities can result that can be disruptive and expensive
43 Darryl Watson, CIH, CSP, JD Cardno ATC Marietta, GA Questions? Thank you!Darryl Watson, CIH, CSP, JDCardno ATCMarietta, GA