1. REGULATORY OVERVIEW

2. FEDERAL ASBESTOS REGULATIONS
OSHA
OSHA 29 CFR
OSHA 29 CFR
OSHA 29 CFR
RESPIRATORY PROTECTION 29 CFR
EPA
NESHAP 40 CFR 61, Subpart M
NESHAP 40 CFR 61, Subpart M
AHERA 40 CFR 763, Subpart E
WORKER PROTECTION 40 CFR 763, Subpart G
ASHARA (Model Accreditation Plan)
AHERA 40 CFR 763, Subpart E
AHERA 40 CFR 763, Subpart E

3. SCOPE OF FEDERAL REGULATIONS
OSHA: Work Site Procedures For Worker Protection
NESHAP: Waste Generation and Management
AHERA: Identification and Management in Buildings
MAP: Certification of Persons

4. SCOPE & APPLICABILITY OF
OSHA
Applies wherever a worker works who may be exposed to asbestos
Requires employers to protect employees
The building owner is an employer
A notification regulation for building owners
A specification regulation for contractors
Generally applies even when EPA does not
OSHA DOES NOT REQUIRE THE WORK TO BE DONE, BUT REGULATES THE WORK PROCEDURES IF AN EMPLOYEE DISTURBS OR CONTACTS ASBESTOS. OSHA GIVES US WORK PRACTICES!

5. CLASSES OF WORK DEFINITIONS
Class I Work The removal of TSI, fireproofing or popcorn
Class II Work The removal of anything else
Class III Work The small scale, short duration disturbance of ACM
Class IV Work Contact, but no disturbance, or cleanup of previously generated debris

6. CLASSES OF WORK APPLICATION
Class I Work Requires NPE, shower decon, full PPE, certified people, air monitoring, NEA
Class II Work No initial NPE, NEA exemptions for shower decon, PPE, certified workers, air monitoring. One day training.
Class III Work Requires PPE for TSI & Surfacing, NEA exemptions for all other ACM Two day training. SS, SD only.
Class IV Work Requires NEA, all exemptions allowed, 2 hour training required.

7. SCOPE & APPLICABILITY OF
NESHAP
Applies to all facilities except single residential buildings having 4 living units or less.
REQUIRES A THOROUGH INSPECTION BEFORE DISTURBANCE
Requires controlled removal of RACM about to be disturbed by DEMOLITION or RENOVATION
Requires prior notification to EPA
Requires proper management thru & after disposal
No visible emissions
NESHAP REQUIRES CONTROLLED REMOVAL OF ASBESTOS, BY REGULATING THE GENERATION, MANAGEMENT AND DISPOSAL OF THE WASTE. NESHAP IS ASBESTOS WASTE MANAGEMENT!

8. Applicability (a) 61.145 Standard for Demolition and Renovation
(a) Applicability. To determine which requirements of paragraphs (a), (b) and (c) of this section apply to the owner or operator of a demolition or renovation activity and prior to the commencement of the demolition or renovation, thoroughly inspect the affected facility or part of the facility where the demolition or renovation operation will occur for the presence of asbestos, including Category I and Category II nonfriable ACM.
Applicability
Notification Requirements
Procedures for Asbestos Emission Control

9. Definitions (cont.) e) EPA says that the material is RACM
Regulated Asbestos Containing Material (RACM)
Friable asbestos containing material
b) Category I nonfriable ACM that has become friable
c) Category I nonfriable ACM that will be or has been
subjected to sanding, grinding, cutting or abrading
d) Category II nonfriable ACM that has a high
probability of becoming or has become crumbled,
pulverized, or reduced to powder by the forces
expected to act on the material in the course of
demolition or renovation operations
e) EPA says that the material is RACM

10. Definitions (cont.) Nonfriable ACM Categories
Category I nonfriable ACM: asbestos-containing packings, gaskets, resilient floor covering and asphalt roofing products containing more than 1% asbestos. IN GOOD CONDITION.
Category II nonfriable ACM: any material, excluding Category I nonfriable ACM, containing more than 1% asbestos that when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure. IN GOOD CONDITION.
Rule of Thumb: a material would not be Category I or II non-friable
ACM if it cannot be removed without significant breakage
(i.e. rendered friable). The material would be RACM.

11. SCOPE & APPLICABILITY OF
AHERA
Applies in schools
Requires identification of all ACBM
Requires safe management of ACBM
Industry standards for identification & management
Contains the Model Accreditation Plan (appendix C)
AHERA TELLS US WHAT IS ASBESTOS AND WHAT IS NOT, AND REQUIRES THAT ACBM BE MANAGED SAFELY IN OCCUPIED SCHOOL BUILDINGS. AHERA DOES NOT REQUIRE REMOVAL !

12. MAJOR OBJECTIVES OF AHERA
IDENTIFICATION OF ALL ACBM
EVALUATION OF HAZARDS
SAFE MANAGEMENT OF ACBM

13. AHERA FACILITIES SCHOOLS
KINDERGARTEN - 12
PUBLIC AND PRIVATE
NOT FOR PROFIT

14. AHERA CONCEPTS USED UNIVERSALLY
ACCREDITATION
ASBESTOS INSPECTION PROTOCOL
NVLAP CERTIFIED LABORATORIES
RESPONSE ACTIONS
O & M PROGRAMS
FORMAL PROJECT DESIGN
FINAL CLEARANCE.

15. MAP SCOPE & APPLICABILITY OF Requires certification of inspectors
Applies in all buildings except residential housing through 10 units
Requires certification of inspectors
Requires certification of persons who design or conduct response actions:
Project Designers
Contractor/Supervisors
Workers
Requires certified specifications
The Model Accreditation Plan is an EPA regulation that came out of AHERA, and as such, it applies to Response Actions (friable abatement), inside buildings.

16. SCOPE of the MAP Requires accreditation of training curriculums.
Requires certification of people who design and conduct response actions.
Requires certification of asbestos inspectors.

17. DEFINITIONS RESPONSE ACTION: A response to Friable ACM
Inside the building
Bigger than SS/SD

18. Application of the MAP
When addressing a Response Action, the following is required:
Formal specs done by a certified Project Designer
Contractor/Supervisor certification of the competent person
Worker certification of all workers