Asbestos Issues for Facility Management

Report
Asbestos Issues for
Facility Management
Darryl Watson, CIH, CSP, JD
Cardno ATC
Marietta, GA
7-13
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
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
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
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.
Surfacing material (SM)
– Material that is spray or trowel applied;
generally to ceilings and structural steel
Modern non-ACM
Fireproofing
Can look like older ACM
fireproofing
ACM fireproofing banned
in 1973
Thermal System Insulation (TSI)
• Insulation materials on systems such as:
boilers/steam delivery, chilled water,
condensate returns and ductwork
• Prevents heat gain or loss
If undamaged..
EPA & OSHA
allow in-place
management
Undamaged TSI
Badly Damaged TSI
“Air Cell” Corrugated Insulation
Miscellaneous Materials
• A broad spectrum of ACM’s that do not fall into the
categories SM or TSI
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
Wallboard Joint Compound & Tape
Recent construction
Older construction
Asbestos?
Asbestos Packing & Gaskets
New!
Corrugated Asbestos Cement Board
Corrugated
Cement Sheet
Roof Panel
Asbestos
Cement Pipe
Fire Rated Doors
Ceiling Tiles
Some ceiling tiles do contain asbestos, but they are not common
Roof Felts, Coatings and Flashing
Roof materials (flashing,
cements and coatings) may
STILL contain asbestos
materials in new construction
Electrical Applications
Asbestos cloth used to
insulate electrical lines
Federal Asbestos Regulations
Common to day-to-day asbestos control work
OSHA
EPA
NESHAP
AHERA
40 CFR Part 61
Subpart M
40 CFR Part 763
Demolition,
renovation and
waste issues
K-12 schools, public and
private
Inspections &
Assessments
Inspections prior to
disruption
Management Plans
Notifications
Communication
Required removal
Training requirements
Waste packaging &
approved landfills
Waste shipment
records
Always check for
State/Local program
requirements!
Abatement final clearance
issues
Worker Protection
Rule
40 CFR Part 763 Subpart G
OSHA protection for those
in State/Municipal
employment
General
Industry
Construction
29 CFR 1910.1001
Permissible exposure
limits and exposure
assessments
Permissible exposure
limits and exposure
assessments
Inspection before
exposures
Communication
Worker protection;
Respiratory protection
must meet
29 CFR 1910.134
Training
Mandatory appendices
29 CFR 1926.1101
Inspection before
exposures
Communication
Worker protection;
Respiratory protection
must meet
29 CFR 1910.134
Classes of asbestos
disturbing work (I-IV)
Significant work practice
requirements
Training
Mandatory appendices
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)
OSHA Communication
Requirements of the Owner
• 1926.1101(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
OSHA Communication
Requirements of the Owner
• 1926.1101 (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
OSHA Communication
Requirements of the Owner
• Employers working at the Owner’s site
have responsibilities, 1926.1101 (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
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
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
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
Environmental Site Assessments (ESA) or
“Phase I”
• These are NOT designed to meet regulatory
requirements as an asbestos inspection
– ASTM E-1527-05…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 E2308) are also NOT compliant with required
regualtion-required sampling protocols
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
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
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
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
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
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
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
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?
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?
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
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
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
Questions?
Thank you!
Darryl Watson, CIH, CSP, JD
Cardno ATC
Marietta, GA

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