1. Asbestos Issues for Facility Management
Darryl Watson, CIH, CSP, JD
Cardno ATC
Marietta, GA
7-13

2. Asbestos in Use
There are more the 3000 products that have contained asbestos
Some were made in the US, some imported
Almost all building products contained asbestos at one time or another
There has never been a regulation that requires the removal of asbestos from buildings merely because it is present
Nor have all asbestos-containing materials been banned in the US

3. 6 Regulated Asbestos Minerals
Chrysotile - most common – White
>90% of products in US
Amosite - less common - Brown
Crocidolite - uncommon – Blue
Amosite & crocidolite most common in pipe & boiler insulation
Others - Tremolite, Actinolite, Anthophyllite sometimes found as contaminants with other minerals such as talc and vermiculite

4. Asbestos Containing Materials (ACM)
A material containing >1% asbestos
A term global to EPA and OSHA
Accredited Inspectors perform surveys and issue reports
Sample Analysis
ACM 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 ACM
Friable (EPA): material, that when dry, may be crumbled, pulverized or reduced to powder by hand pressure
EX: Such pipe insulation or fireproofing
Intact (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 ductwork
Prevents heat gain or loss

9. EPA & OSHA allow in-place management
If undamaged..
EPA & OSHA allow in-place management
Undamaged TSI

10. Badly Damaged TSI
Workers 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.

11. “Air Cell” Corrugated Insulation

12. Miscellaneous Materials
A broad spectrum of ACM’s that do not fall into the categories SM or TSI

13. Resilient Floor Coverings (RFC)
Floor Tiles, Linoleums, and Mastics (glue)
In good shape on the left
Damage on the right should be repaired or removed

14. Wallboard Joint Compound & Tape
Recent construction
Older construction
Asbestos?

15. Asbestos Packing & Gaskets New!

16. Corrugated Asbestos Cement Board

17. Corrugated Cement Sheet Roof Panel
Asbestos Cement Pipe

18. Fire Rated Doors

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 Regulations
Common to day-to-day asbestos control work
EPA
OSHA
NESHAP
40 CFR Part 61
Subpart M
Demolition, renovation and waste issues
Inspections prior to disruption
Notifications
Required removal
Waste packaging & approved landfills
Waste shipment records
AHERA
40 CFR Part 763
K-12 schools, public and private
Inspections & Assessments
Management Plans
Communication
Training requirements
Abatement final clearance issues
Worker Protection Rule
40 CFR Part 763 Subpart G
OSHA protection for those in State/Municipal employment
General Industry
29 CFR
Permissible exposure limits and exposure assessments
Inspection before exposures
Worker protection;
Respiratory protection must meet
29 CFR
Training
Mandatory appendices
Construction
29 CFR
Classes of asbestos disturbing work (I-IV)
Significant work practice requirements
Always check for State/Local program requirements!

23. OSHA – Definitions Presumed Asbestos Containing Material (PACM)
Surfacing Materials and TSI in buildings constructed through 1980
Also: (k)(1)(i) Flooring and Adhesives installed in buildings constructed through 1980
This was not a ban!
OSHA has not banned any ACM
Also 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 work
Employees of the Owner
Multi-employer worksite employers and employees
Tenants
Applies 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 hours
General 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) and
1978 (decorative material),
The following asbestos containing materials are banned:
Corrugated Paper
Rollboard
Commercial Paper
Specialty Paper
Flooring Felt
Any other new uses of asbestos
1977 CPSC, asbestos tape & joint compound
Homes & schools, persisted commercially for some time, imports

28. ACM Not Banned
There are many products yet in the market place that can get into new construction
ACM not subject to the current bans…a few:
asbestos cement
corrugated and flat sheet
asbestos cement pipe
asbestos cement shingle
pipeline wrap
vinyl asbestos floor tile
millboard
asbestos clothing
Friction products
disc brake pads
drum brake linings
automatic transmission components
clutch facings
brake blocks
gaskets & packings
roofing products
typically flashing & cements
caulks, 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 regulation
NESHAP; Demo/Renovations, must inspect for all possible ACMs prior to disruption; notifications
OSHA; 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 inspection
ASTM E …asbestos is excluded
Despite reporting language (caveats) in the ESA report…clients often believe they have an asbestos inspection
Limited 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 Materials
Fireproofing, textured ceilings etc.
Thermal System Insulation
Pipe and boiler insulation etc.
Miscellaneous Materials
Basically everything else; floor tiles, ceiling tiles, wallboard joint compound, mastics, etc.
Assess All Friable Materials
And non-friable ACM which have become friable
This is to describe the condition of the friable ACM
For management purposes

32. OSHA Requirements
For buildings constructed before 1981, suspect surfacing material and TSI must be assumed to be ACM or tested
Sheet flooring or floor tiles & mastics installed before 1981 must be assumed to be ACM or tested
OSHA “due diligence” for any material
Must sample and communicate prior to disruption
Sample BEFORE exposure; may be limited in scope
The sampling and analytical portion of the survey must be conducted in accordance with AHERA

33. NESHAP Requirements
National Emission Standard for Hazardous Air Pollutants (NESHAP)
Demolition and renovation activities & waste
NESHAP requires:
inspection prior to disturbance
A THOROUGH survey!
NESHAP has no “end date” when surveys must be performed
An 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 demolition
notification for all demos and most renovation activities

34. Managing Survey Data
An asbestos survey acts as your inventory of what materials are ACM and where they are found
A 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 info
Allows for easier access to data and for updating as materials they are removed
Spreadsheets or databases, CAD drawings, GIS system info
Whichever 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. Reactive
EPA asbestos NESHAP requires a thorough survey before renovation or demo & removal of RACM as required
Can 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 certified
Asbestos Inspector; performs the survey
Management Planner; write O&M plans etc.
Certification a matter for school work (AHERA)
Project Designer; those that write plans/specs for abatement activities
Supervisor/Worker; those that perform/manage abatement activities
Project Monitors; those that manage abatement activities and provide air sampling services
Certification is by State/Local program here
State/Local program may also require licensing

38. In-house or Subcontracted ACM survey
Depends on the scope of the survey
AHERA? NESHAP? OSHA?
What is the purpose?
If subcontracted remember to define
What will be sampled/assumed?
EPA and OSHA allow “assume” ACM
What 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 removal
Can be performed in-house
Training, medical monitoring, fit testing, waste issues, specialized equipment (HEPA vacuums, glovebags etc.)….
Subcontractor
Availability of qualified, certified firms
In some areas these are abundant, not all
Cost
Level of detail of work, location of client, State/Local regs
Facility security issues; nights/weekends? badging?

40. OSHA Classes of Work Knowing these work classes is important
Class I
Removal of surfacing material, TSI or PACM
Training: 4 day worker, 5 day supervisor (AHERA)
Can perform all classes of work
Class II
Removal of other than surfacing and TSI
EX: flooring, ACM cement siding, mastics, roofing, wallboard
Training same as Class I if all Class II performed
Single media (task) 8 hr min worker training
If trained to one type of work; roofers common
Supervisors: in most cases 5 day training

41. All work classes have annual refresher requirements
OSHA Classes of Work
Class III
Asbestos Surveys; Inspector is subject to Class III requirements
Maintenance & Repair
Non-removal (same as AHERA O&M)
1 glovebag, mini-enclosures (2 workers max.), 1 waste bag (1/3 – 1/2 full), 60”x60” bag max
16 hour training
Class IV
Maintenance & custodial cleaning activities, incidental contact or incidental to construction (Class I, II, III)
2 hour awareness training
All work classes have annual refresher requirements

42. Closing the Loop
No matter if the survey or abatement is completed by a vendor or in-house…
If the data in not managed, the program will fail
Cost of periodic re-inspections
Cost of reactive responses and OSHA matters
ACM disturbance issues
A 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, JD
Cardno ATC
Marietta, GA