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

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

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.

“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

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 1910.1001 Permissible exposure limits and exposure assessments Inspection before exposures Worker protection; Respiratory protection must meet 29 CFR 1910.134 Training Mandatory appendices Construction 29 CFR 1926.1101 Classes of asbestos disturbing work (I-IV) Significant work practice requirements Always check for State/Local program requirements!

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 E-2308) 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

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

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

Darryl Watson, CIH, CSP, JD Cardno ATC Marietta, GA Questions? Thank you! Darryl Watson, CIH, CSP, JD Cardno ATC Marietta, GA