EPA - 455/B-93-001a
Draft revision, August 1997
Asbestos NESHAP
Inspection and Safety Procedures
Workshop
Draft
Student Manual
U.S. ENVIRONMENTAL PROTECTION AGENCY
Education and Outreach Group
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
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EPA - 455/B-93-001a
Draft revision, August 1997
Asbestos NESHAP
Inspection and Safety Procedures
Workshop
Draft
Student Manual
U.S. ENVIRONMENTAL PROTECTION AGENCY
Education and Outreach Group
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
-------
Asbestos NESHAP
Inspection and Safety Procedures
Workshop
Draft
Student Manual
Author
Nancy Lebedzinski
NLEnvironmental Associates
7 Bennett Street
Pepperell, MA 01463
U.S. ENVIRONMENTAL PROTECTION AGENCY
Education and Outreach Group
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
Developed under grants l-yU2743 to University ot Texas at Arlington and
CT-902765 to North Carolina State University
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DISCLAIMER
The opinions, findings, and conclusions expressed are those of the authors and not
necessarily those of the Environmental Protection Agency or the cooperating agencies.
Mention of company or product names is not to be considered as an endorsement by the
Environmental Protection Agency. The guidance provided in this manual does not create any
rights for defendants nor responsibilities for the Environmental Protection Agency. The
Agency reserves the right to act at variance with these procedures at any time without notice
to the regulated community. Nothing contained in this manual can be used as a defense in an
enforcement action. The safety precautions set forth in this manual are general in nature.
The precise safety precautions required for any given situation depend upon and must be
tailored to the specific circumstances or situation. NL Environmental Associates (NLEA)
expressly disclaims any liability for any personal health problems, death, or economic loss
arising from any actions taken in reliance upon this manual.
ACKNOWLEDGMENTS
This draft manual was prepared by NL Environmental Associates (NLEA) for the Industrial
Extension Service, North Carolina State University, Raleigh, NC. The work was funded
under the USEPA Cooperative Agreement No. CT 902765. The grant is sponsored by the
Education and Outreach Group, Office of Air Quality Planning and Standards, U.S.
Environmental Protection Agency. NLEA appreciates the support and input provided by the
NCSU project manager, Inez vanArsdall; Mr. Michael Beard, American Society for Testing
and Materials; and EPA project advisors: Mr. Charles Pratt, Education and Outreach Group,
OAQPS; Mr. Bob Trotter, Asbestos NESHAP Coordinator, U.S. EPA Region 9; Mr. Tom
Ripp, Manufacturing, Energy, and Transportation Division, OECA, U.S. EPA; and Mr. Phil
King, Regional Asbestos Coordinator, U.S. EPA Region 5. This draft manual will be subject
to internal and administrative reviews by the sponsor agency before distribution as a final
training document for federal, State and local air pollution control agency compliance
personnel.
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TABLE OF CONTENTS
Section Page
1 BACKGROUND INFORMATION 1-1
History of Asbestos Use 1-1
Geological Information 1-2
Federal Regulatory Agencies 1-4
Federal Legislation 1-4
2 ASBESTOS DEMOLITION AND RENOVATION ENFORCEMENT
STRATEGY 2-1
Strategy Components 2-2
Additional Information 2-6
3 HEALTH EFFECTS OF EXPOSURE TO ASBESTOS 3-1
Routes of Exposure 3-1
Health Effects Associated With Inhalation 3-2
Health Effects Associated With Ingestion 3-9
Health Effects Associated With Skin Contact 3-9
Theories on Hazard Relationships 3-9
4 IDENTIFYING ASBESTOS-CONTAINING MATERIALS 4-1
Important Definitions 4-1
Asbestos Uses and Characteristics 4-2
Asbestos Use in Buildings 4-3
5 ASBESTOS INSPECTOR SAFETY GUIDANCE ! 5-1
OSHA Asbestos Standards 5-1
EPA Worker Protection Rule 5-15
EPA/NIOSH Guidance 5-16
SHEMD Guidelines 5-17
6 ABATEMENT TECHNIQUES 6-1
Important Terms 6-1
Regulatory Requirements 6-2
Class I Work Operations 6-3
Class II Work Operations 6-9
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7 OTHER SAFETY CONSIDERATIONS IN ASBESTOS WORK 7-1
Heat Stress 7-1
Climbing Hazards 7-2
Working Surfaces 7-3
Illumination (Lighting) 7-3
Electrical Safety 7-3
Miscellaneous Hazards 7-4
8 RESPIRATORY PROTECTION 8-1
Classes of Respirators 8-1
Respiratory Protection 8-6
Respirator Fit Testing 8-8
Selection of Respirators 8-11
Medical/Physical Considerations in Respirator Usage 8-19
Routine Inspection and Maintenance 8-20
Field Inspection and Checkout Procedures 8-23
Additional Information .'. 8-24
9 PROTECTIVE CLOTHING 9-1
Recommended Protective Clothing 9-2
Operational Practices for Entering and Exiting Sites 9-4
Disposal of Contaminated Clothing 9-8
10 ASBESTOS NESHAP REGULATION 10-1
Historical Information 10-1
Applicability (ง61.140) 10-3
Definitions (ง61.141) '. 10-4
Standard for Demolition & Renovation (ง61.145) 10-7
Applicability [ง61.145(a)J 10-7
Notification Requirements [ง61.145(b)] 10-8
Procedures for Asbestos Emission Control [ง61.145(c)] 10-14
Waste Disposal Requirements (ง61.150) 10-20
Visible Emissions [ง61.150(a)J 10-20
Deposition of ACWM [ง61.150(b)] 10-23
Vehicle Marking [ง61.150(c>] 10-23
Off-site Transport of ACWM [ง61.150(d)] 10-23
Record Availability [ง61.150(e)] 10-23
Air Cleaning (ง61.152) 10-23
Applicability [ง61.152(a)J 10-24
Exceptions [ง61.152(b)] 10-24
Source Reporting Requirements (ง61.153) 10-27
New & Existing Sources [ง61.153(a>] 10-27
Active Waste Disposal Sites [ง61.153(b)] 10-27
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Active Waste Disposal Sites (ง61.154) 10-27
Site Operation [ง61.154(a-d)] 10-28
Site Operation Recordkeeping & Reporting Requirements [ง61.154(e)] 10-28
Site Closure Recordkeeping & Reporting Requirements [ง61.154(f-h)] 10-29
Record Availability [ง61.154(i)] 10-29
Excavation Notification [ง61.1540)] 10-29
Inactive Waste Disposal Sites (ง61.151) 10-30
Site Operation [ง61.151(a)] 10-30
Site Demarkation [ง61.151(b)] 10-30
Control Alternatives [ง61.151(c)] 10-32
Excavation Notification [ง61.151(d)] 10-32
DeedNotation [ง61.151(e)] 10-32
11 PRE-INSPECTION PLANNING AND PREPARATION 11-1
Inspector Responsibilities 11-1
Review Notification 11-1
Identify Non-Notifiers 11-2
Prepare Inspection Equipment/Materials 11-2
12 FACILITY INSPECTIONS 12-1
Evidence 12-1
Pre-Entry Observations 12-8
Gaining Entry 12-8
Pre-Entry Worksite Observations (OSHA/NESHAP Compliance) 12-12
Pre-Removal Inspection 12-13
Active Removal Inspections 12-15
Post-Removal Inspection 12-24
Post-Inspection Interview 12-25
Exit Observations 12-26
13 LANDFILL INSPECTIONS 13-1
Targeting Waste Disposal Sites 13-1
Planning the Waste Disposal Site Inspection 13-2
Recordkeeping Requirements 13-4
Reporting Requirements 13-4
Landfill Inspection Activities 13-7
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TABLE OF CONTENTS (CONTINUED)
Section Page
14 POST-INSPECTION ACTIVITIES 14-1
Inspection Follow-up 14-1
Documentation 14-1
Records Maintenance 14-3
Inspection Reports 14-3
15 ASBESTOS BULK SAMPLING AND ANALYSIS 15-1
Importance of Sampling 15-1
Protective Equipment 15-1
Sampling Equipment/Materials 15-2
Procedural Guidelines 15-3
Dust Sampling Procedures 15-8
Bulk Sample Analysis 15-11
Quality Assurance 15-14
Bulk Sample Shipment 15-18
16 ASBESTOS AIR SAMPLING AND ANALYSIS 16-1
Types of Air Monitoring 16-1
Measurement Approach 16-2
Sampling Equipment 16-2
Analytical Techniques 16-3
Continuous Monitors 16-6
17 LEGAL PERSPECTIVES 17-1
Owner or Operator 17-1
Authority for Inspections 17-2
Enforcement Options 17-2
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Appendix Page
A Inspection Equipment Checklist A-l
B Asbestos Demolition & Renovation Field Data Collection Checklist B-l
C Milling, Manufacturing and Fabricating Operations Checklist C-l
D Asbestos Waste Disposal Site Inspection Checklist D-l
E Sample Collection Log E-1
F Photo Identification Log Sheet F-l
G AHERA Compliance Checklist G-l
H Worker Protection Rule Checklist H-l
I Glossary 1-1
J References J-l
K Asbestos NESHAP Fact Pattern K-l
L ASMARA Compliance Referral Form and State Worker Accreditation L-l
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TABLE OF CONTENTS (CONTINUED)
Table Page
1-1 The Asbestos Minerals 1-3
1-2 Asbestos Ban and Phaseout Rule 1-11
3-1 Asbestos Abatement Fiber Levels 3-4
3-2 Ambient Asbestos Fiber Levels 3-5
4-1 Summary of Asbestos-Containing Products 4-2
4-2 Trade Names 4-5
4-3 Asbestos-Containing Materials Found in Buildings 4-6
8-1 Respirator Protection Factors 8-7
8-2 Respiratory Protection Requirements 8-13
9-1 Protective Clothing Costs 9-2
10-1 ง61.145(b) Notification Requirements Summary 10-16
10-2 ง61.145(c) Asbestos Emission Control Summary 10-21
10-3 ง61.150 Waste Disposal Summary 10-26
16-1 Comparison of Methods for Measuring Airborne Asbestos 16-5
Figure Page
1 -1 Size Comparisons 1-3
3-1 The Respiratory System : 3-2
6-1 LEV Air Filtration System 6-6
6-2 Illustration of a Glove Bag 6-7
10-1 Notification of Demolition and Renovation 10-12
10-2 EPA Asbestos Warning Label 10-19
10-3 OSHA Asbestos Warning Label 10-22
10-4 Waste Shipment Record 10-25
10-5 Waste Disposal Site Requirements 10-31
12-1 Abatement Area Diagram 12-6
12-2 Land Use Diagram 12-9
15-1 Representative Chain of Custody Record 15-15
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INTRODUCTION
By the early 1970s the health hazards of asbestos exposure were widely recognized. In 1973,
in order to reduce the public's potential exposure to airborne asbestos, the Environmental
Protection Agency (EPA) published the asbestos National Emission Standards for Hazardous
Air Pollutants (NESHAP) regulation. The asbestos NESHAP regulated the demolition of
buildings containing asbestos-containing fireproofing and insulating material and restricted
the spraying of asbestos-containing materials on buildings and structures for fireproofing and
insulating purposes.
Since 1973 the asbestos NESHAP has been revised several times. The regulation now
prohibits use of pre-molded, wet-applied, or decorative spray-on asbestos-containing material
and regulates renovation, waste handling and disposal activities as well.
In 1984 EPA issued its first Asbestos Demolition-and Renovation Enforcement Strategy
whose primary objective was to provide effective and uniform enforcement of the asbestos
NESHAP. Since on-site inspections were critical to accomplishing this goal, EPA developed
two workshops - one which detailed inspection procedures and the other which dealt with
inspector safety. These workshops were soon combined to create the current Asbestos
NESHAP Inspection and Safety Procedures Workshop which has been used to train EPA,
State and local agency personnel charged with enforcing the regulation.
During the asbestos NESHAP workshop, inspection procedures and the asbestos NESHAP
regulation are discussed in detail. In addition, since EPA, State and local agencies are
beginning to implement coordinated asbestos programs under the Clean Air Act (CAA) and
the Toxic Substances Control Act (TSCA), the basic requirements of other regulations, such
as the Asbestos Hazard Emergency Response Act (AHERA) and the Worker Protection Rule
(WPR) are also discussed. It is hoped that inspectors conducting asbestos NESHAP
compliance inspections will be able to recognize potential violations of other regulations as
well and contact the appropriate asbestos program personnel for follow-up.
The information contained in this workshop is consistent with the Asbestos Demolition and
Renovation Enforcement Strategy regarding inspector training, inspection criteria, and
enforcement procedures, and is also consistent with EPA policy to coordinate all asbestos
program offices.
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:99"
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SECTION 1
BACKGROUND INFORMATION
HISTORY OF ASBESTOS USE
Thousands of years ago ancient people discovered that certain rock fibers could be woven into a
tough fabric that would not burn. This material, known as "asbestos" (a term incorrectly derived
from a Greek word meaning "inextinguishable") was used to create lamp wicks, clothing,
cremation cloths, handkerchiefs and napkins.
Use of asbestos fabric continued throughout the ages. It has been reported that Emperor
Charlemagne (A.D. 742-814) impressed his enemies with the incombustible properties of a
tablecloth, and that Benjamin Franklin, in 1725, similarly impressed his London host by tossing a
purse made of asbestos into a lit fireplace.
The properties of asbestos were not generally known, nor asbestos commercially available, until the
mid-1800s when commercial production of asbestos products began in Italy and subsequently
spread to the British Isles and North America. During this time the Industrial Revolution
catapulted our society from an organically-based culture (one dependent on wood, bone, hide,
hemp, etc.) to one based on the widespread use of extracted metals and ores. The expanding use of
the steam engine during this time fostered the growth of the gasket and insulation industries where
the properties of the "miracle fiber" asbestos were soon recognized and put to use.
In the late 1870s large deposits of asbestos were discovered in Canada. Asbestos has also been
found and commercially mined in Australia, Korea, and South Africa and in the States of Arizona,
California, Georgia, New Hampshire, North Carolina, Vermont and Virginia.
Asbestos product use in America was greatest from the 1940s until the late 1970s when the health
hazards associated with asbestos exposure became widely recognized. By this time asbestos had
become an integral component of approximately 3600 commercial products. During World War II
enormous quantities of asbestos were used in ship-building and other industries. Following the
war, and until the late 1970s, asbestos was widely used in buildings for fireproofing, thermal and
acoustical insulation, condensation control and decoration.
It has been estimated that in the U.S. approximately 30 million tons of asbestos have been used in
the construction and manufacturing industries since the early 1900s.
GEOLOGICAL INFORMATION
Asbestos minerals formed millions of years ago as molten material filled cracks in the cooling
surface of the earth and hardened. Unlike other minerals which form tightly-bound crystals upon
cooling, asbestos minerals coalesce into densely-packed bundles of fibers.
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Asbestos
Serpentine
Group
Amphibole
Group
Serpentine
(Chrysotile)
Cummingtonite - Grunerite (Amosite)
Riebeckite (Crocidolite)
Anthophyllite
Actinolite - Tremolite
Asbestos minerals are divided into two major classes - serpentine and amphibole asbestos - which
differ from one another both physically and chemically. The serpentine group contains only one
asbestos mineral, chrysotile, whose scroll-like, white fibers are very fine (0.02-0.08 /^m in
diameter), flexible, heat resistant, and exhibit high tensile strength. Because of these
characteristics, chrysotile has been incorporated into thousands of commercial products including
insulation, cement products and roofing materials, and consequently is the type of asbestos most
commonly found in buildings. The amphibole group contains five asbestos minerals: amosite,
actinolite, anthophyllite, crocidolite and tremolite. Of these, however, .only amosite, a brown
asbestos with brittle, needle-like fibers (0.06-0.35 /^m in diameter), has been used extensively,
primarily in high-temperature applications where great thermal resistance is needed. Amosite is
commonly found in high-pressure steam line and boiler block insulation.
Table 1-1 provides a brief synopsis of the mineralogy and chemistry of asbestos minerals.
Asbestos Fibers
Since the 1960s asbestos fibers monitored in workplaces where asbestos is in use have been defined
as any of the minerals named in Table 1-1 that display, by phase-contrast microscopy (PCM),
particles of aspect ratio greater than or equal to 3:1, lengths greater than 5 /um, and widths less than
3 urn. Since the fiber has become the principal occupational exposure measurement, however, a
more specific definition for the physical properties of asbestos fibers was published in EPA's
Method for the Determination of Asbestos in Bulk Building Materials, EPA/600/R-93/116, July
1993.
As stated in this document, asbestiform minerals, when viewed by light microscopy, generally have
the following characteristics:
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Mean aspect ratios ranging from 20:1 to 100:1 or higher for fibers longer than 5 /um (with
aspect ratios being determined for fibers, not bundles);
Very thin fibrils, usually less than 0.5 /^m in width, and
Two or more of the following:
Parallel fibers occurring in bundles,
Fibers displaying splayed ends,
Matted masses of individual fibers, and/or
Fibers showing curvature.
TABLE 1-1. THE ASBESTOS MINERALS
Group
Name
Nominal Composition
Characteristics
Serpentine
Chrysotile
Mg3Si205(OH)4
White asbestos; fine, silky, wavy fibers; flexible
and high tensile strength.
Amphiboles
Amosite
Crocidolite
Anthophyllite
Tremolite-Actinolite
(Mg,Fe)7Si8022(OH)2
23 +Fe32+Si8O22(OH)2
(Mg,Fe)7Si8022(OH)2
Ca2(Mg,Fe)5Si8022(OH)2
Brown asbestos; straight, rigid fibers; high
thermal resistance.
Blue asbestos; straight, rigid fibers.
Brittle white fiber. Rarely used.
Colorless to pale green; rarely used.
Figure 1-1 illustrates a comparison of asbestos fibers to .other more recognizable materials.
Fine Sand
Human Hair
Bacteria
Asbestos (length)
M^MMM
i i i mill t i i tii.nl I I Illllll I Mill
' ' niii
0.01
0.1 1 10 100
Size Range, micrometers (urn)
Figure 1-1. Size Comparisons
1000
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FEDERAL REGULATORY AGENCIES
FEDERAL
GOVERNMENT
EPA
Several federal agencies which regulate asbestos are discussed below.
Department of Labor (DOL)
Within the DOL, OSHA (Occupational Safety and Health Administration) has published several
asbestos standards designed to protect employees at their worksites: Shipyard Employment
Asbestos Standard (29 CFR 1915.1001), General Industry Standard (29 CFR 1910.1001), and
Construction Asbestos Standard (29 CFR 1926.1101).
Department of Health and Human Services (DHHS)
Within DHHS, NIOSH (National Institute of Occupational Safety and Health), tests respirators and
acts as the research arm of OSHA.
Department of Transportation (DOT)
DOT regulates the transport of commercial asbestos and asbestos waste and dictates the labeling of
waste bags and marking of transport vehicles.
Environmental Protection Agency (EPA)
EPA enforces several regulations (Clean Air Act, Toxic Substances Control Act, Safe Drinking
Water Act. Resource Conservation and Recovery Act, Comprehensive Environmental Response,
Compensation anJ I lability Act, etc.) which help protect citizens from the harmful effects of
asbestos.
FEDERAL LI (.1st. \TION
In order to red IK i- potential exposure to asbestos, numerous regulations have been developed by
Federal. State. anJ l^al governments. Only Federal asbestos regulations will be discussed in this
manual, however Mr it would be impractical to attempt to provide information concerning the
widely van ing stale and local regulations as well. Inspectors should, however, become familiar
with other asbestos regulations applicable in their areas.
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Federal Legislation
Clean Air Act (CAA) (42 U.S.C. 7401, et seq.)
Demolition/
Renovation
Waste
Disposal
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The Clean Air Act (CAA) was signed into law in 1970 to address the problem of hazardous air
pollutants, substances for which "no ambient air quality standard is applicable and which, in the
judgment of the Administrator, may cause or contribute to an increase in mortality or an increase in
severe irreversible, or incapacitating reversible illness."
Once EPA lists a material as a hazardous air pollutant, stationary source emission standards may be
established. To date, National Emission Standards for Hazardous Air Pollutants (NESHAP) have
been developed under Section 112 of the CAA for arsenic, benzene, beryllium, coke oven
emissions, mercury, perchloroethylene, radionuclides, vinyl chloride, and asbestos.
The purpose of the asbestos NESHAP, first promulgated in 1973, is to protect the public from
exposure to asbestos in the ambient air. The asbestos NESHAP program is examined in this
manual as it pertains to demolition and renovation of buildings containing asbestos building
materials and subsequent waste disposal. (The asbestos NESHAP also regulates manufacturing
and fabricating operations, spray application of asbestos, waste disposal, for asbestos mills, inactive
waste disposal sites, and establishes standards for asbestos mills and roadways.)
Non-compliance with the provisions of the CAA constitutes a felony.
The demolition/renovation provisions of NESHAP are broken down into four basic categories
which will be discussed in detail during this workshop.
Demolition/
Renovation
Notification
Work Practices
Waste Handling
Waste Disposal
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Toxic Substances Control Act (TSCA) (15 U.S.C. 2601, et seq.)
Asbestos in
Schools Rule
1982
Asbestos
Hazard
Emergency
Response Act
1986
Asbestos-Containing
Materials in Schools Rule
1987
Worker
Protection
Rule
1987
Asbestos Ban and
Phaseout Rule
1989
Model Accreditation
Plan
1987
The Toxic Substances Control Act (TSCA), signed into law in 1976, permits EPA to identify and
evaluate potential hazards from chemical substances. It also allows EPA to regulate the
production, use, distribution and disposal of such substances. Several regulations, discussed below,
have been issued under the auspices of TSCA. Copies of TSCA documents may be obtained by
calling the TSCA Hotline at 202-554-1404.
Asbestos in Schools Rule (40 CFR Part 763 Subpart F)
Asbestos in Schools (AIS) Rule
Inspections (friable ACM)
ACM analysis
Notifications
Recordkeeping
The original Asbestos in Schools (AIS) Rule, proposed in 1979 and enacted in 1982, set up
requirements for inspection of public and private schools (as defined in the Elementary and
Secondary Education Act) grades K-12 for friable suspect asbestos-containing material (ACM).
The required inspections involved sampling and subsequent analysis of such material to determine
the presence of asbestos. The AIS Rule also required the schools to provide notification to school
workers and parents concerning the presence of asbestos, to post warning signs if friable ACM
were found, and to maintain records accessible to the public regarding the inspections. There were
no requirements for abatement nor provisions for funding. The AIS Rule did provide guidance for
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abatement (i.e., removal, encapsulation, enclosure or maintenance programs). The requirements of
this regulation were to have been met by June 1983.
Asbestos Hazard Emergency Response Act (AHERA) (15 U.S.C. 2641)
ACM in
Schools
Model Accreditation
Program
Accreditation
Program
Management
Plans
In order to improve upon the 1982 AIS, Congress passed the Asbestos Hazard Emergency
Response Act (AHERA) in 1986. AHERA was added as an amendment (Title II - Asbestos
Hazard Emergency Response) to TSCA and required both EPA and the States to address
asbestos hazards which might exist in schools. EPA was required to promulgate rules
regarding asbestos-containing materials in schools and had to develop a model accreditation
plan for persons who inspect for asbestos, develop management plans, and design or conduct
response actions. States were required to adopt an accreditation program at least as stringent
as the EPA model and to review management plans submitted by school systems.
Asbestos-Containing Materials in Schools Rule (ACM in Schools) (CFR Part 763
Subpart E)
ACM in Schools
Inspections
Management Plans
Response Actions
Reinspections
In 1987. in response to the AHERA mandate, EPA published its Asbestos-Containing
Materials in Schools Rule, commonly referred to as AHERA, which required that public and
private schools (grades K-12) be inspected for the presence of friable and nonfriable
asbestos-containing building materials (ACBM) and that determinations of ACBM
conditions and hazards be made. Based on the inspections, the schools were also required to
develop and implement management plans and reinspect schools every three years.
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Model Accreditation Plan (MAP) (40 CFR Part 763 Subpart E Appendix C)
Model Accreditation Plan
(MAP)
Workers
Contractors/Supervisors
Inspectors
Management Planners
Project Designers
In 1987, also in response to the AHERA mandate, EPA published its Model Accreditation
Plan (MAP) which established initial and refresher training requirements for inspectors,
management planners, abatement project designers, asbestos abatement
contractors/supervisors, and asbestos abatement workers. The MAP also included
information regarding qualifications, examinations, decertification requirements and
reciprocity.
Model Accreditation Plan (MAP)
Interim Final Rule (1994)
Clarifies applicability
Increases minimum number of training hours
Adds definitions and recordkeeping requirements
Specifies deadlines for States, course providers and individuals
In 1990, revisions to the original MAP were mandated by the Asbestos School Hazard
Abatement Reauthorization Act (ASMARA). On February 3, 1994, EPA published its
Asbestos Model Accreditation Plan; Interim Final Rule (59 FR 5236) which replaces the
original MAP. The revised document, effective April 4, 1994, clarifies the types of persons
who must be accredited to work with asbestos in schools and public and commercial
buildings; increases the minimum number of hours' of training, including additional hours of
hands-on health and safety training for asbestos abatement workers and
contractor/supervisors; and effects a variety of other necessary changes as mandated by
ASHARA.
The new MAP adds two new components to the original MAP: (1) definitions which help to
determine the scope and applicability of the rule, and (2) new recordkeeping requirements for
the providers of accredited training courses. The changes also specify the deadline for States
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to modify their accreditation programs to be no less stringent thari the revised MAP and
prescribe deadlines for training course providers and persons who must obtain accreditation
to comply with new requirements.
Additional MAP Components
Training requirement distinctions for five training disciplines
New project designer topics
New enforcement criteria and Federal procedures for withdrawing approval
(persons/programs)
New training certificate information
The revised MAP also distinguishes between the training requirements for each of the five
accredited training disciplines; adds several new topics to the project designer training
curriculum; establishes new enforcement criteria and Federal procedures for withdrawing
approval from accredited persons and training programs; and stipulates new information
requirements for training certificates. The organization and some of the language of the
original MAP have also been changed, but these modifications are only technical and do not
impose new substantive requirements.
Worker Protection Rule (WPR) (40 CFR Part 763 Subpart G)
Worker Protection Rule (WPR)
State/Public Employees
OSHA Construction Standard
Abatement Activities
Notification
- Emergency projects
- Projects > 3 LF/SF
In 1987 FP A puhh>hed the Worker Protection Rule (WPR) which extended the provisions of
the OSHA a-N>t.'s construction standard to State and public employees who had been
exempted K thซ.-:r states from the OSHA regulation. The WPR essentially duplicates the old
OSHA Constr.Kthm Standard (29 CFR 1926.58) with the following exceptions:
it applies i>nl> to State and public workers involved in abatement activities; and
it contains notification requirements for emergency projects and projects involving
more than three linear or square feet of friable asbestos-containing material.
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It is EPA's intention to revise this document in the future to reflect changes made to OSHA's
Construction Standard.
Asbestos Ban and Phaseout Rule (ABPO) (40 CFR Part 763 SubpartI)
Asbestos Ban and Phaseout Rule (ABPO)
3 stages
Manufacture, import, processing ban
Distribution in commerce ban
In 1989 EPA published the Asbestos Ban and Phaseout Rule (ABPO) which prohibited, at
staged intervals, the future manufacture, importation, processing, and distribution in
commerce of almost all asbestos-containing products. The ABPO required that products
subject to the bans be labeled to promote compliance with and enforcement of the rule. Upon
application, and in very limited circumstances, EPA may allow exemptions from the Rule's
bans.
In October 1991 the U.S. Court of Appeals for the Fifth Circuit overturned EPA's ban,
arguing that the Agency failed to consider less burdensome alternatives than an outright ban.
In November 1991, in response to a request by EPA for clarification of the overturning of the
ABPO, the U.S. Court of Appeals stated that EPA could ban new uses of asbestos and
products that were not on the market on July 12,1989, the effective date of the ABPO rule.
EPA most recently clarified the provisions'of the ABPO in the Federal Register (58 FR
58964), November 5, 1993. (See Table 1-2)
Table 1-2. ACM Currently Banned
Sou uses of asbestos
Corrugated paper
RollKurd
( ommercial paper
Spccialt> paper
} loonni: felt
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Asbestos School Hazard Abatement Act (ASHAA) (Public Law 101-637)
Asbestos School Hazard Abatement Act (ASHAA)
Grants and loans
Information distribution
Training institutes
In 1984 the Asbestos School Hazard Abatement Act (ASHAA) was written to provide a source
of special funding for the Asbestos in Schools program. The Act provided a $600 million
grant and loan program to assist financially needy schools with asbestos abatement projects.
ASHAA also provided for compilation and distribution of information concerning asbestos,
and funded the start-up of training institutions. The original recipients of training funding
were Tufts University (MA), Georgia Institute of Technology, and the University of Kansas.
Asbestos School Hazard Abatement Reauthorization Act (ASHARA) (Public Law 101-
637)
Asbestos School Hazard Reauthorization
Act (ASHARA)
Grants and loans
MAP revisions
The Asbestos School Hazard Abatement Reauthorization Act (ASHARA), signed into law in
1990. reauthorized funding for schools in need and mandated revisions to EPA's Model
Accreditation Plan (MAP) developed under AHERA. ASHARA required EPA to increase
the minimum number of training hours required for asbestos abatement workers, and extend
accreditation requirements to include persons who inspect for ACM or who design or
conduct response actions with respect to friable ACM in public and commercial buildings. In
addition. ASHARA authorized EPA to modify the MAP as necessary' to implement the
extension of accreditation requirements to public and commercial buildings, and amended
penalty provisions of TSCA Section 207 (15 U.S.C. 2647).
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Asbestos Information Act of 1988 (AIA) (Public Law 100-577)
Asbestos Information Act (AIA)
Manufacturers
EPA
The Asbestos Information Act (AIA) was signed into law in October 1988. The AIA required
former and current manufacturers and processors of certain asbestos products to submit
information identifying their products to EPA and required EPA to organize and publish the
submitted information. On February 13,1990 EPA published in the Federal Register a
summary of the information submitted by 38 companies.
Resource Conservation and Recovery Act (RCRA) (42 U.S.C. 6901, et seq.)
Resource Conservation and Recovery Act
(RCRA)
Cradle to grave management
Facility siting
Landfill operations
The Resource Conservation and Recovery Act (RCRA) was enacted in 1976 to regulate the
management of hazardous waste, to ensure the safe disposal of wastes, and to provide for
resource recovery from the environment by controlling hazardous wastes "from cradle to
grave."
In 1976 asbestos became regulated as a hazardous substance under RCRA. It was delisted
that same year, however, because its classification as a RCRA waste was inappropriate -
unlike other substances regulated by RCRA, asbestos does not migrate appreciably in soils,
nor does it pose any threat to ground water. RCRA currently regulates asbestos waste
disposal only in a general way, through facility siting and general landfill operation
requirements.
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
(42 U.S.C. 9601, et seq.)
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Comprehensive Environmental
Response, Compensation and Liability
Act (CERCLA)
"Superfund"
RQ = 1 pound asbestos
National Response Center
The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of
1980, most commonly referred to as "Superfund" because its authority was clarified in the
Superfund Amendments Reauthorization Act (SARA) of 1986, was passed into law to address
the problems associated with the actual or potential release of hazardous substances into the
environment. Under CERCLA, reportable quantities (RQs) have been established for a
number of hazardous materials. The RQ for asbestos is one pound. Should a release or
threat of release of at least one pound of asbestos occur, the National Response Center
(1-800-424-8802) must be informed immediately. Noncompliance with the provisions of
CERCLA may result in prosecution for a felony offense and the assessment of heavy fines.
Safe Drinking Water Act (SDWA) (42 U.S.C. 300)
Safe Drinking Water Act (SDWA)
Digestive tract cancers
7 x 106 fibers (>10 um in
length) per liter
The Safe Drinking Water Act (SDWA) was enacted in 1974 in order to assure that all people
served by public water systems would be provided with a supply of high-quality water. The
Act established a program to require compliance with national drinking water standards for
contaminants that may have an adverse effect on public health. The Act also focused on the
removal of contaminants found in water supplies and established programs intended to
protect underground sources of drinking water from contamination.
During the early 1980s the issue of potential health hazards associated with ingestion of
asbestos fibers was closely examined by EPA's Office of Drinking Water (ODW). The ODW
reviewed numerous human and laboratory animal epidemiological studies and, despite the
uncertainty of research conclusions linking an increased risk of development of digestive
tract cancers to exposure to asbestos fibers, proposed to establish an asbestos fiber limit in
drinking water.
The 1986 SDWA Amendments required EPA to regulate asbestos as a contaminant of
drinking water. In 1991 a limit of seven million asbestos fibers (greater than 10 urn in
length) per liter of drinking water was established in the National Primary Drinking Water
Regulations.
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SECTION 2
ASBESTOS DEMOLITION AND RENOVATION
ENFORCEMENT STRATEGY
On April 5, 1984, the first Asbestos Demolition and Renovation Enforcement Strategy was
issued. This strategy document focused on demolitions and renovations because EPA had
determined that the number of these sources was greater than the total number of all other
sources, the compliance status for demolition/renovation sources was much worse, and
inspections of these sources were more difficult due to the transitory nature of the operations.
The objectives of the enforcement strategy were to: 1) provide effective and uniform
enforcement of the Asbestos NESHAP standard by regions and the delegated States, and 2)
provide emphasis and assurance to regions and States that asbestos is a high priority item and
that EPA is committed to a strong enforcement posture.
From October 1, 1985 through November 17,1987, the Inspector General (IG) Office
conducted an audit of EPA's administration of the asbestos NESHAP. The audit included
EPA regional, State and local programs.
The audit had six principle objectives:
1. To determine whether regional EPA offices, State and local agencies gave sufficient
priority to implementing an effective asbestos NESHAP program;
2. To determine whether inspections of demo/reno sites were conducted properly;
3. To evaluate inspection strategies;
4. To determine if enforcement actions were appropriate (Would they deter future
violations?);
5. To determine whether proper safety equipment was used and if inspectors were
adequately trained prior to field activities; and
6. To determine the accuracy of SPMS (Strategic Planning and Management System)
data for demo/reno sites.
Since the IG audit revealed many weaknesses in the administration of the asbestos NESHAP
program, EPA reexamined its enforcement strategy and published a revised version of it on
March 31, 1988.
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In November 1990 revisions to the asbestos NESHAP were promulgated to promote
compliance and enhance enforcement efforts. The revisions include monitoring,
recordkeeping, and reporting requirements for milling, manufacturing, and fabricating. In
addition, notification requirements for demolitions and renovations were modified, and
recordkeeping and reporting requirements were added for waste disposal. Also, several
revisions clarify the intent of the rule and others reflect enforcement determinations
previously made.
In February 1991, EPA published its Implementation Strategy for Revised Asbestos NESHAP
as an addendum to the enforcement strategy in effect. This new strategy document was
designed to assist EPA Regional offices and the States in implementing the revisions to the
NESHAP. Because the regulation of disposal sites and the addition of requirements for
waste shipment records are among the more significant changes in the NESHAP, the new
implementation strategy focuses primarily on requirements for waste disposal. Outreach
strategies for informing building owners and contractors of the revisions are discussed as are
strategies for informing disposal site operators of the new requirements.
In view of the new waste disposal requirements, suggestions are made on how to inspect
waste shipment records (WSRs) and adjust agency inspection schemes, including targeting,
to accommodate the new requirements. Suggestions are given for using construction permits
and WSRs to identify non-notifiers. Data management and targeting using the National
Asbestos Registry System (NARS) are discussed in general, while enforcement of the new
recordkeeping and reporting requirements is covered specifically. Finally, policy and
guidance documents that are relevant to the interpretation and enforcement of the asbestos
NESHAP are identified.
STRATEGY COMPONENTS
The following summarizes the most current strategy information issued by Headquarters to
regional agencies. The complete strategy documents (1988 ... Enforcement Strategy and 1991
Implementation Strategy ...) can be found in supplemental materials provided with this course
manual.
1. Outreach
Outreach programs aimed at increasing public awareness of the asbestos NESHAP
requirements should be established. Agencies are encouraged to publicize the asbestos
NESHAP requirements by the following mechanisms:
national and local press releases;
distribution of informational pamphlets to removal contractors, State or local
associations of building owners/managers, asbestos
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abatement groups, State or local air pollution and environmental associations;
distribution of information concerning waste disposal requirements to waste haulers,
waste site operators and State or local solid waste associations;
on-site educational efforts;
cooperative arrangements with building inspection departments;
informational mailings to previous asbestos NESHAP violators;
distribution of a list of available asbestos training courses to contractors, building
owners and managers;
seminars and demonstration workshops for contractors, and owners and managers of
commercial buildings;
discussion forums with school district administrators, architects, lenders, real estate
groups, and insurance agency representatives; and
radio talk shows on the hazards of asbestos.
2. Contractor Training
Contractor training is a requirement (effective November 1991) and an effective way of
educating contractors as to what is required of them under the asbestos NESHAP. Most
States have established some type of training program and/or certification for asbestos
removal contractors. Also, the Asbestos Hazard Emergency Response Act (AHERA)
requires States to establish accreditation programs for persons who inspect, develop
management plans, or design or conduct response actions in schools. States should be
encouraged to extend the AHERA certification requirements to all demolition/ renovation
contractors.
3. Inspector Training
To increase inspector effectiveness in finding violations and documenting evidence at
demolition and renovation projects, inspectors should receive training on inspection
procedurev saiet>. the NESHAP requirements and other pertinent regulations. The
Stationary Source Compliance Division (SSCD) offers such training to Region and State
inspectors \shestos inspectors should also attend courses at one of the Hazard Abatement
Assistance Branch (HAAB) training centers to become aware of what certified removal
contractors are being taught about the asbestos NESHAP. Delegated State and local agencies
should he encouraged to send their inspectors to both the SSCD and HAAB training, as well
as am contractor certification training provided at the State level.
Inspectors should contact local AHERA personnel or State departments of labor and industry,
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or refer to the National Directory of AHERA Accredited Courses (NDAAC) available
through the NDAAC Clearinghouse (1-800-462-6706) to obtain information regarding
worker, contractor/supervisor, inspector, management planner, and project designer training
course providers.
4. Inspections
Inspections are the foundation for enforcement actions for substantive violations. In order to
determine compliance and to collect evidence, inspectors must enter active removal areas.
Three items ~ the inspectors' checklist, a camera, and safety gear -- are especially important
and are considered standard inspection gear. Whenever possible, inspectors should collect
samples and observe work practices. While it is preferable to inspect a site during active
removal operations, a compliance determination based on evidence collected (e.g.,
photographs and samples of material) is possible at a removal site when no removal activity
is occurring.
5. Inspection Targeting
Because of the tremendous increase in the number of notifications received by EPA and the
delegated agencies, Regions and their delegated agencies must make more efficient use of
inspectors' time by implementing a targeting system that strategically identifies which
notifications or contractors to follow up with inspections. A computer tracking system is
available that will assist in prioritizing inspections by identifying removal sites where
violations are most likely to occur. Inspection priority should be based on a simple
evaluation of computer tracking data involving the assessment of contractor compliance
history and on specific criteria for notifications. In addition to inspection targeting based on
computer tracking data, citizen complaints should be followed up with inspections. Special
attention should also be given to demolitions and renovations for which no notification was
received. Information from building permits, waste disposal site records, other contractors
and agencies, and various publications can assist in this effort.
6. Program Alternatives
When delegated agencies find it difficult to maintain a high level of inspections due to
funding limitations, they should adopt cost-effective alternative mechanisms. Examples of
alternatives include adoption of a state-wide contractor certification program or the adoption
of a system of collecting fees for each removal operation to help fund enforcement programs.
When combined with a penalty policy of sufficient stringency for each violation type, the
adoption of one or more such alternatives would be an acceptable State asbestos NESHAP
enforcement program modification.
7. Federal Enforcement Options
EPA may take administrative and/or judicial actions against a NESHAP violator. EPA can
pursue administrative actions through Section 113(d) orders or Section 303 orders. Section
113(d) administrative penalty orders may be issued to violators when they are found out of
compliance with requirements, or to sources which submit deficient notifications.
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Administrative penalty orders may assess civil penalties of up to $25,000 per day of
violation. In general, they may be used only in cases where the total penalty does not exceed
$200,000 and the first alleged date of violation occurred no more than 12 months prior to
initiation of the administrative action.
Judicial action can take the form of civil action as provided for in Section 113(b), or criminal
action as provided for in Section 113(c). Procedures are available for negotiated settlement
through judicial consent decrees and are designed to facilitate the settlement process and
enable Regions to increase judicial enforcement without straining resources. Section 113(b)
civil actions can be used to seek immediate compliance and civil penalties of up to $25,000
per day of violation. Section 113(c) criminal enforcement actions are taken against parties
who knowingly violate provisions of the asbestos NESHAP.
Another enforcement option is contractor listing under Section 306. When EPA lists a
contractor, that contractor cannot be awarded any contract to perform work where Federal
funds are involved. Under mandatory listing, contractors convicted of criminal air Act
violations are automatically listed. Under discretionary listing, contractors that have
continuing or recurring violations of clean air standards may also be listed.
8. Choosing an Enforcement Option
Each violation, listed by contractor, should be entered into the computer tracking system to
provide a record of violations for individual contractors. Instructions are provided in Tables
1 and 2 of the Asbestos Demolition and Renovation Enforcement Strategy to assist in
deciding when a particular enforcement action is appropriate.
9. Assessing Penalties
The Clean Air Act Stationary Source Civil Penalty Policy ("General Penalty Policy")
provides guidance for determining the amount of civil penalties EPA will seek in pre-trial
settlement of civil judicial actions under Section 113 (b) of the Clean Air Act ("the Act"). In
addition, the General Penalty Policy is used by the Agency in determining an appropriate
penalty in administrative penalty actions brought under Section 113 (d) (1) of the Act. Due
to certain unique aspects of asbestos demolition and renovation cases, an appendix entitled
Asbestos Demolition and Renovation Civil Penalty Policy (May 5, 1992) provides separate
guidance for determining the gravity and economic benefit components of the penalty.
Adjustment factors should be treated in accordance with the General Penalty Policy.
10. Reporting
The reporting format for STARS has been revised (see Appendix G of the Asbestos
Demolition and Renovation Enforcement Strategy). Report violations in terms of substantive
violations and notification violations and include the number of sources inspected. Regions
must ensure that there is no double-counting of notifications.
11. Regional Oversight
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Joint EPA-State inspection is the best method to review delegated agency inspections and
establish the criteria for an acceptable compliance inspection. For Regions with both
delegated and undelegated States, Regional inspections should be concentrated in the
undelegated States. Regions should develop written inspection programs containing
inspection criteria and targeting systems and should provide a written assessment of each
delegated agency's compliance record.
12. Cross-Program Coordination
EPA NESHAP and TSCA inspections and OSHA inspection programs should be coordinated
to maximize information collection and sharing, consolidate compliance assistance efforts,
and unify enforcement activities among all EPA and OSHA asbestos programs.
ADDITIONAL INFORMATION
The 1991 Implementation Strategy also provides a summary of new requirements and
information regarding waste disposal site inspections and recordkeeping inspections at waste
sites and contractors. The strategy also discusses the current status of NARS as it relates to
incorporating waste shipment information into the database, and future plans. Violations
associated with waste handling and disposal recordkeeping and reporting requirements are
discussed, and information regarding important applicability and policy determinations
provided as well.
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SECTION 3
HEALTH EFFECTS OF EXPOSURE TO ASBESTOS
The fact that asbestos is a hazard to man's health was recognized quite early. In the first
century AD both Romans and Greeks wrote of a sickness of the lungs in slaves whose
occupation was the weaving of asbestos into cloth. However, the association of asbestos with
chronic respiratory disease had to be rediscovered in the modern era.
A number of nonmalignant and malignant conditions are now known to be related to asbestos
exposure. These include asbestosis, lung cancer, mesothelioma, and other cancers and
conditions.
In the late 1920s, Dr. E.R. Merriweather, a London physician whose interest was piqued by a
series of case reports, conducted ah epidemiological study of 363 asbestos textile workers.
He stated in his 1930 published report that 26 percent of the workers examined showed signs
of asbestosis, a scarring of the lungs. This report firmly linked asbestos exposure with lung
disease.
In 1949, Dr. Kenneth Smith, Medical Director of Johns-Manville, published a report
describing an excess of cancer of the lung and pleura among individuals dying from
asbestosis.
In South Africa, in the 1960s, numerous crocidolite miners were reportedly dying of a form
of tuberculosis unresponsive to traditional antibiotic therapy. Dr. Chris Wagner discovered
that many of these cases of "TB" were actually mesothelioma, a rare and fatal cancer of the
tissue (mesothelium) that covers the internal organs and lines the chest and abdominal
cavities.
It is now clear that among asbestos workers there is, in addition to the risk of asbestosis, a
greatly increased risk of death from lung cancer and from pleural (chest) and peritoneal
(abdominal) mesothelioma, malignancies that are seldom found in the general population.
Moreover, asbestos has been linked with gastrointestinal and other cancers and conditions.
ROUTES OF EXPOSURE
Through the course of normal human activities there are three principle exposure routes for
asbestos fibers: (1) inhalation; (2) ingestion; and (3) skin contact. The following provides
information regarding the potential hazards of each route of entry.
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HEALTH EFFECTS ASSOCIATED WITH INHALATION
As previously mentioned, epidemiological investigations have demonstrated that inhalation
of asbestos fibers may lead to increased risk of developing one or more diseases. It is
important to recognize that the majority of people who have developed asbestos-related
diseases were asbestos workers who were frequently exposed to high concentrations of
asbestos fibers every working day with little or no respiratory protection to minimize their
risk.
In this section the respiratory system and each of the major diseases associated with asbestos
exposure will be described. The risks of developing such diseases and ways to minimize the
risks also will be noted.
The Respiratory System
The respiratory system is divided into two segments: the upper and lower air passages. The
upper air passage extends from the nose to the larynx, while the lower air passage extends
from the larynx to the terminal bronchioles of the bronchial tube system. Once air has passed
through the upper air passages, it moves into the region of the lower air passages via the
trachea (windpipe) which traverses the neck. The trachea enters the thorax where it divides
into two branches called bronchi. These bronchi lead to the left and right lungs as illustrated
in Figure 3-1.
Nasal cavity
Nostril
Mouth cavity
Larynx
Bronchia]
tree
Right bronchus
Secondary
bronchi
Bronchioles
Diaphragm
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Figure 3-1. The Respiratory System
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Each bronchus subdivides into many smaller bronchial tubes which, in turn, divide to become
even finer bronchioles. The bronchioles end in microscopic air sacs made up of clusters of
even tinier sacs called alveoli, which constitute most of the lung tissue. There are
approximately 300,000,000 alveoli whose combined surface area is about 70 m2.
The alveolar walls contain numerous capillaries, the body's tiniest blood vessels. In the lung
the exchange of carbon dioxide for oxygen takes place across the thin membranes of the
alveoli and capillaries.
Defense Mechanisms
During inhalation the larger particles in the air stream entering the nose are filtered out by the
nasal hairs or trapped by the secretions of mucous membranes in the sinus cavities. A second
level of defense is the triggering of the cough mechanism which forces particles out of the
trachea into the throat area where they can be swallowed. A third level of physiological
defense occurs in the lining of the trachea and bronchial tubes. There, tiny, hair-like, mucus-
coated structures known as cilia beat upward in a wave-like motion. This motion, known as
the muco-ciliary escalator, is responsible for moving contaminants from the air passageways
to the throat where they are swallowed. The respiratory system appears to be able to filter
out particles which are at least 5u long.
The final line of defense rests within the alveoli. There, alveolar macrophages (mobile white
blood cells) engulf foreign bodies and digest them using-strong acids and enzymes.
Routes of Inhalation Exposure
It is important to recognize that there are asbestos fibers in all the air we breathe. Since the
majority of asbestos-related health problems involves the lung and lung region, inhalation of
asbestos fibers is undoubtedly a situation that must be minimized. Individuals may control
their exposure to asbestos fibers by properly using respirators and minimizing the time spent
in areas of high asbestos fiber concentrations. The various types of inhalation exposure
pathways are listed below.
Occupational Exposure
Direct occupational exposure occurs in individuals who work in asbestos mines, mills,
landfills, manufacturing or fabricating plants and asbestos abatement sites (See Table 3-1).
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TABLE 3-1. ASBESTOS ABATEMENT FIBER LEVELS
Work Area
Air Samples
All work areas
Wet removal only
Dry removal only
Geometric Mean (f/cc)
(50th percentile)
0.74
0.48
11.9
Range of Mean Fiber
Concentrations Among
Abatement Projects (f/cc)
less than 0.1 -30.0
less than 0.1 - 12.0
3.7-30.0
Reference: "Air Sampling at 52 Asbestos Abatement Projects" (William M. Ewing) referred to in "Draft Scenarios
and Respiratory Protection Recommendations for EPA Inspectors (OHSS Memorandum, January 30, 1987).
Para-occupational Exposure
Individuals who are exposed to asbestos fibers brought home by workers on their
contaminated work clothes or who encounter asbestos fibers from deteriorating or disturbed
friable asbestos building materials experience para-occupational exposure.
A 1984 EPA study estimated that over 700,000 of more than 3 million public and
commercial buildings have some type of friable ACM within their structure.
In 1991 the Health Effects Institute-Asbestos Research (HEI-AR), established to determine
for EPA the public's actual exposure to asbestos in such buildings, reported that their
literature search revealed that occupants of public and commercial buildings are exposed to
average concentrations of 0.00008 f/ml, an exposure level almost identical to urban outdoor
concentrations of 0.0001 f/ml (See Table 3-2).
Neighborhood Exposure
Neighborhood exposure is incurred by people who live or work near asbestos mines,
manufacturing or fabricating plants, demolition or renovation sites, asbestos landfills or areas
where equipment or machinery is sprayed with asbestos-containing fireproofmg or insulating
material.
Ambient Background Exposure
Asbestos exposure by this pathway is a result of the release of fibers from the weathering of
exposed asbestos-bearing rocks and from the use or weathering of asbestos-containing
products such as brake linings, shingles or cladding (See Table 3-2).
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TABLE 3-2. AMBIENT ASBESTOS FIBER LEVELS
Area
Outdoor
rural
urban
Indoor
school2
public/commercial4
Mean Fiber Concentration (f/ml)1
0
0
.00001
.0001
0
0
.00051 (0.00038)3
.00020 (0.00008)3
1 Fibers >5 urn in length
2 N = 48
3 Mean fiber concentration with highest sample concentration excluded from mean
4 N = 54 (43 = GSA buildings)
Source: HEI-AR "Asbestos in Public and Commercial Buildings..." (1991) - non litigation data only.
On average, an adult male breathes approximately 20 cubic meters of air per day. Since
airborne asbestos concentrations are expressed in fibers/cubic centimeter of air, for a typical
ambient concentration of 0.0001 f/cc (or 100 f/m3), the daily exposure to asbestos through
inhalation is approximately 2000 fibers/day.
Because the medical community has been unable to establish a "safe level" of asbestos
exposure, the regulatory community has been forced to rule that asbestos release be kept "to
the minimal extent economically feasible."
Diseases Associated with Asbestos Inhalation
Several diseases and conditions have been linked to asbestos fiber inhalation. These include
asbestosis, lung cancer, mesothelioma, gastrointestinal cancers, and other abnormalities.
Much of the following information concerning the health effects of airborne asbestos has
been extracted from the HEI-AR "Asbestos in Public and Commercial Buildings..." 1991
document.
Asbestosis
Asbestosis is a progressive, disabling, and potentially fatal disease caused by the inhalation
of asbestos fibers. Inhaled asbestos fibers cause inflammation (alveolitis) to occur, which
may result in the development of scarring and fibrosis and subsequent impairment of gas
exchange. The extent of damage to the lungs is dependent upon the amount of asbestos in the
lungs, fiber type and length, and individual susceptibility. Although all forms of asbestos are
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known to cause asbestosis, some researchers have found that amphiboles are more likely than
chrysotile to cause the disease.
Common symptoms of asbestosis include fatigue, shortness of breath, chest pain, a dry or
productive cough, and rales (a crackling sound heard posteriorly in the bases of the lungs).
Asbestosis appears radiologically as irregular linear opacities predominantly in the lower
lobes.
Studies designed to elucidate the development of asbestosis have revealed that alveolar
macrophages (AMs) may be responsible for the initiation of the inflammatory and ultimate
fibrotic response. AMs which accumulate where asbestos fibers are deposited in the lung
produce a complex mixture of chemical substances including growth factors, prostaglandins
(inflammatory agents), and active oxygen species (AOS) which are cytotoxic chemicals. In
vitro studies involving rodent Ams have revealed that long asbestos fibers (those greater than
10 ^m in length) cause a greater production of AOS than short fibers and nonfibrous particles
do. Incomplete phagocytosis of long fibers is theorized to cause this difference.
There is a clear dose-response relationship between asbestos exposure and the development
of asbestosis - the greater the exposure, the greater the likelihood of developing the disease.
Asbestosis is prevalent among workers who have been exposed to large doses of asbestos
fibers over a long period of time. These include miners, millers, manufacturers of asbestos
products, insulators, shipyard workers, and veteran custodians. Like all asbestos-related
diseases, asbestosis has a long latency period, typically 15-30 years.
Many individuals with asbestosis may suffer from asbestos-related lung cancer as well,
although the relationship between lung fibrosis and cancer is unclear. There are an estimated
4,000 deaths/year associated with asbestosis; nearly all of these deaths occur in individuals
who smoke and also suffer from emphysema.
Asbestos inspectors who use appropriate safety precautions as described in this workshop
have a very small risk of developing asbestosis as a result of their work.
Lung Cancer
Asbestos-related lung cancers typically arise in the tracheobronchial epithelial or alveolar
cells of the respiratory tract. Although such tumors are indistinguishable from those caused
by cigarette smoke or radon decay products, the relationship between asbestos exposure and
lung cancer has been well documented.
Lung cancer, like asbestosis, appears to be dose-related and exhibits a long latency period,
typically 20-30 years. Symptoms of lung cancer include a cough or a change in cough habit
and/or persistent chest pain.
Death rates among exposed workers are lowest in chrysotile miners and workers who
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manufactured friction materials and highest among individuals who mined and worked with
amphibole asbestos. Lung cancers have also been found in talc miners and millers
(tremolite/anthophyllite contamination suspected as the cause) and in building janitors,
plumbers, pipefitters, construction laborers, welders and sheet metal workers.
While employees who did not smoke and were exposed to industrial concentrations of
asbestos in the past have had a 5X greater risk of developing lung cancer than that of the
general public, their risk is not as great as that experienced by a smoker with no known
asbestos exposure (10X the risk). The effects of cigarette smoking and asbestos exposure are
synergistic; that is, the combined effects create a greater than SOX risk of developing lung
cancer in those individuals exposed to both asbestos and cigarette smoke.
Research into the relationship between smoking and asbestos exposure has revealed that
smoking impairs clearing of asbestos fibers from the lungs and increases the retention of
fibers in airway epithelial cells. A combination of cigarette smoke and asbestos has been
shown to induce the production of AOS which can cause chemicals in smoke to become
more mutagenic and carcinogenic. Toxic chemicals from cigarette smoke have also been
found to adsorb onto asbestos fibers which, if taken into cells, may initiate tumor formation.
Lung cancer is extremely rare among nonsmokers, even those who have experienced quite
heavy asbestos exposure, so an individual's decision not to smoke is an important defense
mechanism.
While there are more than 434,000 deaths/year attributable to cigarette smoking, only 2,000
lung cancer deaths/year are believed to be caused by asbestos exposure. Since most of the
lung cancers noted are thought to have resulted from exposures incurred in the past in
industries where workers wore little or no protective equipment in highly contaminated
environments, an asbestos inspector who follows appropriate safety procedures has very little
risk of developing asbestos-related lung cancer.
Mesothelioma
Mesothelioma is a rare cancer of the mesothelium, a thin tissue layer which lines body
cavities and surrounds internal organs. Mesothelioma arises from mesothelial cells or
underlying mesenchymal cells in the pleura, pericardium or peritoneum. Mesothelioma
which arises in the chest cavity is called pleural mesothelioma; that which develops in the
abdominal cavity is called peritoneal mesothelioma. Both types of mesothelioma spread
rapidly and are always fatal, usually within a year of diagnosis. There does not appear to be
any increased risk of mesothelioma for smokers.
Pleural mesothelioma may begin as a small nodule which seeds the pleural cavity. The
tumor involves both layers of mesothelium and can invade the chest wall and lung and spread
to the rest of the body via the lymphatic and circulatory systems. Pleural mesothelioma
accounts for approximately 85% of all reported cases and is characterized by shortness of
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breath, chest wall pain, and fluid in the chest cavity. The risk of acquiring pleural
mesothelioma is higher following exposure to crocidolite than to either chrysotile or amosite
asbestos.
Peritoneal mesothelioma, which accounts for the remaining 15% of reported cases, is
characterized by abdominal pain and swelling and is almost always attributed to amosite or
crocidolite exposure.
The latency period for the development of mesothelioma is usually 20-40 years or more
following exposure. Although approximately 1500-2500 cases of mesothelioma are
diagnosed each year in the U.S., the annual incidence of this disease may be either under- or
overestimated, for mesothelioma may resemble metastases of other tumor types.
Most mesotheliomas can be linked to past asbestos exposure in an industrial environment or
household contact with an asbestos worker. In some cases only brief exposure to asbestos
has been implicated in the disease. Mesothelioma is also known to afflict individuals who
live near asbestos mines. In 10-30 percent of all reported cases of mesothelioma, however,
no known asbestos exposure has occurred.
Post-mortem studies involving lung tissue analysis have concluded that, like other asbestos-
related diseases, the risk of developing mesothelioma is also dose-related. Although all
asbestos fiber types have been implicated in the development of mesothelioma, amphiboles
(amosite, and particularly crocidolite) appear to be more potent causes. Exposure to long
(>8//rn), thin (<0.25/um) fibers is also more likely to result in mesothelioma than exposure to
shorter, thicker fibers.
Other Diseases
In some studies of workers occupationally exposed to asbestos, an increased risk of tumors of
the gastrointestinal tract, larynx, kidney, ovary, pancreas, pericardium, eye and lymphatic
system has been reported. Since many of these cancers may have other etiologies, the role of
asbestos in their initiation is not clearly understood.
A Journal of the National Cancer Institute article published in December 1991 indicated that
an elevated risk of colorectal cancer and adenomatous polyps (growths of glandular origin
which are common precursors to colorectal cancer) was seen among study subjects who had a
significant exposure to asbestos. Although the number of subjects was small (51 with cancer,
153 with adenomatous polyps, and 195 controls), of the 12 subjects (3% of the total
population) who were classified as having had significant exposure to asbestos, 6 (50%) had
adenomatous polyps and 3 (25%) had colorectal cancer.
Other A bnormalities
In addition to asbestosis, lung cancer and mesothelioma, inhalation of asbestos fibers is
associated with the development of pleural plaques, diffuse pleural thickening, pleuritis and
benign lung masses. Such diseases typically do not develop for 20 or more years following
1997 3-8
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initial exposure and their prevalence is related to the duration of exposure.
Pleural plaques are diffuse areas of scar tissue that may form on the mesothelium of the chest
cavity or, more rarely, on the pericardium. In individuals free of other lung disease, pleural
plaques are asymptomatic and cause no significant lung dysfunction.
Diffuse pleural thickening is a more pronounced scarring of the pleura caused in most cases
by adhesions resulting from pleuritis, an inflammation of the pleura. Pleural thickening can
cause lung restriction and reduce lung volume.
Benign lung masses (that can be mistaken for carcinomas) are found in up to 10 percent of
workers occupationally exposed to asbestos. Most benign lung masses are sites of
inflammation and infolding of the lung tissue associated with adhesive fibrothorax.
Although once regarded as simply indicators of asbestos exposure, fibrotic pleural lesions are
now recognized as capable of reducing lung function and causing disability. Some
unconfirmed studies have reported that pleural plaques are associated with a higher incidence
of lung and laryngeal cancer, and probably mesothelioma.
Since pleural disease may be the only indication of asbestos exposure in an individual, the
detection of such abnormalities should trigger close medical surveillance.
HEALTH EFFECTS ASSOCIATED WITH INGESTION
During the early 1980s the issue of potential health hazards associated with ingestion of
asbestos fibers was closely examined by EPA's Office of Drinking Water (ODW). The ODW
reviewed numerous human and laboratory animal epidemiological studies and, despite the
uncertainty of research conclusions linking an increased risk of development of digestive
tract cancers to exposure to asbestos fibers, proposed to establish an asbestos fiber limit in
drinking water. In January 1991 a limit of 7 million asbestos fibers (greater than 10 /^m in
length) per liter of drinking water was established in the National Primary Drinking Water
Regulations.
HEALTH EFFECTS ASSOCIATED WITH SKIN CONTACT
Although repeated contact with asbestos has been known to cause warts, the dermal route of
asbestos fiber entry to the body is not considered a major health issue. However, since ACM
contains a variety of substances which may cause skin irritation and rashes, it is always wise
to wear protective clothing when working with asbestos materials.
THEORIES ON HAZARD RELATIONSHIPS
Factors which contribute to the development of asbestos-related disease include the
following: extent of asbestos exposure; fiber type; fiber dimensions; age at exposure; and
1997 3'9
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individual susceptibility. At the present time, however, no means exists to conclusively
determine which individuals will or will not develop asbestos-related illnesses following
exposure.
Extent of Exposure
In general, individuals who experience a lengthy exposure to high levels of airborne asbestos
suffer a greater risk of developing any of the asbestos-related diseases than individuals who
have not been so exposed. In addition, in the case of asbestosis, the greater the exposure, the
greater the likelihood of developing a severe form of the disease.
Asbestos Fiber Types
All asbestos fiber types have been implicated in .the development of asbestos-associated
illnesses. Some human epidemiological studies, however, indicate that the risk of developing
asbestosis, lung cancer, or mesothelioma is greater if an individual has been exposed to
amphibole rather than serpentine (chrysotile) fibers.
The increased risk following exposure to amphibole fibers is thought to result from the
body's inability to purge itself of inhaled amphibole fibers. Unlike chrysotile fibers, which
ones body can rapidly dissolve following deposition (and whose lung burden thus
equilibrates over time), amphibole fibers accumulate in the lungs throughout the duration of
exposure.
This fact may help explain why both amosite and crocidolite have caused a high risk of
mesothelioma after only a brief exposure, whereas chrysotile has not been so implicated.
Short intense amosite exposure has also resulted in a high lung cancer rate.
Since the medical community cannot come to a consensus regarding the relative risks of
amphibole vs. serpentine exposure (and because most people are exposed to a mixture of
such fiber types anyway), the EPA and OSHA have chosen not to distinguish one from the
other when regulating asbestos.
Asbestos Fiber Dimensions
In vitro studies, experiments with laboratory animals, and reviews of human exposure studies
indicate that both fiber length and diameter (which affect penetration into and deposition of
fibers within the lungs) are critical factors in the incidence of asbestos-related disease.
The pathogenicity of asbestos fibers increases with increasing length. Although the
minimum length of asbestos fibers capable of generating a deleterious response is not
specifically known, in vivo inhalation and injection studies have found that fibers less than 5
^m are much less toxic than those greater than 5 ^m. Very short fibers appear to produce
little or no asbestos-related disease.
1997
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Medium-length fibers (8-10 /^m) are capable of reaching the alveoli of the lungs and are
implicated in the development of mesothelioma.
Fibers longer than >10 ,wm tend to be captured by the body's defense mechanisms and
deposited in the airways. Some evidence suggests that very long fibers (>20 /urn) cause
severe damage to lung tissue. Fibers ranging from 15-25 /urn have been implicated in the
development of lung fibrosis and lung cancer.
The diameter of asbestos fibers also affects their pathogenicity; smaller diameters appear
more harmful than thicker diameters. Fibers with diameters of approximately 0.1-3.0 //m
appear to be most capable of causing harm. Fibers thinner than 0.1 /urn are poorly retained in
the lungs, and those with diameters >3 /^m appear incapable of penetrating the lungs where
they could do harm. The upper fiber diameter limit associated with asbestosis and lung
cancer is about 3 //m. In the case of mesothelioma, the upper fiber diameter limit is much
less, apparently because thin fibers more readily penetrate to the alveoli from which the
durable fibers may migrate to the lung interstitium, pleural surfaces, and other parts of the
body.
In conclusion, evidence suggests that exposure to long (>5 fj.m), thin (<3 /um) fibers
generates a greater risk of developing asbestos-related diseases than exposure to short, thick
fibers.
The EPA and OSHA do not attempt to regulate any particular size of asbestos fiber. In fact,
it should be noted that the PCM analytical method for counting air fiber concentrations
considers only those particles greater than 5 microns in length which have a minimum length
to width (aspect) ratio of 3:1.
Age at Exposure
HEI-AR's literature review reports that lifetime risks of developing lung cancer and
mesothelioma have been predicted in a number of studies which took into account age at first
exposure and duration of exposure at a given fiber level. In general, the eventual lung cancer
risk is assumed to be independent of age at exposure, but the predicted mesothelioma risk is
much greater when exposure begins at an early age. The mesothelioma risk exceeds the lung
cancer risk, even among smokers, for childhood exposure, whereas exposure in middle age
results in a substantially lower mesothelioma risk. Among nonsmokers, the lung cancer risk
is much smaller than the mesothelioma risk irrespective of age at exposure.
Individual Susceptibility
Another factor to consider in looking at the risks from asbestos exposure involves one's
body's reaction to asbestos fibers. Why some people who are greatly exposed to airborne
asbestos develop an asbestos-related disease while others who are similarly exposed develop
1997 3-11
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a different asbestos disease or none at all is a question our present scientific/medical
community cannot answer.
1997 3-12
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SECTION 4
IDENTIFYING ASBESTOS-CONTAINING MATERIALS
In order to properly conduct asbestos NESHAP compliance inspections, inspectors must be
knowledgeable of the various commercial uses and applications of asbestos products and
which of these are regulated under the asbestos NESHAP. Recognizing the various
appearances, compositions, uses and application techniques can assist the inspector in
deciding if a violation has or has not occurred. The remainder of this section provides
information that should assist inspectors in recognizing ACM, both in the intact and
disturbed state.
IMPORTANT DEFINITIONS
A CM- Asbestos-containing material.
Asbestos - The asbestiform varieties of serpentinite (chrysotile), riebeckite (crocidolite),
cummingtonite-grunerite (amosite), anthophyllite, and actinolite-tremolite.
Asbestos-containing waste materials (ACWM) - Mill tailings or any waste that contains
commercial asbestos and is generated by a source subject to the provisions of this subpart.
This term includes filters from control devices, friable asbestos waste material, and bags or
other similar packaging contaminated with commercial asbestos. As applied to demolition
and renovation operations, this term also includes regulated asbestos-containing material
waste and materials contaminated with asbestos including disposable equipment and
clothing.
Category I nonfriable A CM - Asbestos-containing packings, gaskets, resilient floor
covering, and asphalt roofing products containing more than 1 percent asbestos as determined
using the method specified in appendix A, subpart F, 40 CFR part 763, section 1, Polarized
Light Microscopy.
Category II nonfriable ACM - Any material, excluding Category I nonfriable ACM,
containing more than 1 percent asbestos as determined using the methods specified in
appendix A, subpart F, 40 CFR part 763. section 1, Polarized Light Microscopy that, when
dry. cannot be crumbled, pulverized, or reduced to powder by hand pressure.
Friable asbestos material - Any material containing more than 1 percent asbestos as
determined using the method specified in appendix A, subpart F, 40 CFR part 763 section 1,
Polarized Light Microscopy, that, when dry. can be crumbled, pulverized, or reduced to
powder by hand pressure. If the asbestos content is less than 10 percent as determined by a
method other than point counting by polarized light microscopy (PLM), verify the asbestos
content by point counting using PLM.
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In poor condition - The binding of the material is losing its integrity as indicated by peeling,
cracking, or crumbling of the material.
Regulated asbestos-containing material (RACM) - (a) Friable asbestos 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, or (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 regulated by this subpart.
Resilient floor covering - Asbestos-containing floor tile, including asphalt and vinyl floor
tile, and sheet vinyl floor covering containing more than 1 percent asbestos as determined
using polarized light microscopy according to the method specified in appendix A, subpart F,
40 CFR part 763, section 1, Polarized Light Microscopy.
ASBESTOS USES AND CHARACTERISTICS
Since asbestos minerals are fibrous and exhibit varying degrees of heat resistance, tensile
strength, flexibility, and chemical resistance, they have been incorporated into approximately
3,600 products. These products include heat-resistant textiles, reinforced cement, special
filters for industrial chemicals and cigarettes, thermal and acoustical insulation, floor tiles,
gaskets, and brake linings.
Table 4-1 provides a summary of asbestos content in several commercial product categories.
In addition to asbestos, commercial products typically contain fillers, binders and other
components.
TABLE 4-1. SUMMARY OF ASBESTOS-CONTAINING PRODUCTS
Product
Average Percent Asbestos
Insulating and Decorative Products
Spray Coating
Troweled Coating
Preformed Pipe Wrap
Boiler Insulation
Cement Pipe and Sheet
Paper Products
Roofing Felt
Gaskets
Plastic Products
Floor Tile
Coatings and Sealants
Rigid Plastics
Friction Products
Textile Products
50
70
50
10
20
10
80
20
10
50
50
80
1997
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Of the six asbestos minerals, chrysotile use comprises approximately 93 percent of the total
consumption of asbestos fibers. Chrysotile fibers are very thin, flexible, and strong, and have
been used in fireproofmg, cement products, asphalt and vinyl flooring, brake linings, clutch
facings, gaskets, reinforced plastics and many other products.
The remaining 7 percent of the total asbestos fibers consumed consists primarily of amosite
and crocidolite. Amosite, less flexible but more heat and acid resistant than chrysotile, is
often found in high-temperature applications (e.g., block insulation, fire brick), but may also
be found in small amounts as filter aids in pressure piping products and in spray-on
fireproofing. Crocidolite, very resistant to acids and to the effects of outdoor exposure, may
be found in combination with chrysotile in asbestos-cement pressure pipes, textile, and
filtration products.
Anthophyllite, actinolite, and tremolite are used primarily in adhesives and cements. They
are too brittle for textile products or for use as fibrous reinforcement.
The use of asbestos products has declined greatly since the late 1970s as EPA and the
Consumer Product Safety Commission have banned the use of some products (insulation,
fireproofing, lagging, etc.). There has also been a. voluntary banning of asbestos use in items
such as hair dryers.
Table 4-2 is provided to help inspectors recognize trade names of asbestos building products.
This list includes information received by EPA from previous and current manufacturers of
asbestos products under the Asbestos Information Act of 1988 but should not be considered
all-inclusive.
Table '4-3 provides additional information concerning asbestos-containing materials found in
buildings.
ASBESTOS USE IN BUILDINGS
The following categories of ACM are often found in buildings:
surfacing materials
fireproofing
thermal insulation
acoustical insulation
decorative uses
thermal system insulation
miscellaneous
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Asbestos Surfacing Materials
Asbestos-containing surfacing materials are coatings which were spray-applied or troweled
onto steel I-beams, decks, concrete ceilings and walls, and other surfaces. They were used
for fireproofing, thermal insulation/condensation control, acoustical insulation, and
decorative purposes. Often a single application served more than one of these purposes (e.g.,
acoustical and decorative; fireproofing and thermal insulation).
Sprayed coatings may appear cementitious or fluffy, while troweled coatings have a smooth
finish and may be covered with a layer of plaster or other non-asbestos material. Both
sprayed and troweled asbestos coatings are friable in most applications. In 1973 the spray
application of most asbestos coatings to buildings, structures, pipes, and conduits was
banned.
In its 1986 standard, OSHA banned all applications of asbestos-containing products through
spray techniques. However, the U.S. Court of Appeals for the District of Columbia reviewed
this ban and concluded that "the support for the ban plainly fails to meet the "substantial
evidence' standard... (and stated that the) ban cannot stand."
Effective January 19,1990, OSHA amended the regulatory text of the final asbestos standard
by deleting the prohibition regarding the spray application of asbestos-containing products.
It is believed that deleting this prohibition will not significantly increase the risk to
employees.
Fireproofing
Since high temperatures can result in a deterioration of ductility, tensile and compressive
strengths in building materials, asbestos has been widely used by the construction industry to
fireproof structural steel.
Thermal Insulation/Condensation Control
Asbestos-containing materials exhibit very low thermal conductivity. For this reason they
were often applied to steel, concrete, or other building surfaces to minimize heat loss or gain.
Such use of ACM reduced the amount of energy needed to heat or cool buildings and
controlled condensation which could result in ceiling and wall "sweating," metal corrosion,
and rotting of wood components.
Acoustical
Since asbestos is fibrous in nature and thus lacks a reverberant surface, it has proved to be an
excellent soundproofing material. It was used extensively in schools (hallways, stairwells,
band rooms, gymnasiums), restaurants, hotels, and auditoriums for this purpose prior to the
1970s.
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TABLE 4-2. TRADE NAMES
Type of Application
Trade Names
Spraycd-on
Armaspray
Spray craft
l.ilccast 30
Decorative Spray Coalings
Cover-Tex
Spray-Tex
Kaiser-Tex
K-Spray Ceiling Texture
Pyrospray
Mono-spray
Mono-K
Fire-Shield Plaster
White Spray-on Acoustical Plaster
Super White Sprayolite
QT Simulated Acoustical Spray Texture
Imperial "QT" Texture Finishes
Improved Spray Texture B-8
Zonolite
Econo-White 70
Z-tex
Perltex Super-40 Perlite
High-Sorb Acoustical Plaster
Spray-Wyt
Versakote
Prep Coat #3
Perlcoustic
Pipe Coverings, Block
Products, Cements
Superex(M, 1900)
Thermobestos
Min-K products
Nonpareil
LT Cork Covering
Alltemp
Careytemp
Aircel (Aircell)
Carocel
Defendex
Excel
Glosscell
Multi-Ply
Tempcheck
Hi-temp
Thermalite
Thermasil
Enduro
Prasco
Caltemp (Caltherm)
Kaylo
LK insulation
Pyrocal
Calsilite
Celasbestos
Watcocel
Imperial insulation
Aristo insulation
Anti-Sweat Pipe Covering
Frost-Proof Pipe Covering
Range Boiler Jacket
K-Fac 19
Corrugated Wool Felt Air Cell Covering
Pyrobestos
Cement (707, Super 606, 100, 303,
A-01.7M-O.LF-0, MW-0)
Careytemp Finishing Cement
Vitricel Cement
Porter Binding Mortar
Transite products
Firelite Furnace Cement
Insulkote
Duplex
Asbestile
Laptite
Pallite
Super "66"
Eagle "66"
One-Cote Insulating and Finishing Cement
Thermal insulating cement (No. 127, Colorok,
Stormlap, Pabflex, Stonite)
Insulating Cement (115, 214, Grade AA, A, HF,
H.T., 203, A-ll)
Satin Finish Cement
I Source = Asbestos: Publication of Identifying Information (55FR 5144), February 1990
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TABLE 4-3. ASBESTOS-CONTAINING MATERIALS FOUND IN BUILDINGS'
Surfacing material
Preformed thermal
insulating products
Textiles
Cemenutious
concrete-like products
Paper proCuC't
Roofing (*':ป
Generic name
sprayed- or
troweled-cn
baits, blocks, and
pipe covering
85% magnesia
calcium silicate
cloth"
blanxets (lire)
felts:
blue stripe
red stripe
green stripe
sheets
cord/ rope/ yarn
tubing
tape/ strip
curtains
(theatre, welding)
extrusion panels:
corrugated
flat
flexible
flexibly perforated
laminated
(outer surface)
roof tiles
clapboard and shingles:
clapboard
siding shingles
roofing shingles
P'pe
corrugated:
high temperature
moderate temperature
indented
millboard
smooth surface
mineral surface
shingles
pipeline
Asbestos (%)
1-95 .
15
6-8
100
90-95
80
90
95
50-95
80-100
80-85
90
60-65
8
20-45
40-50
30-50
30-50
35-50
20-30
12-15
12-14
20-32
20-15
90
35-70
98
80-85
'10-15
10-15
1
io
Dates of use
1935-1970
1926-1949
1949-1971
1910-present *
1 920-present
1 920-present
1 920-present
1 920-present
1 920-present
1 920-present
1 920-present
1 920-present
1 945-presem
1965-1977
1930-present
1930-present
1 930-present
193O-present
1 930-present
1930-present
1944-1945
unknown-present
unknown-present
1935-present
1935-present
1910-present
1935-present
1925-present
1910-present
1910-present
1971-1974
1 920-present
Binder '"sizing
sodium silicate,
Portland cement.
organic binders.
magnesium carbonate
calcium silicate
none
cotton/wool
cotton
cotton
cotton
cotton/wool
cotton/wool
cottor 'wool
cotton /wool
cotton
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
Portland cement
pordand cement
Portland cement
sodium silicate
Starch
cotton and organic binder
starch, lime, clay
asphalt
asphalt
asphalt
asphalt
1997
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Table 4-3 (Continued)
Subdivision
Asbestos-containing
compounds
Asbestos ebony products
Flooring tile and
Sheet Goods
Generic name
caulking putties
adhesive (cold applied)
joint compound
roofing asphalt
mastics
asphalt tile cement
roof puny
plaster/stucco
spackles
sealants fire/water
cement, insulation
cement, finishing
cement, magnesia
vinyl/asbestos tile
asphalt/asbestos tile
sheet goods/ resilient
Asbestos (%)
30
5-25
5
5-25
13-25
10-25
2-10
3-5
50-55
20-100
55
15
50
21
26-33
30
Dates of use
1 930-present
1945-present
1945-1975
unknown-present
1920-present
1959-present
unknown-present
unknown-present
1930-1975
1935-present
1900-1973
1920-1973
1926-1950
1 930-present
1950-presem
1920-present
1 950-presem
Binder/sizing
linseed oil
asphalt
asphalt
asphalt
asphalt
asphalt
asphalt
Portland cement
starch, casein, synthetic
resins
caster oil or poiyisobutylene
clay
clay
magnesium carbonate
ponland cement
poly(vinyl)chlonde
asphalt
dry oils
Wallcovering
Paints and coatings
vinyl wallpaper
roof coating
air tight
6-8
4-7
15
unknown-present
1900-present
1940-present
asphalt
asphalt
Source = Guidance for Controlling Asbestos-Containing Materials in Buildings (Purple Book), 1985 (EPA-
560/5-85-024)
1 Present = Mid- to late '70's
1997
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Decorative Uses
Although the spray application of asbestos onto structural components was banned in 1973,
architects continued to specify the use of asbestos for decorative purposes. In 1978 EPA banned
this use of ACM.
Thermal System Insulation
Thermal system insulation includes a wide variety of materials applied to pipes, fittings, boilers,
breechings, tanks, ducts, and other structural components to prevent heat transfer or water
condensation. The following examples of thermal system insulation are based on product
categories.
Pipe Insulation
Preformed pipe insulation with an asbestos content of about 50 percent has
been used for thermal insulation of steam pipes in industrial, commercial, institutional, and residential
applications. This product is usually white and chalky in appearance and typically was applied as 3-
foot long, half-round sections, held onto the pipe by a covering of plaster-saturated canvas and metal
bands. Preformed insulation was applied on straight runs of pipe, while wet-applied coatings were used
on elbows, flanges, and other irregular surfaces. The installation of wet-applied and preformed asbestos
insulation was banned in 1975.
Another type of asbestos-containing pipe insulation is known as "air-cell" insulation. Air-cell
insulation is manufactured on conventional papermaking equipment using asbestos fibers rather than
cellulose. The final product may contain up to 85 percent asbestos and is typically coated or laminated
with other materials.
Air-cell insulation looks and feels like corrugated cardboard and is generally rolled onto the pipe in
several layers. It is medium gray in color and commonly held in place with a canvas wrap and metal
bands.
Pipes may also be insulated with an asbestos-containing felt.
Boilers and Hot Water Tanks
Asbestos-containing preformed block insulation has been used as thermal insulation on boilers, hot
water tanks, and heat exchangers in industrial, commercial, institutional, and residential applications.
The blocks are commonly chalky, white, 2 inches thick and from 1 to 3 feet square. They are often held
in place around the boiler by metal wires or expanded metal lath. A plaster-saturated canvas was often
applied as a final covering or wrap. The installation of this type of asbestos insulation was banned by
EPA in 1975. Asbestos-containing fire brick and gaskets may also be found as heating system
components.
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Elbows, Valves and T-Fittings
Batch mixed ACM has been trowel-applied to irregular joints (elbows, valves, T-fittings, etc.) on
thermal systems. The insulation is often covered with a canvas wrap or other covering similar to the
adjacent pipe wrap which may make it difficult to distinguish from the material in the straight runs. It
is not uncommon to find asbestos-containing "elbow mud" or "lagging" adjacent to straight-runs of
non-asbestos pipe insulation. ACM may also be found in valve packings.
Note: Fiber glass insulation may have been applied over existing asbestos insulation. Be sure to check
the entire depth of insulation when searching for suspect ACM.
Miscellaneous Building Materials
Miscellaneous materials include both friable and non-friable forms of asbestos-containing materials.
Friable materials include ceiling tiles (such as the 2' x 3' drop-in types and the 1' x I1 glue-in panels),
asbestos-containing paper (commonly found underneath wooden floor boards), plaster, and joint
compound. It is estimated that 5 to 10 percent of currently installed ceiling tiles contain asbestos.
Both Category I and Category II nonfriable ACM may be found in buildings. Category I materials
include resilient floor covering and mastic, packings, gaskets, and asphaltic roofing products. Category
II materials include such items as asbestos-cement (Transite) sheet and pipes, terrazzo flooring,
caulkings, glazing, ductwork flex connectors, siding shingles, and laboratory table tops. Although the
asbestos in these products is typically tightly bound and nonfriable, with age, or during the course of
demolition or renovation, such materials may .become friable. Because of this, inspectors must evaluate
such materials for their potential to become friable on a case-by-case basis.
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1997 4-10
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SECTION 5
ASBESTOS INSPECTOR SAFETY GUIDANCE
Safety requirements and/or guidelines for government employees involved in asbestos
activities are addressed in one form or another in regulations and policies developed by
several Federal government agencies/groups.
The Occupational Safety and Health Administration (OSHA) and the U.S. Environmental
Protection Agency (EPA) have each promulgated regulations pertaining specifically to
workers involved in the asbestos industry. The OSHA standards (29 CFR Parts 1910, 1915
and 1926) apply to general industry, shipyard and construction workers. The EPA Worker
Protection Rule (40 CFR Part 763 Subpart G) extends provisions of the OSHA asbestos
standard to State and local asbestos workers not covered by the Federal OSHA standard.
The National Institute for Occupational Safety and Health (NIOSH) and EPA were
responsible for publishing respiratory protection safety guidance for persons who work in the
asbestos abatement industry. Their document, A Guide to Respiratory Protection for the
Asbestos Abatement Industry (EPA-560-OPTS-86-001, April 1986), provides information on
the hazards associated with airborne asbestos, a model respiratory protection program, and
recommendations concerning appropriate respirators for reducing asbestos exposure.
Most applicable to EPA asbestos NESHAP inspectors are the guidelines provided in EPA's
Health and Safety Guidelines for EPA Asbestos Inspectors. These guidelines incorporate
many of the procedures and practices recommended or required by the previously mentioned
regulations and policies.
OSHA ASBESTOS STANDARDS
OSHA regulates employee exposure to airborne asbestos fibers in the workplace. The
current OSHA regulation encompasses three standards: General Industry (29 CFR Part
1910.1001), Shipyard Employment (29 CFR Part 1915.1001) and Construction (29 CFR Part
1926.1101). The Construction Standard is the first health standard issued solely for the
construction industry.
The remainder of this subsection focuses on the regulatory requirements of the Construction
Standard most pertinent to asbestos NESHAP enforcement personnel. This information is
provided so that inspectors at abatement sites can better assess their personal needs regarding
respiratory protection and protective clothing.
1997
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Scope and Application
The Construction Standard regulates asbestos exposure in all work as defined in 29 CFR
1910.12(b), including, but not limited to, the following activities where chrysotile, amosite,
crocidolite, tremolite asbestos, anthophyllite asbestos, or actinolite asbestos is present:
demolition or salvage;
removal or encapsulation;
construction, alteration, repair, maintenance or renovation;
installation of products containing asbestos;
spill/emergency cleanup; and
on-site transportation, disposal, storage, containment of and housekeeping activities
involving asbestos or products containing asbestos.
Definitions
Amended water - Water to which surfactant (wetting agent) has been added to increase the
ability of the liquid to penetrate ACM.
Asbestos - Includes chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite
asbestos, actinolite asbestos, and any of these minerals that has been chemically treated
and/or altered. For purposes of this standard, "asbestos" includes PACM, as defined below.
Asbestos-containing material (ACM) - Any material containing more than one percent
asbestos
Class I asbestos work - Activities involving the removal of TSI and surfacing ACM and
PACM
Class II asbestos work - Activities involving the removal of ACM which is not thermal
system insulation or surfacing material. This includes, but is not limited to, the removal of
asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and
construction mastics.
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Class III asbestos work - Repair and maintenance operations, where "ACM", including TSI
and surfacing ACM and PACM, may be disturbed.
Class IV asbestos work - Maintenance and custodial activities during which employees
contact but do not disturb ACM or PACM and activities to clean up dust, waste and debris
resulting from Class I, II, and III activities.
Clean room - An uncontaminated room having facilities for the storage of employees' street
clothing and uncontaminated materials and equipment.
Competent person - One who is capable of identifying existing asbestos hazards in the
workplace and selecting the appropriate control strategy for asbestos exposure, who has the
authority to take prompt corrective measures to eliminate them, as specified in 29 CFR
1926.32(f): in addition, for Class I and Class II work who is specially trained in a training
course which meets the criteria of EPA's Model Accreditation Plan (40 CFR part 763) for
supervisor, or its equivalent and, for Class III and Class IV work, who is trained in a manner
consistent with EPA requirements for training of local education agency maintenance and
custodial staff as set forth at 40 CFR 763.92(a)(2).
Critical barrier - One or more layers of plastic sealed over all openings into a work area or
any other similarly placed physical barrier sufficient to prevent airborne asbestos in a work
area from migrating to an adjacent area.
Decontamination area - An enclosed area adjacent and connected to the regulated area
consisting of an equipment room, shower area and clean room...
Demolition - The wrecking or taking out of any load-supporting structural member and any
related razing, removing or stripping of asbestos products.
Disturbance - Activities that disrupt the matrix of ACM or PACM, crumble or pulverize
ACM or PACM, or generate visible debris from ACM or PACM. Disturbance includes
cutting away small amounts of ACM and PACM, no greater than the amount which can be
contained in one standard sized glove bag or waste bag in order to access a building
component In no event shall the amount of ACM or PACM so disturbed exceed that which
can be contained in one glove bag or waste bag which shall not exceed 60 inches in length
and \\idth
Equipment room (change room) - A contaminated room located within the decontamination
area thai is supplied with impermeable bags or containers for the disposal of contaminated
protective clothing and equipment.
Fiber - \ paniculate form of asbestos, 5 micrometers or longer, with a length-to-diameter
ratio of at least 3 to 1
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Glovebag - Not more than a 60 x 60 inch impervious plastic bag-like enclosure affixed
around asbestos-containing material, with glove-like appendages through which material and
tools may be handled.
High-efficiency particulate air (HEPA) filter - A filter capable of trapping and retaining at
least 99.97 percent of all mono-dispersed particles of 0.3 micrometers in diameter.
Negative Initial Exposure Assessment - A demonstration by the employer, which complies
with the criteria in paragraph (f)(2)(iii) of this section, that employee exposure during an
operation is expected to be consistently below the PELs.
PA CM- Presumed asbestos containing material.
Presumed Asbestos Containing Material - Thermal system insulation and surfacing material
found in buildings constructed no later than 1980. The designation of a material as "PACM"
may be rebutted pursuant to paragraph (k)(5) of this section.
Regulated area - An area established by the employer to demarcate areas where Class I, II,
and III asbestos work is conducted, and any adjoining area where debris and waste from such
asbestos work accumulate; and a work area within which airborne concentrations of asbestos
exceed, or there is a reasonable possibility they may exceed, the permissible exposure limit.
Removal - All operations where ACM and/or PACM is taken out or stripped from structures
or substrates, and includes demolition operations.
Renovation - The modifying of an existing structure, or portion thereof.
Repair - Overhauling, rebuilding, reconstructing, or reconditioning of structures or
substrates, including encapsulation or other repair of ACM or PACM attached to structures or
substrates.
Surfacing material - Surfacing material which contains more than 1% asbestos
Thermal system insulation (TSf) - ACM applied to pipes, fittings, boilers, breeching, tanks,
ducts or other structural components to prevent heat loss or gain.
Thermal system insulation ACM - Thermal system insulation which contains more than 1%
asbestos.
Permissible Exposure Limits (PELs)
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Time-weighted average limit (TWA)
No employee may be exposed to an airborne concentration of asbestos in excess of 0.1 f/cc of
air as an 8-hour, time-weighted average (TWA).
Excursion limit
No employee may be exposed to an airborne concentration of asbestos in excess of 1.0 fiber
per cubic centimeter of air (1 f/cc) as averaged over a sampling period of thirty (30) minutes.
Regulated Areas
Establish where PEL may be exceeded.
All Class I, II and III asbestos work shall be conducted within regulated areas.
The area must be demarcated to minimize the number of people in the area and
protect persons outside from exposure to airborne asbestos. Critical barriers, negative
pressure enclosures, or signs [in accordance with paragraph (k)(7) of the standard]
may demarcate the area.
Access shall be limited to authorized persons.
Respirators must be supplied to all persons entering a regulated area.
Employees may not eat, drink, smoke, chew tobacco or gum, or apply cosmetics in
the regulated area.
All asbestos work performed in a regulated area must be supervised by a competent
person.
Exposure Monitoring
General Monitoring Criteria
Each employer who has a workplace or work operation where exposure monitoring is
required must perform monitoring to determine accurately the airborne concentrations of the
asbestos to which employees may be exposed. Such determinations must be made from
breathing zone air samples that are representative of the 8-hour TWA and 30-minute short-
term exposures of each employee.
Initial Exposure Assessment
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A competent person must conduct an exposure assessment immediately before or at the
initiation of the operation to ascertain expected exposures during that operation or workplace.
The initial exposure assessment may be based on:
representative 8-hour TWA and 30-minute short-term exposure monitoring conducted
at the site;
objective data demonstrating that the product or material containing asbestos minerals
or the activity involving such product or material cannot release airborne fibers
exceeding the TWA and excursion limit...;
monitoring within the past year at other jobs which closely resemble the current job...
Periodic Monitoring
For Class I and II operations, daily representative monitoring is required unless a negative
exposure assessment for the entire operation has been made.
For other than Class I and II operations, periodic monitoring of all work where exposures are
expected to exceed a PEL, at intervals sufficient to document the validity of the exposure
prediction must be performed.
Exception: Except when unlisted or modifications of listed control methods are being used,
employers need not daily monitor employees who are equipped with supplied-air respirators
operated in the pressure demand mode or other positive pressure mode respirator.
Employee Notification
Employers must notify affected employees, in writing, of the monitoring results as soon as
possible (Note: asbestos NESHAP inspectors should examine monitoring results at the
worksite, but keep in mind that the data may not reflect current conditions.)
Methods of Compliance
Engineering Controls and Work Practices
The employer must use the following controls and work practices regardless of the levels of
exposure:
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vacuum cleaners equipped with HEPA filters to collect all debris and dust containing
ACM and PACM (except roofing); and
wet methods or wetting agents (except where infeasible); and
prompt cleanup and disposal of asbestos-contaminated wastes and debris in leak-tight
containers (except in roofing operations).
In addition, the employer also must use the following to achieve compliance with the TWA
permissible exposure limit and excursion limit:
local exhaust ventilation equipped with HEPA filter dust collection systems;
enclosure or isolation of processes producing asbestos dust;
ventilation of the regulated area to move contaminated air away from the employee
toward a HEPA filtration or collection device;
work practices or other engineering controls that the Assistant Secretary can show to
be feasible;
supplemental respiratory protection (only when the feasible engineering and work
practice controls described above have proven insufficient at reducing employee
exposure to or below the PEL).
Prohibitions
The following work practices and engineering controls may not be used for any work related
to asbestos or for work which disturbs ACM or PACM:
high-speed abrasive disc saws (unless equipped with necessary engineering controls);
compressed air (unless used in conjunction with an enclosed ventilation system
designed to capture the dust cloud);
dry sweeping, shoveling or other dry clean-up of dust and debris containing ACM or
PACM; and
employee rotation as a means of reducing employee exposure to asbestos.
Class I Requirements
Additional requirements for all Class I work (TSI and surfacing ACM and PACM):
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a competent person must supervise the activity;
where more than 25 linear or 10 square feet of TSI or surfacing material is to be
removed; or where a negative exposure assessment cannot be produced; or where
employees are working in areas adjacent to the regulated area while Class I work is
being performed:
critical barriers must be used (except outdoors); OR
another effective barrier or isolation method is used (surveillance and
monitoring required);
HVAC systems must be isolated in the regulated area by sealing with a double layer
of 6 mil plastic or equivalent;
impermeable dropcloths must be placed on surfaces beneath all removal activity;
all objects within the regulated area must be covered with securely fastened,
impermeable dropcloths or plastic sheeting;
where a negative exposure assessment cannot be produced, or where exposure
monitoring shows that a PEL is exceeded, the employer must ventilate the regulated
area to move contaminated air away from the breathing zone of the employees toward
a HEPA filtration or collection device;
one or more of the following control methods must be used:
negative pressure enclosure system;
glovebag system (2 persons required);
negative pressure glovebag or glove box system;
water spray process system (40-hour training required)
mini-enclosure;
alternative controls may be used as specified.
Appendix F (Work Practices and Engineering Controls for Class I Operations - Non-
mandatory) of the Construction Standard contains more specific engineering controls and
work practices
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Class II Requirements
For all Class II work (not TSI or surfacing):
a competent person must supervise the activity;
if conducted indoors where an NEA cannot be produced; where changed conditions
indicate there may be an exposure > PEL; or where the ACM is not removed
substantially intact:
critical barriers must be used;
another barrier or isolation method must be used;
impermeable dropcloths must be placed beneath;
include use of HEPA filtered vacuum cleaners; wet methods or wetting agents; and
prompt clean-up and disposal of asbestos-contaminated wastes and debris in leaktight
containers;
use specified work practices for the removal of vinyl and asphalt flooring materials;
roofing materials; cementitious asbestos-containing siding and shingles or transite
panels containing ACM on building exteriors (other than roofs); or gaskets;
use alternative work practices and controls as specified.
Alternative Methods of Compliance for Certain Roofing and Pipeline Coating Materials
When installing, removing, repairing; or maintaining intact pipeline asphaltic wrap, or roof
cements, mastics, coatings, or flashings which contain asbestos encapsulated or coated by
bituminous or resinous compounds:
a competent person must inspect and determine the roofing material is intact and will
remain so;
workers must have been properly trained;
the material must not be sanded, abraded, or ground - manual methods are required;
removed material must not be dropped or thrown to the ground (covered, dust-tight
chute; crane; or hoist) and must be removed from the roof no later than the end of the
work shift;
the building owner must be informed of the presence and location of asbestos-
containing products installed on non-residential roofs no later than the end of the job;
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all removal or disturbance of pipeline asphaltic wrap must be done using wet
methods.
Respiratory Protection
The employer must:
provide respirators and ensure that they are used when required during all:
Class I asbestos jobs;
Class II work where the ACM is not removed in a substantially intact state;
Class II and III work not performed using wet methods (exception: sloped
roof, NEA, intact removal);
Class II and III work where an NEA is not produced;
work where employees are exposed above the TWA or excursion limit;
emergencies;
select and provide the appropriate respirator (MSHA/NIOSH approved) to the
employee at no cost;
provide a tight fitting powered air-purifying respirator (PAPR) in lieu of a negative
pressure respirator when requested and appropriate, and inform the employee of this
option;
institute a respiratory protection program when necessary; and
ensure the proper fit of employee respirators.
Quantitative or qualitative fit testing must be performed at the initial fitting and every six
months thereafter for each employee wearing a negative-pressure respirator. The qualitative
fit tests may be used only for testing the fit of half-mask respirators where they are permitted
to be worn, or of full-facepiece air purifying respirators where they are worn at levels at
which half-facepiece air purifying respirators are permitted.
Protective Clothing
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The employer must provide and require the use of protective clothing by employees exposed
to > the TWA and/or excursion limit or when a NEA cannot be produced, or for any
employee performing Class I > 25 LF or 10 SF of TSI or surfacing ACM'and PACM.
Contaminated clothing must be laundered and transported appropriately. Protective clothing
must be periodically examined and repaired or replaced as needed.
Hygiene Facilities and Practices
Class I>25 Linear or 10 Square Feet of TSI or Surfacing ACM and PACM
The employer must:
establish a decontamination area consisting of a properly designed and equipped
equipment room, shower area, and clean room (in series) adjacent and connected to
the regulated area;
provide described alternatives when the above is not feasible;
ensure that employees use proper entry, use, and exit procedures;
provide appropriate lunch areas.
Class I<25 Linear or 10 Square Feet of TSI or Surfacing ACM and PACM, and Class II
and Class III (Exposures > PEL or No NEA)
The employer must:
establish an appropriately-sized equipment room or area adjacent to the regulated area
for the decontamination of employees and equipment;
ensure proper cleaning of work clothing, equipment and containers, and proper entry
and exit from the regulated area.
Communication of Hazards
Building and facility owners must:
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determine the presence, location and quantity of ACM and/or PACM at the worksite
before asbestos work begins;
notify (in writing or personal communication) individuals who may occupy or work
in or adjacent to work sites containing ACM or PACM.
Employers whose Employees Perform Work Subject to the Construction Standard must:
identify the presence, location, and quantity of ACM and/or PACM;
inform owners, employees who will perform the asbestos work, and adjacent
personnel of this information and precautions to be taken.
Signs
The building owner must post comprehendible signs at the entrance to mechanical
rooms/areas which contain ACM and/or PACM which identify the ACM, its location, and
required work practices.
Warning signs which state the following must be provided to demarcate a regulated area:
DANGER
ASBESTOS CANCER AND LUNG DISEASE HAZARD
AUTHORIZED PERSONNEL ONLY
Where respirators and protective clothing are required, the following must also appear on the
sign:
RESPIRATORS AND PROTECTIVE CLOTHING
ARE REQUIRED IN THIS AREA
Labels
Labels printed in large, bold letters on a contrasting background which state the following
must be affixed to all products or containers of asbestos:
DANGER
CONTAINS ASBESTOS FIBERS
AVOID CREATING DUST
CANCER AND LUNG DISEASE HAZARD
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DO NOT BREATHE ASBESTOS FIBERS
Labels are not required where the asbestos fibers have been modified and will not foreseeably
release airborne concentrations exceeding the PEL and/or excursion limit, or asbestos is
present in concentrations less than 1.0 percent.
Employee Information and Training
Employers must provide and ensure participation in free, comprehendible training for all
employees who are likely to be exposed in excess of a PEL and for all employees who
perform Glass I through IV asbestos operations. The training:
must be provided prior to or at the time of initial assignment and at least annually
thereafter;
for Class I (and certain Class II) operations must be equivalent to EPA's Model
Accreditation Plan (MAP) asbestos abatement workers training (hands-on, minimum
32 hours);
for other Class II operations involving asbestos containing roofing, flooring or siding
materials, ceiling tiles or transite panels, must conform to the requirements of the
Construction Standard (hands-on, minimum 8 hours);
for Class III employees must be consistent with EPA requirements for training of
local education agency (LEA) maintenance and custodial staff [hands-on, 16 hours
per40CFR763.92(a)(2)];
for Class IV operations must be consistent with EPA requirements for training of
local educational agency (LEA) maintenance and custodial staff [2 hours per 40 CFR
763.92(a)(2)].
Housekeeping
HEPA vacuums are required where vacuuming methods are selected;
asbestos waste consigned for disposal must be collected and disposed of in sealed,
labeled, impermeable bags or other closed, labeled, impermeable containers (except in
roofing operations);
asbestos-containing flooring material must be cared for as specified;
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waste, debris and dust in an area containing accessible TSI or surfacing ACM/PACM
or visibly deteriorated ACM must be cleaned and disposed of as specified.
Medical Surveillance
Employees are covered by this part of the standard if engaged in Class I, II or III work or
exposed at or above a PEL for a total of 30 or more days per year or required to wear a
negative-pressure respirator.
Medical examinations must be free and performed by appropriate medical personnel. The
exam must include a medical and work history, standardized questionnaire, a physical
examination directed to the pulmonary, cardiovascular and gastrointestinal systems, a chest
x-ray (physician's discretion) and pulmonary function tests [FVC and FEV(l)], and must be
repeated annually.
Recordkeeping
The following objective data and exposure measurements must be maintained made available
for review, and transferred as specified:
information that products and activities cannot release asbestos fibers at or above the
PEL and/or excursion limit (duration of employer's reliance upon this data);
employee exposure monitoring (30 years);
employee medical surveillance (duration of employment plus 30 years);
employee training records (one year beyond last date of employment by employer);
data to rebut PACM (as long as they are relied upon);
required notifications (duration of ownership and transfer to successive owners).
Competent Person
The competent person must:
have qualifications and authorization as required;
provide frequent and regular inspection of the job sites;
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inspect Class I jobs at least once per work shift;
inspect Class II, III and IV jobs as needed;
be trained to meet the criteria of an EPA MAP supervisor for Class I and II work;
be trained consistent with LEA maintenance and custodial staff [40 CFR 763.92(a)(2)
- 16 hours) for Class III and IV work.
Appendices
The OSHA Construction Standard also incorporates several appendices; some are mandatory
and others informational:
Appendix Title
A OSHA Reference Method (Mandatory)
B Sampling and Analysis (Non-Mandatory)
C Qualitative and Quantitative Fit Testing Procedures
(Mandatory)
D Medical Questionnaires (Mandatory)
E Interpretation and Classification of Chest Roentgenograms
(Mandatory)
F Work Practices and Engineering Controls for Class I
Asbestos Operations (Non-Mandatory)
G Removed and reserved.
H Substance Technical Information for Asbestos
(Non-Mandatory)
I Medical Surveillance Guidelines for Asbestos (Non-Mandatory)
J Smoking Cessation Program Information for Asbestos
(Non-Mandatory)
K Polarized Light Microscopy of Asbestos (Non-Mandatory)
EPA WORKER PROTECTION RULE (WPR)
The EPA Worker Protection Rule (40 CFR Part 763, Subpart G) was first published in the
Federal Register on April 25, 1986. It was amended in 1987 to reflect OSHA's reduction of
the PEL from 2.0 f/cc to 0.2 f/cc and is being revised once again. The WPR extends
provisions of the OSHA Construction Standard to State and local government employees
who are not covered by State asbestos standards approved by OSHA or by standards that
EPA has determined are comparable or more stringent than the EPA rule. The WPR is
essentially the same as OSHA's 1986 Construction Standard; the WPR, however, applies
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solely to asbestos abatement activities, whereas the OSHA standard applies to all
construction activity involving potential asbestos exposures.
The WPR also has specific reporting requirements not included in the OSHA rule; EPA must
be notified prior to undertaking an asbestos abatement project, and notice must be
postmarked or delivered at least 10 days prior to abatement. The notification must also
include a statement that governmental employees are conducting the asbestos abatement
activities.
The 10-day notification is not required for abatement projects involving less than 3 square or
linear feet of friable asbestos nor for emergency projects. For emergency projects, the
employer must notify EPA "as soon as possible but in no case more than 48 hours after the
project begins."
Alternatively, a source subject to the EPA WPR may choose to notify EPA pursuant to the
asbestos NESHAP, as long as such notification clearly states that individuals subject to the
WPR will be perform some or all of the abatement work.
EPA/NIOSH GUIDANCE
In April 1986, NIOSH and EPA published a jointly prepared guidance manual entitled A
Guide to Respiratory Protection for the Asbestos Abatement Industry (EPA 560-OPTS-86-
001). This document was intended to provide practical guidance in the selection and use of
respiratory protection for persons working in the asbestos abatement industry. The guide was
also meant to apply to other types of work activities where exposure or the potential for
exposure to airborne asbestos exists.
The document contains the following information:
a model respiratory protection program;
a checklist for use in developing or evaluating a respiratory protection program;
a section on breathing air systems;
a listing of sources of help for respirator users;.
appendices concerning fit test procedures, general safety considerations, heat stress
considerations, and breathing air systems; and
recommendations concerning the types of respirators appropriate for use in the
abatement industry
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Because the potential harm which can result from even minimal exposure to asbestos fibers
has been well documented, NIOSH and EPA recommend that employers provide workers
with the maximum feasible level of respiratory protection. This can be achieved through use
of either:
a Type C supplied-air respirator with a full facepiece operated in the pressure-demand
mode and with an auxiliary self-contained breathing apparatus (SCBA) operated in
the pressure-demand mode; or
an SCBA with a full facepiece operated in the pressure-demand mode.
SHEMD GUIDELINES
EPA's Safety, Health and Environmental Management Division's (SHEMD's) Health and
Safety Guidelines for EPA Asbestos Inspectors (provided in the supplemental materials
accompanying this manual) are designed to:
provide for the health and safety of asbestos inspectors based on the best currently
available information; and
reduce the likelihood of significant asbestos exposures to the public through enhanced
inspector guidance.
The guidelines, although developed for use by EPA inspection staff, are encouraged to be
used by State and local.inspectors, as well as contractors.
SHEMD will continue to monitor and analyze health and safety issues of concern to EPA
asbestos inspectors and revise these guidelines periodically as additional significant
information from field experience and other sources becomes available.
The following subsections outline the general requirements detailed in the guidance
document. Specific recommendations pertaining to respirator selection, entry and exit
procedures, and protective clothing requirements are addressed in other sections of this
workshop manual.
Health and Safety Plan
A general asbestos inspector health and safety plan must be prepared by each agency/group
involved in conducting asbestos inspections. The plan should, at a minimum, include
information on the following:
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Emergency Procedures - The plan must include procedures to follow in case of: (1) a
medical emergency; (2) accidental release of asbestos; and (3) other emergency
situations.
Personal Protective Equipment - The plan must specify protective equipment
requirements including respiratory equipment and protective clothing available and
the types of inspections during which they should be used.
Operational Practices - The operational practices for each type of inspection likely to
be performed must be specified in the plan.
Evaluation
The senior management official should assure that the health and safety plans are reviewed
and revised as necessary at least annually.
Incident Reporting and Response
The appropriate program manager must coordinate the reporting and response to any
incidents involving injury or illness from asbestos for EPA's asbestos inspectors.
Training
All employees engaged in asbestos-related field inspection activities must receive a minimum
of 24 hours of approved basic occupational health and safety training, must accompany an
experienced asbestos inspector for at least three days of directly supervised field activities,
and must receive eight hours of approved, formal refresher training annually.
All EPA employees required to wear respirators must receive six hours respiratory protection
training, must be fu-tested at least semi-annually, and must receive approved refresher
training annualK All EPA employees requested to enter hazardous waste sites or Superfund
sites must receive the necessary training required under OSHA's regulation 29 CFR Part
1910 120
Medical Monitoring
Employees wru> arc routinely engaged in field activities which are likely to result in exposure
to toxic suhNtan.cN or which require the use of respiratory protection, must be included in the
Agency's Ckvupaiional Medical Monitoring Program. In addition, employees who wear
respiratory protection must be deemed medically fit to wear such equipment.
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Protective Clothing
Protective clothing selection and use are based on the type of inspection being done. The
need for proper disposal of contaminated protective clothing is emphasized.
Respiratory Protective Equipment
Respiratory protection selection information specific to the following activities is provided:
removal, demolition, and renovation inspections;
asbestos manufacturing and fabricating inspections;
bulk sample collection;
waste disposal and storage site inspections;
emergency removal operations at Superfund site inspections; and
abandoned building inspections.
The guidance document mandates the establishment of a written respiratory protection
program in accordance with OSHA 29 CFR Part 1910.134 and other OSHA and EPA
documents.
OSHA 29 CFR Part 1910.134 stipulates that in an acceptable respiratory protection program:
written standard operating procedures governing the selection and use of respirators
must be established;
respirators must be selected on the basis of hazards to which the worker is exposed;
the user must be instructed and trained in the proper use and limitations of respirators;
respirators must be regularly cleaned, disinfected, inspected, repaired, and stored
properly;
appropriate surveillance of work area conditions and degree of employee exposure or
stress must be maintained;
there must be regular inspection and evaluation to determine the continued
effectiveness of the program;
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persons must not be assigned to tasks requiring the use of respirators unless it has
been determined that they are physically able to perform the work and use the
equipment (local physician, medical status reviewed periodically); and
approved or accepted respirators which provide adequate respiratory protection must
be used when available (MSHA).
Specific information regarding selection of respiratory protective equipment will be
discussed elsewhere in this manual.
Other Personal Protection Equipment
The guidance recommends that eye protection be worn in eye hazard areas and that safety
shoes and hard hats be worn where head and foot injuries might occur.
Prohibited Practices
Prohibited practices include smoking, eating, drinking, chewing gum or tobacco, and
applying makeup in asbestos-contaminated areas.
Personal Hygiene
All persons who have been in asbestos-contaminated areas must remove contaminated
clothing and other articles, dispose of waste material properly, and decontaminate
thoroughly.
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SECTION 6
ABATEMENT TECHNIQUES
A NESHAP asbestos inspector should be familiar with the procedures the asbestos abatement
industry implements to comply with Federal and State regulations. This knowledge will
result in a more complete inspection, especially in a pre-removal situation where actual
abatement has not yet begun. By evaluating the set-up and proposed abatement plan, the
inspector can determine if the project may be done in compliance with the asbestos
NESHAP.
Although removal, encapsulation, enclosure and repair are all forms of asbestos abatement,
NESHAP inspectors investigating demolition and renovation sites will most commonly
encounter asbestos removal operations. For this reason, this section describes work area
preparation, removal, and post-removal activities associated with common OSHA Class I and
Class II abatement activities.
IMPORTANT TERMS
Aggressive air sampling - Air sampling which takes place after final cleanup while the air is
being physically agitated with leaf blowers and fans to produce a "worst case" situation.
Amended water - Water to which surfactant (wetting agent) has been added to increase the
ability of the liquid to penetrate ACM.
Asbestos-containing material - Any material containing more than one percent asbestos.
Class I asbestos work - Activities involving the removal of TSI and surfacing ACM and
PACM.
Class II asbestos work - Activities involving the removal of ACM which is not TSI or
surfacing material. This includes, but is not limited to, the removal of asbestos-containing
wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics.
Clean room - An uncontaminated room having facilities for the storage of employees' street
clothing and uncontaminated materials and equipment.
Critical barrier - One or more layers of plastic sealed over all openings into a work area or
any other similarly placed physical barrier sufficient to prevent airborne asbestos in a work
area from migrating to an adjacent area.
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Decontamination area - An enclosed area adjacent and connected to the regulated area
consisting of an equipment room, shower area and clean room.
Equipment room (change room) - A contaminated room located within the decontamination
area that is supplied with impermeable bags or containers for the disposal of contaminated
protective clothing and equipment.
Glovebag - An impervious plastic bag-like enclosure affixed around not more than a 60 x 60
inch asbestos-containing material, with glove-like appendages through which material arid
tools may be handled. Information on glovebag installation, equipment and supplies, and
work practices is contained in OSHA's Construction Standard (29 CFR Part 1926.1101).
High Efficiency Paniculate Air (HEPA) - A filter capable of trapping and retaining at least
99.97% of all mono-dispersed particles of 0.3 micrometers in diameter.
HVAC system - Heating, Ventilation, and Air Conditioning system usually found in large
buildings and industry facilities.
LEV unit - Local Exhaust Ventilation machine designed to mechanically remove air
contaminants from a point of operation.
Mil - Prefix meaning one-thousandth; commonly used to describe thickness of polyethylene
sheeting (6 mil poly = 0.006" thick.)
Polyethylene (poly) - Plastic sheeting often used to seal off an area in which asbestos
removal is taking place; used to prevent contamination of other areas.
Regulated area - An area established by the employer to demarcate areas where Class I, II,
and III asbestos work is conducted, and any adjoining area where debris and waste from such
asbestos work accumulate; and a work area within which airborne concentrations of asbestos
exceed, or there is a reasonable possibility they may exceed, the permissible exposure limit.
REGULATORY REQUIREMENTS
Both OSHA's Construction Standard [29 CFR 1926.1101 (g)] and EPA's Asbestos NESHAP
regulation [40 CFR 61.145(c) and 61.150] specify engineering controls and work practices to
be used during asbestos abatement.
OSHA
OSHA requires the use of the following engineering controls:
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vacuum cleaners equipped with HEPA filters;
wet methods or wetting agents (where feasible);
prompt clean-up and disposal of wastes and debris contaminated with asbestos in
leak-tight containers;
local exhaust ventilation equipped with HEPA filter dust collection systems;
enclosure or isolation of processes;
ventilation of the regulated area to move contaminated air away from the employees
and toward a HEPA-filtration or collection device; and
respiratory protection, where necessary.
EPA
EPA requires the following controls in most circumstances:
adequately wet friable ACM and Category I and Category II nonfriable ACM in poor
condition prior to its removal;
after wetting, seal all asbestos-containing waste material in leak-tight containers or
wrapping while wet;
produce no visible emissions to the outside air during collection, mixing, and wetting
operations;
do not drop, throw, slide, or otherwise damage RACM and use dust-tight chutes or
containers to transport RACM to the ground if it has been removed or stripped more
than 50 feet above ground level and it was not removed as units or sections;
use emission control methods which include: local exhaust ventilation and collection
systems (designed to capture paniculate asbestos); glove bag systems and leak-tight
wrapping.
CLASS I WORK OPERATIONS
OSHA requires a competent person to supervise Class I operations and allows the following
control methods: negative pressure enclosures; glove bag systems; negative pressure glove
bag and box systems; water spray process systems;.small, walk-in enclosures; and
appropriate alternatives. Since asbestos NESHAP enforcement personnel will typically
encounter negative pressure enclosures and glove bag systems, these are described below.
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NEGATIVE PRESSURE ENCLOSURE
The following paragraphs detail typical preparations for establishing a negative pressure
enclosure for a Class I operation involving the removal of more than 25 linear or 10 square
feet of thermal system insulation or surfacing material.
Work Area Preparation
Precleaning of the work area is conducted. HEPA vacuums are used to clean floors, walls
and movable as well as immovable objects. Wet-wiping may also be done. Carpets may be
steam-cleaned or removed entirely. Movable items are taken out of the work area and
stationary objects covered and secured.
Critical barriers are established. Duct tape, expandable foam, caulking, poly, plywood and
sheetrock are commonly used to seal all windows, doors, drains and other penetrations into
the worksite. In the event that other engineering controls fail, these barriers will help prevent
the escape of asbestos fibers from the work area.
Warning signs which meet the requirements of the OSHA asbestos standards must be posted
at each entrance to the work area. These signs inform the reader that breathing asbestos dust
may cause serious bodily harm.
The HVAC system is shut down and isolated by sealing with a double layer of 6 mil plastic
(or the equivalent) to prevent transfer of asbestos dust throughout the building. The control
panel for this system is tagged and locked (to prevent activation of the system) or the breaker
associated with the HVAC system removed entirely. All contaminated air filters are removed
from the system and disposed of as asbestos-containing waste. All vents and air ducts inside
the work area are sealed, typically with plywood, sheet metal, poly and tape.
The electricity supplying the work area is shut off and the control panel locked and tagged.
Contractors typically have an electrician wire in necessary amperage at the worksite. OSHA
requires all electrical equipment in the enclosure to be connected to ground-fault circuit
interrupters
The walls ot the v\ork area are usually covered with two layers of 4- or 6-mil poly.
Strapping naiimc blocks, spray adhesive, staples and tape may be used to attach the poly to
the walls Varru m the two layers are offset and the bottoms of the sheets alternately
overlapped w ith the floor poly which extends up the walls 18-24".
Ceilings nu. he poked when floor tiles are to be removed via mechanical means.
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The floor of the work area is covered with a minimum of two layers of 6-mil poly. Seams are
sealed using spray adhesive and duct tape, and strapping, spray adhesive, double-sided tape
and/or staples may be used to securely fasten the poly at the wall/floor junction.
In certain situations an inspector may encounter a product known as Spray Polyฎ being used
to prepare the walls and floor. This material is applied in equivalent thicknesses to
polyethylene sheeting and serves the same purpose.
Arrows are applied to the prepared walls to indicate the locations of exits.
A decontamination area (decon) is established (Figure 6-1), in most cases contiguous to the
work area. It is designed to allow passage to and from the work area while minimizing
leakage of asbestos-containing dust to the outside. A typical unit consists of a clean room, a
shower room and an equipment (dirty) room separated by airlocks. The airlocks may simply
be two layers of poly hung at the openings to each room of the decon or they may be separate
three-foot chambers alternating with and separated from each of the rooms in the decon by
overlapping poly. The doorways themselves may be of various designs - arches, slits,
inverted T's, etc.
Local exhaust ventilation (LEV) machines are brought in and turned on (Figure 6-1). An
LEV machine contains a fan which draws contaminated air through a series of filters and
exhausts the cleaned air to the outside. The final filter in the series is a High Efficiency
Paniculate Air (HEPA) filter.
LEV units are used to provide the OSHA-required four air exchanges per hour and -0.02
column inches of water pressure differential relative to outside pressure. Such a reduced
pressure environment helps prevent the escape of contaminated air should a breach of
containment occur. The air pressure inside the worksite may be monitored electronically. If
the pressure differential is compromised, an alarm will sound to alert the abatement
personnel
LEVs must be situated to direct air movement away from employees performing asbestos
work within the enclosure. To provide the best movement of air through the workspace,
LEV units should be located as far as possible from the decon and vent to the outside if
possible The number of units needed depends on the volume and configuration of the room.
The ma Junes operate 24 hours a day from the beginning of a job until final air clearance is
obtained
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WINDOWS AND DOORS
COVERED WITH POLYETHYLENE
CLEAN
EXHAUST
DIRTY
ROOM
SHOWER
ROOM
CLEAN ROOM
(LOCKERS)
HEPA FILTERS
AIR FLOW
Figure 6-1. LEV Air Filtration System
Asbestos Removal
Beginning at the decon and proceeding toward the negative air machines, workers spray the
asbestos-containing material so that it can be more easily removed. A wide variety of water-
handling equipment may be used: garden sprayers, hoses and extension wands. Garden
sprayers and hoses are used to soak the ACM prior to its removal and to maintain it in the
wet state until it is properly collected for disposal. Extension wands provide a fine spray of
water precisely where it is needed, thereby reducing the amount of water required
Misters are used to moisten asbestos as it falls during the removal process Pumps are used
to apply amended water to the ACM and may also be used to apply encapsulants or other
materials to the substrate after ACM removal.
Workers use a variety of tools for removing ACM and collecting it for disposal. Removal
tools include long- and short-handled scrapers, joint compound knives, paint scrapers, nylon
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scrub pads, and a large assortment of brushes (ranging from toothbrushes to toilet brushes!).
For cementitious ACM, chisels and hammers and various types of saws may be used. For
hard-to-reach areas, power washers, whose water stream pressure is measured in thousands of
pounds per square inch, may be used to clean asbestos-coated surfaces.
Collection tools include shovels and squeegees which are often made of plastic or rubber to
prevent damage to the polyethylened floor.
ACM is usually loaded into plastic bags which are sealed, washed off in the shower or waste-
handling area, placed into other labeled waste disposal containers (i.e. bags, fiber drums,
metal drums) and removed from the worksite.
On occasion, however, usually on large jobs, two types of heavy-duty vacuum machines may
be employed. Each machine transports wetted ACM to the outside equipment via a vacuum
hose. Workers may use the hose itself to remove the ACM off the substrate or may collect
material in a hopper first.
Depending on the type of vacuum apparatus, the removed ACM may enter the tank of a truck
which will transport it as a slurry to an approved landfill or it may enter a hopper where it is
further wetted and then bagged.
Heavy duty shredders may also be used at the job site. These break up metal lath and other
materials being removed, making it easier to handle and dispose of the waste.
Post-removal Activities
Once all of the ACM has been removed, workers carefully clean all surfaces. A final visual
inspection is made and an encapsulant may be applied to the cleaned surfaces (including the
poly) to lock down any remaining fibers. On occasion, encapsulants of contrasting colors are
applied at right angles to one another to ensure complete lockdown of remaining fibers.
The first layer of poly is then removed.
If the abatement work is being conducted in a school, or if the abatement contract specifies,
aggressive sampling is done at this point. Leaf blowers or fans are used to create a "worst
case" scenario in the cleaned area while large-volume air samples are taken.
PCM or TEM analysis of the air samples is then done. A job is often considered complete
when the average fiber count as determined by PCM is < 0.01 f/ml or when there are no more
than 70 structures/mm as determined by TEM analysis, or when ambient or contract-
specified levels are met.
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Once final air clearance is obtained, the area may be reinsulated, the second sheet of poly and
critical barriers removed, and the area reoccupied.
GLOVE BAG SYSTEMS
Contractors may use the glove-bag technique to remove thermal system insulation (see
Figure 6-2). Glove bags must be seamless on the bottom and made of 6-mil thick plastic.
Linked bags, multi-sleeve bags, and bags which have been designed to permit the removal of
horizontal or vertical runs of pipe insulation are available. Those used on elbows and other
connections must be designed for that purpose and used without modifications. OSHA also
permits the use of a glove bag which has a detachable waste bag.
Glove bags may be used only on surfaces not exceeding 150ฐF, and may be
used only once and not moved.
Figure 6-2. Illustration of a Glovebag.
OSHA requires two persons to perform a glovebag operation. These individuals must seal
adjacent loose and friable material prior to attaching the glove bag.
Necessary tools and other materials are placed in the tool pouch of the glove bag and the bag
sides cut down so that, when applied, the bag completely covers the circumference of pipe or
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other structure. The bag is sealed airtight and is required to be smoke-tested for leaks (and
leaks sealed) prior to use.
The wand of a garden sprayer containing amended water is attached to the bag and the
insulation soaked, removed and dropped into the bottom of the bag. The pipe and upper
section of the bag are wiped clean and the ends of remaining insulation are sealed with
encapsulant, rewettable fiber glass, or other wrapping material. The reusable tools are
grasped in a glove and pulled outward; the sleeve is twisted and taped in two locations and
the glove containing the tools cut off between the two taped sections. The enclosed tools are
then placed into another glove bag for use or are deposited into a bucket of water and later
cleaned. The glove bag is then twisted and loosely taped to isolate the ACM in the bottom of
the bag. The sprayer wand is removed and a HEPA vacuum is required to be attached and
used to remove the remaining air from the bag. The bag is tightly taped, the vacuum hose
removed and the bag cut down from the pipe and deposited into another labeled disposal bag.
Some contractors now establish and maintain a reduced-pressure environment within the
glove bag itself as the insulation is being removed. Two techniques have been devised; in
both, a HEPA vacuum attached to the glove bag is operated continuously during the removal
process. In one method the glove bag is altered to allow air from outside the bag to replace
the extracted air. In the other method the HEPA vacuum is fitted with a special nozzle which
significantly reduces air flow from the bag.
CLASS H WORK OPERATIONS
The OSHA Construction Standard requires certain work practices and engineering controls
for Class II work. All Class II work must be supervised by a competent person and HEPA
vacuums, wet methods or wetting agents, and prompt clean-up and disposal of wastes and
debris in leak-tight containers (except for roofing materials) must be employed.
FLOORING MATERIAL REMOVAL
OSHA Requirements
For all indoor Class II jobs where a negative exposure assessment has not been produced;
where there may be exposure above the PEL; or where the ACM is not removed substantially
intact:
critical barriers must be installed;
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another barrier or isolation method must be used to prevent migration of
airborne asbestos from the regulated area; and
impermeable dropcloths must be placed on surfaces beneath all removal activity.
For removing ACM-containing vinyl and asphalt flooring (or where the absence of ACM in a
building constructed no later than 1980 has not been confirmed), employees must comply
with the following work practices:
flooring or its backing must not be sanded;
vacuums equipped with HEPA filter, disposable dust bag, and metal floor tool (no
brush) must be used to clean floors;
resilient sheeting must be removed by cutting (with wetting of the snip point and
wetting during delamination) - rip-up is prohibited;
all scraping of residual adhesive and/or backing must be performed using wet
methods;
dry sweeping is prohibited;
mechanical chipping is prohibited unless performed in a negative pressure enclosure
which meets regulatory requirements;
tiles must be removed intact, if possible;
wetting may be omitted if tiles are heated and removed intact.
Note: Asbestos linoleum/vinyl-sheet good backing is considered friable under the asbestos
NESHAP.
Flooring Removal Techniques
Water/Amended Water/Solvents
Water, amended water or solvents may be spread onto floor tiles in order to loosen them.
After a period of soaking, the tiles may be removed using long-handled scrapers (ice
chippers) or gas- or electrically-powered mechanical chisels. Remaining mastic may be
removed using solvents or sanders.
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Note: If extensive breakage renders the material friable, RACM is produced and the
provisions of the asbestos NESHAP apply.
Dry Ice
Although rarely used for this purpose nowadays, dry ice (frozen carbon dioxide) can be used
to remove floor tiles. When dry ice is applied to the tiles, the intense cold causes the tiles to
contract and detach from the substrate.
Infrared Machines
Infrared machines may be used in the removal of floor tiles. These machines heat the
flooring, thereby softening the tiles and adhesive, and allow for its easy removal.
Shot-blasters
Shot-blasters are sometimes used in the removal of floor tile mastic. These machines direct a
barrage of small pellets (shot) against the mastic and vacuum up and separate the
mastic/pellet mixture. The pellets are continually reused and the pulverized material is
segregated for disposal.
EPA permits the use of shot blasters only when wet methods are utilized; any other use
constitutes dry removal.
Other Mechanical Methods
Since friable material is created during their use, the provisions of the asbestos NESHAP
apply to the removal of regulated amounts of resilient flooring subjected to:
jackhammers;
rotatmu blade scrapers (buffers with blades);
mcxhamcal sanders;
blade saws.
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ROOF REMOVAL
OSHA Requirements
OSHA requires the following work practices to be followed:
roofing material must be removed in an intact state to the extent feasible;
wet methods must be used to remove roofing materials that are not intact, or that will
be rendered not intact during removal (if feasible, and safety hazards are not created);
cutting machines must be continually misted during use (unless safety hazards are
created);
dust resulting from the use of a power roof cutter must be collected by a HEPA dust
collector, HEPA vacuumed, or gently swept and completely wiped up and
immediately bagged or placed in covered containers.
Roof Removal Techniques
Most of the following information has been extracted from Applicability of the Asbestos
NESHAP to Asbestos Roofing Removal Operations (EPA 340-B-94-001, August 1994).
Shingles are normally used on inclined roofs and may be either asphalt or cement-based.
Because of steep slopes, shingles are typically removed manually by workers using shovels
and/or pry bars. When removing asbestos-cement shingles, workers may first clip off the
heads of the nails, remove the shingles, and then remove the rest of the nails.
With built-up roofs, several methods of cutting the roof membrane are available. The method
chosen depends not only upon the nature of the job, but upon State and local asbestos
regulations as well In most cases power roof cutters are used to cut roof membranes into
manageable sections, but manual methods are sometimes used.
Generally, for built-up roofs, the membrane is separated (e.g., by cutting, slicing, punching or
shearing) into sections approximately 2'x2', or 2'x4' or other sizes that can be managed by
one or two workers, and that will fit into a cart or wheel-barrow and a 2' diameter chute The
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sections are pried up using power roof removers, shovels or tear-off bars. Single-ply
membranes may be sliced into long strips and rolled up.
Wetting is required whenever the method used may create RACM.
Manual Methods
Removal by manual methods usually involves the use of axes, hatchets and utility knives to
chop or slice the roof membrane into sections that can be lifted by one or two workers with
shovels, spud burs, pry bars, etc.
Mechanical Methods
Rotating Blade (RB) Roof Cutter
RB roof cutters are used extensively by roofing contractors to cut roof membranes for
removal. A gasoline-powered engine turns a blade mounted near or toward the front of the
machine. The cutting edge of the blade is blunt with about a 1A" kerf, as opposed to a
tapered, sharp edge. This design allows the cutter to be used on gravel-covered roofs which
would dull sharp blades. The adjustable-depth blade rotates so that the cutting action is from
the underside of the membrane when the cutter is moving forward. RB roof cutters are used
on both smooth- and gravel-surfaced roofs and are manually propelled.
Note: Rotating blade cutters render the asbestos roofing friable. EPA considers a roof 5580
square feet or greater to be a regulated renovation when rotating blade cutters are used.
"Slicer"
A slicer is a self-propelled, two-wheeled tractor equipped with a blade that is used to slice
through smooth roof membranes. Although this equipment is not commercially available,
the slicer can be fabricated by attaching a heavy metal plate which houses an adjustable blade
to the rear of the tractor. As the tractor moves forward, the blade neatly slices through the
roofing material much like a utility knife.
Note: Slicers do not render asbestos roofing material in good condition friable.
"RoofPlow"
A roof plow is similar to a slicer except that it slices the roof membrane from below. As a
result, it is not dulled by roof aggregate and can be used on such roofs The "plow" is
attached to the rear of a self-propelled garden tractor and is pulled along through the
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membrane Because the plow slices the membrane, no dust or debris is created during its use.
Plows are also not available commercially, but can be fabricated using available materials.
Concrete/Asphalt Planer
A planer is a machine used to remove concrete or asphalt from surfaces at controlled depths
and profiles. Some models of planers come equipped with a misting device over the cutter
assembly and can be used with a vacuum system designed for the planer. Both the concrete
planer and vacuum unit are commercially available. The planer, however, has rarely been
used in roof removal projects because the cutters are easily clogged with bituminous
materials, and the short cutting depth necessitates several passes.
Power Remover (Power Tear-off Machine)
A power remover is used as an alternative to manually prying up pieces of sliced roofing
material. A power remover consists of a wide actuating blade that can be mounted onto the
front of a self-propelled tractor. Power removers also come as a one-piece assembly, i.e.,
with the blade and tractor as a single unit.
Note: Power removers do not render asphalt asbestos roofing in good condition friable.
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SECTION 7
OTHER SAFETY CONSIDERATIONS IN ASBESTOS WORK
Because the inspection environment for evaluating compliance with the asbestos NESHAP
regulation is usually a building awaiting demolition or in some stage of renovation, increased
asbestos exposure is only one of the many hazards an inspector may encounter on the job.
This section enumerates the risks associated with worksite conditions and recommends safety
procedures inspectors should follow.
HEAT STRESS
All forms of heat illness are caused either directly or indirectly by the body's attempt to
maintain its normal temperature of 98.6ฐF. Physical activity causes an increase in the body's
metabolic rate, thereby increasing body temperature. The body attempts to dissipate heat via
sweating. The loss of water and electrolytes via perspiration is the main factor responsible
for all forms of heat stress, which include heat cramps, heat exhaustion, and heat stroke.
Heat cramps are painful muscular contractions of the arms, legs, hands,, and trunk. They
typically affect the lower legs first and are always preceded by marked sweating. Treatment
consists of leaving the hot area and replenishing liquids.
Heat exhaustion usually results from dehydration. The individual becomes pale, has cold,
clammy skin and is weak to the point of exhaustion. Other symptoms which may appear
include headache, nausea, vomiting, muscle cramps, diarrhea, and giddiness. The blood
pressure is low and the body temperature may be above or below normal. There is no
increase in the body core temperature. If heat exhaustion occurs, the individual should rest in
a cool area and drink ample fluids.
Heat stroke occurs when the body's sweating mechanism shuts down entirely. The skin
becomes hot and dry and the body temperature quickly rises. The afflicted person must be
cooled down immediately and, if conscious, encouraged to drink cool liquids. Medical help
must be sought, for the condition may progress to delirium, stupor, unconsciousness,
convulsions, deep coma, or even death in 30-50 percent of all cases.
Heat stress can be prevented almost entirely by taking a few simple precautions. Since
dehydration is the main contributing factor to the development of heat stress, adequate fluid
intake is essential. Plain water is the best liquid, but fruit juices (not fruit drinks, which
contain inordinate amounts of sugar and may cause excessive thirst) may also be used. One
should avoid all forms of alcoholic beverages, and tea, coffee, and other caffeinated drinks,
for they are diuretic.
Use of electrolyte replacement drinks is usually not necessary. Since peoples' diets nowadays
supply vast amounts of electrolytic substances, it is highly unlikely that anyone, even with
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profound perspiration, will suffer from a deficiency of them. Additionally, it has been
determined that the use of such fluids actually slows down the absorption of water from the
stomach into the bloodstream, thus retarding rehydration.
Other measures that can be taken to reduce the possibility of developing heat stress include
use of a powered air-purifying respirator or a supplied air respirator (which help cool the face
and lungs), increased local exhaust ventilation, and gradual acclimatization to the hot
environment.
For any inspection lasting more than 15 minutes in an atmosphere of 70ฐF or higher, the
inspector should follow the recommendations found in the NIOSH interagency document
Health and Safety Guidelines for Hazardous Waste Workers.
CLIMBING HAZARDS
In demolition/renovation jobs, a variety of climbing hazards exists. Railings and other
structures may not be properly secured or may have been removed entirely during salvage
operations. Scaffolding and ladders may not be in good condition. In addition, wearing a
respirator may restrict an inspector's vision, thereby creating more need for caution when
climbing.
Scaffolding
Most asbestos renovation projects involve the use of both stationary and mobile scaffolding.
OSHA standards require that when free-standing mobile scaffolding is used, the height must
not exceed four times the minimum base dimension. This requirement is based on the fact
that scaffolding is easily overturned. For mobile scaffolding on which workers can ride, the
minimum base dimension should be one-half the height. OSHA also has established
standards regarding guardrails, kickboards, and planking overhang. (See 29 CFR Part 1910
Subpart D "Walking/Working Surfaces.")
Ladders
One should simply use common sense when using ladders. Be sure stepladders are fully
opened and always face the ladder when using it. Check to see that all the steps are in good
condition and never stand on the top step.
Extension ladders should be examined for missing safety feet and proper (1:4) lean ratio
before use. Such simple precautions can prevent serious injury.
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WORKING SURFACES
Standard preparation of a worksite involves the placement of polyethylene sheeting on the
floor. Amended water, often used to ensure the safe removal of asbestos, makes the floor
very slippery, so great care must be taken by the inspector.
Additionally, the disposable boots worn by the inspector, airlines, electrical cords, bags of
waste, stripped asbestos, and other debris present a tripping hazard to the inspector.
ILLUMINATION
Active removal operations will have the best lighting since workers need to see well in order
to properly clean the asbestos-coated surfaces. High humidity, however, may reduce
visibility in the work area.
Pre-removal or post-removal inspections may need to be done with no on-site electrical
lighting available. In order to see above suspended ceilings or into crawl spaces, etc., an
inspector will need to use a powerful flashlight.
Hazards of poor lighting include risk of head injury from suspended objects such as low
hanging pipes, light fixtures, etc., and other injuries due to tripping or falling over objects.
ELECTRICAL SAFETY
One of the most common hazards, and one that gives the least warning, is electricity.
Incorrect wiring, improper grounding, and lack of proper shielding result in a great number of
electrocution deaths each year. Many of these fatalities result from contact with only 120
volts. The use of wet methods when removing asbestos increases the potential for electrical
shock, especially when a person is working around electrical panels, conduit, light fixtures,
alarm systems, junction boxes, computers, transformers, etc. In a typical removal project, the
power to the worksite is locked out at the junction box and temporary power lines equipped
with ground-fault circuit interrupters wired in.
Where injury may be caused by electrical hazards, protective gear (helmets, insulated gloves,
etc.) should be worn.
The following is a listing of procedures that can reduce the risk of electrical shock:
Have the site foreman escort you and explain how the electrical system has been
ground faulted (as required by OSHA).
Use non-conductive sample collection devices (wood, plastic, rubber).
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Use extreme caution when inspecting around energized wiring or equipment.
Use care not to break through insulated coverings during inspection activities.
Avoid accumulated water if an electrical wire or extension cord is lying in or near it.
Consider electrical equipment and lines to be energized unless tested and determined
firsthand otherwise.
MISCELLANEOUS HAZARDS
Falling Objects
Where there is a possibility of head injury from impact or from falling or flying objects,
inspectors should wear head protection which meets ANSI Z89.1-1969 safety requirements
for industrial head protection.
Structurally Unsound Building
An inspector should determine, prior to entering a building, whether all or part of a building
is structurally sound and safe to enter. Older buildings undergoing renovation may have
stairs or floors in danger of collapse. If floors or stairs seem unsafe, the inspector should
vacate the area immediately, taking care to walk along the outer edge of the floor or stairs
where there is more support.
Chemical Hazards
Some asbestos demolition/renovation activities may be conducted in buildings that have
chemicals stored or in use. An inspector should be aware of items such as PCBs from
transformers, hazardous chemicals from manufacturing operations, and chemical lines in the
work area, and use appropriate protective equipment. Organic vapor respirator cartridges
should be used where spray adhesives are being applied. Ammonia filtration may be
necessary when Spray Polyฎ is being applied or at fertilizer manufacturing plants.
Inspectors visiting abatement worksites where solvents are being used in the removal of floor
tiles should wear knee-high rubber boots to avoid a dermatitis reaction to the chemicals in
use. Although dermatitis may not occur following initial contact with the chemical (liquid or
fumes), subsequent exposure may result in a severe reaction.
Some inspectors develop a sensitivity to the rubber in the respirator facepiece. Such
individuals should wear a silicone respirator instead.
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Individuals who are allergic to latex should avoid wearing latex gloves.
Biological Hazards
An inspector entering abandoned buildings or confined spaces during an inspection should be
aware that rats, stray dogs, poisonous spiders and snakes, bats or other creatures (including
dangerous humans!) may reside there. Harmful insects, animal and bird feces, and mites are
additional hazards inspectors may encounter.
An inspector's equipment should include a first aid kit containing supplies appropriate for
medical emergencies which may arise. Bee-sting or snake-bite kits should be carried where
necessary.
Oxygen Deficiency
Any poorly ventilated area (e.g., a crawl space, attic, or other confined space), areas which
contain chemical, natural gas, or sewer lines, or sites where kerosene heaters or dry ice are in
use may be oxygen-deficient. Supplied-air respirators must be used in such areas.
Inspectors should refer to OSHA's "Permit-Required Confined Spaces for General Industry"
[29 CFR 1910.146 (Subpart J)] published 1/14/93 in the Federal Register (58 FR 4462) for
further details regarding confined-space entry.
Painted Skylights
Inspectors should be aware that individuals have unwittingly stepped on and broken through
skylights that have been painted over to match the roof.
Claustrophobia
An inspector, perhaps wearing a body-enclosing plastic suit and SCBA, may enter a confined
area and become claustrophobic. Subsequent panicky behavior may cause severe injury not
only to the inspector but to other individuals as well. One should discontinue the inspection
if claustrophobia occurs.
Noise
Inspectors should carry hearing protection with them as standard equipment and use it when
necessary.
Machinery Hazards
Inspectors should take adequate safety precautions when visiting sites where power washers,
shredders or high-powered vacuum machines are in use.
Thermal Hazards
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Inspectors may conduct asbestos NESHAP compliance inspections in areas with live steam
lines. Since surface temperatures of these lines may be greater than 600 ฐF and pinhole leaks
may be invisible, inspectors should be exceptionally cautious. Inspectors should also avoid
the use of protective clothing with low melting points (Kleenguardฎ=>300ฐF;
Tyvekฎ=275ฐF) in these areas, for such clothing can adhere to the skin if contact is made
with a heat source.
Inspectors should also be cautious in the vicinity of quartz lights used at abatement sites since
these also generate a great deal of heat.
Fire Hazards
Since many types of electrical equipment, heat sources, flammable chemicals, and
polyethylene are present at most abatement sites, inspectors should know the locations of fire
extinguishers and emergency exits.
Drowning Hazards
Asbestos inspections may need to be done in such places as offshore oil rigs or beneath piers.
Flotation devices should be used wherever a drowning hazard exists.
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SECTION 8
RESPIRATORY PROTECTION
Much of the information in this section can be found in EPA's Health and Safety Guidelines
for EPA Asbestos Inspectors which provides guidance in the selection and use of respiratory
protection, and OSHA's respiratory protection regulation 29 CFR Part 1910.134 which
requires employers to establish a respiratory protection program. Additional information has
been extracted from EPA Order 1440.3 which establishes Agency-wide policy,
responsibilities, and basic requirements regarding respiratory protective devices, and EPA's
Respiratory Protection Program Guideline which provides management personnel with
information necessary to establish and operate a respiratory protection program.
CLASSES OF RESPIRATORS
The two major types of respiratory protection equipment available are air-purifying
respirators (APRs) and supplied-air respirators (SARs). APRs have filters through which air
passes before it is breathed. APRs may be classified as positive- or negative-pressure
respirators depending on whether the user creates the suction to draw air into the mask
(negative-pressure) or a fan propels filtered air to the facepiece (positive-pressure). SARs
deliver air through a hose or airline from a tank or compressor to the user.
Air-Purifying Negative-Pressure Respirators
Single-use, disposable dust mask - Held onto the face by an elastic band or cloth ties.
Disposable masks should never be used in an asbestos-contaminated atmosphere for
they do not seal to the face and therefore cannot provide sufficient protection.
Half-Mask - Fits over the bridge of the nose, along the cheeks, and under the chin.
Two head bands form a four-point suspension to hold the mask in place and maintain
the facepiece seal. During inhalation a slight vacuum (negative pressure) is created
within the facepiece which causes ambient air to be drawn through filter media and
into the facepiece. The expired air exits through an exhalation valve at the bottom of
the facepiece.
Full-Face - Fits over the face across the forehead, along the temples and cheeks, and
under the chin. These devices have a head harness with a 5- or 6-point suspension.
During inhalation a slight vacuum (negative pressure) is created in the facepiece
which causes ambient air to be drawn through the filter media and into the facepiece.
The expired air exits through an exhalation valve at the bottom of the facepiece.
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Advantages
size;
cost ($ 106 - $215 for full-face);
freedom of movement;
ease of decontamination, cleaning and storage;
availability of combination cartridges;
adapter kit may be available to convert mask to a positive pressure
airline
respirator.
Disadvantages
filter use limited to specified contaminants;
filter loading increases breathing resistance;
facepiece fit is critical;
require filter changes;
not suited for atmospheres having less than 19.5 percent oxygen;
physiologically more stressful than supplied-air respirators;
require fit testing;
full facepiece reduces range of vision;
nose cup may have to be purchased as an accessory.
Powered Air-Purifying Respirators (PAPRs)
Powered air-purifying respirators (PAPRs) have battery-powered, motorized filtration units
which blow purified air to the facepiece. Since this creates a slight positive pressure in the
mask, any breach in the facepiece seal should permit only the outward flow of air from the
mask, thereby preventing inhalation of contaminated air.
PAPRs may have tight-fitting facepieces or loose-fitting hoods or helmets. PAPRs with
tight-fitting masks must supply a minimum of 4 cubic feet of air per minute (4 cfm) to the
user, whereas the hood or helmet type must supply 6 cfm.
Some PAPRs are designed so that the motorized filtration unit is worn on the waist.
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Alternatively, the unit may be an integral part of the mask itself.
Advantages
minimize leakage of unfiltered air into the mask;
fit testing is not required by OSHA;
possibly less stressful to use than negative-pressure respirators;
provide greater comfort to wearer.
Disadvantages
not suited for atmospheres having less than 19.5 percent oxygen;
require filter changes;
combination filters may not be available for expected contaminants;
operating time is limited by the battery pack;
tight-fitting facepiece PAPRs have the same protection factor as full facepiece
negative-pressure respirators (according to EPA);
higher cost ($342 - $924) than negative-pressure respirators;
motor may short out if it gets wet (during showering, i.e.);
battery pack may develop "use life" memory shorter than expected operating
time if the battery is not fully used;
due to their loose fit, hood or helmet type PAPRs do not afford the wearer
protection from airborne asbestos fibers if the battery pack fails;
full facepiece reduces range of vision.
Airline (Type C) Supplied-Air Respirators
Airline (Type C) respirators consist of a half-mask, full-facepiece, hood or helmet to which
Grade D breathing air is supplied through a small diameter, high-pressure airline. There are
two modes of operation:
Pressure-Demand Mode - The pressure-demand, supplied-air respirator has a regulator and
valve design that maintains a positive pressure in the facepiece at all times. Should a
reduction of pressure within the mask be sensed, air flow is increased to preserve a positive
pressure.
Continuous-Flow Mode - The continuous-flow, supplied-air respirator maintains a constant
airflow and therefore, in most cases, a positive pressure within the facepiece at all times.
Instead of a regulator, it uses a control valve or orifice to adjust air flow.
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Each of the two types of supplied-air respirators has its advantages and disadvantages:
Advantages
lightweight;
breathing air supply is not limited to that which the user can car
ry;
provides a high level of protection.
Disadvantages
hose or airline restricts wearer's movement and may become
damaged;
offers no protection if air supply fails;
expensive system to establish;
compressor which supplies the air must be located in an uncontaminated
(asbestos-free) environment;
compressor which supplies the air should not be located in areas where there
may be elevated levels of CO, gas fumes, or other potentially toxic
substances;
full facepiece reduces range of vision;
system cannot easily be transported;
high cost ($854-$1417)
Airline Respirator with Self-Contained Auxiliary Air Supply
This respirator combines an airline respirator with an auxiliary air supply (SCBA) to provide
the user with respirable air if the main air supply fails.
Advantages
may be used in IDLH (Immediately Dangerous to Life and Health)
atmospheres;
as previously stated for other SARs.
Disadvantages
auxiliary air supply time is limited (for escape purposes only);
additional equipment carried increases wearer stress;
requires additional training;
hose or airline restricts wearer's movement and may become damaged;
expensive system ($2117 - $2430);
compressor requirements as previously stated for Type C SARs;
full facepiece reduces field of vision.
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Supplied-Air (Type C) Respirator with HEPA Filter
This respirator system consists of a full-facepiece airline respirator with a backup HEPA
filter. It allows the user to disconnect from the air supply system in an emergency and
proceed through standard decontamination procedures while breathing through the HEPA
cartridges.
Advantages
greater mobility during decontamination;
affords the wearer protection if the air supply fails.
Disadvantages
facepiece requires fit testing since respirator reverts to a negative-pressure
mode when utilizing HEPA cartridges;
restriction of wearer's movement due to the airline;
not suitable for IDLH atmospheres;
possibility of damage to the hose or airline;
full facepiece reduces range of vision;
cost ($1423).
Self-Contained Breathing Apparatus (SCBA)
The self-contained breathing apparatus consists of a full facepiece, regulator, and a respirable
compressed air supply.. The SCBA allows the user to carry the air supply, thus eliminating
the need for a stationary air supply. The SCBA must operate in the pressure-demand mode to
be used in asbestos atmospheres.
Advantages
wearer carries own air supply;
highest protection factor;
pressure-demand type respirator is approved for IDLH conditions.
Disadvantages
use time limited by air supply (30 - 60 minutes);
devices are bulky and heavy;
requires more extensive training than for other respiratory devices;
decontamination may be difficult;
refilling tanks may pose problems;
very expensive ($1055 - $3338 for 30-min system.)
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RESPIRATORY PROTECTION
The overall protection afforded by a given respirator may be stated in terms of its protection
factor and fit factor. Each of these is defined as the ratio of the concentration of a
contaminant in the ambient atmosphere to that inside the respirator facepiece under use
conditions.
Protection factors are values assigned to an entire class of respirators (e.g., half-face, full-
face, etc.); they provide an average value which takes into account the variety of makes and
models, and the different facial structures of the user population. Half-face, negative-
pressure, air-purifying respirators have the lowest protection factor of all classes of
respirators, whereas self-contained breathing apparatus (SCBA) systems have the highest.
Fit factors, on the other hand, are values specific to a given respirator model and to the
individual being tested. It is highly possible, therefore, that a fit factor can be determined
that is less than or greater than the protection factor assigned to that class of respirator. It
should be noted, however, that at no time can the assigned protection factor be exceeded,
regardless of the fit factor obtained. Also, if the obtained fit factor turns out to be less than
the assigned protection factor, the fit factor must be used to determine the maximum fiber
concentration in which the respirator may be worn.
Protection Factors
Protection factors are determined using a procedure known as a quantitative fit test. During
quantitative fit testing, an individual wearing a mask fitted with a probe is placed within an
enclosure containing a challenge atmosphere. While the test subject performs a series of
activities, air samples are drawn from within the facepiece and test chamber and analyzed for
their relative concentrations of challenge material. The ratio between the amount inside the
enclosure and the amount inside the mask is the protection factor.
The results of such fit testing conducted at the Los Alamos Scientific Laboratory on a great
number of human subjects wearing various types of respirators were used to establish
universal!) -accepted protection factors for all classes of respirators (See Table 8-1.).
Protection factors nu\ be used to select appropriate respiratory protection when the ambient
concentration ot a contaminant and its PEL are known. For example, a respirator given a
protection ta>.tปr oj >o may be used in atmospheres not exceeding levels 50 times the PEL.
However. according to OSHA, the protection factor assigned to any of the negative-pressure
respirators nu\ oni\ he applied if the respirator has been quantitatively fit tested on the
individual. It ซnl\ qualitative fit testing (a less exacting procedure) has been done, the
wearer can assume a protection factor of only 10.
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Table 8-1. Respirator Protection Factors
Respirator Type
Protection Factor
(PF)
APR, half-mask, HEPA
APR, full-face, HEPA
PAPR, HEPA
OSHA
NIOSH - hood, helmet
NIOSH - tight-fitting
SAR, continuous flow
SAR, full-face, pressure-demand
SAR, full-face, pressure-demand
with auxiliary SCBA, or SCBA
10
50
100
25
50
100
1,000
> 1,000
The higher the protection factor, the higher the maximum use concentration. Thus, the
OSHA standard defines a range of protection factors from 10 for a half-mask air-purifying
respirator to > 1,000 for a supplied-air respirator equipped with auxiliary SCBA, or for an
SCBA. It should be noted that the protection factor of 100 for a PAPR, as allowed by
OSHA, has been reduced in a NIOSH Respirator Certification proposal (52 FR 32402,
August 27, 1987). The proposed regulation allows a protection factor of 50 for a tight-fitting,
full-facepiece PAPR and a protection factor of 25 for a loose-fitting hood or helmet PAPR.
Fit Factors
Fit factors, like protection factors, are determined by conducting a quantitative fit test on an
individual wearing a specific make or model of a respirator. As with protection factors, a fit
factor is defined as the ratio of challenge agent concentration outside the facepiece with
respect to the challenge agent concentration inside the respirator facepiece.
As mentioned earlier, fit factors are specific to an individual and model of respirator. As
such, fit factors may be greater or less than the assigned protection factor designated in the
OSHA regulation. A fit factor can, therefore, be viewed as a check on assigned protection
factors for that person and respirator model. It is important to recognize that if the fit factor
for a specific respirator is found to be lower than the assigned protection factor, the
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calculated fit factor must be used to determine the maximum fiber concentration in which the
respirator may be worn. If the fit factor for a specific respirator is found to be greater than
the assigned protection factor, the protection factor must be used to determine the maximum
fiber concentration in which the respirator may be worn.
RESPIRATOR FIT TESTING
OSHA regulations require that either qualitative or quantitative respirator fit testing be
conducted to ensure that a negative-pressure, air-purifying respirator seals properly to the
worker's face. If a fit test is not successful with one brand or size of respirator, other brands
or sizes should be tested until a proper fit is achieved. Employers must provide fit tests at the
time of initial fitting and at least every 6 months thereafter.
Qualitative Fit Testing
In qualitative fit testing a subject's sensitivity to a certain smell, taste or irritation from a
"challenge" atmosphere helps determine the respirator fit. There are currently three
recognized test protocols: (1) isoamyl acetate vapor (banana oil/IAA); (2) saccharin solution
aerosol; and (3) irritant smoke (or stannic chloride). The banana oil test is based on
individual sensitivity to smell; the saccharin solution aerosol to taste; and the irritant smoke
to taste, smell and sensory irritation. Organic vapor cartridges are used in the respirator
during the banana oil test, while particulate and HEP A/acid gas filters are worn during the
saccharin and smoke test protocols, respectively. Screening must be performed before the
qualitative fit test to ascertain whether the subject can sense the challenge agent.
Prior to having a qualitative fit test performed, the test subject must select the most
comfortable respirator from a group of respirators of various sizes from different
manufacturers. The respirator chosen must be worn at least 5 minutes to allow the individual
adequate time to evaluate the positioning of the mask on the nose, mouth and chin, and to
assess strap tension and slippage and determine overall comfort.
After this five-minute period, the subject "seats" the mask by rapidly moving the head from
side to side and up and down, while taking a few deep breaths, and then performs a negative
and positive "fit-check".
A negative-pressure "fit check" involves blocking the respirator inlets while inhaling. If air
leaks into the facepiece, the mask should be repositioned and/or straps tightened, and the
negative-pressure fit check repeated. If no leakage is noted, a positive-pressure test should be
performed. The positive-pressure "fit check" involves blocking the exhalation valve and
breathing out slightly to determine whether air can leak out of the mask through the facepiece
seal.
The respirator must be worn for at least 10 minutes prior to fit testing in the challenge
atmosphere.
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Qualitative Fit Test Procedure
The subject enters the test chamber located in a room separate from the screening
room where the "fit checks" and odor screening were performed;
The subject is given a piece of paper towel or other porous absorbent, single-ply
material wetted with pure IAA and instructed to hang it on a hook at the top of the
chamber. Alternatively, a nebulizer is used to introduce saccharin aerosol into the test
chamber, or a ventilation tube containing stannic chloride or equivalent is used to
introduce irritant smoke.
After the IAA, saccharin or smoke is introduced, the subject performs each of the
following test exercises (as delineated in 29 CFR Part 1926.1 101, Appendix C) for at
least one minute:
1 . Breathe normally.
2. Breathe deeply. Be certain breaths are deep and regular.
3. Turn head all the way from one side to the other. Inhale on each side. Be
certain movement is complete. Do not bump the respirator against the
shoulders.
4. Nod head up and down. Inhale when head is in the full up position (looking
toward ceiling). Be certain motions are complete and made about every
second. Do not bump the respirator on the chest.
5. Talk aloud and slowly for several minutes. Reciting the Rainbow Passage will
result in a wide range of facial movements and be useful in satisfying this
requirement.
RAINBOW PASSAGE
When the sunlight strikes raindrops in the air, they act like a prism and
form a rainbow. The rainbow is a division of white light into many
beautiful colors. These take the shape of a long round arch, with its
path high above, and its two ends apparently beyond the horizon.
There is, according to legend, a boiling pot of gold at one end. People
look, but no one ever finds it. When a man looks for something
beyond reach, his friends say he is looking for the pot of gold at the
end of the rainbow.
6. Jog in place.
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7. Breathe normally.
If at any time during the test the subject detects the banana-like odor, tastes the
saccharin aerosol, or detects the irritant smoke, a different mask (manufacturer, size,
material) should be tested until the individual passes the test.
The qualitative fit test procedure is essentially a pass/fail test that does not produce an
absolute fit factor. It is assumed that a user who passes the test wearing a half-face respirator
has achieved a protection factor of at least 10.
Quantitative Fit Testing
Quantitative fit testing is also conducted using a challenge atmosphere, but a probe is
attached to the respirator to allow sampling of the air inside the facepiece. The air inside and
outside the facepiece is measured using an electronic instrument that quantifies the test agent.
The ratio of the two values provides a "quantitative" determination (fit factor) regarding
respirator fit.
Quantitative Fit Test Procedure
Quantitative fit testing may be conducted using a special enclosure or an electronic device
such as a Portacountฎ which does not require use of a chamber. A typical quantitative fit
test involving a chamber is described below:
Select a respirator for comfort and proper "fit" as discussed under qualitative fit
testing and learn what procedures will be required during the test.
Adjust selected respirator and conduct a negative- and positive-pressure test. Wear
respirator at least 5 minutes to seat the facepiece.
Conduct a qualitative fit test as previously described. (The test subject may undergo a
quantitative test only after passing a qualitative fit test).
Once a stable challenge agent concentration in the test chamber is established, enter
chamber.
Connect the facepiece probe and wait while the peak penetration of the challenge
agent concentration inside the mask is measured. (It must not exceed 5 percent for a
half mask or 1 percent for a full facepiece.)
Be sure the challenge agent concentration inside the test chamber has stabilized.
Perform the following nine exercises as the concentration of the challenge agent
inside the facepiece is measured:
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Breathe normally, without talking, for 1 minute.
Breathe deeply for 1 minute, taking care not to hyperventilate.
Slowly turn head from side to side between the extreme positions for each
side. Perform at least three complete cycles, holding the head at each extreme
position for at least 5 seconds.
Slowly move head up and down between the extreme positions of straight up
and straight down. Hold the head at each extreme position for at least 5
seconds and perform at least three complete cycles.
Recite the Rainbow Passage slowly and loudly.
Grimace, frown, smile and generally contort the face for at least 15 seconds.
Bend at the waist and touch toes. Return to upright position. Repeat for at
least 30 seconds.
Jog in place for at least 30 seconds.
Breathe normally, as before, for one minute.
Fit Factor Determination
As the test subject performs the exercises, a strip chart recorder transcribes a trace indicating
percent penetration of the challenge agent for each exercise. When the average peak
penetrations for all the exercises are averaged, the quantitative "fit factor" is established.
Note: Qualitative or quantitative fit tests must be repeated whenever an individual has a
weight change of 20 pounds or more, significant facial scarring in the area of the
facepiece seal, significant dental changes, reconstructive or cosmetic surgery, or any
other condition that may interfere with facepiece sealing.
SELECTION OF RESPIRATORS
The following information can be found in EPA's Health and Safety Guidelines for EPA
Asbestos Inspectors. This document addresses the use of known or expected fiber
concentrations and the type of inspection activity as the principal criteria for determining
respirator usage. The entire guidelines document (which can be found in the supplemental
materials accompanying this manual) should be reviewed by anyone conducting asbestos
inspections.
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General Requirements
All EPA employees required to wear respirators must receive 6 hours of respiratory
protection training, be fit-tested at least semi-annually, and receive approved refresher
training annually.
In general, inspectors should not wear respirators unless they have been deemed "medically
fit" to wear such protection. The determination of whether the individual is medically fit is
made by a physician relying on information obtained through a medical and work history
questionnaire, a physical examination including a chest x-ray, pulmonary function tests and
other tests or information deemed necessary.
Inspectors should use only agency-owned respiratory protection equipment that they have
been specifically trained and fit-tested to use. Inspectors should never use equipment offered
by the abatement contractor. Supplied-air respirators other than SCBAs probably will not be
worn by inspectors since it is doubtful that their agencies will provide the equipment
necessary for this type of system.
Respiratory Protection Equipment
Ideally, respirators should be selected according to the actual or potential airborne asbestos
concentrations present at the site (See Table 8-2.). When an anticipated exposure level
cannot be determined, an unknown exposure condition exists. Such a situation requires the
use of atmosphere-supplying respirators such as a self-contained breathing apparatus
(SCBA). Of currently available respiratory protective equipment, the SCBA offers the
maximum level of respiratory protection. The buddy system is required in situations where
the SCBA user is in an atmosphere that is either oxygen-deficient or highly toxic and would
be life-threatening in case of respirator failure. All activities covered by these guidelines
which would not result in a life-threatening or permanent injury situation would not require
using the buddy system.
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Table 8-2. Respiratory Protection Requirements
Respirator Type
APR, half-mask, HEPA
APR, full-face, HEPA
PAPR, HEPA
OSHA
NIOSH - hood, helmet
NIOSH - tight-fitting
SAR, continuous flow
SAR, full-face, pressure-demand
SAR, full-face, pressure-demand
with auxiliary SCBA, or SCBA
Protection Factor
10
50
100
25
50
100
1,000
> 1,000
Maximum Fiber
Concentration (f/cc)
(PF x PEL)
1
10
2.5
5
10
100
MOO
Fortunately, much is known about the exposure conditions encountered at various worksites.
In 1989. PCM analytical data for over 4,000 air monitoring samples taken during renovation
activities at schools, residential buildings, hospitals, offices and industrial buildings were
reviewed in a study conducted for EPA. The study concluded that when the OSHA asbestos
standards tor renovations were followed, no concentrations in excess of 0.82 f/cc were found
in the rcmo\ al areas during active abatement 95 percent of the time.
The OS! I \ permissible exposure limit (PEL) for asbestos is 0.1 f/cc and the NIOSH-
recommen Jed exposure limit is 0.1 f/cc. The EPA, on the other hand, recommends that
inspectors exposures to asbestos be limited to below 0.01 f/cc as an 8-hour time-weighted
average i I Vs \ i Respirator selection criteria found in the Health and Safety Guidelines... are
based on this I \V/\.
If asbestos inspectors can make a determination of a project's OSHA compliance prior to
entering containment, and plan to spend no more than two hours inside containment, they can
choose to use the lowest acceptable level of respiratory protection: a NIOSH-approved,full-
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facepiece respirator with HEP A filtration, or any approved tight-fitting (Le. having a tight
face-to-facepiece seal) powered air-purifying respirator (PAPR) with HEP A filtration.
This conclusion is based on the following assumptions:
Exposures in renovation sites in compliance with OSHA rarely approach 2.0 f/cc.
Full-facepiece, air-purifying respirators (and tight-fitting PAPRs) provide a protection
factor of 50x.
Inspectors will not be in the asbestos enclosure envelope for more than two hours per
day.
A 50x protection at a concentration of 2.0 f/cc for two hours would result in an 8-hour TWA
exposure of 0.01 f/cc TWA. Actually, most exposures would be far less than 0.01 f/cc, for
most individuals attain greater than a 50x protection factor from full-face respirators and
PAPRs, and often will not be in the envelope for two hours.
Air-purifying respirators include powered air-purifying respirators (PAPRs). These
guidelines assume that PAPRs do not provide greater protection than do other air-purifying
respirators due to the possibility that overbreathing (i.e., inhaling at a rate that is greater than
the air supplied to the facepiece, resulting in a negative pressure in the facepiece) can occur.
This guideline is consistent with the NIOSH Respirator Decision Logic of 1987 with respect
to the protection offered by PAPRs. Additional PAPR studies are being planned by NIOSH;
if PAPRs are shown to have higher protection factors in the future, appropriate changes will
be made regarding selection of respiratory protection.
OSHA Asbestos Standard Compliance
An abatement project's compliance with the OSHA asbestos standards can be gauged by
findings that:
1. Records indicate that all employees have been trained as required. Individuals
(workers, contractors/supervisors) who perform the following activities with respect
to friable ACBM in a school or public and commercial building must be accredited:
(1) a response action other than a small-scale, short-duration (SSSD) activity, (2) a
maintenance activity that disturbs friable ACBM other than an SSSD activity, or (3) a
response action for a major fiber release episode. Such individuals must have their
initial and current accreditation certificates at the location where they are conducting
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work [40 CFR Part 763, Subpart E, Appendix C - Asbestos Model Accreditation Plan
(MAP)}.
Individuals performing abatement work in facilities other than schools, public, or
commercial buildings need not be accredited under the MAP; they may, however, be
subject to State and/or local training requirements.
2. Records, either on- or off-site, show that project employees have been given medical
exams, including a determination that they are fit to wear respirators.
3. Amended water is being used to wet the ACM. (Check to see that amended water is
on-site outside the envelope.).
4. No power tools are being used to remove ACM.
5. The envelope is secure and no dust or debris appears to be coming from the removal
area.
6. Warning signs are posted and adequately labeled containers are being used.
7. Employees are carefully removing ACM and are not dropping materials on the floor.
8. Decontamination accommodations, including shower facilities, are in place.
9. Existing monitoring data indicate that asbestos fibers in the work area do not exceed
. 2.0 f/cc as an 8-hour TWA.
10. There is a written respiratory protection program and respirators are being used.
11. A removal plan has been (or can be) made available for review.
The asbestos NESHAP inspector must exercise proper judgment in determining that
air-purifying respirators will provide adequate protection. The capability to make such
determinations must be obtained through both classroom and on-the-job training.
Removal, Demolition or Renovation Inspections
EPA inspectors entering a removal area should select the appropriate respiratory protection
according to the following locations and conditions.
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No Respiratory Protection Required
No respiratory protection is required outside of the asbestos area enclosing envelope when:
inspecting office areas and other locations outside the barrier. All barrier seals must
be intact, and all envelope entrances must have at least a double barrier. No visible
airborne dust or debris that is potentially asbestos-contaminated should be present on
any surface in the area;
secondary containment is in place during glove-bagging operations. The secondary
containment enclosure must be complete, and, for all but small-scale, short-duration
operations, must also be under negative pressure;
materials removed from the envelope have been cleaned and the pathway for removal
of bags and equipment is clear and clean;
all ventilation systems in the envelope are off and sealed (excluding negative-pressure
systems designed for the removal project); and
wet methods are being used.
No respiratory protection is required inside the envelope when:
inspecting any restricted area that has already passed an appropriate clearance test
(minimum of aggressive sampling demonstrating a concentration below O.Olf/cc by
PCM); or
no removal work has begun and all ACM is intact, not disturbed, not damaged, and
no debris is present.
Respiratory Protection Required
Respiratory protection will be required in many situations encountered by inspection
personnel, both inside and outside the active removal area. For example, respiratory
protection and personal protective equipment are required for inspections conducted outside
the work area if the conditions listed in "No Respiratory Protection Required" have not
been met. In addition, respirators and personal protective equipment are required whenever
an inspector enters a work area that has not been cleared for reoccupancy. To determine the
type of respiratory protection required, an inspector must rely on available information and
observations of the conditions at the work site. As a minimum, an inspector must use either a
full-face, air-purifying, negative-pressure respirator with HEPA filters or a powered air-
purifying respirator (PAPR) with HEPA filters. An inspector can upgrade respirator
selections at any time.
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To determine the type of respirator to use, a number of conditions must be met. These
conditions can be identified through a records review, pre-entry observations and
interviewing site personnel. If adequate information is not available to document all of these
conditions, an inspector must use his/her judgment to determine the level of respiratory
protection to wear. If upon entering the work area enclosure the inspector determines that the
conditions have not been met, he/she should immediately leave the work area and upgrade
the level of respiratory protection.
Air-purifying Respirators
Full facepiece air-purifying respirators or tight-fitting PAPRs shall be worn by inspectors
when:
inspecting outside the barrier, and workers outside the barrier are wearing
air-purifying respirators;
inspecting outside the barrier where the barrier is not complete and/or asbestos-
containing debris is present;
inspecting inside the envelope when an inspection of the operation shows it to be in
compliance with the OSHA asbestos standard. If, upon entering the envelope, visible
emissions are seen or other evidence suggesting non- compliance is apparent, the
inspector will immediately leave the area. Prior to returning to the removal area to
document the violations, the inspector shall don SCBA gear;
inspecting inside the barrier and no active removal or disturbances have occurred in
past 24 hours and the inspection will not disturb any ACM.
A tmosphere-supplying Respirators
Atmosphere-supplying respirators are required when:
performance of the asbestos abatement project is not in accordance with OSHA
standards;
materials are being removed which are not being properly wetted, or removal causes
the generation of significant levels of dust;
monitoring data at the site show levels in excess of 2.0 f/cc, or the EPA inspection
may last for more than 2 hours;
others at the site are wearing atmosphere-supplying respirators.
Collecting Bulk Samples
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Inspectors collecting bulk samples should wear full-face, air-purifying respirators with HEPA
filter cartridges (This includes NIOSH-approved, tight-fitting PAPRs equipped with HEPA
filters.).
Inspecting Asbestos Waste Disposal and Storage Sites
Inspectors should select respiratory protection according the following criteria:
No Respiratory Protection Required
All disposal trenches have been covered for a minimum of 24 hours and no ACM is
visible at the disposal site.
Respiratory Protection Required
Full-face APRs or tight-fitting PAPRs should be worn when:
airborne dust is not visible AND
trenches are being dug at the disposal site; OR
asbestos materials are on the ground or floor of the site, or damaged bags or drums
are present; OR
a storage site is being inspected.
Atmosphere-supplying respirators (SCBAs or SARs) should be worn when:
others at the site are wearing atmosphere-supplying respirators; or
airborne dust is visible.
Inspecting an Abandoned Building
Inspectors should select respiratory protection according to the following conditions:
No Respiratory Protection
no suspect materials are present;
intact suspect materials are present but no debris from those materials is observed.
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Respiratory Protection Required
Full-face APRs or tight-fitting PAPRs should be worn when:
suspect materials are visible on the floor or surfaces;
collecting bulk samples.
MEDICAL/PHYSICAL CONSIDERATIONS IN RESPIRATOR USAGE
Medical Fitness
Wearing a respirator imposes a physical stress on the user. Air-purifying respirators require
some effort during inhalation and exhalation to overcome the resistance of the filter media
and valve seals. The physical weight of an SCBA may create a problem especially if
extended work time and strenuous work are required. Airline respirators impose some
physical stress due to the weight of the attached airline hose. OSHA regulations state that a
person shall not be required to wear respiratory protective devices unless it has been
determined that he/she is physically capable of doing so. A physician knowledgeable in the
field of occupational health should assess one's pulmonary and cardiovascular status relative
to respirator usage.
Pulmonary considerations: the wearer should be examined for any respiratory
impairment from disorders such as emphysema, obstructive lung disease, bronchial
asthma, etc. Pulmonary function tests, chest x-rays, and completion of a medical and
work history questionnaire provide useful information.
Cardiovascular: the wearer's medical history and current cardiovascular status should
be determined. A stress test may be required for certain individuals.
Miscellaneous Considerations
Respirator, protective devices must not be worn when any condition prevents a good
seal
1 acial hair lying between the sealing surface of a respirator facepiece and the
wearer's skin prevents a good seal. Stubble, a moustache, sideburns, or a
beard that extends outward between the face and the sealing surface of the
respirator will prevent a proper fit.
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Spectacle temple bars or straps that pass between the sealing surface of a full
facepiece and the wearer's face prevent a good seal. Special corrective lenses
that can be mounted inside the full facepiece are available and should be used
by employees who need them.
Scars, hollow temples, high cheekbones, deep skin creases, and the lack of
teeth or dentures may cause respirator sealing problems. Full dentures should
be worn when wearing a respirator, but partial dentures may or may not have
to be removed.
Employees with perforated eardrums may not wear respirators.
Contact lenses must not be worn by a person wearing a respirator because the lenses
may fall out or concentrate contaminants under them and cause eye damage.
An inspector may be deemed medically fit to wear a respirator yet feel claustrophobic
in one. The individual should therefore be considered "psychologically" unfit. Prior
to using personal protective clothing and a respirator during an actual inspection,
inspectors are advised to conduct a "test run".
Respirator cartridges must be stored properly to ensure they will afford appropriate
protection (e.g., HEPA cartridges - dry; organic vapor cartridges - airtight).
Avoid purchasing respirators which are difficult to decontaminate (e.g., those with
Velcroฎ closures or mesh head harness).
ROUTINE INSPECTION AND MAINTENANCE
Any organization using respirators on a routine basis must institute a written respirator
inspection maintenance and cleaning program. The purpose of this program is to assure that
all respirators are maintained at their original level of effectiveness. Most, if not all,
equipment manufacturers supply literature which lists the care and cleaning of their
respirator's components, including information on servicing. Replacement parts for
respirators must be those of the same manufacturer of the equipment. Substitution of pans
from a different brand or type of respirator, or unauthorized modification could decrease or
cause a total loss of worker protection. Also, such substitution of parts or modification will
invalidate the approval of the respirator, leading to violation of applicable regulations.
An important part of a respirator maintenance program is the continual inspection of the
devices. If properly performed, inspections will identify damaged or malfunctioning
respirators before they can be used. Respirator cleaning presents a good opportunity to
examine each respirator thoroughly. Respirators should be checked again after cleaning and
reassembly operations have been accomplished.
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All respirators must be inspected routinely before and after each use. Inspectors must check
the tightness of connections and the condition of the facepiece, headbands, valves,
connecting tube, and canisters. Rubber or elastomer parts must be inspected for pliability and
signs of deterioration. Stretching and manipulating rubber or elastomer parts with a
massaging action will keep them pliable and flexible, and prevent them from taking a set
during storage.
Routine Inspection Requirements
Whether used on a regular basis or not, all respirators should undergo routine inspection and
maintenance at least once a month to ensure that all essential parts are in place and
functioning properly. The following provides the minimum requirements for such inspection
of stored respirators and is not meant to eliminate the need for equipment checkout
immediately prior to use. Since different respirator manufacturers employ various designs,
their instructions or guidance should be followed when checking and maintaining respirators.
Air-Purifying Respirators
For air-purifying respirators, thoroughly check all connections for gaskets and "O"
rings and for proper tightness. Check the condition of the facepiece and all its parts
(connecting air tube, headbands, etc.). Inspect rubber or elastomer parts for pliability
and signs of deterioration.
Maintain a record for each respirator inspection, including date, inspector, and any
unusual conditions or findings.
Supplied-Air Respirators
Inspect self-contained breathing apparatus monthly. Make sure air and oxygen
cylinders are fully charged according to the manufacturer's instructions. Determine
whether the regulator and warning devices function properly.
Keep a record of inspection dates and findings for respirators maintained for
emergency use.
Maintenance of SCBA equipment is more difficult than supplied-air or air-purifying
respirators, primarily because of the complexity of the valve and regulator assembly.
Because of this, all repairs or adjustments must be done by the manufacturer, by an
authorized repair facility, or by a worker who has been trained and certified by the
manufacturer. Refer to the manufacturer's instructions for details concerning a specific
SCBA model.
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Cleaning and Disinfecting
Respirators should be cleaned after each use in accordance with the manufacturer's
instructions. This cleaning is usually done by the wearer if respirators are individually
assigned. If such is not the case, it is best to have one person responsible for daily cleaning
and inspection of respirators.
OSHA regulations specify that a respirator must be cleaned and disinfected as frequently as
necessary to insure that the wearer is provided proper protection. In asbestos abatement
operations, it is recommended that respirators be rinsed after each inspection and thoroughly
cleaned and inspected at the end of each day's use. Each wearer should be briefed on the
cleaning procedure and be assured that a clean and disinfected respirator will always be
issued. This is of greatest significance when respirators are not individually assigned.
The following general instructions may be helpful in cleaning and disinfecting the respirator.
Remove all cartridges, canister, filters and gaskets or seals not affixed to their seats.
Remove headband assembly, straps, exhalation valve cover and cartridge holders.
Remove speaking diaphragm or speaking diaphragm/exhalation valve assembly.
Remove inhalation and exhalation valves.
Wash components separately from the facemask.
Wash facepiece and breathing tube in cleaner/sanitizer powder mixed with warm
water, preferably at 120ฐ to HOT. Most respirator manufacturers market their own
cleaners/sanitizers which are dry mixtures of a bactericidal agent and a mild
detergent. One-ounce packets for individual use and bulk packages for quantity use
are usually available. Remove heavy soil from surfaces with a hand brush.
Remove all parts from the wash water and rinse twice in clean warm water.
Air dry parts in a designated clean area.
Wipe facepieces, valves, and seats with a damp, lint-free cloth to remove any
remaining soap or other foreign materials. Reassemble respirator.
Storage
Follow the manufacturer's storage instructions. Instructions are always furnished with new
respirators or affixed to the lid of the carrying case. In addition, these general instructions
may be helpful:
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After inspection, cleaning, and necessary repair, store respirators where they will be
protected from dust, sunlight, heat, extreme cold, excessive moisture, or damaging
chemicals. Note: Respirators should be thoroughly dried before being sealed in any
container for storage.
Store respirators in a convenient, clean, and sanitary location. The purpose of good
respirator storage is to ensure that the respirator will function properly when used.
Do not store respirators in clothes lockers, bench drawers, or tool boxes. Place them
in wall compartments at work stations or in a work area designated for emergency
equipment. Store them in the original carton or carrying case.
Pack or store respirators so that the facepiece and exhalation valves will rest in the
normal position. Respirators should not be hung by their straps since this may stretch
the straps and distort the facepiece.
FIELD INSPECTION AND CHECKOUT PROCEDURES
Immediately prior to use, a respirator must be thoroughly inspected by the individual who
will be using it. As a minimum, OSHA standards require that the respirators be inspected for
the following:
tightness of all connections;
integrity of the facepiece, valves, connecting tube, and canisters; and
proper functioning of the regulator and warning devices on an SCBA.
Specific to each respirator type, the following should be performed each time the respirator is
used.
Air Purifying Respirator
Examine the facepiece for scratches, cracks, tears, holes, distortion, excessive or
residual lint, dirt, etc.
Examine facepiece seal to ensure that it is flexible and that there are no cracks or
tears.
Examine filter cartridge holders for cracks, badly worn threads or missing gaskets.
Check head straps and harness for breaks, loss of elasticity, broken or malfunctioning
buckles, or excessively worn serrations.
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Determine the existence of inhalation and exhalation valves and examine them for
wear, foreign particles, cracks, tears, improper seating or installation, or breaks or
cracks in the valve body seating surface.
Ensure that cartridges are the correct type. Cartridges must be from the same
manufacturer as the respirator and must be approved for use in an asbestos
atmosphere (type H, high-efficiency filter, magenta color code).
If the device has a corrugated breathing tube, examine for broken or missing end
connectors, gaskets or o-rings, missing or loose hose clamps, or deterioration of the
tubing.
If respirator is a PAPR, determine whether the battery is fully charged, the cartridges
are properly connected, the fan is functioning properly, and appropriate amounts of
air are being delivered to the facepiece.
Conduct a negative-pressure test. With the respirator on and adjusted, block the flow
into inhalation valves and inhale. The facepiece should collapse inward with no
noticeable leaks.
Conduct a positive-pressure test. With the respirator on and adjusted, block the flow
from the exhalation valve and exhale. The facepiece should balloon outward slightly
with no noticeable leakage,
Self-Contained Breathing Apparatus (SCBA)
Check the facepiece in a similar fashion as for air-purifying respirators.
Check the air supply system for:
integrity and good condition of air supply lines and hoses, including
attachments and end fittings;
correct operation and condition of all regulators, valves, and alarms; and
sufficient air charge in the high pressure cylinder for the use period.
Preferably, the tank should be fully charged.
ADDITIONAL INFORMATION
EPA's Health and Safety Guidelines for EPA Asbestos Inspectors also provides guidance
concerning respirator selection for inspections conducted at asbestos manufacturing and
fabricating plants and emergency removal operations at Superfund sites. Inspectors should
review the Guidelines recommendations prior to conducting such inspections.
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SECTION 9
PROTECTIVE CLOTHING
Protective clothing is worn during inspections of active asbestos removal projects for a
number of reasons including:
preservation of health;
comfort; and
ease of decontamination.
Asbestos is a known cause of asbestosis, mesothelioma, lung cancer and other ailments.
Using protective clothing and following proper decontamination procedures help to protect
the inspector and his/her family members by preventing asbestos from being brought out of
the worksite.
Use of protective clothing can also reduce the occurrence of skin problems associated with
ACM contact. In addition to asbestos, ACM commonly contains substances such as mineral
wool, fiberglass, plaster, and cement which can produce rashes in sensitive individuals. Long
term exposure to ACM can also cause "asbestos warts" which often take months to heal.
Protective clothing can also ease the decontamination process. Following an inspection, an
improperly clothed individual will find it very difficult to remove ACM from his/her
clothing, skin and hair because the adhesives used to make the ACM stick to the substrate are
reactivated by the water applied during the removal process.
The most common protective clothing worn in contaminated environments consists of
disposable coveralls, foot and head coverings, and gloves. These items are available in many
styles and materials. The advantage of a particular style depends on what type of inspection
is being conducted. Table 9-1 provides an approximate cost range for several types of
protective clothing.
The use of protective clothing during pre-removal, post-removal and outside inspection
situations will be a discretionary decision on the part of the inspector. In general, protective
clothing should be worn any time friable ACM is being disturbed or if there is any
uncertainty as to the adequacy of cleanup of an area. Protective clothing should be worn
whenever asbestos waste storage areas are inspected or if the inspector will be opening bags
to determine if the asbestos is adequately wet.
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TABLE 9-1. PROTECTIVE CLOTHING COSTS
Item
Approximate Cost (S)
Coveralls (each):
Attached hood and boots, elasticized wrists
Tyvekฎ
Saranexฎ (chemical-resistant)
Kleenguardฎ
Nomexฎ (flame/static-resistant)
4.00 - 6.25
18.75-25.00
7.85
110.00-126.15
Expandable back
Tyvekฎ/Saranexฎ 23-P
Tychemฎ 7500
83.70
35.75
Boots (pair):
Latex overboot
Steel-toed
4.95
18.20-73.00
Gloves (unpowdered, 100):
Disposable vinyl
Polyethylene
Latex, unpowdered
PVC, unpowdered
11.00-14.85
1.55-2.00
14.50
2.45 (per pair)
Note: These costs are subject to change.
RECOMMENDED PROTECTIVE CLOTHING
The following information has been extracted from EPA's Health and Safety Guidelines for
EPA Asbestos Inspectors which can be found in supplemental materials accompanying this
manual.
Removal, Demolition, and Renovation Inspections.
Inspectors should be prepared to wear the following protective clothing when entering a
removal, demolition, or renovation area:
disposable, full-body, hooded outer coveralls (e.g., Tyvekฎ suit or equivalent).
Coveralls with an expanded back should be worn with an SCBA. In certain cases, an
inspector may be required to use specialty coveralls such as Saranex-coated Tyvekฎ
(chemically resistant) or Nomexฎ (fire retardant).
a bathing suit (or equivalent) or inner disposable coveralls. When possible,
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particularly when a changing or decontamination area is available, all street clothing
should be removed before donning protective clothing. When clothing is removed,
the inspector may choose to wear a bathing suit under the protective clothing. If it'is
not possible to remove street clothing, the inspector should roll up pant legs and
sleeves and don inner disposable coveralls. Outer coveralls are then worn over the
bathing suit or inner coveralls.
disposable gloves taped to the outer coveralls.
disposable inner booties (e.g., Tyvekฎ or equivalent).
disposable outer booties (water-resistant material) taped to outer coveralls.
hard hats, safety glasses, safety shoes, hearing protection, when required by the
situation or by the owner/operator.
Collecting Bulk Samples
Inspectors should wear the following protective clothing over their street clothes when
collecting bulk samples whenever there is a significant chance of releasing fibers:
disposable, full-body, hooded coveralls;
eye and head protection as needed;
disposable gloves and shoe coverings.
Waste Disposal and Storage Site Inspections
Inspectors should wear the following protective clothing over their street clothes when
inspecting asbestos waste disposal and storage sites:
disposable, full-body, hooded coveralls;
disposable gloves and shoe coverings.
Abandoned Building Inspections
Inspectors should wear, or carry with them, the following protective clothing while
inspecting an abandoned building:
disposable, full-body, hooded coveralls;
eye and head protection as needed;
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disposable gloves and shoe coverings.
OPERATIONAL PRACTICES FOR ENTERING AND EXITING SITES
The procedures for entering and exiting sites described in this section include those described
in EPA's Health and Safety Guidelines for EPA Asbestos Inspectors and have been
generalized to cover both the use of an air-purifying respirator and SCBA.
Entering and Exiting Site with a Three-Stage Decontamination System
A three-stage decontamination system consists of a clean room, shower room, and equipment
room (sometimes referred to as a dirty room) contiguous with the active removal area. A
detailed description of this type of decontamination system, commonly used in the asbestos
abatement industry, can be found in the OSHA Construction Standard, 29 CFR 1926.1101.
Prior to Entering the Clean Room
Examine the respirator thoroughly to determine whether it will function properly.
Make sure that you have all materials and equipment necessary to conduct the
inspection safely (e.g., protective clothing, respirator, duct tape, extra plastic bags,
spray bottle, disposable towels, flashlight, camera, etc.). All materials carried into the
contaminated area should be sealed in a plastic bag to minimize contamination.
If you take a camera which is not waterproof into the contaminated area, seal it in an
impermeable clear camera box to protect it and facilitate decontamination.
In the Clean Room
Remove all street clothing including socks and underwear and seal them in a clean
plastic bag. If desired, wear a bathing suit (or equivalent), appropriate footwear
(sneakers, steel-toed shoes, etc.) and inner disposable footcoverings. Tape tops of
inner disposable foot coverings to your skin. (Inner footwear and foot coverings are
unnecessary if washable, steel-toed boots can be worn.) Any equipment not taken
into the contaminated area should also be placed in the plastic bag.
If an SCBA will be used, don the SCBA with the air flow valve closed; let the
respirator facepiece hang from the neck by the strap.
Don disposable, full-body, hooded coveralls. Do not yet put on the hood or zip up the
1997 9-4
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suit. If using an SCB A, use a coveralls with an expandable back or oversize (XXL)
Tyvekฎ.
Since Tyvekฎ booties will rip quite easily once they become wet, wear disposable,
reinforced, or steel-toed washable rubber boots over coveralls. Use duct tape to attach
boots to coveralls.
Don respirator facepiece and tighten straps. Perform negative- and positive-pressure
field checks for air-purifying respirator. For SCBA, connect hose to regulator and
open air valve.
Fit the hood of the coveralls snugly around the respirator facepiece and zip up the
coveralls. Use duct tape to close gap at neck if desired.
Don disposable gloves. Use duct tape to seal them to the coveralls.
Proceed to the shower area; leave disposable towels (sealed in a plastic bag), an extra
plastic bag and soap near the shower.
Proceed through the equipment room to the contaminated area and conduct the
inspection.
Before Leaving the Contaminated Area
While standing near the exit, HEP A vacuum (if possible) and wet wipe all visible
debris from protective clothing, sample containers, sampling equipment, and any
other items which are being taken out of the work area. (Use a spray bottle and
disposable towels as necessary). Proceed to the equipment room.
In the Equipment Room
If possible, decontaminate all non-disposable equipment including footwear at the
site. If decontamination is not possible, seal all contaminated nondisposable materials
in a plastic bag and take them with you to decontaminate later.
While still wearing the respirator, carefully remove the outer boots or booties and
gloves and take off the coveralls, rolling them inside out in the process. If a PAPR is
worn, remove the belt which supports the motor/filter unit and hold the unit while
removing coveralls.
Place all disposable contaminated protective clothing in a proper waste disposal
container and place nondisposable items in the shower.
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Wearing respirator (bathing suit, and taped inner booties, if worn), proceed to the
shower.
In the Shower Area
Clean nondisposable items and place them in clean room.
Thoroughly wet the entire body. Remove respirator. Soak and dispose of HEP A
filter cartridges as asbestos-containing waste. (Place them in waste container in
equipment room). Clean respirator and place it into the clean room. Remove booties
and inner footwear (if worn). Place footwear in clean room.
If wearing a bathing suit, remove and thoroughly rinse it, put it in a plastic bag, and
place it in the clean room. Finish showering, thoroughly washing the entire body
with soap and water.
Proceed to the clean room.
In the Clean Room
Dry off and dress in street clothes.
Give all disposables (including used towels) to the site operator if permitted and if
they will be disposed of in an approved landfill. Otherwise, place disposables in
labeled plastic bags and remove them for proper disposal.
Entering and Exiting Sites Without a Three-Stage Decontamination System
Inspections are often required at sites where a three-stage decontamination system is not
available. When confronted with such a situation, the inspector must use his or her judgment
regarding the safest method of conducting the inspection.
Before Entering the Contaminated Area
Examine the respirator thoroughly to determine whether it will operate properly.
Make sure you have all materials and equipment necessary to conduct the inspection
safely (e.g., protective clothing, disposable towels, extra plastic bags, spray bottle,
flashlight, camera etc.). Materials carried into the inspection site should be sealed in
a plastic bag to minimize contamination.
If you take a camera which is not waterproof into the contaminated area, seal it in an
impermeable clear camera box to protect it and facilitate decontamination.
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Leave all street clothing on. Short-sleeve shirts and short pants are preferable. If you
are wearing long pants or long sleeves, roll them up.
Don inner booties (e.g., Tyvekฎ or equivalent) and an inner disposable coveralls over
street clothes. (Inner footwear and foot coverings will not be necessary if steel-toed,
washable boots can be worn.)
If an SCBA will be used, don the SCBA with the air flow valve closed; let the
respirator facepiece hang from the neck by the strap.
Don an outer disposable coveralls. Wear coveralls with an expandable back or an
oversize (XXL) Tyvekฎ suit if an SCBA is used, but do not zip it up.
Since Tyvekฎ booties will rip quite easily once they become wet, wear disposable,
reinforced, or steel-toed washable rubber boots over the outer coveralls. Use duct
tape to attach boots to the coveralls.
Fit the respirator facepiece to the face, tighten the facepiece straps and check face
seal. If using an SCBA, connect hose to regulator and open the air valve. If using an
air-purifying respirator, conduct negative- and positive-pressure field tests.
Fit the hood of the coveralls snugly around the respirator facepiece and zip up the
coveralls.
Don disposable gloves; use duct tape to seal gloves to the sleeves of the outer
coveralls.
Proceed to the contaminated area and conduct the inspection.
Before Leaving the Contaminated Area
While standing near the exit, HEPA vacuum (if possible) and wet wipe all visible
debris from the outer protective clothing. Use a spray bottle containing amended
water and disposable towels to wet wipe the suit; use plenty of water. Standing at the
doorway inside the work area, remove outer protective clothing and immediately step
outside the area. Place all disposable materials in a proper container for disposal.
Outside the Contaminated Area
Once outside, thoroughly wet wipe and mist spray the respirator and inner protective
clothing. Move away from the doorway and remove the respirator and inner
protective clothing. Place all disposable materials into a proper container for
disposal.
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Seal all contaminated nondisposable materials in a plastic bag and take them with you
to decontaminate later.
DISPOSAL OF CONTAMINATED CLOTHING
Contaminated or potentially contaminated protective clothing worn during asbestos
inspections should be discarded as asbestos-containing waste. Asbestos-contaminated waste
materials include coveralls, disposable boots, disposable gloves, respirator cartridges, and
other items such as paper towels or wet wipes. Inspectors can usually discard their
contaminated clothing in labeled, scalable waste containers provided by the owner/operator.
Since the owner/operator must treat the waste disposed in this container as
asbestos-containing, the inspector can assume that the materialhe or she discards will be
disposed of properly. Although this procedure is generally acceptable, it is always a good
idea to obtain permission from the owner/operator before discarding contaminated clothing.
There will be cases, however, when disposal of contaminated clothing will present a problem
to the inspector. For example, the inspector may be conducting an inspection where the
owner/operator is not properly disposing of waste, or where permission to discard inspector
waste is not granted. In such cases, proper handling and subsequent disposal of contaminated
clothing becomes the responsibility of the inspector. It is important, therefore, that the
inspector come to the site prepared for such instances and that policies exist within his/her
agency to deal with asbestos-containing waste. Contaminated clothing must be sealed in
plastic bags before leaving the site. These bags should be pre-labeled asbestos waste
containers; plastic trash bags should not be used. Each agency should provide the inspector
with the exact procedures to. follow in handling the bagged waste and ultimately disposing of
the material.
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SECTION 10
ASBESTOS NESHAP REGULATION
The Environmental Protection Agency (EPA), under requirements of the Clean Air Act (CAA) is
required to develop and enforce regulations necessary to protect the general public from exposure
to airborne contaminants that are known to be hazardous to human health. EPA's specific
authority regarding asbestos is derived from the National Emission Standards for Hazardous Air
Pollutants (NESHAP) which are listed under Section 112 of the CAA.
The asbestos NESHAP regulation (40 CFR Part 61, Subpart M) has been in existence since 1973
and has been amended several times. Information regarding the asbestos NESHAP may be
obtained through EPA's TTN (Technology Transfer Network), a network of electronic bulletin
boards providing information and technical support on air pollution control.
COMPLI, (stationary source COMPLIance) is a BBS (Bulletin Board System) on the TTN
providing stationary source compliance policy and guidance information. NARS, the National
Asbestos Registry System, is one of the databases on the COMPLI BBS; NARS stores the
compliance history of owners and operators of asbestos demolition and renovation activities
related to the Asbestos NESHAP, and is updated at least quarterly.
EPA's TTN service is free, except for the cost of using the phone, and is available 24 hours a day
(except Mon. Sam-noon EST), at 919-541-5742. Help in accessing the network may be obtained
by calling 919-541-5384 (l-5pm EST).
HISTORICAL INFORMATION
The following is a summary relative to demolition/renovation and associated waste-handling and
disposal provisions:
April 6. 1973 - Original promulgation:
regulated the demolition of buildings containing friable asbestos-containing
fireproofing and insulating material; and
restricted spraying of asbestos-containing materials on buildings and structures for
fireproofing and insulating purposes.
May 3, 1974 - Regulations were expanded to include:
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clarification of definitions;
expansion of demolition provisions; and
clarification of "no visible emission" standard to exclude uncombined water from
regulatory requirement.
October 14, 1975 - Substantial changes were made including:
addition of renovation projects to the list of regulated activities;
adoption of provision to prohibit use of wet-applied and molded insulation (e.g.,
pipe lagging); and
expansion of regulatory scope to cover asbestos-containing waste handling and
disposal.
March 2, 1977 - Subtle changes, mostly addressing definitions.
June 19, 1978 - Important changes made include:
expansion of spraying restrictions to prohibit application of asbestos-containing
materials for decorative purposes;
adoption of a provision to exempt bituminous or resinous-based materials from
the spraying restrictions; and
repromulgation of certain work practice provisions.
April 5, 1984 - Repromulgation to ensure existing work practices enforceable.
The need to repromulgate stemmed from the 1978 Supreme Court decision in the case of
Adamo Wrecking Company of Michigan vs. United States. The Court held that parts of
the asbestos NESHAP, specifically the work practice standards, were not emission
standards within the meaning of Section 1 12 of the Clean Air Act. Thus, certain work
practice standards were deemed not enforceable at the time of the Adamo Wrecking case.
To ensure that similar challenges would not be initiated, the CAA was amended (August
7. 1977) to authorize the use of "design, equipment, work practice and operational
standards " Since some, but not all, of the work practice standards were repromulgated
on June W. ll)78. the April 5, 1984 repromulgation of the entire asbestos NESHAP
ensured that all work practice standards were
subsequent l> enforceable. The asbestos NESHAP was also rearranged and parts of it
lor clarit.
No\ ember 2(). 1 990 - Repromulgation of the entire asbestos NESHAP regulation to
enharuc enioreement and compliance. The repromulgated rule:
requires daily monitoring for visible emissions, weekly inspections of air-cleaning
de\ ices, and recordkeeping and reporting at asbestos milling, manufacturing and
fabricating sources;
1997 10-2
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revises notification requirements for demolition and renovation activities;
provides exemptions from the use of wet removal methods;
clarifies EPA's position regarding the handling and treatment of nonfriable
asbestos material;
requires recordkeeping and reporting regarding asbestos waste disposal; and
clarifies that operations which convert asbestos-containing waste material into
nonasbestos material are regulated by NESHAP.
The following text is a summary of 40 CFR Part 61, Subpart M as it pertains to
demolitions/renovations and associated waste handling and disposal. The entire asbestos
NESHAP regulation is included in supplemental materials provided with this manual.
APPLICABILITY (ง61.140)
The following activities are regulated by the asbestos NESHAP:
asbestos mill operations (ง61.142);
surfacing of roadways with asbestos-containing material (ง61.143);
manufacturing products which contain commercial asbestos (ง61.144);
demolition and/or renovation of facilities that contain asbestos material (ง61.145);
spraying of asbestos-containing materials (ง61.146);
fabricating operations involving commercial asbestos (ง61.147);
use of insulating materials that contain commercial asbestos (ง61.148);
waste disposal for asbestos mills (ง61.149);
disposal of asbestos-containing waste generated during manufacturing, fabricating,
demolition, renovation, and spraying operations (ง61.150);
closure and maintenance of inactive waste disposal sites for asbestos mills and
manufacturing and fabricating operations (ง61.151);
operation of air cleaning devices (ง61.152);
reporting of information pertaining to new and existing sources, filter devices, inactive
and active waste disposal sites, etc. (ง61.153);
operation of active waste disposal sites (ง61.154); and
operations involving conversion of asbestos-containing waste material into nonasbestos
(asbestos-free) material (ง61.155).
10-3
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DEFINITIONS (ง61.141)
Adequately wet - To sufficiently mix or penetrate with liquid to prevent the release of
particulates. If visible emissions are observed coming from asbestos-containing material, then
that material has not been adequately wetted. However, the absence of visible emissions is not
sufficient evidence of being adequately wet.
Asbestos - The asbestiform varieties of serpentinite (chrysotile), riebeckite (crocidolite),
cummingtonite-grunerite, anthophyllite, and actmolite-tremolite.
Asbestos-containing waste materials (ACWM) - Mill tailings or any waste that contains
commercial asbestos and is generated by a source subject to the provisions of this subpart. This
term includes filters from control devices, friable asbestos waste material, and bags or other
similar packaging contaminated with commercial asbestos. As applied to demolition and
renovation operations, this term also includes regulated asbestos-containing material waste and
materials contaminated with asbestos including disposable equipment and clothing.
Category I nonfriable ACM - Asbestos-containing packings, gaskets, resilient floor covering,
and asphalt roofing products containing more than 1 percent asbestos as determined using the
method specified in Appendix A, Subpart F, 40 CFR Part 763, Section 1, Polarized Light
Microscopy.
Category II nonfriable ACM - Any material, excluding Category I nonfriable ACM, containing
more than.l percent asbestos as determined using the methods specified in Appendix A, Subpart
F, 40 CFR Part 763, Section 1, Polarized Light Microscopy that, when dry, cannot be crumbled,
pulverized, or reduced to powder by hand pressure.
Cutting - To penetrate with a sharp-edged instrument (includes sawing, but does not include
shearing, slicing, or punching).
Demolition - The wrecking or taking out of any load-supporting structural member of a facility
together with any related handling operations or the intentional burning of any facility.
Emergency renovation operation - A renovation operation that was not planned, but results from
a sudden, unexpected event that, if not immediately attended to, presents a safety or public health
hazard, is necessary to protect equipment from damage, or is necessary to avoid imposing an
unreasonable financial burden. This term includes operations necessitated by nonroutine failures
of equipment.
Facility - Any institutional, commercial, public, industrial, or residential structure, installation,
or building (including any structure, installation, or building containing condominiums or
individual dwelling units operated as a residential cooperative, but excluding residential
1997 10-4
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buildings having four or fewer dwelling units); any ship; and any active or inactive waste
disposal site. For purposes of this definition, any building, structure, or installation that contains
a loft used as a dwelling is not considered a residential structure, installation, or building. Any
structure, installation, or building that was previously subject to this subpart is not excluded,
regardless of its current use or function.
Facility component - Any part of a facility including equipment.
Friable asbestos material (FAM) - Any material containing more than 1 percent asbestos as
determined using the method specified in Appendix A, Subpart F, 40 CFR Part 763, Section 1,
Polarized Light Microscopy (PLM) that, when dry, can be crumbled, pulverized, or reduced to
powder by hand pressure. If the asbestos content is less than 10 percent as determined by a
method other than point counting by PLM, verify the asbestos content by point counting using
PLM.
Glove bag - A sealed compartment with attached inner gloves used for the handling of
asbestos-containing materials. Properly installed and used, glove bags provide a small work area
enclosure typically used for small-scale asbestos stripping operations. Information on glove bag
installation, equipment and supplies, and work practices is contained in OSHA's final rule on
occupational exposure to asbestos (29 CFR Part 1926.1101).
Grinding - To reduce to powder or small fragments. This includes mechanical chipping or
drilling.
Inactive waste disposal site - Any disposal site or portion of it where additional
asbestos-containing waste material has not been deposited within the past year.
In poor condition - Means that the binding of the material is losing its integrity as indicated by
peeling, cracking, or crumbling of the material.
Installation - Any building or structure or any group of buildings or structures at a single
demolition or renovation site that are under the control of the same owner or operator (or owner
or operator under common control).
Leak-tight - Means that solids or liquids cannot escape or spill out. It also means dust-tight.
Natural barrier - A natural object that effectively precludes or deters access. Includes physical
obstacles such as cliffs, lakes or other large bodies of water, deep and wide ravines and
mountains. Remoteness by itself is not a natural barrier.
Nonfriable asbestos-containing material - Any material containing more than one percent
asbestos as determined using the method specified in Appendix A, Subpart F, 40 CFR Part 763,
Section 1, Polarized Light Microscopy that, when dry, cannot be crumbled, pulverized, or
reduced to powder by hand pressure.
1997 10'5
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Nonscheduled renovation operation - A renovation operation necessitated by the routine failure
of equipment, which is expected to occur within a given period based on past operating
experience, but for which an exact date cannot be predicted.
Outside air - The air outside buildings and structures, including, but not limited to, the air under
a bridge or in an open-air ferry dock.
Owner or operator of a demolition or renovation activity - Any person who owns, leases,
operates, controls, or supervises the facility being demolished or renovated or any person who
owns, leases, operates, controls, or supervises the demolition or renovation operation, or both.
Planned renovation operation - A renovation operation, or a number of such operations, in
which some RACM will be removed or stripped within a given period of time and that can be
predicted. Individual nonscheduled operations are included if a number of such operations can
be predicted to occur during a given period of time based on operating experience.
Regulated asbestos-containing material (RACM) - (a) Friable asbestos 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, or (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
regulated by this subpart.
Remove - To take out RACM or facility components that contain or are covered with RACM
from any facility.
Renovation - Altering a facility or one or more facility components in any way, including the
stripping or removal of RACM from a facility component. Operations in which load-supporting
structural members are wrecked or taken out are demolitions.
Resilient floor covering - Asbestos-containing floor tile, including asphalt and vinyl floor tile,
and sheet vinyl floor covering containing more than 1 percent asbestos as determined using
polarized light microscopy according to the method specified in Appendix A, Subpart F, 40 CFR
Part 763, Section 1, Polarized Light Microscopy.
Strip - To take off RACM from any part of a facility or facility components.
Structural member - Any load-supporting member of a facility such as beams and
load-supporting walls; or any nonload-supporting members, such as ceilings and
nonload-supporting walls.
Visible emissions - Any emissions (excluding condensed uncombined water vapor) which are
visually detectable without the aid of instruments, coming from RACM or asbestos-containing
1997 10-6
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waste material, or from any asbestos milling, manufacturing or fabricating operation.
Waste generator - Any owner or operator of a source covered by this subpart whose act or
process produces asbestos-containing waste material.
Waste shipment record (WSR) - The shipping document, required to be originated and signed by
the waste generator, used to track and substantiate the disposition of asbestos-containing waste
material.
Working day - Monday through Friday and holidays that fall on any of the days Monday through
Friday.
STANDARD FOR DEMOLITION AND RENOVATION (ง61.145)
APPLICABILITY [ง61.145(a)J
Various requirements of this section apply to the owner or operator of a demolition or renovation
activity depending on the presence, relative amounts and condition of asbestos (including
Category I and Category II nonfriable ACM) found in the facility.
To determine the applicability of the demolition/renovation standard, prior to the commencement
of demolition or renovation activities, the owner or operator must thoroughly inspect the affected
facility or part of the facility where the demolition or renovation will occur for the presence of
asbestos, including Category I and Category II nonfriable ACM.
Demolitions > 260/160/35 [ง61.145(a)(l)]
In a facility being demolished, all notification requirements of ง61.145(b) and emission control
procedures of ง61.145(c) (see Tables 10-1 and 10-2) apply if the combined amount of RACM is
at least:
260 linear feet (80 linear meters) on pipes; or
160 square feet (15 square meters) on other facility components; or
35 cubic feet (1 cubic meter) off facility components where the length or area could not
be measured previously.
Note: Future references to these regulated amounts of ACM will be designated: 260/160/35.
Demolitions <260/160/35 |ง61.145(a)(2)]
1997 10~7
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In a facility being demolished, if the combined amount of RACM is less than the regulated
amounts, or there is no asbestos in the facility, only the notification procedures of
ง61.145(b)(l),(2),(3)(i and iv) and (4)(i-vii, ix and xvi) apply (see Table
10-1). Notification must be received by the EPA for a building that will be demolished even if
there is no asbestos in the building; this provides an opportunity for EPA to inspect the facility
prior to demolition to verify that it contains less than the regulated quantity of asbestos.
Ordered Demolitions (ง61.145(a)(3)]
If a facility which contains at least 260/160/35 is ordered demolished by a State or local
governmental agency because the building is structurally unsound and in danger of imminent
collapse, notification requirements of ง61.145(b)(l),(2),(3iii),(4, excluding viii) and (5) and
emission control procedures of ง61.145(c)(4-9) apply (see Tables 10-1 and 10-2).
Renovations ^260/160/35 [ง61.145(a)(4>]
If the combined amount of RACM to be stripped, removed, dislodged, cut, drilled or similarly
disturbed during a renovation (including any individual nonscheduled renovation operation) is at
least 260/160/35, notification requirements of ง61.145(b) and emission control procedures of
ง61.145(c) apply (see Tables 10-1 and 10-2).
Renovations <260/160/35 [ง61.145(a)(4>]
If the amount of RACM that will be stripped, removed, dislodged, cut, drilled or similarly
disturbed is less than 260/160/35, and the renovation is not a component of Planned Renovations
Involving Individual Nonscheduled Operations as described in ง61.145(a)(4)(iii), the
requirements of the asbestos NESHAP do not apply.
Planned Renovations Involving Individual Nonscheduled Operations [ง61.145(a)(4)(iii)]
If the predicted combined additive amount of RACM to be removed or stripped during planned
renovation operations involving individual nonscheduled operations during a calendar year of
January 1 through December 31 is at least 260/160/35, notification requirements of ง61.145(b)
and emission control procedures of ง61.145(c) apply (see Tables 10-1 and 10-2).
Emergence Kt novations [ง61.145(a)(4)(iv)]
If the estimated wombmed amount of RACM to be removed or stripped as a result of the sudden,
unexpected ooni that necessitated the renovation is at least 260/160/35, notification
requirementป ot :M I45(b) and emission control procedures of ง61.145(c) apply (see Tables 10-
1 and 10-: i
NOTIFICATION REQUIREMENTS [ง61.145(b)]
1997 10-8
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Note: Notification requirements of ง61.145(b) are summarized in Table 10-1.
Notifying Responsibility [ง61.145(b)(l-3)]
Each owner or operator of a demolition or renovation activity to which this section applies is
required to:
Notify the Administrator, in writing, of the intent to demolish or renovate. (The
Administrator is anyone with delegated authority within the EPA asbestos NESHAP
program. Inspectors should be aware that where the EPA has delegated authority for the
program to a State, in some cases only the State may require notification; in other
instances, both the State and EPA must be notified.) Delivery of the notice by U.S.
Postal Service, commercial delivery service, or hand delivery is acceptable.
Update the notice as necessary (e.g., change in start date, 20 percent increase in affected
asbestos).
Postmark or deliver the notice as required.
Provide necessary information in an appropriate format (see Figure 10-1).
Notification Submittal [ง61.145(b)(3)]
The asbestos NESHAP has established the following notification submittal requirements
concerning demolition and renovation activities. Lead.times have been designated in certain
circumstances to provide the regulatory agency with sufficient time to determine compliance
with the standard.
Demolitions and Renovations (^260/160/35)
Notices must be postmarked or delivered at least 10 working days before asbestos stripping or
removal work or any other activity which would disturb asbestos material begins. This
notification requirement does not apply to planned renovations involving individual
nonscheduled operations involving <260/160/35 or emergency renovations.
Demolition* ( J60160/35 or No Asbestos)
Notice muM K- k'i\cn 10 working days before demolition begins.
Planned Remnation Operations Involving Individual Nonscheduled Operations (which total
? 260/160 .?$ during a calendar year)
For these renmat.on operations, notice must be given at least 10 working days before the end of
the calendar >car preceding the year for which notice is being given.
Ordered Demolitions (^260/160/35)
1997
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For demolitions ordered by a governmental agency, notice must be given as early as possible
before, but not later than the working day following the demolition.
Emergency Renovation Operations (^260/160/35)
Notice must be given as early as possible before, but not later than the working day following the
renovation.
Renovations (<260/160/35)
EPA requires no notification for a single renovation involving less than the regulated amount of
RACM. However, if the total RACM involved in several nonscheduled renovation projects
exceeds 260/160/35, notice must be given as indicated in Planned Renovations Involving
Individual Nonscheduled Operations.
Updated Notifications [ง61.145(b)(3)(iv)]
Whenever asbestos stripping or removal in demolition and renovation operations involving at
least 260/160/35 (excluding planned renovation operations involving individual nonscheduled
operations and emergency renovation operations) or demolitions involving less than 260/160/35
will begin on a date other than the one contained in the original notice, the Administrator must be
notified of such a change. In no event shall an operation begin on a date other than the date
contained in the written notice of the new start date.
Later Starting Date
If the new start date is scheduled after the date contained in the original notice, the
Administrator must be:
notified by telephone as soon as possible before the original start date; and
provided with a written notice of the new start date as soon as possible before, and no
later than, the original start date.
Delivery of the updated notice by U.S. Postal Service, commercial delivery service, or hand
delivery is acceptable.
Earlier Starting Date
If the new start date is scheduled before the date contained in the original notice, EPA must be
notified of the change:
in writing; and
at least 10 working days before asbestos stripping or removal work or demolition begins.
1997 10-10
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Delivery of the updated notice by U.S. Postal Service, commercial delivery service, or hand
delivery is acceptable.
Contents of Notification [ง61.145(b)(4>]
Whenever notification is required, the following information must be included:
an indication of whether the notice is the original or revised notification;
names, addresses and telephone numbers of the facility owner and operator, asbestos
removal contractor owner or operator, and waste transporter;
type of operation: demolition or renovation;
description of the facility or affected part of the facility (size, number of floors, age,
present and prior use, etc.);
procedure employed to detect the presence of RACM and Category I and Category II
nonfriable ACM (including analytical methods);
estimate of the approximate amount of RACM to be removed from the facility;
estimate of the approximate amount of Category I and Category II nonfriable ACM in the
affected part of the facility that will not be removed before demolition;
facility address and location of work site in the facility;
scheduled starting and completion dates of asbestos removal work or other activity that
would disturb asbestos material in a demolition or renovation (for planned renovation
operations involving individual nonscheduled operations, January 1 to December 31
should be reported);
scheduled starting and completion dates of demolition or renovation;
description of planned demolition/renovation work to be performed, method(s) to be
employed, and description of affected facility component;
description of work practices and engineering controls to be used (includes asbestos
removal and waste-handling emission control procedures);
name and address of the waste disposal site to be used;
1997
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43422 Federal Register / Vol. 55, No. 224 / Tuesday, November 20,1990 / Rules and Regulations
NOTIFICATION OP DEMOLITION AND RENOVATION
Operator Project ff
postmark
Date, Received
Notification *
I. TYPE OF NOTIFICATION ( 0-Oriqinal R-Reviaed C-Cancelled | r
II. FACILITY INFORMATION ( identity owner, removal contractor, and other operator )
OWNER NAME:
Addrecai
Cityi
Statei
Zipt
Contact i
Tell
REMOVAL CONTRACTOR}
Addrecai
Cityi
Statei
Zipi
Contact!
nit
OTHER OPERATOR:
Address i
Cityi
Statei
Zipi
Contact!
Teli
Ill; TYPE OF OPERATION ( DปDeoo 0-Ordered Demo R-Rsnovation B-tmer.Renovation )i
IV. IS ASBESTOS PRESENT? ( Yea/Ho }
V. FACILITY DESCRIPTION ( include building name, number and floor or room nnater )
Bldg Haoei
Address i
Cityi
Statei
County i
Site Locationi
Building Sizet
I of Floors!
Age in yearn i
Present Usei
Prior Utet
VI. PROCEDURE, INCLUDING ANALYTICAL METHOD, IF APPROPRIATE, USED TO DETECT THE PRESENCE
OF ASBESTOS MATERIAL:
VII. APPROXIMATE AMOUNT OF
ASBESTOS, INCLUDING:
1. Regulated ACM to be removed
2. Category I ACM Hot Removed
3. Category II ACM Hot Removed
RACM
To Be
Removed
Konfriable
Asbestos
Material Hot
To Be Removed
Cat I
Cat II
Indicate Unit of
Meaaureneat Below
OMIT
Pipes
Lnrti
Ln at
Surface Ares
Sqrtl
Sq !
Vol RACM Off Facility Conponent
curti
cu
VIII. SCHEDULED DATES ASBESTOS REMOVAL ( MM/DO/ YT) Start!
Complete i
IX. SCHEDULED DATES DEMO/RENOVATION (MM/DO/YY) Slarti
Coapletei
Continued on page two
Figure 10-1. Notification of Demolition and Renovation
1997
10-12
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Federal Register / Vol. 55. No. 224 / Tuesday. November 20.1990 / Rules and Regulations 48423
NOTIFICATION OF DEMOLITION AMD REBOVATIOK teonttnued)
X. DESCRIPTION OF PLANNED DEMOLITION OR RENOVATION WORK, AND HETBOD(S) TO BE USED.
XI. DESCRIPTION OF WORK PRACTICES AND ENGINEERING CONTROLS TO BE USED TO
EMISSIONS OF ASBESTOS AT THE DEMOLITION AND RENOVATION SITEl
XII. WASTE TRANSPORTER *1
Hanai
Address
Cltyi
Statei
Contact Personi
WASTE TRANSPORTER 12
Zipi
Telephonei
Name i
Addressi
Cityt
Statei
Contact Persont
Zip i
Telephonei
XIII. HASTE DISPOSAL SITE
Name I
Locationi
Cityt
Statei
tip i
Telephonei
XIV. IF DEMOLITION ORDERED BY A GOVERNMENT AGENCY, PLEASE IDENTIFY THE AGENCY BELOWซ
Titlei
'Authority!
Date of Order (MM/DD/TY)!
Bate Ordered to Begia (HM/DD/TT)l
XV. FOR EMERGENCY RENOVATIONS
Date and Hour of Emergency (MM/DO/YIM
Description of the Sudden, Unexpected Zventi
Explanation of how the event caused unsafe conditions or would cause equipment damage
or an unreasonable financial burdeni
XVI. DESCRIPTION OF PROCEDURES TO BE FOLLOWED IN THE EVENT THAT UNEXPECTED ASBESTOS IS
FOUNI) OR PREVIOUSLY NONFRIABLE ASBESTOS MATERIAL BECOMES CRUMBLED, PULVERIZED,
OR REDUCED TO POWDER.
XVI I CERTIFY THAT AN INDIVIDUAL TRAINED IN THE PROVISIONS OF THIS REGULATION (40 CFR
PART 61 SUBPART Mป WILL BE ON-SITE DURING THE DEMOLITION OR RENOVATION AND EVIDENC
THAT THE REQUIRED TRAINING HAS BEEN ACCOMPLISHED BY THIS PERSON WILL BE AVAILABLE
FOi INSPECTION DURING NORMAL BUSINESS HOURS. (Required 1 year after promulgation)
(Signature of Owner/Operator)
(Date)
XVII. I CERTIFY THAT THE ABOVE INFORMATION IS CORRECT.
(Signature of Owner /operator)
(Date)
Figure 10-1. Notification of Demolition and Renovation (Continued)
1997
10-13
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a certification that an appropriately trained person will supervise the stripping and
removal operation; and
a description of the procedures to be followed in the event that unexpected RACM is
found or generated.
When a facility has been ordered to be demolished, notification must also include:
the name, title and authority of the government representative who ordered the
demolition;
the date the order was issued;
the date the demolition was ordered to begin; and
a copy of the order.
For emergency renovations, notification must include:
the date and hour that the emergency occurred;
a description of the sudden, unexpected event; and
an explanation of how the event caused an unsafe condition, or would cause equipment
damage or an unreasonable financial burden.
PROCEDURES FOR ASBESTOS EMISSION CONTROL [ง61.145(c>]
Because an acceptable, safe, ambient source concentration of asbestos is unknown, the standard
sets forth requirements to prevent emissions of paniculate asbestos material to the outside air.
Table 10-2 provides a summary of emission control requirements.
Removal of ACM [ง61.145(c)(l)]
Remove all RACM from a facility being demolished or renovated before any activity begins that
would break up. dislodge, or similarly disturb the material or preclude access to the material for
subsequent removal.
Exceptions from Removal [ง61.145(a)(3) and (c)(l)(i-iv)J
RACM need not be removed prior to demolition if it:
is located in a facility ordered demolished by a governmental agency because the facility
is structurally unsound and in danger of imminent collapse. (The portion of the facility
containing the RACM must be adequately wet during wrecking.);
1997 10-14
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is Category I nonfriable ACM that is not in poor condition and is not friable;
is on a facility component that is encased in concrete or other similarly hard material and
is adequately wet whenever exposed during demolition;
was not accessible for testing and was, therefore, not discovered until after demolition
began and, as a result of the demolition, the material cannot be safely removed. If not
removed for safety reasons, the exposed RACM and any asbestos-contaminated debris
must be treated as ACWM and adequately wet at all times until disposed of;
is Category II nonfriable ACM and the probability is low that it will become crumbled,
pulverized, or reduced to powder during demolition.
Removal of Units or Sections [ง61.145(c)(2>]
When a facility component that contains, is covered with, or is coated with RACM is being taken
out of the facility as a unit or in sections:
adequately wet all RACM exposed during cutting or disjoining operations; and
carefully lower each unit or section to the floor and to ground level. (Do not drop,
throw, slide or otherwise damage or disturb the RACM.)
Stripping RACM from an In-place Facility Component [ง61.145(c)(3)]
Adequately wet RACM while it is being stripped from in-place facility components.
Techniques for Wetting
Wetting may be accomplished in a variety of ways:
portable garden sprayer;
faucet tap/hose;
water barrel and pump; or
hose and nozzle connected to a hydrant.
Workers should appl> the wetting agent as a fine mist or spray to ensure adequate wetting of the
RACM. Depending on the type of RACM being removed, repeat or continuous application of
the wetting j^ent ma> be necessary.
10-15
1997
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TABLE 10-1. ง61.145(b) NOTIFICATION REQUIREMENTS SUMMARY
(1) Provide written notice.
(2) Update notice as necessary.
(3) Postmark
(i) planned demo/reno - 10 working days before activity
(ii) planned reno involving nonscheduled operations - 10 working days before end of
calendar year
(iii) ordered demo or emergency reno - ASAP before, not later than following working
day
(iv) provide notice of new start date
(A) later start date
(1) telephone ASAP before original start date
(2) written notice ASAP, no later than original start date
(B) earlier start date
(1)(2) written notice 10 working days before reno or demo work begins
(C) work cannot commence on other than new start date
(4) Notification information
(i) original or revised notification?
(ii) owner, operator, removal contractor owner or operator name, address, telephone
(iii) demolition or renovation?
(iv) facility description (size, # floors, age, present, prior use)
(v) procedures employed to detect RACM, Category I and II nonfriable ACM
(vi) approximate amount of RACM to be removed; approximate amount of Category I
and II to remain (demo only)
(vii) facility address and location of worksite in facility
(viii) starting/completion dates of asbestos removal work which would disturb asbestos
material (Jan 1 - Dec 31 for planned but nonscheduled renos)
(ix) starting/completion dates of demo or reno
(x) description of planned demo/reno work, methods to be used, facility component
description
(xi) work practices/engineering controls to be used
(xii) waste disposal site name/address
(xiii) certification that trained individual will supervise
(xiv) name, title, authority of individual ordering demolition; date order issued and demo
to begin; attach copy to notification
(xv) date/hour/description of emergency and explanation re: unsafe condition, equipment
damage, or financial burden
(xvi) procedures to be followed if unexpected RACM is found or generated
(xvii) waste transporter name, address, telephone number
(5) Report information on appropriate form.
1997 10-16
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High-pressure power washers are not recommended for use in wetting RACM because the force
of the water stream (measured in thousands of pounds per square inch) dislodges RACM so
quickly that adequate wetting of the material cannot take place.
Although not specifically required by the asbestos NESHAP, surfactants, chemicals which
reduce the surface tension of water, are commonly added to the water used for wetting RACM.
Surfactants aid in the penetration and wetting of RACM and reduce the amount of water
required.
EPA guidance recommends using a mixture of 50 percent polyoxyethylene ester and 50 percent
polyoxyethylene ether, or the equivalent, in a 0.16 percent solution (1 oz. per 5 gallons) of water
(Purple Book - EPA 560/5-85-024).
Wetting Exemptions [ง61.145(c)(3)(i-iii), (6)(iv), (7)(i-iii)J
Wetting is not required where the wetting operation would damage equipment or present a safety
hazard, where RACM being handled is contained in leak-tight wrapping, or where the abatement
is taking place below freezing temperatures. Detailed information concerning these situations is
provided below.
Equipment Damage or Safety Hazards [ง6L145(c)(3)(i-iu)J
Wetting is not required if the owner or operator:
has obtained prior written approval from the Administrator based on a written application
that wetting to comply would unavoidably damage equipment or present a safety hazard;
and
uses one of the following emission control methods during the renovation activity:
an appropriately designed and operated local exhaust ventilation and collection
system for paniculate asbestos; or
a glove-bag system designed and operated to contain paniculate asbestos material; or
leak-tight wrapping to contain all ACM prior to dismantlement; or
another equivalent wetting or emission control method approved, in writing, by
the Administrator; and
keeps a copy of the written approval at the worksite and makes it available for inspection.
Wrapped RACM[ง61.145(c)(6)(iv)J
1997
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Wetting is not required when RACM has been contained in leak-tight wrapping prior to the
facility component's dismantlement, or after a facility component has been removed as a unit or
in sections.
Below Freezing Temperatures [ง6L145(c)(7)J
When the temperature at the point of wetting is below 32 ฐF (0ฐC), wetting is not required. The
owner or operator must, however:
remove facility components containing, coated with, or covered with RACM as units or in
sections to the maximum extent possible;
record the temperature in the area containing the facility components at the beginning,
middle and end of each workday;
keep daily temperature records available for inspection by the Administrator during normal
business hours at the demolition or renovation site; and
retain temperature records for at least 2 years.
Treatment of Facility Components Taken Out as Units or Sections [ง61.145(c)(4)J
Facility components, except those described in ง61.145(c)(5), which have been taken out of a
facility as a unit or in sections must be stripped or contained in leak-tight wrapping. If they are
to be stripped:
adequately wet the RACM during stripping; or
use an appropriately designed and operated local exhaust and ventilation and collection
system for paniculate asbestos.
Exemptions from Stripping [ง61.145(c)(5)]
RACM does not have to be removed from large facility components such as reactor vessels, large
tanks, and steam generators, but not beams, if the following requirements are met:
the facility component is removed, transported, stored, disposed of, or reused without
disturbing or damaging the RACM; and
the component is encased in a leak-tight, appropriately-labeled wrapping (see Figure 10-2)
during all loading and unloading operations and during storage.
1997 10-18
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DANGER
ASBESTOS DUST HAZARD
CANCER AND LUNG DISEASE
HAZARD
Figure 10-2. EPA Asbestos Warning Label
Handling of RACM [ง61.145(c)(6)]
For all RACM, including material that has been removed or stripped:
adequately wet the material and ensure that it remains wet until collected and contained or
treated in preparation for disposal;
carefully lower the material to the ground and floor (Do not drop, throw, slide or otherwise
damage or disturb the material.); and
transport the material to the ground via leak-tight chutes or containers if it has been
removed or stripped more than 50 feet above ground level and was not removed as units or
in sections.
NESHAP Training Requirements [ง61.145(c)(8)]
No RACM shall be stripped, removed, or otherwise handled or disturbed at a facility unless at
least one on-site representative, such as a foreman or management-level person or other
authorized representative, trained in the provisions of this regulation and the means of complying
with them is present. Every 2 years this individual must receive refresher training in the
provisions of this regulation. Evidence that the required training has been completed must be
posted and made available for inspection by the Administrator at the demolition or renovation
site.
Ordered Demolitions [ง61.145(c)(9)J
For facilities ordered to be demolished, the portion of the facility that contains RACM must be
kept adequately wet during the wrecking operation.
Intentional Burning [ง6U45(c)(10)l
If the facility is demolished by intentional burning, all RACM, including Categories I and II
nonfriable ACM, must be removed before burning.
1997 10-19
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WASTE DISPOSAL REQUIREMENTS (ง61.150)
Section 61.150 of the NESHAP asbestos standard addresses collection, processing, packaging,
transport, deposition, and recordkeeping requirements pertaining to asbestos-containing waste
material (ACWM). Table 10-3 provides a summary of these requirements.
ACWM is defined as any waste that contains commercial asbestos and is generated by a source
subject to the provisions of the standard. ACWM includes:
filters from control devices;
friable asbestos waste material;
bags or other similar packaging contaminated with commercial asbestos;
RACM waste material; and
materials contaminated with asbestos (disposable equipment, clothing, plastic sheeting,
cleanup equipment waste, shower water, excess water from wetting procedures, etc.).
VISIBLE EMISSIONS [ง61.150(a)]
Note: ง61.150(a) does not apply to Category I nonfriable ACM waste and Category II nonfriable
ACM waste that is not RACM.
Each owner or operator of any source covered under the provisions of the NESHAP asbestos
standard must either discharge no visible emissions (VE) to the outside air during the
collection, processing (including incineration), packaging or transporting of any ACWM
generated by the source, or use one of the following emission control and waste treatment
methods:
adequately wet ACWM;
process ACWM into nonfriable forms;
use emission control alternatives.
Adequately Wet ACWM (ง61.150(a)(l) and (3)]
Owners/operators who choose this option must:
Adequately wet ACWM.
Discharge no VE.
After wetting, seal ACWM in leak-tight containers while wet. For materials that will not
fit into containers without additional breaking, enclose them in leak-tight wrapping.
1997 10-20
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TABLE 10-2. ง61.145(c) ASBESTOS EMISSION CONTROL SUMMARY
(1) Remove RACM before demo/reno unless:
(i) Category I nonfriable (not in poor condition, not friable)
(ii) encased in concrete; adequately wet during demo
(iii) not accessible for testing; adequately wet, treat as ACWM
(iv) Category II nonfriable ACM (low probability of becoming RACM)
(2) Removal of facility components in units/sections with asbestos intact
(i) adequately wet (cutting or disjoining)
(ii) carefully lower
(3) RACM stripping
(i) adequately wet unless:
(A) written approval (equipment damage, safety hazard) and
(B) one of following emission control methods:
(1) LEVCor
(2) glove bag or
(3) leak-tight wrapping
(ii) where (1), (2), or (3) cannot be used, written approval for an alternative method.
(iii) keep copy of written approval at worksite.
(4) Strip or wrap facility component (units/sections) or handle per (5). If stripped:
(i) adequately wet RACM or
(ii) use LEVC
(5) Large facility components (but not beams) - no need to strip if:
(i) RACM not disturbed/damaged and
(ii) leak-tight wrapping and
(iii) labeled
(6) All RACM (including removed or stripped material)
(i) adequately wet and maintain wet
(ii) carefully lower
(iii) leak-tight chutes/containers (>50' and not units/sections)
(iv) wetting not required for RACM wrapped leak-tight
(7) Temperature <0ฐC (32ฐF)
(i) wetting not required
(ii) remove RACM as units/sections
(iii) record temperature beginning, middle, end of workday; keep records available at site;
retain records 2 2 years.
(8) Trained on-site representative; refresher training every 2 years; post evidence of required
training at site
(9) Ordered demos - adequately wet RACM during demo
(10) Intentional burning - remove all RACM and Category I and II nonfriable ACM before
burning
1997 10'21
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Label containers of ACWM or wrapped ACWM using warning labels specified by OSHA
29 CFR 1910.1001 or 1926.58 (now 1926.1101 - see Figure 10-3).
Label ACWM destined for off-site transport with the name of the waste generator and the
location where the waste was generated.
Keep ACWM generated during ordered demolitions (or demolitions where RACM is not
required to be removed) adequately wetted at all times after demolition and during
handling and loading for transport to a disposal site. Such ACWM does not have to be
sealed in leak-tight containers or wrapping, but may be transported and disposed of in
bulk.
DANGER
CONTAINS ASBESTOS FIBERS
AVOID CREATING DUST
Figure 10-3. OSHA Asbestos Warning Label
Process ACWM into Nonfriable Forms [ง61.150(a)(2)]
Owners/operators may choose to form all ACWM into nonfriable pellets or other shapes while
discharging no visible emissions to the outside air.
Use Emission Control Alternatives [ง61.150(a)(4)|
Owners/operators may use an alternative emission control and waste treatment method that has
received prior approval by the Administrator.
Note: In a 1989 court ruling in Rhode Island (Hugo Key vs. EPA), the judge ruled that debris on
the ground outside a building was a violation of the "No VE" requirement. In this case,
the evidence consisted of pieces of friable asbestos material that had come off an
asbestos-covered tank as it was dragged out of a building into a parking lot. The court's
interpretation of this part of ง61.150 provides greater enforcement flexibility of the "No
VE" requirement and, hence, a need for inspectors to collect samples of ACWM found
outside a facility.
1997 10-22
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DEPOSITION OF ACWM [ง6U50(b)J
Deposit, as soon as is practical, all ACWM (excluding Category I ACM that is not RACM) at a
waste disposal site operated in accordance with ง61.154, or at an EPA-approved site that
converts RACM and ACWM into nonasbestos (asbestos-free) material according to ง61.155.
VEHICLE MARKING [ง61.150(c)]
Vehicles used to transport ACWM must be marked during the loading and unloading of waste so
that the signs are visible and markings in conformation with ง61.149(d)(l)(i-iii) (see Figure 10-
OFF-SITE TRANSPORT OF ACWM [ง61.150(d)J
Each owner or operator of a demolition/renovation operation must:
Maintain appropriate waste shipment records (WSRs) (see Figure 10-4).
Provide a copy of the waste shipment record to the disposal site owners or operators
when the ACWM is delivered to the site.
Contact appropriate personnel to determine the status of the waste shipment if a copy of
the waste shipment record, signed by the owner or operator of the waste disposal site, is
not received by the waste generator within 35 days of the date the waste was accepted by
the initial transporter.
Report in writing to the agency responsible for administering the asbestos NESHAP
program for the generator if a signed copy of the WSR has not been received by the waste
generator within 45 days of the date the waste was accepted by the initial transporter.
Retain a copy of all waste shipment records, including the signed copy of the waste
shipment record, for at least 2 years.
RECORD AVAILABILITY |ง61.150(e)j
Each owner or operator of a demolition/renovation operation must furnish upon request, and
make available for inspection by the Administrator, all records required under this section.
AIR CLEANING (ง61.152)
1997 10-23
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APPLICABILITY [ง61.152(a)]
Under certain conditions detailed in ง61.145 (Standardfor demolition and renovation) and
ง61.150 (Standardfor waste disposal...), an owner or operator may choose to control asbestos
emissions by using fabric filter collection devices. The device must be properly installed, used,
operated, and maintained. In addition, for fabric filter collection devices installed after January
10, 1989, provisions must be made for easy inspection for faulty bags. If a source cannot meet
the air-cleaning requirements when it has elected to use fabric filter collection devices, it defaults
to the "No Visible Emission" component of the standard.
EXCEPTIONS [ง61.152(b)]
Fabric Filters [ง61.152, (b)(l)]
Fabric filters may be used; however, if the use of fabric creates a fire or explosion hazard, or if
the Administrator determines that a fabric filter is not feasible, use of wet collectors may be
authorized.
Note: Fabric filters are uneconomical and therefore rarely, if ever, used at demolition or
renovation sites.
HEPA Filters [ง61.152(b)(2)]
HEPA filters certified to be 99.97 percent efficient for 0.3 micron diameter particles may be
used.
Note: HEPA filters are commonly used at demolition/renovation worksites. They are
components of local exhaust ventilation units, respirator cartridges, and vacuum cleaners.
Other Filtration Devices [ง61.152(b)(3)J
Other filtering equipment may be authorized for use if the owner or operator demonstrates to the
Administrator that it is equivalent to the described equipment in filtering paniculate asbestos
material.
1997 10-24
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Generator 1
Transporter
"V
*j
1/1
IB
I/I
O
Q.
tfl
0
1. Work site name and mailing address
2. Operator's name and address
Owner's name
3. Waste disposal site (WDS) name,
mailing address, and physical site
location
4. Name, and address of responsible
5. Description of materials
Owner's
telephone no.
Operator's
telephone no.
WDS
phone no.
agency
.6. Containers
No. Type
7. Total quantity
m3 (yd3)
8. Special handling Instructions and additional information
9. OPERATOR'S CERTIFICATION: I hereby declare that the contents of this
.consignment are fully and accurately described above by proper shipping
name and are classified, packed, marked, and labeled, and are 1n all
respects 1n proper condition for transport by highway according to
applicable International and government regulations.
Printed/typed name & title
10. Transporter 1 (Acknowledgment of
Printed/typed name & title
Address and telephone no.
11. Transporter 2 (Acknowledgment of
Printed/typed name & title
. Address and telephone no.
Signature
Month Day Year
receipt of materials)
Signature
Month Day Year
receipt of materials)
Signature
Month Day Year
12. Discrepancy Indication space
13' owner operator" Certification of receipt of asbestos materials
H covered by this manifest exceot as noted in item 12.
Printed/typed name 4 title
Signature
Month Day Year
(Continued
Figure 10-4. Waste Shipment Record
1997
10-25
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TABLE 10-3. ง61.150 WASTE DISPOSAL SUMMARY
(a) No visible emissions or use one of emission control and waste treatment methods of
paragraphs (1) through (4):
(1) adequately wet
(i) control device (slurry); adequately wet ACWM and
(ii) no visible emissions; and
(iii) leak-tight containers while wet, or leak-tight wrapping; and
(iv) OSHA label; and
(v) generator identification label (off-site transport only)
(2) process into nonfriable forms
(i) pellets or other shapes
(ii) no visible emissions
(3) for facilities demolished where RACM has not been removed, or in ordered
demolitions, adequately wet ACWM at all times after demolition (leak-tight
containers or wrapping not required)
(4) approved alternative emission control and waste treatment method
(5) paragraph (a) does not apply to demo/reno Category I nonfriable ACM waste and
Category II nonfriable ACM waste that did not become RACM
(b) Deposit ACWM as soon as practical at:
(1) appropriate waste disposal site
(2) EPA-approved asbestos conversion site
(3) paragraph (b) does not apply to Category I nonfriable ACM that is not RACM
(c) Mark vehicles (loading and unloading)
(d) For ACWM transported off the site:
(1) waste shipment records
(i) generator name, address, telephone
(ii) asbestos NESHAP program agency name, address
(iii) quantity ACWM (m3, yd3)
(iv) waste disposal site (WDS) operator name, telephone
(v) disposal site name, physical location
(vi) transport date
(vii) transporter name, address, telephone
(viii) certification
(2) provide WSR to disposal site owner/operator at time of delivery
(3) if signed copy of WSR is not received by generator from WDS within 35 days,
contact transporter and WDS to determine status
(4) submit report to asbestos NESHAP program agency (for generator) if signed WSR
not received from WDS within 45 days
(i) copy of WSR
(ii) cover letter re: efforts
(5) retain WSRs s2 years
(e) Furnish records to Admin, upon request.
1997 10-26
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SOURCE REPORTING REQUIREMENTS (ง61.153)
Ntfes Waste disposal site, but not demolition and renovation owners/operators, are subject to
these provisions.
NEW AND EXISTING SOURCES [ง61.153(a)J
Waste disposal site owners and operators must supply the following information to the
Administrator within 90 days of the effective date of the regulation (for existing sources) or
within 90 days of the date of initial startup (for new sources):
brief description of the waste disposal site;
description of the method(s) or alternative procedures to be used to comply with the asbestos
NESHAP.
ACTIVE WASTE DISPOSAL SITES [ง61.153(b)]
Active waste disposal site owners and operators must also provide the following information (as
required by ง61.10) when submitting information required by ง61.153(a):
name and address of owner or operator;
location of the source;
type of hazardous pollutants emitted;
brief description of the nature, design, and method of operation of the stationary source; and
the average weight per month of asbestos being processed by the source over the last 12
months preceding the date of the report.
Note: Changes in the information required by ง61.153 must be reported to the Administrator
within 30 days of their occurrence.
ACTIVE WASTE DISPOSAL SITES (ง61.154)
1997 10-27
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When the asbestos NESHAP regulation was revised on November 20, 1990, waste disposal site
operators became subject to new reporting and recordkeeping requirements. These and other
applicable components of the regulation are discussed below.
SITE OPERATION [ง61.154(a-d>]
To be an acceptable site for disposal of ACWM, an active waste disposal site must meet the
following requirements:
ง61.154(a) - Produce no visible emissions to the outside air where ACWM has been
deposited [or meet the requirements of ง61.154(c) or (d)];
ง61.154(b) - Unless a natural barrier adequately deters access by the general public, install
and maintain warning signs and fencing [or meet the requirements of ง61.154(c)(l)];
ง61.154(c) - At the end of each operating day, or at least once every 24-hour period while the
site is in continuous operation, cover the ACWM that has been deposited at the site during
the operating day or previous 24-hour period with:
at least 6 inches (15 centimeters) of compacted nonasbestos-containing material
[ง61.154(c)(l)],or
a resinous, petroleum-based, or other dust suppression agent, approved by the
Administrator, that effectively binds dust and controls wind erosion. (Waste oil is not
considered a dust suppression agent.) [ง61.154(c)(2)j.
ง61.154(d) - Rather than meet the no visible emission requirement of ง61.154(a), use an
alternative emissions control method that has received prior written approval from the
Administrator.
Figure 10-5 illustrates waste disposal site requirements.
SITE OPERATION RECORDKEEPING AND REPORTING REQUIREMENTS
(ง61.154(e)]
For all ACWM received, the owner or operator of the active waste disposal site must:
Maintain properly completed waste shipment records (WSRs) (see Figure 10-4).
Report in writing to the Administrator for the waste generator (and, if different, the
Administrator for the disposal site), by the next working day, the presence of a significant
amount of improperly enclosed or uncovered waste. Submit a copy of the WSR along with
1997 10-28
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the report.
Send a copy of the signed WSR to the waste generator as soon as possible, and no longer
than 30 days after receipt of the waste.
Upon discovering a discrepancy between the quantity of waste designated on the WSR and
the quantity actually received, attempt to reconcile the discrepancy with the waste generator.
(If the issue is not resolved within 15 days after receiving the waste, report this in writing to
the governmental agency responsible for administering the asbestos NESHAP program for
the waste generator and, if different, the governmental agency responsible for administering
the asbestos NESHAP program for the disposal site.).
Retain a copy of all required records and reports for at least 2 years.
SITE CLOSURE RECORDKEEPING AND REPORTING REQUIREMENTS
[ง61.154(f-h)]
Waste disposal site operators must:
Maintain, until closure, records of the location, depth and area, and quantity (m3 or yd3) of
ACWM within the disposal site on a map or diagram of the disposal area.
Upon closure, comply with the provisions of ง61.151 (Standard for inactive Waste
Disposal
Sites).
Upon closure, submit a copy of records of asbestos waste disposal locations and quantities to
the Administrator.
RECORD AVAILABILITY [ง61.154(i)]
Owners or operators of waste disposal sites must furnish upon request, and make available
during normal business hours for inspection by the Administrator, all records required under
ง61.154.
EXCAVATION NOTIFICATION (ง61.1540)1
The Administrator must be notified in writing at least 45 days before disturbing any deposited
ACWM. (Notification regarding a later start date must be received by the Administrator at least
10 working days before excavation; an earlier start date is not permitted.)
The notice must indicate:
scheduled starting and completion dates;
reason for disturbing the ACWM;
199V 10 ~ ^ y
-------
emission control methods to be used; and
locations of temporary/final disposal sites.
INACTIVE WASTE DISPOSAL SITES (ง61.151)
SITE OPERATION [ง61.151(a)]
Each owner or operator of any inactive waste disposal site that was operated by an asbestos mill,
manufacturer, or fabricator, or received ACWM from demolition, renovation, spraying or
conversion operations, must follow one of the following procedures:
Discharge no visible emissions from the site.
Cover the ACWM with at least 6 inches of compacted nonasbestos-containing material and
maintain a vegetative cover on it.
Cover the ACWM with at least 2 feet of compacted nonasbestos-containing material and
maintain it.
Use a resinous or petroleum-based dust suppressant agent or other Administrator-approved
agent (for asbestos tailings).
SITE DEMARCATION [ง61.151(b)]
If no natural barrier exists which adequately deters access by the general public, and the ACWM
has not been covered with nonasbestos-containing material as described above, warning signs
and fencing must be used.
1997 10-30
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No Visible Emissions
ง61.154(a)
AND
OR
Six Inch Cover of
Compacted
Nonasbestos-Containing
Material Within
24-Hour Period
ง61.154(c)(l)
OR
Cover with a Resinous
or Petroleum-Based Dust
Suppression Agent Within
24-Hour Period
ง61.154(c)(2)
AND
OR
Alternate Control
Method Receiving
Prior Approval
ง61.154(d)
AND
Warning
Signs
and Fencing
Natural
Barrier that
Deters Public
Access
Warning Signs
and Fencing
Natural
Barrier that
Deters Public
Access
Warning Signs
and Fencing
Natural
Barrier that
Deters Public
Access
Figure 10-5. Waste disposal site requirements.
OR
OR
OR
1997
10-31
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CONTROL ALTERNATIVES [ง61.151(c>]
Alternatives to the site operation/demarcation methods described above may be used if approved
by the Administrator.
EXCAVATION NOTIFICATION [ง61.151(d)]
The Administrator must be notified in writing at least 45 days before disturbing any deposited
ACWM. (Notification regarding a later start date must be received by the Administrator at least
10 working days before excavation; an earlier start date is not permitted.)
The notice must indicate:
scheduled starting and completion dates;
reason for disturbing the ACWM;
emission control methods to be used; and
locations of temporary/final disposal sites.
DEED NOTATION [ง61.151(e)]
Within 60 days of a site's inactivation, the owner or operator must record on the deed and any
other instrument normally examined during a title search that:
The land was used for ACWM disposal.
The survey plot and record of location and quantity of ACWM have been filed with the
Administrator.
The site is subject to 40 CFR Part 61 Subpart M (asbestos NESHAP).
1997 10-32
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SECTION 11
PRE-INSPECTION PLANNING AND PREPARATION
Pre-inspection planning and preparation help ensure that an inspection is conducted
smoothly, efficiently, and professionally. The following describes both generalized pre-
planning activities and those specific to the conduction of high-quality asbestos NESHAP
compliance inspections.
INSPECTOR RESPONSIBILITIES
During pre-inspection planning, an inspector should:
Gain an understanding of the objectives of the inspection and the specific areas to be
investigated.
Arrange logistics, including travel to and from the site, any special travel needs, and
hotel accommodations.
Assemble materials and equipment.
Coordinate with supervisors, attorneys, States, or others as appropriate.
Review pertinent regulations.
Gain an understanding of the Agency's:
standard operating procedures (SOPs);
health and safety plan;
quality assurance/quality control program.
Acquire appropriate credentials.
Make arrangements with the laboratory for the analysis of samples.
C unduct an agency file and compliance data systems review.
REVIKNN NOTIFICATION
Each notification received should be reviewed relative to the requirements of ง61.145(b).
Conducting such a review will assist the inspector in determining whether the asbestos
1997
-------
NESHAP regulation applies to the facility/activities reported and will help determine what
type of personal protective equipment may be needed. Particular attention should be paid to
the:
location of the facility;
schedule for demolition or renovation;
planned work practices; and
types and quantity of ACM involved in the demolition or renovation project.
When a notification regarding asbestos removal operations at a school is received, an
inspector should contact the Regional Asbestos Coordinator for information regarding the
site's compliance with AHERA and WPR regulations.
IDENTIFY NON-NOTIFIERS
The worst violation of the notification requirements of ง61.145(b) is complete failure to
notify. The following techniques can be used by inspectors to identify non-notifiers:
Respond to complaints from the general public, employees, or competitors who may
have recognized a very low bid award. Also, use cross-referral information from
other federal, State and local agency inspectors.
Note locations where demolition or renovation activities appear to be in progress.
The presence of a roll box for disposal of construction debris is strong evidence of
such activities.
Observe trucks entering a landfill and question their origin if suspected asbestos
debris is on board. Regularly review asbestos receiving records at landfills since
these can provide information on contractors who may not have notified.
Review demolition or renovation permits written by the local building department.
Review trade journals, newspapers, etc., for ongoing or past projects.
PREPARE INSPECTION EQUIPMENT/MATERIALS
In order to ensure the most efficient and complete inspection possible, an inspector must
gather and pack all equipment necessary for the inspection. A detailed list of equipment and
1997 11-2
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explanations of the purpose of each item follows. An equipment checklist is included in this
manual as Appendix A.
Copy of notification - The notification should be brought to the worksite so that the
information provided can be compared to on-site conditions.
Protective equipment - The following equipment should be available:
respirator (full-face negative-pressure; PAPR; SCBA)
respirator cartridges (HEPA, HEPA combination cartridges for ammonia,
organic vapors, acids)
respirator disinfectant
disposable, full-body, hooded coveralls
disposable gloves
steel-toed rubber boots or safety shoes
latex overboots
hard hat
duct tape
liquid soap
disposable towels
bathing suit (or equivalent)
climbing harness
disposable underwear
hearing protection
Note: Inspectors should use only agency-supplied respiratory protection that they
have been specially trained and fit-tested to use.
Employee identification - Proper credentials (to prove authority for performing the
inspection) and any certification cards of respiratory fit-testing or medical monitoring
should be brought to the worksite.
Copy of asbestos NESHAP regulation - The inspector can use this to resolve
disagreements if the owner/operator is unfamiliar with regulations; a copy should be
given to the owner/operator.
Inspection checklists - Checklists are useful as a reminder of the baseline information
needed for all inspections. See Appendices to this manual for copies of representative
checklists.
Bound notebook and writing implements - Inspectors should take notes and fill out
checklists to every extent possible before entering the removal area. Notebooks and
checklists should be left outside the contaminated area. Plastic clipboards, plastic
1997
11-3
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transparency sheets, and waterproof pens can be used to record worksite observations.
Following the inspection, the inspector can complete appropriate checklists.
Note: In some situations it may be critical to enter the work area quickly to assess
potential violations; in these cases the checklist and notebook entries can be
made after the inspection.
Camera (with flash) - Take photographs of sample locations and visible emission
sources. Waterproof cameras are convenient when wet removal is occurring and
decontamination is required. Bring extra batteries and film to the site.
Flashlight - Work may be conducted in areas with inadequate lighting such as
basements, above drop ceilings, and in buildings where the electricity has been turned
off. Waterproof, intrinsically-safe flashlights are recommended. Bring extra
batteries/bulbs to the site.
Binoculars - For off-site observations.
Tape measure - Although tape measures can be used to accurately quantify the
amounts of RACM, they are difficult to decontaminate. As an alternative, an
inspector may pace off distances and estimate distance based on a previously-
measured pace. Building diagrams can also prove useful in determining amounts of
RACM seen.
Chain-of-custody forms and labels - These forms and labels allow inspectors to
properly distinguish each sample and to maintain a record of sample possession and
transfer.
Shipping supplies - Samples may be sent to a laboratory from the field.
Sampling equipment - The following equipment and materials are used for bulk
sample collection:
sample containers
water spray bottle
tamperproof tape or labels
tools (needle-nose pliers, slotted and Phillips head screwdrivers, locking-blade
penknife, laboratory spatula)
drop cloth
wet wipes
plastic bags
glove bag (for those situations where waste bags are opened outside the
containment area)
disposable towels
1997 11-4
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bathroom caulking
labeled waste disposal bag
diver's bags
* Extra fresh batteries - for camera and flashlight
Business cards
Building diagrams (if available)
Office supplies
Manila folders/envelopes
Rubber bands
Paper clips
Waterproof watch
1997 H-5
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SECTION 12
FACILITY INSPECTIONS
On-site facility inspections provide the foundation for all asbestos NESHAP enforcement
actions for substantive violations and therefore are critical to enforcing the regulation. On-
site inspections are also used to determine whether potential AHERA, ASHARA (MAP) or
WPR violations exist.
Inspectors typically try to visit sites undergoing active removal; however, since all asbestos
NESHAP inspections are intended to be unannounced, inspectors may discover that removal
has not yet begun or has been completed ahead of schedule.
Inspectors should examine the renovation worksite no matter what the current status of the
operation is, for useful information regarding compliance/noncompliance with the provisions
of the asbestos NESHAP regulation may be gathered. Where violations of the regulation are
suspected, the inspector must gather evidence to prove his/her suspicions. Proper acquisition
and maintenance of evidence enhances the chances of success in bringing an enforcement
action against a facility and ensuring future compliance.
EVIDENCE
To run an effective asbestos NESHAP program (i.e., one that prevents asbestos air pollution),
one must be successful in bringing enforcement actions against violators of the regulation.
The severity of an enforcement action (and ultimately its deterrent effect) that can be brought
against a violator is often directly related to the amount of evidence the agency can produce
regarding the violations. For this reason, the gathering of evidence during on-site inspections
is a crucial component to the potential success of an asbestos NESHAP program.
The American Heritage Dictionary of the English Language defines evidence as "the data on
which a judgment or conclusion may be based, or by which proof or probability may be
established."
The law recognizes five types of evidence:
testimonial - a person's reported sense impressions and the opinions the person
formed based on them (e.g., the inspector's testimony);
real - the object, item or thing itself (e.g., ACM sample);
documentary - a "document" having significance and effect due to its content (e.g.,
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discrepancy reports, messages, logs, stationary source reports);
demonstrative - something other than the above which is prepared or selected to
illustrate or otherwise make some relevant fact clearer or easier to understand (e.g.,
photographs, diagrams, maps, summaries, videotapes); and
judicially noticed - matters about which there could be no dispute and become
evidence by virtue of their being so noticed by a judge (e.g., asbestos analytical
procedures, film development procedures, geographic locations, matters of common
knowledge).
Unless these forms of evidence are gained in an appropriate manner and maintained properly,
they may not be considered admissible in enforcement proceedings.
Field Logbook
The inspector's field logbook is the core of all inspection documentation. It should contain
accurate and inclusive documentation of all inspection activities. The logbook is used as the
basis for preparing the inspection report and to refresh the inspector's memory regarding the
specifics of sample collection and other inspection procedures should the inspector be called
upon to testify. Logbooks become part of the official inspection file.
Language in the logbook should be objective, factual, and free of personal feelings and
conclusions of law. The logbooks can be provided to the opposing side during the discovery
process of an enforcement case and can be entered as evidence in court.
Since an inspector may be called to testify in an enforcement proceeding long after the
inspection was conducted, it is imperative that each inspector keep detailed notes on every
aspect of the inspection, including interviews, visual observations, records assessments, and
sample collection and handling.
Entries in the logbook should correlate readily with particular samples and photographs
taken, and copies of records or other documentation collected by the inspectors. Use of
assigned identification numbers will allow tracing back to the exact time, place, conditions,
and procedures employed for gathering each piece of evidence.
General Procedures
Inspectors should:
Use only bound field logbooks, preferably with consecutively numbered pages.
Bound surveyors' logbooks may be acceptable.
Use a different logbook for each inspection.
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Make entries using waterproof ink.
Write legibly.
Line out (do not obliterate!) incorrect entries and initial them.
Write in the date and time of each entry.
At the end of an entry on a particular event, draw a diagonal line at the conclusion of
the entry and initial it. This will facilitate review of notes by the inspector and case
development staff.
Important Information
In the field logbook inspectors should provide information regarding the following:
Sampling procedures. Note that standard operating procedures have been followed
in the taking of physical samples.
Documents. Record all documents taken or prepared (e.g., photographs) and relate
them to specific inspection activities (such as sample taking).
Unusual conditions and problems. Describe in detail any unusual conditions or
problems.
Interview notes. Record the names, titles, and duties of facility personnel with notes
from the statements they make.
General information. Note the names and titles of facility officials, size of facility,
description of operations, number of employees, and other general information, such
as how the facility keeps its records, since this information may be useful in case
development or future inspections.
Other incidents. Keep detailed notes about any other incidents that occurred during
the inspection, such as an electrical power failure or tampering with government
vehicles or equipment.
Administrative data. Record entries regarding inspection travel and fiscal data in
accordance with Regional and/or program policy.
Identification numbers. Key each piece of evidence collected (document, physical
sample, photograph) to an entry in the field logbook.
Observations. Note conditions or practices that may be useful in inspection report
preparation or will contribute to valid evidence.
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General procedures. List all procedures followed involving entry, records
inspection, and document preparation. Such information will help avoid damage to
case proceedings on procedural grounds.
Statements
Since statements by site personnel can constitute important evidence in the determination of
violations of the asbestos NESHAP, it is essential for inspectors to develop good
interviewing techniques and record statements accurately. Inspectors should record the
name, title (and address, if possible) of all persons interviewed during the inspection.
An inspector should:
Conduct the interview in a comfortable, private location.
Behave in a considerate, nonthreatening, friendly manner.
Take notes as unobtrusively as possible.
Make no promises of confidentiality or protection.
Avoid leading or complex questions.
Ask questions from the general to the specific, and known to the unknown.
Keep time sequencing consistent.
Allow the interviewee to think and answer questions without interruption.
During the course of a site inspection, personnel may admit to or describe illegal activities
that have taken place on site. Such statements may be made because of health concerns or
ignorance of the regulations. While admissions or descriptions may not constitute conclusive
proof of a violation, they may be used to question the credibility of defendant(s) who make
subsequent contradictory statements. Proper elicitation and documentation of such
statements, therefore, is extremely important.
Bulk Samples
The taking of bulk samples is an essential component of an asbestos NESHAP inspection.
Without analytical results proving the existence of asbestos-containing materials on site, an
inspector will find it difficult, if not impossible, to prove that the asbestos NESHAP
regulation was applicable to the facility visited.
Bulk sample locations should be recorded on a site diagram (see Figure 12-1) and pertinent
information recorded in a sample collection log (see Appendix E).
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Although the Clean Air Act does not specifically state whether samples should be split with
the site owner or operator, when requested to do so, inspectors should split samples in order
to maintain good relations between the agency and the source.
Inspectors must be able to testify that the samples:
accurately represent conditions at the site;
were maintained using proper chain of custody; and
were acquired and analyzed using proper methodology.
Observations
Since enforcement cases may not be resolved for years, an inspector must record accurately,
and in sufficient detail, all pertinent observations made. Observations of noncompliance
should be detailed in field notes and supported by personnel statements, photographs, and
drawings as needed (see Figure 12-1).
Photographs
To be admissible as evidence, photographs must accurately and truthfully represent site
conditions at the time in question. Photographs must be taken in sufficient number, be of
high quality, and contain appropriate identification. Although use of a video camera can
provide excellent documentation of an asbestos site inspection, decontamination is a concern.
Inspectors should become familiar with the operation of the camera well before its use
becomes necessary; failure to do so can prove to be exceedingly troublesome, as significant
documentation can be lost (and considerable embarrassment incurred!).
Inspectors should pay particular attention to the following:
focal distance of the lens;
flash distance;
film type and batteries needed; and
how to load the film and batteries.
Photographic documentation should tell the story with as little need for narrative as possible.
This is done by shooting a series of shots which provide general to specific information.
"Establishing shots" are taken from a distance and show not only the subject but one or
several permanent landmarks which can be used for reference in establishing the exact
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location. Subject shots emphasize a specific object or event. Subject shots may be shot in
sequence to show all sides of a subject. "Tight" or "detail" shots are closeup shots which
provide very specific information concerning the subject.
All photographs taken should be noted on a site diagram (see Figure 12-1) and in a
photograph log. This log includes site identification information and picture/frame numbers,
detailed descriptions of the photographic subjects, and dates/times when the pictures were
taken^ The log will become part of the inspection report. A sample photograph identification
log sheet is provided as an appendix in this manual.
Rm. 1305
P2
decon
N
W
SI
S2
S3
-35'
1
~2r
P3
S4 S5
S6
LEV
2,000
cfm
Site Code
Date:
^ sample
I' photograph
Location at site:
Inspector's initials:
Figure 12-1. Abatement area diagram
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Once the photographs have been developed, the inspector should immediately record in
indelible ink the following information on the back of each print:
site name;
date of inspection;
photograph number (as noted in the photograph log);
subject of photograph; and
photographer (inspector) initials.
Records
Inspectors may need to review a variety of records during the conduction of asbestos
NESHAP inspections. These include building and worksite diagrams, as well as waste
shipment records, discrepancy reports, exception reports, stationary source reports, etc.
Required records should be checked for completeness and accuracy,, and retention times
assessed.
If copies of pertinent documents are acquired by the inspector, they should be marked with
the inspector's initials and a code, such as "Attachment A", and detailed in the field log book.
The log book should indicate:
what the document is;
who provided the document; and
the actual physical location of the original document.
PRE-ENTRY OBSERVATIONS
Pre-entry observations (which may be conducted remotely using binoculars) can help
determine the location(s) and type(s) of activities in progress and aid in the selection of
appropriate safety equipment.
Upon arriving at the site, an asbestos inspector should:
Drive around the site and try to establish the magnitude and location of the asbestos
project within the facility.
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Make note of areas to visit (office trailers, waste storage sites, waste load-out areas,
etc.).
Look for visible emissions to the outside air (from windows, doors, etc.) and suspect
ACWM debris outside the facility.
Draw a diagram of (see Figure 12-2) and record on film, land use surrounding the site
(residential, industrial, recreational, etc.).
GAINING ENTRY
To help ensure the admissibility of evidence gathered during an inspection, inspectors must
be able to testify that proper entry was made. Inspectors should:
Visit the facility at a reasonable time (whenever abatement is ongoing).
Enter through the main gate or office.
Locate the person in charge (facility representative, site supervisor) as soon as
possible.
Present identification (credentials) to the person in charge. (State and local inspectors
may need to present specific licenses or certificates to gain entry.)
Explain the purpose of the inspection (compliance with the asbestos NESHAP).
Describe the legal basis for the inspection [Section 114(a)(2) of the Clean Air Act
states that EPA inspectors "have a right of entry to, upon, or through any premises in
which an emission source is located..."].
Describe the scope of the inspection (site inspection, records' review, interviews,
photographs, samples, etc.).
Once these conditions are met, the inspector should begin the inspection. (The facility
representative need not express consent to conduct the inspection. Absence of expressed
denial constitutes consent to proceed.)
On occasion, inspectors will be unable to adhere precisely to recommended entry procedures.
For example, if an unmarked transport vehicle is noticed being loaded with suspect ACWM,
and the inspector suspects that the vehicle may soon leave the property, the inspection should
begin at that location. Such deviations from typical entry procedures must be documented
and justified in the field notes and inspection report.
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Business
Church
City Park
Hi-Rise
Apartment
Buildings
PI
X
t
P2
P3
Mini-mall
Office Building
Office Building
4' fence
400'
Locked
oo
c.
ฐ5
s
ACME Brake Shoe Co.
250'
Parking lot
P4, Sl-4
4' fence
Elementary
School
Wind (NW)
w
N
4' fence
Day Care
Center
Warehouse
Warehouse
Figure 12-2. Land Use Diagram
12-9
C/7
o
c
c
c
Single-family
homes, small
businesses
-------
Denial of Entry
Denial of entry to a site may take several forms: refusal of access to the site, unreasonable
delays, changes in the conditions of inspection, or threats to the safety of the inspector.
Verbal Refusal
An inspector may occasionally be verbally denied access to the facility. Should this happen,
the purpose and authority of the inspection should again be explained to the site
representative. If this proves unsuccessful, the inspector should tell the representative that
the agency's regulatory attorney will be informed and, if necessary, a warrant to gain entry
will be sought.
Unreasonable Delays
If the requested facility representative does not appear after a reasonable amount of time (10-
15 minutes), inspectors should make known to the person in charge (secretary, receptionist,
abatement worker, etc.) that continued delay will be considered denial of entry.
Change in Conditions
Any change in conditions of the inspection clearly understood in the opening conference (use
of photography, gathering of samples, etc.) which compromises the inspector's ability to
conduct or document the inspection constitutes denial of entry.
Threats
Verbal or implied threats of bodily harm are considered denial of entry .PRE-ENTRY
INTERVIEW
In addition to the activities described for gaining proper entry, inspectors should:
Determine the applicability of the regulation to the site.
In order for the asbestos NESHAP regulation to apply, the following must be true:
the site is a "facility" as defined in the regulation;
activities occurring at the site are regulated (demolition, renovation, waste
disposal, etc.); and
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regulated amounts of RACM are being disturbed.
Present evidence of medical monitoring.
In some instances a facility representative may demand to see proof that an inspector
is meeting the requirements of the OSHA medical monitoring program. This is a
reasonable request, for even though EPA personnel are not specifically subject to the
requirements of the OSHA standard, they must comply with the provisions of EPA's
health and safety guidelines which are very similar.
Establish the identities of all responsible individuals.
These include the abatement contractor supervisor, building owner, hygienist, etc.
Collecting business cards from these individuals is a good practice.
Determine whether a notification exists; if it does, review all information with
the facility representative.
Although the asbestos NESHAP regulation requires owners/operators to update
notifications when changes occur, this may not happen. An inspector, therefore, may
have an inaccurate notification form when visiting a facility and should review the
form with the on-site representative to correct inaccuracies. (In some circumstances
very little of the original notification still applies - the contractor, transporter and
waste disposal site may all be different!)
Sign no liability waivers.
It is EPA's policy that liability waivers never be signed. Other inspectors should
follow the specific policies of their State or local agencies. Inspectors should sign
entry logs (which document their presence on site) when requested to do so.
Determine a logical sequence for the site inspection.
Preplanning which areas to visit will promote the overall efficiency of the inspection.
Discuss safety considerations.
The inspector should ask the on-site representative to describe the type of asbestos
being abated (amosite, chrysotile), work practices being employed (wet or dry
removal, use of amended water) and types of potential hazards in the facility
(overhead obstacles, active chemical lines, etc.). The inspector should use this
information to make a preliminary determination regarding the type of personal
protective equipment to use.
Determine the expertise of the owner/operator of the abatement project.
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The inspector should ask questions regarding the owner's/operator's previous
experience, training, and understanding of the NESHAP requirements for the
handling of asbestos during removal.
PRE-ENTRY WORKSITE OBSERVATIONS (OSHA/NESHAP/MAP
COMPLIANCE)
Inspectors should examine the worksite area and make a preliminary assessment of the
project's compliance with the OSHA and NESHAP regulations and other pertinent standards
(e.g., AHERA, ASMARA (MAP), etc.). The project may be in compliance if:
There are records that show that all employees have been trained as required.
OSHA - Individuals who are conducting work subject to the OSHA
Construction Standard must be trained as specified in the Standard. Records
must be kept by the employer for one year beyond the last date of employment
by that employer (29 CFR Part 1926.1101 - Occupational Exposure to
Asbestos).
NESHAP requires that one on-site representative at a demolition or
renovation site be trained in the provisions of the asbestos NESHAP
regulation and that evidence of such training be posted and made available for
inspection at the site (40 CFR Part 61).
AHERA - For individuals subject to the provisions of the AHERA regulation
(public and private schools K-12), training records must be kept in a
centralized location in the administrative office of both the school and the
local education agency as part of the management plan (40 CFR Part 763 -
Asbestos-Containing Materials in Schools).
Note: A sample AHERA Compliance Referral Form is included as
an appendix to this workshop manual.
ASHARA - Individuals conducting work subject to the ASHARA (MAP)
regulation (public and commercial buildings) must have their initial and
current accreditation certificates at the location where they are conducting
work [40 CFR Part 763, Subpart E, Appendix C - Asbestos Model
Accreditation Plan].
Note: A sample ASHARA Compliance Referral Form is included as an
appendix to this workshop manual.
Individuals performing abatement work in facilities other than schools, public,
or commercial buildings need not be accredited under the MAP; they may,
however, be subject to State and/or local training requirements.
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Amended water is being used to wet ACM. (Note whether amended water is on-site
outside the envelope.).
No power tools are being used to remove ACM.
The envelope is secure and no dust or debris appears to be coming from the removal
area.
Warning signs are posted and adequately labeled containers are being used.
Decontamination accommodations, including shower facilities, are in place.
Existing monitoring data indicate that asbestos fibers in the work area do not exceed
2.0 f/cc as an 8-hour TWA.
A reduced-pressure enclosure has been established. HVAC systems, excluding LEV
systems, should be inoperative. Envelope entrances should have a double barrier seal.
Materials removed from the envelope have been cleaned and the pathway for removal
of bags and equipment is clear and clean.
Waste shipment records are available for review.
ป Generator labels are present at the worksite.
PRE-REMOVAL INSPECTION
Facility inspections conducted prior to commencement of asbestos removal do not enable the
inspector to fully evaluate the owner/operator's compliance with the asbestos NESHAP.
However, if an inspector does arrive prior to the onset of removal activities, useful
information still can be gathered. In this case the principal objectives are to verify that the
asbestos NESHAP is applicable and that the owner/operator has the ability to remove the
asbestos properly.
As with any inspection, safety must be considered before the inspection begins. The type of
personal protection used is determined by the inspector. As a general rule, however, if any
friable ACM or nonfriable ACM in poor condition is being disturbed, the inspector should
treat the inspection as an active removal situation and follow appropriate suit-up procedures.
The following summarizes inspection activities relative to NESHAP requirements. The
entire NESHAP text can be found in supplemental materials accompanying this manual.
Applicability [(งง61.141,61.145(a)J
Examine the area to be abated to verify that 260/160/35 will be met.
Notification [ง61.145(b>]
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Determine the accuracy of information conveyed during the pre-inspection interview.
Is the worksite location accurate?
Are the amounts and types of RACM designated for removal accurate relative to what
the inspector thinks will potentially be disturbed during the demolition or renovation?
Planned Emission Controls [ง61.145(c)]
Observe equipment on site and elicit verbal explanations of planned emission control
procedures to ascertain whether the owner/operator is sufficiently equipped and
knowledgeable to meet the wetting and handling requirements of ง61.145(c). Consider the
following:
Will water and wetting agents be available for wetting ACM before removal and for
maintaining it in a wet condition until it is collected for disposal?
If wet methods will not be used, what emission control methods are planned?
Will RACM be removed or stripped more than 50 feet above ground level? If so,
how will it be brought down?
Be aware that the asbestos NESHAP allows exemptions from removal, stripping, wetting,
and packaging of RACM in certain situations. A detailed description of these exemptions
can be found in "Emission Control" of the "ACTIVE REMOVAL INSPECTIONS"
portion of this section.
Disposal Techniques (ง61.150)
Although several waste disposal options are delineated by the asbestos NESHAP, most
owner/operators choose to remove RACM and package it for off-site transport. Inspectors
should determine the following:
Are leak-tight containers or wrapping available to package RACM?
Do these containers or wrappings exhibit the required OSHA warning label?
If the RACM to be removed is destined for off-site transport, are labels containing the
name of the waste generator and the location at which the waste was generated
available for use?
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Note: Either the owner's or operator's name is acceptable for identification of the
waste generator, but many regulators prefer the operator's name be used.
Where will the ACWM be deposited and how often will it be removed from the
worksite?
Has a permit for disposal been obtained? (not required by NESHAP)
Are waste shipment record (WSR) forms available for use?
Is the owner/operator aware of the NESHAP requirements regarding use of WSRs?
(e.g., required information, delivery to waste disposal site, verification of disposal,
recordkeeping, etc.)
Evidence Collection
In addition to the general information conveyed by the owner/operator, the following
evidence should be collected by an inspector during a pre-removal inspection:
Measurements of area, linear footage or volume of suspect RACM that will be
disturbed during the project.
Document technique of measurement - tape measure, pre-measured pace, etc.
Samples of materials which were stated in the notification to be RACM. Collect
these samples and document (using sketches and photographs) their specific locations
within the facility. If the owner/operator later states that the notification was
inaccurate (e.g., that the material removed did not contain asbestos), these samples
may provide legal evidence to the contrary.
Samples of friable and nonfriable suspect ACM which is likely to be disturbed
during the demolition or renovation but which was not listed by the
owner/operator in the notification.
Collect these samples and document (using sketches and photographs) their specific
locations within the facility.
ACTIVE REMOVAL INSPECTIONS
To fully evaluate compliance of the asbestos NESHAP, an inspector must be prepared to
enter the active removal area. The inspector should follow the procedures discussed
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previously for pre-inspection observations and interview. The information gathered during
pre-inspection activities will enable the inspector to select appropriate safety equipment and
procedures to follow.
The inspector's principal objectives in entering the active asbestos removal area are to: (1)
make first-hand observations of the adequacy of wetting and maintaining wetness until
RACM is collected for disposal; (2) take samples of any suspect RACM to serve as evidence
that a violation involved asbestos-containing material; and (3) accurately determine whether
the quantity of suspect ACM meets the minimum regulated quantity of 260/160/35.
Removal Area Entry Preparation
If a three-stage decontamination unit is available, enter the clean room, remove street
clothes (except bathing suit), and suit-up appropriately. Store street clothes in a
plastic bag to keep them dry and clean.
If there is no 3-stage decontamination unit, suit-up with double disposable coveralls
over street clothes.
Gather up inspection and sampling tools. Take into the active removal area only
items that are disposable or can be cleaned in the shower. See Appendix A for a
comprehensive checklist of inspection materials.
Applicability [งง61.141,61.145(a)]
Has 260/160/35 been met?
Notification [ง61.145(b)]
Is the worksite location accurate?
Are the amounts and types of RACM being disturbed accurately noted on the
notification form?
Emission Control |ง61.145(c)]
Has all RACM been removed from a facility being demolished or renovated before
any activity begins that would break up, dislodge, or similarly disturb the material or
preclude access to the material for subsequent removal? [ง61.145(c)(l)]
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For facility component unit/section removal [ง61.145(c)(2)]r
Has RACM exposed during cutting or disjoining operations been adequately
wetted?
Are the units/sections carefully lowered to the floor or ground level and not
dropped, thrown, slid or otherwise damaged or disturbed?
Is RACM adequately wetted while being stripped from in-place facility components
[ง61.145(c)(3)]
Has a facility component which has been removed in units/sections been stripped or
contained in leaktight wrapping? [ง61.145(c)(4)]
Has the RACM, including material that has been removed or stripped [ง61.145(c)(6)J:
been adequately wetted and maintained wet until collected and contained or
treated in preparation for disposal?
carefully lowered to the ground and floor without dropping, throwing, sliding
or otherwise damaging or disturbing it?
(If the RACM has been removed or stripped more than 50 feet above ground
level and it was not removed as units or in sections, has it been transported to
the ground in leak-tight chutes or containers?
Is there evidence posted at the site that at least one on-site representative has been
trained in the provisions of this regulation and the means of complying with them?
[ง61.145(c)(8)]
During an ordered demolition, is the portion of the facility containing RACM
adequately wetted during the wrecking operation? [ง61.145(c)(9)]
Has all RACM, including Categories I and II nonfriable ACM been removed before
intentionally burning a facility? [ง61.145(c)(10)]
Determination of Adequately Wet
"Adequately wet" (as defined in ง61.141) means to:
"sufficiently mix or penetrate with liquid to prevent the release ofparticulates. If
visible emissions are observed coming from asbestos-containing material then that
material has not been adequately wetted However, the absence of visible emissions
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is not sufficient evidence of being adequately wet."
The inspector is responsible for the overall determination of "adequately wet" relative to the
above listed citation from the asbestos NESHAP. It is important for an inspector to
document whether or not material has been adequately wetted and how this determination
was made. (Refer to EPA's Asbestos/NESHAP Adequately Wet Guidance document found in
the supplemental materials accompanying this manual.)
The following questions and procedures will help document compliance with this provision
of the asbestos NESHAP:
Is there a water supply in place?
Is water or a wetting agent observed being sprayed onto the RACM or ACWM both
during stripping or removal and afterwards while the material awaits proper disposal?
If yes, carefully note the method of application used (e.g., misting, fogging, spraying
of surface area only, or drenching to penetrate the ACM throughout).
Does the equipment used to apply the wetting agent appear to be operating properly?
If an aqueous solution is not being used, determine why it is not and document the
reason. Possible (although not necessarily valid) reasons include:
prior permission obtained from the Administrator (safety hazard, potential
equipment damage);
no water source at the facility;
temperature at the point of wetting below 32 degrees F;
portable water supply ran out and contractor continued to work; or
contractor prepared the area earlier, etc.
Examine a stripped or removed piece of suspect ACWM or RACM which wets
readily. Does it appear to be wetted throughout? If it does not, adequately wet the
sample. Describe and photograph how the physical characteristics of the material
change upon wetting (e.g., color, weight, texture, etc.). Take samples, as necessary,
to document the presence of asbestos in the suspect material.
When examining materials that do not readily absorb a wetting agent (e.g., premolded
thermal system insulation, ceiling tiles, floor tiles), inspectors should note whether all
exposed surfaces of these materials have been wetted as required.
Is there visible dust (airborne or settled) or dry suspect ACWM debris in the
immediate vicinity of the operation? Collect samples of such materials and analyze
them to determine their asbestos content.
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Emission Control Exemptions [งง61.145(a, c), 61.150(a)]
If the owner/operator is not following standard work practices relating to removal, stripping,
wetting and packaging of RACM, the inspector must carefully evaluate whether activities
seen are justified by the following exemptions in the asbestos NESHAP:
Removal of ACM is not required before demolition if it:
ง61.145(a)(3)] - is located in a building which has been ordered by a government
authority to be demolished. Wetting of the portion of the facility that contains
RACM is required during the wrecking operation per ง61.145(c)(9), and ACWM
must be handled in accordance with waste disposal requirements of ง61.150.
ง61.145(c)(l)(i) - is Category I nonfriable ACM that is not in poor condition and not
friable.
ง61.145(c)(l)(ii) - is on a facility component encased in concrete or other similarly
hard material and is adequately wet whenever exposed during demolition. (Doubled
concrete-block walls with risers inside do not meet the "encased in concrete"
definition.)
ง61.145(c)(l)(iii) - was not discovered until after demolition began and therefore
cannot be safely removed. The exposed RACM and any asbestos-contaminated
debris must be treated as ACWM and must be adequately wet at all times until
disposed of.
ง61.145(c)(l)(iv) - is Category II nonfriable ACM and the probability is low that the
material will become crumbled, pulverized, or reduced to powder during demolition.
Stripping of ACM from facility components is not required:
ง61.145(c)(4) - if the components have been taken out of the facility as a unit or in
sections contained in leak-tight wrapping.
ง61.145(c)(5) - if large facility components (excluding beams) are handled without
disturbing or damaging the RACM, are wrapped leak-tight, and are appropriately
labeled.
Wetting is not required in renovation operations if:
ง61.145(c)(3)(i) - it would unavoidably damage equipment or present a safety hazard.
Written approval from the Administrator must be obtained (and kept at the worksite)
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and either a local exhaust ventilation and collection system, glove-bag system, or
leak-tight wrapping prior to dismantlement must be employed.
ง61.145(c)(3)(ii) - the Administrator has given written approval to an alternate
equivalent method. This approval must be kept at the worksite.
ง61.145(c)(4) - a facility component taken out as a unit or in sections is contained in
leak-tight wrapping, or an LEVC system is used while stripping the component.
ง61.145(c)(7) - the temperature at the point of wetting is below freezing. Facility
components must be removed as units or in sections to the maximum extent possible
and temperature records maintained.
Packaging of ACWM prior to disposal is not required if:
ง61.150(a) - no visible emissions are discharged to the outside air during the
collection, processing (including incineration), packaging, or transporting of any
ACWM generated by the source.
ง61.150(a)(3) - the ACWM results from a government-ordered demolition. (Wetting
requirements still apply.)
Disposal Techniques (ง61.150)
Although several waste disposal options are delineated by the asbestos NESHAP, most
owner/operators choose to remove RACM and package it for off-site transport. During an
active removal inspection inspectors should determine whether:
There are visible emissions to the outside air during the collection, processing
(including incineration), packaging, or transporting of any ACWM.
The inspector must determine the source of the visible emission and sample the
source to verify that the emission contains asbestos material. It is not necessary to be
a certified visible emission observer to legally document whether a visible emission
exists. The presence of asbestos in such dust constitutes a violation of ง61.150.
ACWM is being adequately wetted.
ACWM generated during ordered demolitions or demolitions where RACM is not
required to be removed is kept adequately wet at all times after demolition and kept
wet during handling and loading for transport to a disposal site. (Sealing in leak-tight
containers or wrapping is not required; ACWM may be transported and disposed of in
bulk.)
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Leak-tight containers or wrapping are being used to package removed RACM.
Containers or wrappings exhibit the required OSHA warning label.
Containerized RACM destined for off-site transport is labeled with the name of the
waste generator and the location at which the waste was generated.
Vehicles used to transport ACWM are appropriately marked during loading and
unloading.
The ACWM will be deposited at an appropriate waste disposal site as soon as is
practical (excluding removed or stripped Category I nonfriable ACM that is not
RACM).
Inspectors should verify ACWM destination information reported in the notification.
This information can provide the inspector with an opportunity to visit a disposal site
and conduct an inspection while deposition of ACWM is taking place.
Inspection of Waste Containers
The presence of a regulatory inspector often causes the owner/operator to quickly and vastly
improve wetting procedures. Inspectors can determine typical wetting procedures, however,
by evaluating the contents of waste containers found both inside containment and in other
waste storage areas. The following protocol should be followed:
Randomly select bags or other containers for inspection.
Lift the bag or container to assess its overall weight. A bag of dry ACWM can
generally be lifted easily with one hand, whereas a bag filled with well-wetted
material is substantially heavier.
If waste material is contained in a transparent bag:
Visually inspect the contents of the unopened bag for evidence of moisture (e.g.,
water droplets, water in the bottom of the bag, change in color of the material due to
the presence of water, etc.).
Without opening the bag, squeeze chunks of debris to ascertain whether moisture
droplets are emitted.
Note: Squeezing cannot be used to determine adequate wetting of materials such as
ceiling tiles, floor tiles, or premolded TSI, etc. which do not readily absorb a wetting
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agent. For these materials, determine whether exposed surfaces have been adequately
wetted, document information, and take samples as needed.
If the material appears dry or not penetrated with water or a wetting agent, open the
bag using steps described below and collect a bulk sample of each type of suspect
material in the bag. Document variations in size, patterns, colors, and textures of
adequately- and inadequately-wetted materials seen.
If the waste material is contained in an opaque bag or other container, or if the material in
a transparent bag appears to be inadequately wetted:
Carefully open the bag or other container (in the containment area, if possible). If
there is no containment area, use a glove bag to enclose the container prior to opening
it. This will minimize the risk of fiber release.
Examine the contents of the container as noted above for evidence of moisture.
Document findings, take samples as needed, and carefully reseal the opened
container.
Note: If inadequately packaged suspect RACM stored outside is discovered upon
arrival at a worksite, don protective gear and take samples before continuing the
on-site inspection.
Waste Shipment Records [ง61.150(d)j
Asbestos inspectors should examine whatever on-site records exist to help determine if the
owner/operator is complying with the waste shipment recordkeeping requirements of the
asbestos NESHAP. Inspectors should obtain copies (or originals) of documents which
indicate potential noncompliance. If originals are acquired, inspectors should leave a receipt
with the facility representative and quickly return the originals after making copies for the
Agency.
Evidence Collection
The following specific evidence should be collected by an inspector during an active removal
inspection:
Measurements of area, linear footage, or volume of suspect RACM to accurately
document that 260/160/35 is met.
Document measurement technique (tape measure, pre-measured pace, etc.).
Samples of material which were stated in the notification to be RACM.
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Collect these samples and document (using sketches and photographs) their specific
locations within the facility. If the owner/operator later states that the notification
was misrepresentative (i.e., that the material removed did not contain asbestos), these
samples may provide legal evidence to the contrary.
Samples of suspect RACM to document violations of the work practice
standards. Document specific sample locations using photographs and sketches.
Samples of friable and nonfriable suspect ACM which has been, or is likely to be
disturbed during the demolition or renovation and which was not listed by the
owner/operator in the notification.
Collect these samples and document (using sketches and photographs) their specific
locations within the facility.
Documents, statements of site personnel, and photographs which illustrate
potential noncompliance.
TSCA Compliance
During the inspection the inspector can also check for evidence of apparent violations of the
AHERA, ASHARA (MAP) and WPR regulations. AHERA regulates asbestos abatement
work conducted at schools. ASHARA (MAP) deals with abatement activities in public and
commercial buildings. WPR regulations apply to State and local government employees who
conduct asbestos abatement work and are not covered by the OSHA asbestos standard.
Abbreviated checklists for the AHERA, ASHARA and WPR regulations are included as
appendices to this workshop manual. The appropriate asbestos program personnel should be
contacted and informed about the possible violations noted.
Exiting the Removal Area
The inspector will leave the active removal area when satisfied that the operation complies
with the requirements of the asbestos NESHAP or has collected sufficient evidence
(observations, samples, photographs, owner/operator admissions) to document potential
violations. It is essential that the inspector properly decontaminate himself/herself and any
items taken into the active removal area that will not be disposed of as asbestos-contaminated
waste.
If a 3-stage decontamination unit is available, enter the dirty room, remove disposable
clothes (keep the respirator on), move into the shower area, quickly rinse head region
and body, and remove respirator. Wet and dispose of filter cartridges. Finish
showering and dry off using disposable towels. Move to clean room to dress in street
clothes.
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If there is no three-stage decontamination unit, just prior to exiting, spray with water
and then remove the outer layer of the doubled disposable coveralls. Spray and
remove the second layer just after exiting. Use wet wipes to clean potential asbestos
fibers from the respirator and face area before removing the respirator and disposing
of cartridges.
POST-REMOVAL INSPECTION
Inspection of a facility after asbestos removal has been completed is the least preferred option
since an improper removal already would have released fibers to the ambient air. An
inspector arriving after removal has taken place, however, can still gather useful information.
The inspector will determine whether the use of protective clothing and respiratory protection
is necessary. As a general rule, if an inspector has any doubt concerning whether the area is
cleared for reoccupancy, he/she should treat the inspection as an active removal situation and
follow appropriate suit-up procedures.
The following inspection procedures apply to most post-removal inspections.
Applicability [ง61.141, ง61.145(a)]
Examine the abated site to verify that the amount of RACM disturbed met the
260/160/35 requirement. Document how the area was measured.
Notification [ง61.145(b)]
Note whether information conveyed during the pre-inspection interview is confirmed
by on-site observations.
Emission Controls [ง61.145(c>]
Verify that all RACM required to be removed has been removed from a facility
scheduled for complete demolition. Take samples as needed.
Verify that all RACM, including Category I and Category II nonfriable ACM, has
been removed from a facility scheduled to be demolished by intentional burning.
Take samples as needed.
Visually inspect all renovated areas from which RACM is said to have been removed
to verify that it has been done. No dust or debris should be left behind. Take samples
as needed.
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Visually inspect other areas of the facility that will be disturbed during the impending
demolition or renovation to determine if any other suspect RACM exists. Determine
if 260/160/35 will be met and take samples as necessary.
Waste Disposal (ง61.150)
If waste is still stored on site at the time of a post-removal inspection, inspect the containers
to determine compliance. Use safety equipment and appropriate sampling procedures.
Inspect for leaking or ripped bags, or other evidence of asbestos contamination.
Lift bags or containers to assess their overall weight. A bag of dry ACWMcan
generally be lifted easily with one hand, whereas a bag filled with well-wetted
material is substantially heavier.
Inspect bags as noted in "ACTIVE REMOVAL INSPECTIONS".
Evidence Collection
In addition to the general information conveyed by the owner/operator, the following specific
evidence should be collected by an inspector during a post-removal inspection:
Samples of any suspect RACM left behind as dust, debris or residue.
Measurements of area, length, or volume where RACM was removed, in order to
establish that the facility met the applicability requirements.
Note: Document technique of measurement - tape measure, pre-measured pace, etc.
Samples of any dry RACM from the storage area if still available.
Sketches and photographs are advisable to illustrate specific locations of samples.
Documents, statements of site personnel, and photographs which illustrate potential
noncompliance.
POST-INSPECTION INTERVIEW
When the inspection is complete, the asbestos NESHAP inspector should conduct a quick,
concise wrap-up interview to obtain any additional information necessary to complete the
checklist and to convey to the owner/operator the findings of the inspection.
Inspectors should give the owner/operator a copy of the regulation and make note of this in
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the log book. Using this copy the inspector should discuss with the owner/operator the
specific provisions of the regulation which may have been violated at the site and should
document how the owner/operator reacted to the items discussed, for this information may
prove useful if similar violations are identified during follow-up inspections.
Inspectors should avoid conveying compliance determinations to the owner/operator for
several reasons:
The inspector has not had time to reflect upon and correlate all observations made.
Laboratory analyses have not been completed.
The intricacies of EPA-administered statutes/regulations do not lend themselves to
"off-the-cuff assessment.
The inspection findings may represent only a portion of the enforcement case.
The inspector should never say "No violations were seen." or "Everything is OK.", as such
statements may create difficulties if the inspector recognizes potential violations after
conducting the inspection.
Also, the inspector should not supply a copy of field notes or inspection checklist to the
owner/operator at the time of the inspection, for any changes or additions the inspector makes
to such documents after leaving the site may be called into question should an enforcement
action be pursued.
EXIT OBSERVATIONS
As the inspector departs a site, he/she should resurvey the site and complete any site
drawings not completed prior to or during the inspection. If possible, the inspector should
observe the waste storage area and other areas to determine if any significant changes have
occurred since the inspection began. Such changes should be noted as they help to assess
whether the inspection observations are representative of operations when a regulatory
inspector is not present. Finally, chain-of-custody forms for any samples collected should be
completed.
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SECTION 13
LANDFILL INSPECTIONS
The asbestos NESHAP provides emission control and work practice requirements from the
time the asbestos is disturbed (potentially releasing airborne fibers) until it is interred in a
landfill or converted into asbestos-free materials. However, since no conversion operations
are currently licensed, demolition/renovation ACWM typically is transported to landfills for
disposal. Regulatory agents should be prepared to conduct inspections of such sites and
should use appropriate personal protective equipment and bulk sampling procedures when
doing so.
It is important to recognize that both the owner or operator of a demolition or renovation
operation and the owner or operator of the active waste disposal site where ACWM is
brought are required to meet waste disposal provisions of the asbestos NESHAP.
Generators must comply with ง61.150 (Standardfor waste disposal for..., demolition,
renovation... operations), and waste disposal site operators must comply with ง61.10
(Source reporting...), ง61.153 (Reporting), and ง61.154 (Standardfor active waste disposal
sites). To assist waste disposal site operators, EPA produced and distributed the document
Reporting and Recordkeeping Requirements for Waste Disposal (EPA 340/1-90-016) which
can be found in supplemental materials accompanying this manual.
This section details waste disposal site owner/operator responsibilities and the procedures an
inspector should use to ascertain whether a landfill is being operated in compliance with the
asbestos NESHAP. A sample inspection form for landfills can be found in Appendix D of
this manual.
TARGETING WASTE DISPOSAL SITES
Waste disposal sites should be selected for inspection based on their size, the amount of
asbestos waste accepted for disposal, other enforcement actions (i.e., RCRA), and exception
reports, etc. Such information may be obtained from a variety of sources:
Landfill lists. Lists of landfills may be obtained from EPA Regional Offices, and
State and local agencies. Only some of these lists indicate whether ACWM is
accepted by a particular landfill; however, individuals noted on the lists may be
contacted to provide additional information.
Notifications. Information pertaining to landfills not previously known to accept
ACWM may be found in generator notifications. Additionally, any landfill noted
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which is scheduled to receive large quantities of AC WM should be targeted for
inspection.
Previous inspection reports. Waste disposal sites identified in inspection reports
concerning demolitions or renovations performed out of compliance should be
targeted for inspection.
PLANNING THE WASTE DISPOSAL SITE INSPECTION
A NESHAP inspector who takes the time to properly plan a field inspection will find that the
actual inspection will be accomplished more efficiently and will be more productive. To
prepare for an asbestos landfill inspection, an inspector should:
Become familiar with the types of records a facility is required to maintain.
Review agency files.
Determine whether the landfill to be inspected has been identified as the waste
disposal site on demolition/renovation notifications received. Make copies of
such notifications for comparison to waste shipment records kept by the owner
or operator of the waste disposal site.
Determine if any reporting or recordkeeping problems have been reported for
the site (e.g., an unexpectedly large number of exception reports). If the
removal jobs and the disposal site are in the same regulatory jurisdiction, this
will be easy to do, since generators are required to inform the regulatory
agency in charge if there are problems with the disposition of their ACWM. If
the disposal site is located outside the regulatory jurisdiction, however, such
information may not be available, for generators are not required to inform the
agency responsible for the waste disposal site. Make copies of such
information.
{ \amine landfill-generated reports (discrepancy, stationary source,
improperly-contained ACWM, closure, and excavation/disturbance reports).
Ke\ ieu any complaints submitted.
Cormv.unu Jte with other agencies or departments. City building departments may
issue dem.'litmn'renovation and construction permits. Health departments may issue
landfill operating permits or have records of complaints. Review any pertinent
inspection reports filed by these agencies.
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Acquire the following information:
where records are maintained;
directions to this location;
the business hours where records are kept;
who is in charge of maintaining these records;
the hours this person works;
directions to the landfill;
landfill operating hours;
how much ACWM is accepted by the landfill;
how often the landfill accepts ACWM; and
how often records are sent to the central storage area from the landfill.
Plan for the efficient use of time. Inspectors will probably have to inspect records
kept both at the landfill and at an office or storage area elsewhere. Determine the
traveling distance/time between the locations and plan accordingly. A full day may
be necessary to properly inspect all records and ACWM disposal operations.
Accumulate necessary inspection materials:
copies of applicable notifications, exception reports, etc;
employee identification;
copy of regulation;
bound notebook and writing implements;
manila folders;
large envelopes;
landfill recordkeeping checklist;
shipping supplies (if necessary);
business cards;
personal protective equipment; and
sampling equipment.
Try to plan the inspection for a day when asbestos is being accepted by the landfill so
that landfill deposition and recordkeeping operations may be observed first-hand.
Bring personal protective equipment, a camera, landfill inspection checklist, and
asbestos sampling materials as needed.
If the landfill records are expected to be too numerous to review individually, devise a
sampling strategy which will fulfill the objectives of the inspection.
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RECORDKEEPING REQUIREMENTS
The revised asbestos NESHAP requires waste disposal site operators to maintain both waste
shipment and ACWM deposition information.
Waste Shipment Records (WSRs)
Landfill operators must check the WSR that accompanies each asbestos waste shipment that
arrives at the facility to make sure that the information on the WSR accurately describes the
waste shipment. The landfill operator must verify that the information in WSR Item 6
(number and type of containers) coincides with the quantities reported in WSR Item 7 (cubic
meters or yards) and determine if the load contains a significant amount of improperly
enclosed or uncovered waste. Any discrepancy seen must be noted in Item 12 (discrepancy
indication space) of the WSR.
Waste disposal site operators need not open bags or other containers to verify that they
contain ACWM; the WSR accompanying the load is sufficient verification. Once the load
has been examined and discrepancies noted, the waste disposal site operator must complete
Item 13 (certification of receipt) of the WSR, return a copy to the generator (within 30 days),
and maintain a file copy.
Copies of all WSRs must be kept for at least 2 years. To facilitate future reference, WSRs
should be kept in chronological order in a secure, water-tight file. Copies of WSRs must be
provided upon request to the agency(ies) responsible for implementation of the asbestos
NESHAP program, and the file must be made available for inspection during normal
business hours.
ACWM Deposition Information
Waste disposal site operators are also required to maintain, until closure, accurate records of
the location, depth and area, and quantity in cubic meters (cubic yards) of ACWM within the
disposal site on a map or diagram of the disposal area.
REPORTING REQUIREMENTS
The revised asbestos NESHAP also subjects waste disposal site owners/operators to several
new reporting requirements. Required reports concern stationary source information, WSR
discrepancies, improperly-contained waste, disturbance of disposed ACWM, and disposal
site closures.
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Waste Site/Stationary Source Report (งง 61.153, 61.10)
Within 90 days of the effective date of the revisions to the asbestos NESHAP (by February
18, 1991) for existing sources, or within 90 days of the initial startup date for sources having
a startup date after the effective date, disposal site operators are required to submit the
following information about their waste site operations to the agency responsible for
administration of the asbestos NESHAP program:
A brief description of the waste disposal site (location, size, etc.).
A description of the method or methods that will be used to comply with the asbestos
NESHAP, or a description of alternative methods that will be used.
Methods to be used may include covering asbestos waste daily with six (6) inches of
nonasbestos-containing material, or using a dust suppressant. Other information that
might be reported includes procedures used to prevent public access to the asbestos
waste disposal area, such as the use of warning signs and fencing. This information
must be reported using the format in 40 CFR Part 61 Appendix A: National Emission
Standards For Hazardous Air Pollutants Compliance Status Information.
In addition to the information listed above, the waste disposal site operator also has to report
(within the same time period) the following information to comply with the source reporting
requirements of 40 CFR Part 61 Subpart A ง61.10:
Name and address of the owner or operator.
Location of the source.
Type of hazardous pollutants emitted by the stationary source.
Brief description of the nature, size, design, and method of operation of the stationary
source, including the operating design capacity of the source. Identify each point of
emission for asbestos.
1 he a\ crage weight per month of asbestos being processed by the source over the last
1 2 months preceding the date of the report.
V. bother the source can/cannot comply with the standard within 90 days of the
date.
If there iป a change in any of the information listed above, the waste disposal site
owner operator must report the changes to the appropriate agency within 30 days after they
occur a.s required by 40 CFR ง 61.10(c).
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Discrepancy Reports [ง61.54(e)(3))
If there is a discrepancy between the number of containers shown on the WSR and the
number counted in the load, waste disposal site operators must make note of this in Item 12
of the WSR and contact the generator to determine if there is a reasonable explanation for the
discrepancy. If the discrepancy is resolved, the waste disposal site operator must note this on
the WSR, send a signed copy of the WSR to the generator (within 30 days), and retain a file
copy.
If the discrepancy cannot be resolved within 15 days of receipt of the ACWM, the waste
disposal operator must send a written discrepancy report immediately to the agency which is
responsible for the generator of the waste and, if different, the agency in whose jurisdiction
the disposal site is located. The report must describe the discrepancy and steps taken to
resolve it. Information provided should include how and when the waste disposal site
operator attempted to reach the generator and the results of these efforts. A copy of the WSR
in question must be submitted as well.
Improperly-Contained Waste Report [ง61.154(e)(l)(iv)]
As disposal site operators check asbestos waste shipments that arrive at their facilities, they
are required to note whether a significant amount of improperly-enclosed or uncovered waste
exists in the load. If such material is discovered, the waste disposal site operator must make
note of this in Item 12 of the WSR and send, by the following working day, a written report
of the problem to the agency responsible for administering the asbestos NESHAP program
for the jurisdiction where the job site is located (identified on the WSR). If the disposal site
is in a different jurisdiction than the job site, the written report must also be sent to the
agency responsible for the disposal site.
The written report must include a copy of the WSR and a detailed description of the
improperly-enclosed or uncovered waste so that the Agency can determine the urgency of the
situation and the course of action to pursue.
Excavation/Disturbance Report [ง61.151(d)]
If an owner or operator of an asbestos landfill plans to excavate or otherwise disturb (e.g.,
drill methane vents) any ACWM that has been deposited and covered at a waste disposal site,
the Administrator must be informed in writing at least 45 days prior to the disruptive activity.
The following information must be contained in the notice:
Scheduled starting and completion dates.
Reason for disturbing the waste.
Procedures to be used to control emissions during the excavation, storage, transport,
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and ultimate disposal of the excavated ACWM. (If deemed necessary, the
Administrator may require changes in the emission control procedures to be used.)
Location of any temporary storage site and the final disposition site.
If the excavation will begin on a date other than the one contained in the original notice,
notice of the new start date must be provided to the Administrator at least 10 working days
before excavation begins. In no event shall excavation begin earlier than the date specified in
the original notification.
Closure Report [ง61.151(e)]
Agency Notification
Upon closure of a facility, the owner or operator of the site must submit to the Administrator
a copy of records of asbestos waste disposal locations and quantities.
Deed Notation
In addition, within 60 days of closing a waste disposal site, the owner/operator must record,
in accordance with State law, a notation on the deed to the facility property and on any other
instrument that would normally be examined during a title search, that:
The land was used for the disposal of ACWM,
. The survey plot and record of the location and quantity of ACWM disposed of within
the disposal site have been filed with the Administrator, and
The site is subject to the National Emission Standards for Hazardous Air Pollutants:
Asbestos (40 CFR Part 61 Subpart M).
LANDFILL INSPECTION ACTIVITIES
Preliminary Interview
During the preliminary interview it is critical that discussions be properly documented, for
they may later prove useful if violations are detected. The following steps should be
followed once an inspector arrives on site:
Show your identification and request to see the person in charge of ACWM disposal.
When this person arrives, introduce yourself and give him/her your business card.
Document the name and title of the person interviewed. Get his/her business card if
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possible.
Explain the authority [Section 114 (a)(2)] of the Clean Air Act, purpose (asbestos
NESHAP compliance), and components (landfill inspection, records review) of the
inspection.
Inform the representative that the facility may be required to provide the inspector
copies of records of interest.
If offloading will be observed, discuss safety requirements and emergency procedures
and indicate that photographs and/or samples may be taken.
Determine whether the landfill has a State-required permit to operate. If it does,
check the expiration date of the permit and record pertinent information on the
inspection form.
Ask the person to describe the procedures used for verifying information on and
maintaining WSRs, and recording locations, depth and quantity of ACWM deposited
at the site.
Complete applicable sections of the Landfill Inspection Checklist.
If this is the facility's first asbestos NESHAP compliance inspection, explain the
waste disposal requirements to the interviewee and answer any questions to the best
of your ability.
Request the files you wish to review. If permission is denied, do not be forceful.
Simply explain again the authority of your visit and ask the person to contact his/her
supervisor regarding the situation. Either you or your agency's attorney may need to
contact the facility's attorney directly to resolve the difficulties.
Reviewing Records
The records ป>! nuปM interest at a waste disposal site are 1) WSRs for each shipment of
ACWM disposed oi at the site, and 2) up-to-date records (on a map or diagram) that indicate
the location, depth and area, and quantity of ACWM within the site. Other records which
may be of inserts: include stationary source reports, discrepancy reports, improperly-
contained uaMe reports, excavation/disturbance reports and closure reports.
Waste Shipment Records
For all ACWM received, the owner or operator of the active waste disposal site must comply
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with the following waste shipment recordkeeping provisions:
Record and maintain the following information on a form similar to that noted in the
regulation:
waste generator's name, address and telephone number;
transporter's name, address and telephone number;
- quantity of AC WM received (cubic yards or meters);
presence of improperly-enclosed or uncovered waste, or any AC WM not
sealed in leak-tight containers; and
date of receipt.
Send a copy of the waste shipment record to the waste generator as soon as possible
but no longer than 30 days after receipt of the waste.
Attempt to reconcile differences between the amounts of ACWM received and those
recorded on the WSR form brought by the transporter. If the discrepancy is not
resolved within 15 days after receiving the waste, immediately submit a discrepancy
report (which details both the discrepancy and attempts made to reconcile it) to the
governmental agency responsible for administering the asbestos NESHAP program
for the waste generator (identified in the waste shipment record), and, if different, the
governmental agency responsible for administering the asbestos NESHAP program
for the disposal site.
Retain a copy of all records and reports required by this paragraph for at least 2 years.
In inspecting the WSR file, note how the file is maintained and if the WSRs have been filled
out completely, including all of the required signatures. AH signatures should be hand-
written.
Note any WSRs that have an entry pertaining to discrepancies or improperly-contained waste
(See Item 12 on the sample WSR in the revised NESHAP) and ask how those discrepancies
were resolved. Ask to see copies of any discrepancy reports or reports of improperly-
contained waste submitted to the responsible agency for the WSRs in question.
Attempt to match information obtained during the pre-inspection agency file review
(notifications, exception reports, etc.) with records maintained by the waste disposal site.
Pay attention to the dates of shipment of ACWM and acceptance by the landfill. ACWM is
often stored by the transporter until a full load is accumulated.
Photocopy WSRs which lack the required information. If a photocopier is not available,
either 1) record the necessary information in sufficient detail or 2) remove the records from
the facility, photocopy them and return them later. (If records are to be removed from the
facility, sign a receipt indicating that they will be returned as soon as possible).
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ACWM Deposition Records
Ask the site operator for the most recent tally of the total quantity of ACWM deposited at the
site. The operator should be able to provide you with a total that includes all but the most
recent shipments. Examine the records showing the location, depth and area, and quantity of
ACWM within the site to determine that they are up-to-date. Check to see that the proper
information is being collected and the backlog of information to be added to the records is
only for current waste shipments.
Site Observations
Inspectors visit landfills primarily to determine owner/operator compliance with the
requirements of ง61.154 (Standardfor active waste disposal sites). However, while
conducting a landfill inspection, inspectors may note a number of other potential violations
of the asbestos NESHAP. By asking the right questions and documenting appropriate
information (photographs, samples, etc.), inspectors may be able to identify non-notifiers or
determine other generator non-compliance with certain provisions of the NESHAP
regulation.
At a landfill, inspectors should:
Verify that the landfill meets one of the following requirements of ง61.154:
No visible emissions are produced. Warning signs must be posted and fencing
is required unless a natural barrier adequately deters access by the public.
A 6-inch cover of compacted, non-asbestos material is provided within 24
hours of the time the waste is deposited. No sign posting or fencing is
required.
An effective resinous or petroleum-based (other than waste oil) dust
suppressant is provided within 24 hours of the time the waste was deposited.
Warning signs must be posted and fencing is required unless a natural barrier
adequately deters access by the public.
An alternative method previously approved by the Administrator is used.
Warning signs must be posted and fencing is required unless a natural barrier
adequately deters access by the public.
Observe ACWM being offloaded into the landfill. Note how the load is verified,
whether improperly-contained waste is present, and whether the vehicle is properly
marked during offloading. Take samples as necessary to help assess compliance with
the provisions of the waste disposal provisions of the asbestos NESHAP.
If suspect ACWM is being offloaded and is not accompanied by a waste shipment
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record, attempt to determine the following:
Has the suspect ACWM come from one or multiple sites? (For the NESHAP
regulation to be applicable, ACWM must be generated at a site which meets
the definition of a "facility" and meets the 260/160/35 quantity
requirements.)
Is the vehicle properly marked with an asbestos hazard warning sign?
Is the suspect ACWM in properly labeled leak-tight containers?
Is the suspect ACWM adequately wet?
If the suspect ACWM is not wrapped or contained in leak-tight containers, is
there a valid reason for this?
If offloading cannot be observed, interview the person directly in charge of waste
disposal site operations. Ask him/her to describe waste handling, load verification,
and recordkeeping activities.
Inspect the asbestos disposal site; compare your observations with information
recorded on the required site map.
Note the accessibility of the asbestos landfill area to the general public. If the landfill
operator claims that a natural barrier or fence is being used to deter access, determine
if the Administrator has been informed and has agreed that access is sufficiently
restricted.
If improperly-containerized, inadequately-wetted or unlabeled suspect materials are
seen, determine:
whether 260/160/35 is met;
the source of the material; and
whether the source is a "facility."
Post-Inspection Interview
Once >ou ha\c reviewed your inspection activities, conduct a quick, concise wrap-up
interview to obtain any additional information necessary and to convey to the
owner operator, in general terms, the findings of the inspection. It is extremely important
that you do not make and convey a field decision concerning the facility's compliance for a
number of reasons which include the following:
You may later recall items you failed to mention and include them in your inspection
report; if an enforcement action is contested, your credibility and integrity could be
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called into question.
Individuals other than yourself may make the final determination pertaining to the
facility's compliance status.
You may not be aware of other enforcement actions being taken.
Samples have not yet been analyzed.
In situations where potential violations have been identified, be sure to note (on your
checklist or in your field logbook) any observed or verbally-communicated responses of the
owner/operator. This documentation may prove to be of great importance where enforcement
actions are considered.
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SECTION 14
POST-INSPECTION ACTIVITIES
No matter how blatant a violation appears to be or how thorough an inspection has been
done, a case cannot be supported without proper records and documentation. It is imperative,
therefore, that each delegated program office set up and implement a system whereby
supporting documentation is properly acquired, controlled, and maintained. Generated
reports, checklists and sample analysis results must be clear and concise and accurately
support the observations of the inspector. Finally, all records must be organized, properly
maintained, and readily available for future access. The purpose of this section is to outline
inspection follow-up procedures and to provide general guidance regarding document
control, report preparation, and record maintenance and storage.
INSPECTION FOLLOW-UP
Once an inspection is completed, a decision will be made regarding how many and how
quickly samples should be analyzed. When there are serious violations, it may be necessary
to have analysis completed within a day or less. Arrangements should be made ahead of time
with an in-house laboratory or a commercial laboratory to facilitate such a request. Those
samples which will provide the greatest proof of asbestos NESHAP violations should be
analyzed; other samples taken need not be. However, samples should not be destroyed; they
should be stored in a locked facility pending future enforcement action.
When violations are suspected, the inspector should brief his/her supervisor and/or attorney
to initiate the decision-making process concerning the (1) need for reinspection; (2) need for
information request under Section 114 of the CAA; (3) enforcement options available, etc.
DOCUMENTATION
Since checklists and reports generated by an inspector may be the basis for civil or criminal
enforcement actions, they must be precise and legible. NESHAP inspections ultimately
involve the actions of several people: one or more inspectors, laboratory personnel,
administrative, legal and clerical staff. Information must be collected and maintained within
a system that allows for processing and expedient access. Additionally, this system must
protect all records or potential evidence that may be required for enforcement actions. It is
imperative that a comprehensive document control system be implemented during all phases
of an investigation.
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Document Control
The purpose of document control is to make certain that all project documents issued or
generated during a NESHAP investigation are accounted for when the project is complete. A
system which accounts for all investigation documents should include serialized document
numbering, document inventory procedures, and an evidentiary filing system. Examples of
accountable documents include:
inspection checklists;
inspection reports;
field data sheets;
sample tags;
chain-of-custody records and seals;
laboratory notebook and reports;
credentials;
warrants;
subpoenas;
internal memoranda;
phone memoranda;
external written communications;
photographs, drawings, maps; and
quality assurance plans.
Under ideal circumstances each document is given a serialized number which is listed in a
Document Inventory Logbook.
Corrections to Documentation
All documents generated during the course of an inspection are considered part of the
permanent evidentiary file and should not be destroyed or thrown away, even if they become
illegible or if inaccuracies are discovered. This is particularly important if serialized
documents are used, for any gaps in the numbering system will be noted by legal staff.
Errors in documents should be noted. If a document requires replacement, it should be noted,
or corrections made to the original document. Corrections may be made by simply drawing a
line through the error, entering the correct information, and initialing and dating the
correction.
If documents are lost or missing (e.g., sample tags, field notes), a written statement should be
prepared detailing the circumstances. The statement should include all pertinent available
information that may be used to support an observation or sample. This statement becomes
part of the permanent case file.
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RECORDS MAINTENANCE
Records need to be properly filed and maintained to allow for quick and easy access of all
case documents. Records also need to be retained under storage conditions which minimize
deterioration or loss of data files. With the widespread use of micro- and personal
computers, data-management capabilities have improved handling, tracking, and
manipulation of large quantities of information. These systems do not, however, replace
physical evidence such as tags, forms, and checklists. They do alleviate tedious record
searching and sorting tasks and can provide quick and easy retrieval of information and
cross-referencing capability.
Regardless of whether computer-based data management systems or manual procedures are
used, responsible individuals within a program office must be able to access and trace the
destination of project files. The inspector must be familiar with and use all filing procedures.
Files should be signed out in such a manner as to indicate to others that the file is in the
possession of an inspector. When returning the file to storage, the inspector should take care
to return it to its proper place.
INSPECTION REPORTS
The purpose of the inspection report is to present a factual record of an inspection, from
preplanning stages through the analysis of samples and other data collected during the
inspection. An inspection report must be complete and accurate because it is an important
piece of evidence for potential enforcement actions. The length and format of inspection
reports may vary based on program and individual office policy and practice.
The objective of an inspection report is to organize and coordinate all evidence gathered in an
inspection in a comprehensive, usable manner. To meet this objective, information in an
inspection report must be:
Accurate. All information must be factual and based on sound inspection practices.
Observations should be the verifiable result of first-hand knowledge. Enforcement
personnel must be able to depend on the accuracy of all information.
Relevant. Information in an inspection report should be pertinent to the subject of
the report. Irrelevant facts and data will clutter a report and may reduce its clarity and
usefulness.
Comprehensive. The subject of the report (i.e., any suspected violations) should be
substantiated by as much factual, relevant information as is feasible. The more
comprehensive the evidence, the better and easier the prosecution task.
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Coordinated. All information pertinent to the subject should be organized into a
complete package. Documentary support (photographs, statements, sample
documentation, etc.) accompanying the report should be clearly referenced so that
anyone reading the report will get a complete, clear overview of the subject.
Objective. Information should be objective and factual; the report should not draw
conclusions.
Clear. The information in the report should be presented in a clear, well-organized
manner.
Neat and Legible. Adequate time should be taken to allow the preparation of a neat,
legible report.
Reports should be completed soon after the inspection. If there is too long a time interval
between the inspection and completion of the report, the report may not be admissible as
evidence or used to refresh the memory of the inspector. Reports must be prepared routinely
and contemporaneously with the inspection.
Elements of an Inspection Report
No single standard EPA asbestos NESHAP inspection report format exists. While the format
and exact contents of an inspection report may vary, the report should always allow the
reader to determine:
the specific reason for the inspection;
who participated in the inspection;
that all notice, receipt, and other legal requirements were complied with;
what actions were taken during the inspection, including the chronology of these
actions;
what statements, records, physical samples and other evidence were obtained during
the inspection;
what observations were made during the inspection; and
the results of sample analyses related to the inspection.
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Although the specific information requirements in a given inspection report will depend on
the type of inspection and what was found, most reports will contain the same basic
elements:
Inspection Report Forms
Narrative Report
Documentary Support
Inspection Report Forms
Individual inspection report forms are designed to collect standard, reviewable information
about an inspection. Inspection report forms are only one aspect of a complete report and
should by no means be considered to be sufficient documentation of the inspection by
themselves. They function as guides to ensure that all basic data are being collected, and are
generally completed as the inspection progresses. Individual items on these forms often need
clarification and elaboration; inspectors normally use the field logbook for this information.
Asbestos NESHAP field inspection checklists are provided as appendices in this manual.
Agencies may use these forms, alter them to suit their needs, or develop their own checklists.
Narrative Report
The narrative portion of an inspection report should be a concise, factual summary of
observations and activities, organized in a logical manner, supported by specific references to
accompanying evidence (documentary support), and legibly written. Basic steps involved in
writing the narrative report include:
reviewing the information;
organizing the material;
referencing accompanying material; and
writing the narrative.
Reviewing the Information. The first step in preparing the narrative is to collect all
information gathered during the inspection. The inspector's field logbook and all inspection
report forms should be reviewed in detail. All evidence should be reviewed for relevancy
and completeness. Gaps may need to be filled by a phone call or, in unusual circumstances, a
follow-up visit.
Organizing the Material. The narrative should be organized so that it will be understood
easily by the reader.
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Referencing Accompanying Material. All evidence (e.g., copies of records, analytical results,
photographs) that accompanies a narrative report should be clearly referenced so that the
reader will be able to locate items easily. All support documents should be checked for
clarity prior to writing the report.
Writing the Narrative Report. Once the material has been reviewed, organized, and
referenced, the narrative can be written. The purpose of the narrative report is to record
factually the procedures used in, and findings resulting from, the evidence-gathering process.
In this report the inspector should refer to routine procedures and practices used during the
inspection, but should describe in detail facts relating to potential violations and
discrepancies. The field logbook is a guide for preparing the narrative report.
Inspectors should:
Use a single writing style; avoid stilted language.
Use an active, rather than passive approach (e.g., "He said that..." rather than "It was
said that...").
Keep paragraphs brief and to the point.
Avoid repetition.
Proofread the narrative carefully.
Important Considerations
Standard Operating Procedures
When the inspector has followed standard operating procedures (SOPs) precisely in gaining
entry, taking samples, etc., this can be easily noted in the report (e.g., "following standard
procedures, Joe Smith gained entry to..."). If there were any unusual circumstances or
deviations, however, these should be included in the report in more detail.
Confidentiality Considerations and Procedures
All documents and other materials that have been declared confidential business information
by facility officials must be handled according to the security measures that have been
established for such materials. Confidential information includes not only the materials
themselves, but also any report -- such as an inspection report ~ generated on the basis of
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confidential information. Generally, this will involve limiting access to the report to the
fewest number of people possible.
In preparing the inspection report, it may be possible to reference confidential material in a
non-confidential way, such as by providing a general description of the information and a
reference number to the confidential documents. An alternative is to include the information
in the inspection report but treat the entire report as a confidential document.
Conclusions Regarding Compliance
Inspection reports should contain only the facts about the inspection. Clearly, however, the
inspector's conclusions and opinions about the compliance of the facility are the critical
factors (and often, the only factors) in the Agency's decision as to whether a violation did or
did not exist. It is essential, however, that the inspection report itself not include the
inspector's conclusions regarding, compliance.
In writing the inspection report, inspectors should avoid using the word "violation," since this
means a conclusion of law has been drawn. It is acceptable to state facts, such as "The
suspect ACM which had been scraped off the ceiling was dry.", rather than "A violation of
ง61.145(c)(3) of the asbestos NESHAP occurred."
If necessary, conclusions should be contained in a separate cover memorandum or other
format that is clearly separate from the inspection report and passed up the management
chain along with the factual inspection report. The principal reason for this is that if an
enforcement case is pursued, the entire inspection report is subject to discovery by the
opposing side. If conclusions of law and opinions are in the report, the opposing side might
be able to weaken the inspector's credibility by suggesting bias. In addition, the inspector
may have been wrong about one or more counts and the Agency did not pursue them; this
would be revealed through discovery, again weakening the inspector's credibility. A separate
"findings" or "conclusions" memorandum will usually be protected from discovery based on
attorney-client privilege or another "exception" rule.
In some agencies, it may be the inspector who determines whether a violation occurred and if
an enforcement action is warranted. In these situations, the inspector is no longer performing
an inspector function; he or she has actually "changed hats" into a different job - that of a
case development officer. The line between the two jobs should be clearly drawn, with the
person staying in a fact-finder role while carrying out inspector functions -- including
inspection report writing.
Tips for Writing an Effective Inspection Report
In general, three rules apply to preparation of good inspection reports.
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Write to express, not to impress. Just relate the facts and evidence that are relevant to
the compliance situation.
Keep it simple. Organize complicated matters and state them in simple, direct terms.
Keep the reader in mind Relate your writing to the reader's experience and use
words that are likely to be familiar.
The following sections provide a summary of the essential elements of good reports and
organizing the writing process.
Essentials of Good Reports
Fairness, accuracy, completeness, conciseness, clarity, and organization are all essential
characteristics of well-written and effective inspection reports.
Fairness. Inspection reports must be entirely objective, unbiased, and unemotional.
Accuracy. Be exact. Say precisely and accurately what you mean to say in plain
language. Precision depends on diction, phrasing, and sentence structure. Avoid
exaggerations. The report should present facts so clearly that there is not need for
conclusions or interpretations.
Avoid superlatives. Any attempt to strengthen a report in this way actually weakens
it, as reviewers tend to doubt its objectivity.
Accuracy means truthfulness. The accuracy of all findings must be verified before
the final report is submitted. A typographical error in date or time may cast doubt on
other facts in a report.
Completeness. Include all information that is relevant and material. Completeness
implies that all the known facts and details have been reported, either in the text of the
report or in an exhibit, so that no further explanation is needed and the reviewer will
be convinced that the inspection was thorough and comprehensive.
Conciseness. Conciseness does not mean omission. It is the avoidance of all that is
elaborate or not essential. Conciseness is not what you say, but how you say it.
Conciseness means omitting unnecessary words; it does not mean omitting facts,
detail and necessary explanation. It is not the same as brevity. If clarity and
completeness require a detailed explanation, do not hesitate to use it.
Clarity. Inspection reports must be written clearly to avoid misinterpretations. Clear
writing leads to clear thinking and vice versa. Order your thoughts; select those most
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useful to the reader, arrange them logically; and select the words that will best convey
your thoughts to the reader.
The careless use of personal pronouns is a frequent cause of ambiguity. If the use of a
pronoun may result in ambiguity, use a noun. Avoid the use of the pronoun "It" and
the word "There" as substitutes for precise word selection. For example, say "We
should do ...", rather than "It should be done ...", and "Changes have been made ...",
rather than "There have been changes."
Punctuate to make the meaning easy to understand. For example, consider the
different meanings of the following three sentences:
The employee said the foreman is a blockhead.
The employee said, "The foreman is a blockhead."
"The employee," said the foreman, "is a blockhead."
In presenting a series of thoughts or actions, parallel construction helps clarify
meaning. For example, write "collecting; depositing, and reporting revenue", instead
of "collection, depositing, and the reporting of revenue."
Organization. An inspection report should be structured to allow a logical order and
coherence in the presentation of facts. This means that the relation of each event to
the main idea and to the events immediately preceding it in the report must be
unmistakable. Otherwise, it is quite likely that the reader will not understand the
significance of the event.
Narrative Report Outline
Inspectors should provide detailed narration for any of the following components not
sufficiently described in the field inspection checklist.
Introduction
The introduction should briefly present all relevant background information about the
conduct of the inspection and summarize the findings of the inspection.
General Information
State the purpose of the inspection and how the facility came to be inspected
(i.e., neutral scheme, follow-up, for cause).
State the facts of the inspection (i.e., date, time, location, name of the agent-
in-charge, etc.).
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Participants in the inspection.
Summary of Findings
Give a brief, factual summary of the inspection findings.
History of Facility
List the status of the facility (i.e., corporation, proprietorship, partnership,
State agency, non-profit organization, etc., and where incorporated).
Give the size of the organization based on inspector observations or agency
records.
List any related firms, subsidiaries, branches, etc.
List the type of operations performed at the facility under inspection.
List names and titles of facility officials interviewed. List the name(s) of
official(s) responsible for day-to-day operations at the facility.
Inspection Activities
The body of the report should present the chronology of the inspection in the same order that
the inspection was conducted. Be certain to insert all observations when appropriate and to
cover the following topics when appropriate.
Entry/Opening Conference
Describe the procedures used at arrival, including presentation of credentials
and to whom they were presented.
Describe any special problems or observations if there was reluctance on the
part of facility officials to give consent, or if consent was withdrawn or
denied.
If special procedures were necessary, such as obtaining a warrant, describe the
procedures.
Summarize the topics discussed during the opening conference.
Note if duplicate samples were requested.
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Records
List the type of records reviewed, noting the reasons for their review, and
referencing documents that were borrowed or copied.
Describe any inadequacies in recordkeeping procedures, or if any required
information was unavailable or incomplete.
Note if recordkeeping requirements were being met.
Evidence Collection
Note and reference any statements taken during the inspection.
Describe and reference photographs taken during the inspection if they were
relevant.
Reference any drawings, maps, charts, or other documents made or taken
during the inspection.
Physical Samples
Describe the purpose for which samples were obtained.
Describe the exact location from which they were obtained.
Describe sampling techniques used. They may be referred to as standard
operating procedures (SOPs) if SOPs were followed exactly. If there were
deviations from SOPs, explain why and what was done.
Describe the physical aspects of the sample (color, texture, viscosity, etc.).
Describe chain-of-custody procedures used in sample handling.
Summarize results of laboratory analyses (include actual data as an
attachment).
Closing Conference
Note and reference receipts for samples and documents given to facility
officials.
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Note procedures taken to confirm claims of confidentiality and issuance of
receipts for Confidential Business Information.
Note any recommendations, referrals, etc., made to facility officials.
Attachments
Supporting information should be attached to the report to ensure that reviewers have all of
the data needed to fully evaluate the compliance situation. All of these attachments should be
fully referenced in the body of the report.
List of Attachments
Prepare a list of all documents, analytical results, photographs, and other
supporting information attached to the report. A general index list, rather than
detailed descriptions, will aid case- development personnel in locating specific
documents.
Documents
Attach copies of all documents and other evidence collected during the
inspection. All documents should be clearly identified.
In cases where documentary support items cannot be included easily with the
report, it may be possible to substitute descriptive information.
Analytical Results
Attach sample data and quality assurance data. These may be presented as
tables, with pertinent information summarized in the body of the report.
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SECTION 15
ASBESTOS BULK SAMPLING AND ANALYSIS
IMPORTANCE OF SAMPLING
The asbestos NESHAP regulates only those materials containing greater than one percent
asbestos. For this reason, the taking of bulk samples is an essential component of an asbestos
NESHAP inspection. Without bulk samples an inspector may find it difficult, if not
impossible, to prove that violations of the asbestos NESHAP regulation occurred at the
facility visited.
Appropriate analysis of bulk samples will reveal both the type and percentage of asbestos
they contain. If the amount of asbestos in bulk samples does not exceed one percent, the
materials are not RACM and therefore are not subject to the requirements of the asbestos
NESHAP.
Samples should be collected whenever feasible, and especially where violations are suspected
or an enforcement action anticipated. Written standard operating procedures should be
followed and only accredited laboratories used for the analysis of bulk samples. Use of
improper sampling techniques or nonaccredited laboratories may jeopardize an agency's
ability to take an enforcement action against a violator of the asbestos NESHAP.
Inspectors must be able to testify that the samples:
accurately represent conditions at the site;
were maintained using proper chain of custody; and
were acquired and analyzed using proper methodology.
PROTECTIVE EQUIPMENT
EPA's Safety. Health and Environmental Management Division's (SHEMD's) Health and
Safety Guidelines for EPA Asbestos Inspectors recommends that the following personal
protective equipment be used by EPA inspectors when collecting bulk samples under the
Asbestos-In-Schools Rule, the Worker Protection Rule, and the asbestos NESHAP:
Protective Clothing
Unless samples can be taken without any significant chance of releasing fibers, EPA
inspectors should wear the following protective clothing when collecting bulk samples:
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a disposable, fUll-body, hooded coverall (e.g., a Tyvekฎ suit or equivalent);
eye protection (if a full-face respirator is not used);
disposable shoe coverings;
hard hat (if applicable); and
disposable gloves.
Inspectors should use safety shoes, hearing protection and other safety equipment as needed.
Respiratory Protection
EPA inspectors collecting bulk samples should wear full-face air-purifying respirators with
HEPA filter cartridges (this includes NIOSH-approved, tight-fitting PAPRs equipped with
HEPA filters).
SAMPLING EQUIPMENT/MATERIALS
The following items are recommended for use during bulk sampling procedures:
Sample containers - any dry, scalable and clean container (such as a 35-mm film
canister; washed before use), plastic vial, or scalable plastic bag (preferably with a
write-on label). (Always wash film canisters before use and never reuse
containers that have contained asbestos.)
Spray bottle - for wetting a surface prior to sampling to prevent generation of dust
(use amended water or encapsulant) and for decontamination purposes.
Duct tape- 1001 uses!
Bathroom caulking - to temporarily repair a sampled area in a noncontaminated
environment.
TamperprooJ tape/labels- to seal sample containers, evidence envelopes.
Tools - forceps, locking-blade penknife, coring device, screwdrivers, needle-nose
pliers, laboratory spatula.
Wet wipes - to clean tools between samples and to decontaminate equipment, sample
containers.
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Plastic bags - to store equipment, supplies, samples, waste materials.
Documentation materials - field logbook, plastic clipboard, inspection checklist,
watch, sample labels, chain-of-custody forms, waterproof pens, overhead
transparency sheets.
Plastic drop cloth - to protect area beneath sampling point from contamination.
Glove bags - for sampling sealed waste bags when a containment area is not present.
Labeled waste disposal bags - for the disposal of contaminated materials.
The above items are considered essential and should be included in every sampling kit.
Other items, such as specialty corers, hammer and chisel, and vinyl tile knives may also be
used. A comprehensive inspection equipment checklist is provided as an appendix to this
manual.
PROCEDURAL GUIDELINES
The asbestos NESHAP regulation does not address the taking of bulk samples. Information
regarding sample collection can be found, however, in several EPA and ASTM (American
Society for Testing and Materials) publications:
Guidance for Controlling Asbestos-Containing Materials in Buildings (EPA 560/5-
85-024, June 1985) ("Purple book")
Asbestos in Buildings: Simplified Sampling Scheme for Friable Surfacing
Material (EPA 560/5-85-030a, October 1985) ("Pink book")
Health and Safety Guidelines for EPA Asbestos Inspectors (EPA, March 1991)
Test Method - Method for the Determination of Asbestos in Bulk Building
Materials (EPA/600/R-93/116)
Asbestos Sampling Bulletin (EPA, 9/30/94)
Standard Test Method for Microvacuum Sampling and Indirect A nalysis of Dust by
Transmission Electron Microscopy for Asbestos Structure Number Concentrations
(ASTM D 5755-95)
Standard Test Method for Microvacuum Sampling and Indirect A nalysis of Dust by
Transmission Electron Microscopy for Asbestos Mass Concentrations (ASTM D
5756-95).
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The Purple and Pink books are geared towards environments which are neither contaminated
nor disturbed, such as those encountered during asbestos school inspections, pre-abatement
inspections, and pre-demolition inspections. The Health and Safety... document describes
protective equipment and procedural guidelines for collecting bulk samples and the Test
Method... details preferred sample sizes for various asbestos-containing materials. The
Asbestos Sampling Bulletin provides detailed information regarding the collection and
analysis of bulk samples of multi-layered materials and the ASTM documents describe
settled dust sampling techniques.
Pre-sampling Procedures (Non-contaminated Areas)
EPA's Health and Safety... document provides the following procedural guidelines for
inspectors (e.g., Asbestos-in-Schools inspectors) taking bulk samples in non-contaminated
areas (i.e., areas where the asbestos-containing materials have not been disturbed).
Discuss with building officials how the samples will be obtained and the rationale for
selecting the sampling locations and the number of samples. Also discuss the
advisability of notifying employees and/or their representatives prior to the
inspection.
Determine the equipment needed during the inspection to adequately access the area
(e.g., ladders, scaffolding).
Determine the best time to obtain the samples in each area selected (i.e., times when
few people are normally in the vicinity or passing through).
Limit access to the area while samples are being collected. Post area(s) with
appropriate signs or construct barricades, if necessary. Under no circumstances
should samples be taken when school children or other unprotected individuals
are present.
Determine the minimum number of people needed in the affected area during sample
collection, and limit access to that number. (These individuals may need to use
personal protective equipment, depending on the asbestos inspector's assessment of
the potential for asbestos fiber release.).
Determine how the area will be decontaminated should there be an accident (e.g., a
piece of asbestos comes loose and drops to the floor). Be prepared to isolate the area
and to damp wipe/mop the area, and/or have access to a HEPA vacuum.
Based on the best information available, determine what personal protective
equipment would be required in the event of an accident, under what conditions it will
be worn, and by whom.
1997 15-4
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Sampling Procedures
Asbestos inspectors may need to collect bulk samples of suspect RACM in pre-, active, and
post-abatement areas and from other sites such as roll-off waste containers, trailers,
abandoned buildings, waste disposal sites, demolished sites, etc.
Bulk samples may be taken of stripped, removed, or in-place materials. Although the
environments in which these samples are collected may not conducive to formal random
sampling approaches, the inspector can ensure the representativeness of samples collected by
using proper judgment. Because the main goal of collecting bulk samples is to determine and
document whether materials associated with a suspect violation contain greater than one
percent asbestos, a subjective approach is warranted and appropriate.
In general, the following procedures should be followed when taking bulk samples.
Identify homogeneous thermal system insulation, surfacing and miscellaneous
materials.
Select sample sites which will minimize disturbance of the asbestos material (e.g., the
upper surface of horizontal thermal system insulation to reduce the possibility of
contamination from material falling out of the sampling hole).
If necessary, place a covering on the floor under the sample collection area.
.Spray the area to be sampled with a water mist or encapsulant mist prior to sampling
to minimize release of fibers.
Collect representative samples (a minimum of three) from each homogeneous area of
suspect material associated with a possible violation.
Collect a complete core or cross-section of suspect materials. In the case of a multi-
layered system, if a bulk sample remains intact through all layers and the sample will
remain intact until it reaches the analytical laboratory, containerize the sample as is.
However, if such a bulk sample crumbles or breaks down at the time of sample
collection, take separate samples from discrete layers at the site and carefully identify
them and their position in the multi-layered system before sending them for analysis.
(See information re: multi-layered systems later in this section.)
Collect sufficient sample volumes. For samples such as floor tiles, roofing felts,
paper insulation, etc., three to four square inches of the layered material are preferred.
For materials such as ceiling tiles, loose-fill insulation, pipe insulation, etc., a sample
size of approximately one cubic inch is preferred. For samples of thin coating
materials such as paints, mastics, spray plasters, tapes, etc., a smaller sample may be
1997 15-5
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obtained.
Place samples in airtight containers. (Be sure to squeeze excess air out of plastic bags
before sealing them.)
Seal containers so that tampering will be evident.
Write a unique identification number and your initials on each sample container.
Clean sampling equipment and wash or change gloves between samples to avoid
cross-contamination.
Record sample information in field notes. If dry material is encountered and a
wetting violation suspected, record this information in the field logbook and note in
both the logbook and on the chain-of-custody form that the material was wetted
during sample collection.
Photograph the sampling location(s). When necessary, place an item of known size in
the picture for reference.
Make a drawing of the inspection site, noting where samples and photographs were
taken. Indicate angles of photographs and written descriptions of materials sampled.
When sampling is completed, decontaminate the sampling equipment and outsides of
sample containers.
Follow appropriate personal decontamination procedures.
Dispose of asbestos-contaminated waste properly.
Post-sampling activities
Complete all documentation including checklist entries and chain-of-custody (COC)
form \ sample COC form is provided in Figure 15-1.
Secure samples before conducting another inspection.
AnaK /e samples as necessary. It is advisable to collect extra samples and analyze
onl> enough to satisfy the evidence requirements (one sample containing greater than
one percent asbestos). Additional samples may be analyzed as needed.
Maintain original samples until such time as an enforcement action is completed.
1997 15-6
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and well-cushioned to prevent breakage.)
Retain original samples until such time as an enforcement action is completed.
Multi-layered Systems
Asbestos NESHAP inspectors may need to determine the applicability of the asbestos
NESHAP to multi-layered systems they encounter. Such systems include plaster wall or
ceiling systems, resilient flooring systems (flooring, mastic, underlayment), plaster/stucco
systems, and wallboard systems with add-on layers. [Note: In its Asbestos Sampling Bulletin
(September 30,1994) EPA stated that it does not consider a sheet of "plasterboard" by itself
("sheetrock", "wallboard", "gypsum board") a multi-layered material under either AHERA or
NESHAP regulations.
EPA has recommended the use of an "improved" analytical method for the analysis of bulk
samples. The Federal Register notice (59 FR 38970, August 1,1994) directs laboratories to
analyze individual layers or strata of a multi-layered sample and to report a single result for
each layer. The 1982 "Interim Method" provided that the analytical results for the discrete
layers of a multi-layered sample be combined and reported as one result across all layers. As
a result, multi-layered systems which may have contained asbestos in a single layer may have
been reported by laboratories as non-asbestos-containing.
Asbestos NESHAP inspectors, therefore, cannot rely on previous analysis of multi-layered
materials to determine applicability of the asbestos NESHAP, unless results of each layer's
analysis are available. Inspectors must sample multi-layered materials and provide necessary
information regarding the samples to the laboratory for proper analysis.
Since EPA had received many questions about analyzing multi-layered systems for asbestos
content to determine the applicability of the asbestos NESHAP, it published the Asbestos
NESHAP Clarification Regarding Analysis of Multi-layered Systems, 59 FR 542, January 5,
1994. In this document EPA discussed the following:
Plaster/Stucco
If the plaster and stucco wall or ceiling systems are layered, and the layers can be
distinguished, then the layers must be analyzed separately.
Add-on Materials
All materials (such as sprayed-on materials, paint, ceiling or wall texture, etc.)
"added" to wallboard or other base materials must be analyzed and reported
separately if possible.
Wallboard
1997 15-7
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When joint compound and/or tape is applied to wallboard it becomes an integral part
of the wallboard and in effect becomes one material forming a wall system.
Therefore, where a demolition or renovation impacts such a wall system, a composite
analysis of the wall system (percent of asbestos in the joint compound, tape and
wallboard) should be conducted."
Since analytical requirements differ for wallboard systems vs. add-on materials, inspectors
need to take samples in a manner which will help distinguish the two. EPA recommends the
following sampling procedures be followed:
Joint Compound - Sample where joints are expected (take a minimum of three
samples):
inside or outside comers;
at wallboard joint intervals;
around nailheads.
Add-on Materials - Take a minimum of three samples where joints are not expected
(e.g., between corners and wallboard joint intervals).
Since a laboratory cannot distinguish joint compound at joints from the same materials used
as a skim coat, the inspector must clearly describe the sample composition so that appropriate
analytical results are reported.
At the laboratory all samples with outer layer having >1% asbestos will be noted. When this
situation applies, the following must be considered:
If only joint sampling areas show layers with >1% asbestos, then the material is joint
compound and analytical results of the layers are composited. If the result is <1%, no
management is necessary. If the result is >1%, the material is RACM and the
asbestos NESHAP applies.
If samples from both joint compound and non-joint areas show layers with >1%
asbestos, the material is a "skim coat" or add-on material. In this case the results must
not be composited and must be reported for each layer. Material so located must be
treated as separate RACM layers according to the asbestos NESHAP.
Inspectors must keep good records of sample locations for later evaluation of results.
DUST SAMPLING PROCEDURES
Note. EPA has no official policy regarding dust sampling or analysis.
1997 15-8
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In some situations (e.g., a post-removal inspection, or an improperly-run abatement site)
inspectors encounter settled dust and would like to determine whether it contains asbestos.
Inspectors may choose to use the tape lift, microvac, wipe, or passive sampling technique
depending upon the type of analysis desired. The tape lift method selection is used for direct
analysis and the microvac, wipe and passive methods are used for indirect analysis of
asbestos in settled dust.
Direct analysis is designed to preserve the integrity of the sample as it occurred on the
collection surface. Such analysis may allow observation of the material of interest and its
associated matrix. If the matrix obscures the fibers of interest, it is necessary to process the
sample to remove the interfering material and analyze the sample using indirect procedures.
In many cases the indirect analysis will produce a larger analytical result than the direct
analysis since more fibers are visible with the indirect preparation. Although direct analysis
results may be lower, they offer the advantage of identifying the associated matrix with the
sample and that information is valuable in identifying the source of the settled dust. It may
be best, therefore, to collect samples for both direct and indirect analysis, so that the amount
of asbestos present and its source can be determined.
Tape Lift Samples
In the tape lift method, adhesive materials such as transparent tape, self-stick office notes, or
forensic tape are used to gather the dust sample. (Duct tape should never be used since
recovery of the dust particles for analysis is essentially impossible.)
At the laboratory the sample is prepared directly for TEM or SEM analysis. This method of
gathering and analyzing the sample minimally disturbs the asbestos present, but other fibers
and matrix material may mask the asbestos fibers.
Microvacuum Samples
The American Society for Testing and Materials (ASTM) Subcommittee D22.07 has
published two documents regarding settled dust: Standard Test Method for Microvacuum
Sampling unJ Indirect Analysis of Dust by Transmission Electron Microscopy for Asbestos
Structure \iimher Concentrations (ASTM D 5755-95) and Standard Test Method for
Micnmu mtm Sampling and Indirect Analysis of Dust by Transmission Electron Microscopy
forAsh-M.H \la\.\ Concentrations (ASTM D 5756-95). Asbestos NESHAP inspectors are
encouraged to follow the microvacuum techniques described in these documents and
summan/cd below:
I'M- onh new. unused air monitoring cassettes containing 25 mm or
.T mm diameter mixed cellulose ester (MCE) or polycarbonate (PC) filter membranes
\sith a pore size less than or equal to 0.8 mm.
1997 15-9
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Maintain a log of all pertinent sampling information and sampling locations.
Calibrate sampling pumps and flow indicators appropriately and record all calibration
information. The internal diameter of the nozzle and flow rate of the pump may vary
as long as the air velocity within the body of the nozzle is 100 (ฑ10) cm/s. This air
velocity can be achieved with an internal sampling tube diameter of 6.35 mm (1A in.)
and a flow rate of 2L/min.
Perform a sampling system leak check at each sampling site.
Attach the sampling cassette to the sampling pump at the outlet side of the cassette
with a piece of plastic tubing. Cut the end of a clean 25.4 mm (10") piece of plastic
tubing at a 45 ฐ angle and attach this to the intake port of the sample cassette. This
tubing will act as the sampling nozzle.
Delineate a sampling area of 100 cm2 and vacuum it until there is no visible dust or
particulate remaining. (Sample smaller or larger areas if needed.)
When done, invert the cassette so that the nozzle inlet faces up before shutting off the
pump. Seal the nozzle and the cassette appropriately.
Wipe off the exterior surfaces of cassettes and nozzles.
Label all samples clearly and complete dust sampling information sheets.
Package cassettes and nozzles for shipment. (Use plastic bubble wrap or other non-
fibrous packing material to minimize the potential for contamination.)
Send samples and a field blank (unused cassette and nozzle) to an analytical
laboratory in a sealed container, but separate from any bulk or air samples.
Samples should be analyzed by a NVLAP laboratory. Although no specific accreditation for
dust analysis exists, these laboratories have demonstrated knowledge and proficiency in
analyzing asbestos by transmission electron microscopy, the analytical technique specified in
the ASTM documents. It is also recommended that the NVLAP laboratory chosen to do the
analyses be a member of ASTM D22.07 and regularly attend its meetings.
Dust sample results, depending on the test method used, are reported in "asbestos structures
per cm2", "asbestos, g/cm2, or "asbestos, weight percent". Results can be used to determine
the presence of asbestos in the dust and to compare "suspect" areas to "clean" areas within the
same building or different buildings. It is inappropriate to use the results of dust analyses in
the determination of whether a suspect material contains "greater than 1% asbestos".
Wipe Samples
1997 15-10
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ASTM recommends the use of an ashless paper filter moistened with particle-free water in
the taking of wipe samples. The inspector should wipe the filter over a known area (e.g., 100
cm2), package it appropriately, and deliver it to a National Voluntary Laboratory
Accreditation Program (NVLAP)-accredited laboratory for analysis. At the laboratory the
sample will be analyzed via transmission electron microscopy (TEM) for its asbestos content.
Passive Samples
In passive sampling a clean collection surface of some sort (usually a shallow metal lid) is
laid out to collect dust over a measured period of time. The dust is rinsed out of the container
and then analyzed via TEM. Since the collection time is usually several or more weeks, this
method is not often used by asbestos NESHAP inspectors. Passive samples are useful,
however, in determining if dust is being deposited during the sampling period.
BULK SAMPLE ANALYSIS
General Information
Bulk sample analysis is performed to determine whether the material from which samples
have been. collected contains greater than 1% asbestos. EPA provides guidance regarding the
analysis of asbestos in bulk samples in its publication Test Method -- Method for the
Determination of Asbestos in Bulk Building Materials (EPA/600/R-93/1 16, July 1993). This
improved analytical method is designed to address certain materials:
that are known to contain asbestos fibers, but in which the asbestos percentage is
where the percentage of asbestos is obscured by a matrix binder of some kind (e.g.,
vinyl or asphalt floor tiles);
in which small, thin fibers are present, but are frequently not detected at the
magnification and resolution limits of polarizing light microscopes.
The improved method builds on the previous (1982) "Interim" polarizing light microscope
(PLM) method. As before, it begins with a careful examination of the sample using a
stereomicroscope, then proceeds (as before) to the examination of sample specimens under a
polarizing microscope. In most cases, these steps will be sufficient to characterize a sample
as asbestos-containing (asbestos present >1%) or non-asbestos-containing (no asbestos
detected, or 1 % or less in the sample).
The improved method includes additional procedures required for the reliable analysis of
certain bulk building materials, such as steps for the elimination of the obscuring matrix
1997 15-11
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Analytical Techniques
Stereomicroscopic Examination
A preliminary visual examination which will help determine homogeneity, texture, friability,
color, and the extent of fibrous components of the sample is required for all samples. This
information helps guide the selection of further, more definitive qualitative and quantitative
asbestos analysis methods.
Since vinyl floor tiles, asphaltic products, etc., contain small asbestos fiber sizes and/or the
presence of interfering components, the use of Stereomicroscopic analysis may be limited.
Polarized Light Microscopy
Polarized light microscopy (PLM) is used to distinguish the various forms of asbestiform
minerals on the basis of their unique optical crystallographic properties (qualitative
examination) and is also used to perform a semi-quantitative analysis of bulk samples (i.e.,
visual area estimation and/or point-counting).
Although PLM analysis is the primary technique used for asbestos determination, it is limited
by the visibility of the asbestos fibers. In some samples the fibers may be reduced to a
diameter so small or masked by coatings to such an extent that they cannot be reliably
observed or identified. For these reasons, PLM analysis is of limited value in analyzing floor
tiles, and gravimetric or other procedures may be required.
When PLM is used to quantify asbestos content of a sample, the following conditions should
be met:
The slide sample should be homogeneous in order to be representative of the total
sample.
Panicles in the slide preparation should have an even distribution and approach a one
panicle thickness to avoid particle overlap.
The thickness relationship between matrix particles and asbestos fibers should be
determined it the results based on projected area are to be related to volume and/or
weight percent
Visual Arcti / >/.".-.///hcstos content by visual area estimation.
Point Counting
1997 15-12
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Point counting is a standard technique used in petrography for determining the relative areas
occupied by separate minerals in thin sections of rock. For asbestos analysis this technique is
used to determine the relative concentrations of asbestos minerals to nonasbestos sample
components. The point-counting analytical method is required to be used when a method
other than point counting has determined that the asbestos content of a sample is less than 10
percent.
In the point-counting method, an ocular reticle (cross-line or point array) is used to visually
superimpose a point or points on the microscope field of view. A total of 400. points
superimposed on either asbestos fibers or nonasbestos matrix material must be counted.
Point counting provides a determination of the projected area percent asbestos.
If one or more samples from a homogeneous suspect ACM is determined to contain more
than one percent asbestos, the entire material is considered to contain asbestos and is thus
subject to the asbestos NESHAP.
Materials which are determined to contain less than one percent asbestos are not subject to
the provisions of the regulation.
Gravimetry
Gravimetry, a process in which acids, solvents and ashing (heating the sample to burn off
organic materials), can be used to selectively remove the binder components from a sample.
Gravimetric procedures:
isolate asbestos from the sample (allowing weight determination);
concentrate asbestos (thereby lowering the detection limit in the total sample;
aid in the detection and identification of fibrous components; and
remove organic (ashable) fibers optically similar to asbestos.
If the sample is friable and contains organic (ashable) components, the ashing procedure
should be followed. If the sample is friable and contains HCl-soluble components, the acid
dissolution procedure is followed. If the sample is friable and contains both types of
components, or if the sample is nonfriable (e.g., floor tiles), the two procedures can be
applied, preferable with acid dissolution following ashing.
Gravimetry is not an identification technique, but is used to aid in qualitative PLM, analytical
electron microscopy (AEM), or x-ray diffraction (XRD).
X-Ray Diffraction
1997 15-13
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X-ray diffraction, a technique which reveals a mineral's unique "fingerprint" on film, is
typically used in conjunction with PLM or AEM. The technique is more expensive than
PLM and cannot distinguish between fibrous and nonfibrous forms of asbestos. However,
qualitative, semi-quantitative, and quantitative results may be obtained from XRD.
Analytical Electron Microscopy (AEM)
Analytical electron microscopy (AEM) is a reliable although expensive method for the
detection and positive identification of asbestos in some bulk building materials. The method
is particularly useful in the analysis of floor tiles and plasters, materials that contain a large
amount of interfering materials and which contain asbestos fibers that may not be resolved by
PLM techniques. The AEM method can also be used to quantify asbestos concentrations.
Other Techniques
Scanning Electron Microscopy (SEM) is very useful for observing surface features in
complex particle matrices, and for determining elemental compositions. SEM cannot,
however, detect small diameter fibers (~<0.2 mm) and cannot determine crystal structure.
Field test kits should never be used to confirm the presence or absence of asbestos since their
results are unreliable.
QUALITY ASSURANCE
Sample Identification Numbers
A unique sample identification number must be assigned to each sample; this number can be
a combination of a site code and the date and time the sample was taken. For example, for a
sample taken at St. Joseph's Hospital on December 17, 1992 at 2:17 pm, the identification
number could be:
SJH 12 17 92 14 17.
Use of such a numbering system can help eliminate a microscopist's potential bias. For
example, if the numbering system chosen indicated that seven samples were taken from the
same room, a microscopist might not be objective about each individual sample.
Chain-of-Custody (COC) Forms
In order to ensure that all samples are properly identified and tracked from the point of
sample collection through receipt by the analytical laboratory, EPA requires that a COC form
be completed and accompany the samples when they leave the possession of the inspector.
(See Figure 15-1.)
1997 15-14
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CHAIN OF CUSTODY RECORD
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NU.
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Figure 15-1 Representative chain-of-custody record.
-------
A COC form should contain the following information:
site name and address;
date of inspection/sampling;
sample identification numbers;
name/signature of sampler and date;
name/signature of recipient(s) and date;
type of analysis to be performed; and
other pertinent information (e.g., use of glove-bag sampling method, use of unusual
sample container, dry material wetted by inspector, etc.).
Since some laboratories require the use of their own COC forms, inspectors should contact
them ahead of time to learn proper procedures.
A COC form should be completed immediately after the inspection. If mistakes are made in
transferring information from field notes or sample containers to the form, a new form should
be completed.
The form should not be signed until just before the samples leave the custody of the
inspector.
Quality Control (QC) Samples
Collection of side-by-side duplicates is recommended at the rate of 1 QC sample per building
or 1 QC sample for every 20 samples taken, whichever is larger. Since analyses of QC
samples can help determine both sampling and analytical precision, it is important that the
laboratory conducting the analysis not know which samples are QC samples.
Inspectors can help ensure nonbiased analysis by collecting a side-by-side sample
nonsequentially. The inspector should gather several samples at the facility and then go back
to one of the sample locations for the side-by-side duplicate. In this way the side-by-side
samples' identification numbers are not consecutive in time.
Side-by-side duplicates are analyzed to determine the consistency of analysis within a
laboratory. Significant differences in analytical results should not be seen. Splits of side-by-
side duplicates may also be sent to a second laboratory to confirm the results of the first
analyses. Any significant disagreements should be investigated; samples should be
reanalyzed, or additional samples collected.
1997 15-16
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Accredited Laboratories
To diminish the likelihood of challenges to the accuracy of laboratory results during an
enforcement action, only laboratories which have participated in and been accredited by the
National Institute for Standards and Technology (NIST) National Voluntary Laboratory
Accreditation Program (NVLAP) should be used to analyze samples. A list of accredited
laboratories is available through the EPA Regional Asbestos Coordinator, the TSCA Hotline
(202-554-1404), and the NVLAP of NIST (301-975-4016).
An inspector should contact the laboratory before conducting the inspection and discuss the
following:
type of analysis;
sampling procedures;
sample containers;
chain of custody forms;
packaging of materials for shipment;
turnaround time for analysis; and
cost of analysis.
BULK SAMPLE SHIPMENT
Inspectors can best maintain chain of custody by personally delivering the samples to the
analytical laboratory. If this is not possible, the U.S. Postal Service, Federal Express, United
Parcel Service or other courier services may be used. Since packaging and labeling
requirements may differ depending on the organization chosen, inspectors should contact
these concerns before shipping samples.
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1997 15-18
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SECTION 16
ASBESTOS AIR SAMPLING AND ANALYSIS
This section is designed to provide inspectors general information concerning the equipment,
methods and procedures involved in air monitoring and air sample analysis. Although there
are no requirements under the asbestos NESHAP for conducting air monitoring at
demolition/renovation or asbestos removal sites, such requirements have been issued by
OSHA (to monitor worker exposure and determine appropriate respiratory protection) and
TSCA (to verify the adequacy of abatement activities at public and private schools, grades
K-12), so asbestos NESHAP inspectors will often encounter monitoring equipment and air
monitoring data during inspections.
The EPA has published a number of guidance manuals which recommend when and where
asbestos air monitoring should be conducted. The most recent guidance can be found in
Measuring Airborne Asbestos Following an Abatement Action, EPA-600/4-85-049 (Silver
book). In addition, procedures for collecting and analyzing asbestos air samples have been
published in Asbestos Containing Materials in Schools (Amended), 40 CFR Part 763, Subpart
E. Additional information pertaining to air monitoring can be found in Appendix J, "List of
Available References".
TYPES OF AIR MONITORING
Asbestos air monitoring is conducted for a number of reasons and in a variety of scenarios.
The most often encountered situations are:
Non-abatement monitoring - helps determine hazard potential by directly measuring
asbestos fiber concentration in the air.
Monitoring during active removal operations - determines worker exposure during
the time interval the monitoring took place; helps determine efficacy of engineering
controls and work practices.
(Available air monitoring data should be examined by the inspector and considered in
the choice of respiratory protection. Inspectors should realize, however, that the data
may not represent current conditions.)
Clearance monitoring - determines whether airborne levels of asbestos in the
containment area are below an acceptable level after the abatement project is
completed; clearance monitoring is done before critical barriers are taken down and
the contractor is released from the job.
1997 16-1
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Ambient or background monitoring - measures outdoor fiber levels or indoor
pre-abatement concentrations.
MEASUREMENT APPROACH
Personal Sampling
An air-monitoring device is worn by the worker during his/her normal work schedule. The
sampling is used to determine the "breathing zone" fiber levels to which the worker is
potentially exposed and is performed to comply with the requirements of the OSHA asbestos
standard.
Area Sampling
A stationary air-monitoring device is placed in an area representative of the overall area
under investigation. This technique is used for hazard assessments, ambient and background
surveys, and for monitoring during and after abatement actions.
Aggressive Sampling
A large-volume area sample is taken while an air-moving device (e.g., a fan or leaf blower)
dislodges and keeps airborne any remaining fibers during the sample collection period. This
technique is performed in the containment area during clearance monitoring.
SAMPLING EQUIPMENT
Sampling Pumps
Available from a variety of manufacturers. Usually described as low-volume (personal) and
high-volume pumps.
Low-Volume
Generally light-weight, battery-powered, personal monitoring pumps with a flow rate range
of 1 to 5 liters per minute. More sophisticated versions are flow compensating and can be
programmed to turn on, shut off, record flow rates, store data and interface with a data logger
or personal computer. Used for both personal and area monitoring.
1997 16-2
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High-Volume
Capable of achieving flow rates up to 25 liters per minute. Heavier, bulkier and more
obtrusive than the smaller, low-volume types. Allow larger volumes of air to be sampled in a
shorter time period. Used for collecting area samples before, during and after abatement
actions.
Filters and Cassettes
Filters used to collect airborne asbestos fibers are most often 25-mm or 37-mm filters housed
in 2- or 3-piece styrene cassettes. Some cassettes, primarily those used for OSHA asbestos
monitoring, have been modified with a 50-mm conductive extension cowl to reduce fiber loss
on the walls of the cassette.
The two most routinely used filter media are:
Cellulose Acetate Membrane - Pore size between 0.8-1.2 \im used for collecting
samples to be analyzed via Phase Contrast Microscopy (PCM). If used for
Transmission Electron Microscopy (TEM), special collection and preparation
techniques must be used.
Polycarbonate - Smooth-surfaced filters with pore size of 0.4 u.m or used for samples
collected for electron microscopy analysis.
ANALYTICAL TECHNIQUES
Two options exist for analyzing air samples to determine airborne fiber concentrations:
Phase Contrast Microscopy (PCM) and Transmission Electron Microscopy (TEM). Each has
certain advantages and disadvantages depending on the circumstances in which it is used and
the investigator's data requirements. Table 16-1 illustrates a general comparison of these
different methods.
Phase Contrast Microscopy (PCM)
Adopted by the Occupational Safety and Health Administration (OSHA) as a standard
protocol for measuring airborne asbestos in the industrial work place (OSHA
Reference Method).
Nonspecific for asbestos fibers. Counts all fibers that are greater than 5 |im in length
with an aspect ratio of 3:1.
Limit of resolution is approximately 0.25 urn in diameter.
1997 16-3
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Least expensive and most widely available analytical technique.
Useful in determining worker exposure levels and for clearing abatement projects.
Transmission Electron Microscopy
TEM is the most sensitive and specific of the cited analytical techniques. It is the
method of choice when definitive results are needed.
Due to magnifications of 1 5,000 - 20,000x, capable of resolving extremely thin asbestos
fibers (typically 0.0025 pm in diameter).
Can be outfitted with EDXS and SAED capabilities to provide definitive information
concerning the chemical composition and crystalline structure of the observed fibers.
Most expensive and least available of all of the cited techniques.
Exists as a standard protocol. Method most recently published in 40 CFR Part 763,
Appendix A to Subpart E - Interim Transmission Electron Microscopy Analytical Method
and Field Sampling Protocol for the Clearance Testing of an Abatement Site.
1997 16-4
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TABLE 16-1. COMPARISON OF METHODS FOR MEASURING AIRBORNE ASBESTOS
PCM
TEM
Standard
Methods
NIOSH 7400
Method*
EPA AHERA method**
Quality
Assurance
Proficiency Analytical
Testing Program; no
NIST reference materials
NVLAP accreditation;
NIST reference materials
available
Cost
Time
Requirements
Sensitivity
(Thinnest
Fiber Visible)
Specificity
Collection
Filters
ffO ->0
Jo-Zo
1 hour preparation and
analysis, less than 6
hours turnaround
0.15 urn at best;
0.25 jam typical
Not specific for
asbestos
0.8-1.2 urn
cellulose ester
$75-250
4-24 hour preparation and
analysis, 2-7 days turnaround
0.0002 urn at best
0.0025 um typical
Definitive for asbestos
(TEM with EDXS & SAED)
0.4 um polycarbonate, or
0.45 um cellulose ester with
special preparation
'Revision #2: 3/1/87. OSHA Reference Method (ORM, 1986) is a modification of NIOSH 7400. NIOSH P&CAM 239
(Leidal 1979) may be used in some instances as an alternative.
**U.S. EPA, Asbestos-Containing Materials in Schools, 40 CFR 763, Subpart E, Appendix A, 1987
Source: Based on information from the EPA/NBS conference on post-abatement air monitoring (NBS/EPA, 1985), the
open literature, and government reports, and on peer review comments (modified). Table updated June 1997.
1997
16-5
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CONTINUOUS MONITORS
Continuous monitors provide real time data concerning nonspecific fiber concentrations.
They are designed to mimic the NIOSH methodology and count all airborne fibers greater
than 5 urn in length and with a 3:1 aspect ratio which pass through the sensor during a
preselected time period. At the completion of the sampling period, the monitors
electronically compute the fiber concentrations in fibers/cc.
Advantages:
provide real time data;
have a working range of 0.0001 to 30 f/cc;
can indicate whether engineering controls and work practices are effective;
can be used to prescreen prior to conducting more expensive analysis; and
can be used to monitor preset action levels.
Disadvantages:
not approved by NIOSH/OSHA;
interferences can occur at high dust loading; and
high capital cost ($ 19,750).
1997 16-6
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SECTION 17
LEGAL PERSPECTIVES
The following information describes who is subject to the asbestos NESHAP, the authority
for inspections, and various enforcement options. This material was obtained from EPA's
national strategy document and from EPA attorneys. Further legal questions should be
addressed to Regional Counsels or to counsels for the State or local enforcement agency.
OWNER OR OPERATOR
In the general provisions of 40 CFR Part 61, National Emission Standards for Hazardous Air
Pollutants (NESHAP), "owner or operator" is defined as:
"any person who owns, leases, operates, controls, or supervises a stationary source"
("stationary source" being defined as "any building, structure, facility, or installation
which emits or may emit any air pollutant which has been designated as hazardous by
the Administrator.").
Within Section 61.141 (Definitions) of Subpart M of the NESHAP regulation, the term
"owner or operator" is redefined specific to demolition or renovation activities. "Owner or
operator of a demolition or renovation activity" means:
"any person who owns, leases, operates, controls, or supervises the facility being
demolished or renovated or any person who owns, leases, operates, controls, or
supervises the demolition or renovation operation, or both."
Since this definition applies to both the facility owner or operator and demolition or
renovation contractors hired by the owner or operator, each party is considered legally
responsible in the event of noncompliance with the asbestos NESHAP. Other individuals
such as hygienists, electricians, plumbers, transporters, etc., hired either by the facility owner
or operator or demolition or renovation contractor, are also subject to the regulation's
requirements and may be held legally responsible as well. It has been EPA's policy,
however, to cite both the facility owner and the demolition/renovation contractor for
violations of the asbestos NESHAP seen at demolition or renovation worksites.
In addition to the above responsible parties, Section 61.154 (Standardfor active waste
disposal sites) of Subpart M notes that "each owner or operator of an active waste disposal
site that receives asbestos-containing waste material" from mills, demolition or renovation
operations, or conversion operations must comply with the waste disposal provisions of the
asbestos NESHAP.
1997 17-1
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Such owners or operators may thus be cited and held legally responsible for violations seen at
active waste disposal sites.
AUTHORITY FOR INSPECTIONS
Statutory authority for inspection is under Section 114 of the Clean Air Act. Allowed
activities during inspection include sampling, photography, and visual observations. The
inspector need not be a certified visible emissions observer to judge whether there is an
emission.
If denied access to a facility, an inspector may apply for a warrant to perform the inspection.
In order to obtain a warrant, the agency should show either that the inspection is scheduled
under a "neutral" inspection format, or that there is probable cause to suspect violations at the
subject source. The agency must obtain the exact street address of the site and name of the
owner in order to have a warrant issued.
An inspector discovering obvious violations of the asbestos NESHAP during an inspection is
not empowered by EPA to order a work stoppage to curtail asbestos emissions. This order
must be made, when necessary, at the level of a Division Director. Other orders may be
feasible under the power of local health agencies.
ENFORCEMENT OPTIONS
Enforcement options used to remedy ongoing violations and/or deter future violations
(previously summarized in Section 2, "Asbestos Demolition and Renovation Enforcement
Strategy") include informal, administrative, and judicial actions.
Field citations, although a program authorizing their use is not yet in place, are expected to
become another enforcement option available to asbestos NESHAP inspectors. EPA is
developing such a program and expects to promulgate final rules regarding field citations
sometime in 1994.
A source, due to improper waste disposal, may also be subject to regulation under RCRA
and/or CERCLA, so air and hazardous waste enforcement personnel should coordinate their
actions whenever possible. (Note that the AHERA legislation of 1986 established interim
requirements for transport and disposal by reference to Chapters 4 and 5 of EPA's Asbestos
Waste Management Guidance EPA/530-SW-85-007).
Other types of relief may be sought besides monetary compensation to enhance future
compliance with the regulation. For example, depending on the types of violations seen,
consent degrees issued during settlement proceedings may require defendants to:
1997 17-2
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Conduct representative sampling of suspect ACM to be disturbed and have samples
analyzed at a NVLAP laboratory.
Develop an asbestos control program which details procedures the defendant will
follow to comply with the asbestos NESHAP.
Develop and implement an asbestos training program and implement it within a
certain time frame.
Train a corporate asbestos program manager who will be responsible for company
compliance with the regulation.
Supply some of the following information with future notifications:
date of previous notification;
if previous notification was made by telephone, name of Agency contact who
received the call;
name of on-site supervisor;
facility contact and telephone number;
survey inspector name and address, date of training, and training provider
identification;
specific information regarding the types of RACM to be disturbed;
working hours at abatement site;
definitive description of abatement techniques (wetting, waste handling, etc.)
to be employed;
name of waste disposal facility contact; and
reason for an ordered demolition.
Examine loads for obvious violations of the asbestos NESHAP (improperly contained
ACWM, dry material, lack of labels, etc.) before accepting them for transport.
1997
17-3
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THIS PAGE INTENTIONALLY LEFT BLANK
1997 17-4
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APPENDIX A
INSPECTION EQUIPMENT CHECKLIST
General Inspection Materials and Equipment
Copy of notification
Employee I.D./credentials
letter of authorization,
med. monitoring/fit test cert.
Business Cards
Copy of regulation
Field notebook
Pens/pencils
Highlighting marker
Indelible markers
fine
medium
large
Inspection checklist
Waterproof camera
extra battery(ies)
film
Waterproof flashlight
extra batteries
extra bulb
Plastic clipboard
Custody tape/labels
Overhead projector trans, sheets
Chain of custody forms
Shipping supplies
Waterproof watch
Plasticized enlarged bus. card
Plain paper
Office supplies
Ig. envelopes
folders
paper clips
binder clips
Binoculars
Utility knife
Diver's bags
1997 A-l
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Personal Protective Equipment
Dufflebags
Full-face neg. pres. resp. (NPR)
Respirator cartridges for NPR:
HEPA
HEPA/NH3
HEPA/Org. vapor
HEPA/Org./Acid
PAPR (tight-fitting)
Respirator cartridges for PAPR
Backup battery for PAPR
Spectacle kit
SCBA (pressure-demand type)
Resp. disinfectant (pads, powder)
Disposable full-body coveralls
Duct tape
Latex overboots
Hard hat
Safety glasses (clear/tinted)
Steel-toed rub. boots/safety shoes
Hearing protection
Asbestos waste bags (6 mil)
Bathing suit/disposable underwear
Disposable gloves
Paper towels
1997
A-2
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Personal Protective Equipment (Continued)
Glove bags
Liquid soap
Safety harness/lanyard
Shower thongs
Sampling Equipment
Sample containers
Spray bottle
Tools:
needle-nose pliers
locking blade knife (2)
screwdrivers (slotted, Phil.)
laboratory spatula
coring tool
metal forceps
Plastic dropcloth
Wet wipes
Resealable plastic bags (qt, gal.)
Bathroom caulking
1997 A-3
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ASBESTOS DEMOLITION AND RENOVATION (D/R)
FIELD DATA COLLECTION CHECKLIST
A. GENERAL INFORMATION
Site name:
Location:
Site code:
Date of inspection: Time of inspection:
Weather conditions:
Inspector(s):
Notification received? Yes:
No:
Reason for inspection:
Routine compliance inspection Citizen complaint
Suspected non-notifier State oversight/Joint
Other (explain) ;
B. REMOTE OBSERVATIONS
Using the space provided, draw a sketch of the facility. Indicate compass directions, waste.
storage area(s), location(s) of debris, land use surrounding site, vehicles of importance, etc.
Estimate and indicate dimensions and distances as accurately as possible on the drawing.
Note where photographs/samples were taken.
A92-1495. fie B-l
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REMOTE OBSERVATION SKETCH
Referring to the above sketch, describe any visible emissions to the outside air or suspect
ACM debris seen.
A92-1495.fic B-2
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C. PRE-INSPECTION INTERVIEW
Yes No
1. Credentials shown:
Agency identification
Medical monitoring certification
2. Name(s) and position(s) of person(s) being interviewed (include company name):
3. Review the entire notification form with the on-site representative and note below any
changes in the information provided.
4. Subcontractors [Provide the following information for each subcontractor or any other
party on site (e.g., hygienist, consultant, etc.) who controls or supervises the D/R
project.]
a. Company name:
b. Main contact person and title:
c. Mailing address: .
City State Zip Code
A92- 1495. fie
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A92-1495. fie
B-4
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d. Telephone number:
(area code)
e. Name/title of on-site representative:
f. Responsibilities at job:
5. Activity Description
Yes No
a. Is more than one project occurring at the facility?
(If "yes", complete a separate checklist for each
or differentiate accordingly.)
b. Describe each project and indicate its current phase.
D. PRK-ENTRY OBSERVATIONS
1. Abatement workers present:
a. Number
Yes No
A92-1495.fic B-5
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b. Training records available?
A92-1495.fic B-6
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Yes No
c. State licenses on site?
d. Medical exam records available?
2. Amended water in evidence?
3. Power tools in use?
4. Dust/debris (VE?) outside removal area?
5. Warning signs posted?
6. Containers properly labeled with asbestos hazard warning?
7. Waste disposal permit on site?
8. Worksite properly contained?
9. Functional decontamination facility available?
10. Personal air monitoring data indicate <2.0 f/cc 8 hour TWA_
11. Written respiratory protection program?
12. Respirators in use?
13. Removal plan available for review?
14. Evidence of on-site representative's NESHAP training
posted?
15. Name of on-site representative/affiliation:
Comments:
A92-1495.fic
B-7
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E. WORKSITE INSPECTION
Yes
No
1. Is the site a "facility"?
2. Are regulated amounts of suspect RACM being handled?
QUANTIFICATION OF SUSPECT RACM
Facility Component
Quantity Suspect RACM to
be Disturbed (ft, ft2, ft3)
Measurement/Estimation
Technique
TOTAL AMOUNT SUSPECT RACM PRESENT
Pipes
Other faciht\
Off faciiit\ t>
components
>m portents (components no longer present)
linear feet
square feet
cubic feet
A92-1495.fic
B-8
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Yes No
3. Is the material friable?
Describe how friability was determined. ^^^^
4. Is the material likely to become friable during
demolition or renovation?
Explain:
5. Which of the following types of suspect RACM are involved in the project?
Category I Nonfriable ACM
Asphalt roofing products
Gaskets
Mastic
Packings
Resilient floor coverings (vinyl/asbestos tile, asphalt/asbestos tile, linoleum)
Insulation
Block insulation
Pipe insulation (felt, air-cell, premolded, asbestos-cement)
Miscellaneous
Acoustical tiles
Ceiling tiles
Surfacing Materials
Joint compound
Plaster
Spackling compound
Sprayed-on (acoustical, decorative or insulative)
Stucco
A92-1495.fic
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Category II Nonfriable ACM
Boiler fire brick
Clapboards/shingles
Concrete/asbestos board
Concrete/asbestos pipe
Extrusion panels
Laboratory benchtops'
Millboard
Paints and coatings
Pegboard
Putties
Sealants
Textiles (fire blankets, laboratory
aprons,theater and welding
curtains, gloves)
Vinyl wallpaper
Other (specify)
A92-1495. fie
B-10
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6. If necessary, draw a diagram of the worksite. Indicate dimensions and amounts,
locations of samples/photographs, etc.
Comments:
F. NOTIFICATIONS
1. What t> pc of activity is described on the notification?
a I)cmo/reno(>260/160/35) _
b Demolition (<260/160/35 or no asbestos) _
A92-1495.fic
B-ll
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c. Planned renovation involving individual non-
scheduled operations (>260/160/35)
d. Ordered demolition
e. Emergency renovation
2. When was the notification received?
3. When did work that disturbed RACM begin?.
Yes No N/A
4; Did the notification require updating?
If "yes", the reason for updating was:
a. change in notification information
b. later start date
c. early start date
If there was a later start date, did the owner/operator:
a. telephone before original start date?
b. provide written notice by original start date?
If there was an earlier start date, did the owner/operator:
a. notify in writing?
b. notify at least 10 days before RACM disturbance?
G. DEMOLITION? _ _
1. Ordered demolition?
a. Copy of order accompany notification?
b. Reason for order justified by on-site observations?
c. Portion of facility containing RACM kept adequately
A92-1495.fic B-12
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wet during wrecking?
d. ACWM kept adequately wet at all times after
demolition?
Comments:
Yes No
2. ACM left in facility during demolition?
a. Category I nonfriable (not in poor condition,
not friable)?
b. Encased in concrete?
Adequately wet when exposed?
c. Not discovered until after demolition and
cannot be safely removed?
Adequately wet when exposed?
d. Category II with low probability of becoming RACM?
e. ACWM kept adequately wet at all times after
demolition?
3. Demolition by intentional burning?
AH ACM removed before burning?
Comments:
Yes No N/A
H. RENOVATION?
1. Unit/section removal?
a. Adequately wet where cut or disjoined?
A92-1495.fic B-13
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b. Carefully lowered?
Yes No N/A
c. RACM stripped?
1. Adequately wetted? (or)
2. LEVCused?
d. RACM wrapped?
1. Leak-tight wrapping? (and)
2. Labeled?
2. RACM stripping?
a. Adequately wet? (or) _
b. Wetting exemption?
1. Potential equipment damage or
safety hazard? :
a. Written approval? (and)
b. Emission control? (and)
1. LEVC?
2. glove bag?
3. leak-tight wrapping?
4. written approval for
alternative method?
c. Written approval on site?
2. Temperature at point of wetting
below 32 ฐF(0ฐC)?
a. Unit/section removal?
A92-1495. fie B-14
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Yes No N/A
b. Temperature recorded?
1. beginning?
2. middle?
3. end?
c. Records available for
inspection at site?
d. Records retained >2 years?
3. Large facility component not stripped?
a. RACM not disturbed or damaged? (and)
b. Leak-tight wrapping? (and)
c. Labeled? (loading, unloading, storage)
4. All RACM
a. Adequately wetted and maintained wet? _
b. Carefully lowered? _
c. Leak-tight chutes/containers (>50')?
d. Wrapped leak-tight? _
I. WASTE DISPOSAL
1. Which of the following waste disposal options has the owner/operator chosen to
follow?
a. No visible emissions to the outside air (collection,
processing, packaging, transporting). _
(or)
b. Adequately wet ACWM. (or)
c. Process ACWM into nonfriable forms. (or)
A92-1495.fic B'15
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d. For ordered demos and demos where RACM has not been removed,
adequately wet ACWM all times after demolition and keep wet
during handling and loading.
e. Approved alternative method.
Comments:
Yes No
2. Has adequate wetting of ACWM been chosen?
a. Is RACM awaiting containerization adequately wetted?
If "no", describe:
b. Is the ACWM already containerized adequately wetted?
If "no", describe:
If necessary, adequately wet the ACWM and describe how it changes (e.g.,
color, texture):
c. Are there visible emissions to the outside air?
If "yes", describe:
A92-1495.fic B-16
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Yes No
d. Are leak-tight containers or wrapping used?
Are there any open or ripped bags outside containment?
How many?
Are the contents adequately wetted?
If "no", describe:
e. Are OSHA labels used?
f. If the ACWM will be transported off site, are the
containers labeled with the:
1. name of the waste generator? (and)
2. location of ACWM generation site?
Comments:
Note: None of 2 (a-f) above applies to Category I nonfriable ACM waste and Category
II ACM waste that is not RACM
3. Is all ACWM (excluding Category I nonfriable ACM that is not
RACM) disposed of as soon as practical? (and)
a. at a waste disposal site operated per ง61.154? (or)
b. at an EPA-approved asbestos conversion site?
Comments:
A92-1495. fie
B-17
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Yes No
4. Are vehicles used to transport ACWM marked:
a. during loading?
b. during unloading?
c. visibly?
d. appropriately?
Comments:
5. Is ACWM to be transported off site?
a. Are waste shipment records maintained?
b. Do they contain the following required information?
1. name, address, telephone number of waste
generator
2. name, address of agency administering asbestos
NESHAP program
3. quantity (m3, yd3)
4. waste disposal site (WDS) operator name,
telephone number
5. WDS name, location
6. transport date
7. transporter name, address, telephone
8. certification
Comments:
A92-1495.fic B-18
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6. Is a copy of the WSR given to the WDS at time of delivery?
Yes No
7. Has the generator ever failed to receive a copy of the WSR
signed by the WDS within 35 days of ACWM transport?
If "yes", did the generator:
a. contact the transporter and/or WDS?
b. determine the status of the waste?
8. Has the generator ever failed to receive a copy of the WSR
signed by the WDS within 45 days of transport?
If "yes", has the generator reported this in writing to the
agency responsible for the waste generator?
Did the generator include:
a. a copy of the WSR in question? (and)
b. a cover letter explaining attempts at resolution?
9. Are required records available for review?
Comments:
J. ADDITIONAL INFORMATION
1. Glove bags in use?
a. small-scale, short duration project?
b. secondary containment?
c. reduced pressure inside glove bag?
2. Size of containment area (LxWxH)?
3. Number/cfm ratings of LEV units
A92-1495.fic B"19
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K. SUMMARY OF RECOMMENDATIONS/DISCUSSION WITH
OWNER/OPERATOR
L. ADDITIONAL COMMENTS
M. ATTACHMENTS
Sample Collection Log
Photo Identification Log Sheet
AHERA Compliance Checklist
Worker Protection Rule Checklist
A92-1495.fic B-20
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Field Notes
Chain of Custody Form
Generator Identification Label
Waste Shipment Record
Notification
Photographs
Site map/diagram/blueprint
Others (list):
Inspector signature:
Date:
A92-1495. fie B"21
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ASBESTOS NESHAP
MILLING, MANUFACTURING & FABRICATING OPERATIONS
FIELD INSPECTION CHECKLIST
I. GENERAL INFORMATION:
Site name:
Location:
Date of inspection:
Time of inspection: am/pm
II. FACILITY INFORMATION:
Type of facility: Milling Manufacturing Fabricating
Material manufactured (if applicable):
1. cloth, cord, wicks, tubing, tape, twine, rope, thread, yarn, roving, lap, or other
textile materials
2. cement products
3. fireproofing and insulating materials
4. friction products
5. paper, millboard, and felt
6. floor tile
7. paints, coatings, caulks, adhesives, and sealants
8. plastics and rubber materials
9. chlorine (utilizing asbestos diaphragm technology)
10. shotgun shell wads
11. asphalt concrete
Typical operating hours:
Date construction of facility commenced:
Date facility commenced asbestos-related operations:
Date modification of facility commenced:
A. Reason for Inspection:
Routine compliance Citizen complaint
State oversight/Joint
B. Site Conditions:
Ambient air temperature: ฐC/ฐF
Wind description:
1997
C-l
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Wind direction:.
Visibility:
(e.g., clear, partly cloudy, overcast...)
Other conditions:
(e.g., drizzle, rain, sleet, snow ...)
C. Owner Information:
Name: _
Address:
Phone number: ( )_
D. Operator Information:
Company name:.
Address:
Phone number: (
Contact person:
Title: "
III. PRE-INSPECTION INTERVIEW:
1. Credentials shown: Yes No
a. agency identification
b. medical monitoring certification
2. Name and title of person being interviewed:
3. Company:
4. Principle product produced:
5. Process information:
a) Description:
b) Amount of asbestos-containing material produced by the facility:
c) Dates of operation:
d) Does the source use a spray-on method? Y N
If "yes", was EPA informed of the process 20 days prior to the application? Y N
1997 C-2
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6. Control equipment/measures:
7. Are HEPA vacuums available on site? Y N_
8. Waste handling procedures:
9. Is there an active waste disposal facility on site?
10. Is there an inactive waste disposal facility on site?
11. Disposal procedures:
12. Primary waste transporter:
Name:
Address: _
Telephone:
13. Primary ACWM waste disposal site:
Name:
Address: _
Telephone:
14. Interview notes/comments:
1997 C"3
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IV. INSPECTION:
Using the space provided, draw a general location map of the facility. Note land use surrounding site
(residential, industrial, recreational). Estimate and indicate dimensions and distances as accurately as
possible.
2. Using the space provided, draw a sketch of the process and control equipment locations. Note sample
and photograph locations.
1997 C-4
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3. Which of the following emission control options has the facility selected?
a. Discharge no visible emissions to the outside air
b. Use a fabric filter collection device
c. Use an Administrator-approved wet collector
d. Use a HEPA filter certified to be 99.97% efficient ~
for 0.3 micron particles
e. Use other Administrator-approved filtering equipment
4.
Describe any visible emissions seen.
6.
Is the facility using a fabric filter collection device?
If "yes",
a. Is the facility using woven or felted fabric filters?
b.
How does the facility ensure that the airflow specifications for these
filters are not exceeded?
c.
d.
e. Weight of felted fabric in g/m2:
Visible emission monitoring
a.
b.
Is visible emission monitoring performed once per day during
daylight operating hours for at least 15 seconds per emission source?
Who conducts the visible emission monitoring?
Name:
Title: .' .
Comments:
Yes No
What is the current manometer reading of the pressure drop
across the fabric filter of the air cleaning device?
Was the fabric collection device installed after January 10,1989?
If "yes", have provisions been made for easy inspection for faulty
bags(61.152(a)(3))?
1997
C-5
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Yes No
7. Conduct a walkthrough and identify monitoring sites. Does the facility
monitor each potential source?
Comments:
8. Are records of the results of visible emission monitoring and air cleaning
device inspections maintained?
If "yes", is the following information included?
a. Date and time of each inspection.
b. Presence or absence of visible emissions.
c. Condition of fabric filters, including presence of any tears, holes, and abrasions.
d. Presence of dust deposits on clean side of fabric filters.
e. Brief description of corrective actions taken, including date and time.
f. . Daily hours of operation for each air cleaning device.
Comments: . .
9. Are the records available for this inspection?
10. Are air cleaning devices used on site?
a. If "yes",
i. Is each air cleaning device inspected at least once per week for proper
operations and for changes that signal the potential for malfunction?
ii. Who conducts the air cleaning device inspections?
Name:
Title:
1997 C-6
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Yes No
b. If "no",
i. Has a written maintenance plan been submitted to the
Administrator?
ii. Does the plan include a:
Maintenance schedule?
Recordkeeping plan?
iii. Has the plan been revised since submission?
If "yes", has the administrator been sent the revised plan?
11. Has the facility retained a copy of all monitoring and inspection records for at
least two years?
12. Are monitoring and inspection records available for inspection?
13. Have any visible emissions been recorded during visible emission monitoring?
If "yes", has the facility submitted a copy of the visible emission monitoring records to the
Administrator within 30 days of the end of the quarter when visible emissions occurred?
(Quarterly reports are due April 30, July 30, October 30 and January 30).
Comments: ;
1997 C"7
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WASTE DISPOSAL REQUIREMENTS FOR MANUFACTURING AND FABRICATING OPERATIONS
All asbestos-containing waste material must be deposited at a waste disposal site operated in accordance with the
provisions of Sec. 61.154.
1. Describe waste materials:
2. Describe waste handling procedures:
Yes No
3. Has the source chosen to discharge no visible emissions to the outside air during the
collection, processing (including incineration), packaging, or transporting of any ACWM
generated? _ _
or
Does it use one of the following emission control and waste treatment methods? _ _
a. Adequately wet asbestos-containing waste material as follows: _ _
i. Mix control device asbestos waste to form a slurry (Sec. 61.1 50ฃa)( 1 )(i));
Adequately wet other asbestos waste material (Sec. 61.150(a)ฃH(i)); and
ii. Discharge no visible emissions to the outside air from collection, mixing,
wetting, and/or handling operations (Sec. 61.150(a)(l)(ii)) or use methods
of Sec. 6 1.1 52; and ' _
iii. Seal all asbestos-containing waste material in leak-tight containers while
wet(Sec. 6
For materials that will not fit into leak-tight containers without additional
breakage, put materials into leak-tight wrapping; and _
1997 C-8
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Yes No
iv. Label the containers or wrapped materials as follows:
DANGER
CONTAINS ASBESTOS FIBERS
AVOID CREATING DUST
CANCER AND LUNG DISEASE HAZARD
or
b. Process asbestos-containing waste material into nonfriable forms as follows:
i. Form all asbestos-containing waste into nonfriable pellets or other shapes;
and
ii. Discharge no visible emissions to the outside air from collection and
processing operations, including incineration or;
iii. Use the method specified by Sec. 61.152 to clean emissions containing
paniculate asbestos material before they escape to, or are vented to, the
outside air;
or
c. Use an alternative emission control and waste treatment method that has received
prior approval by the Administrator.
Is ACWM transported off site to a disposal site?
If "yes",
a. Are the containers or wrapped ACWM materials labeled with the
i. name of the waste generator; and
ii. location at which the waste was generated?
C-9
1997 ^ y
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Yes No
b. Is waste deposited as soon as practical? (and)
i. at an active waste disposal site operated in accordance with the provisions
of Sec. 61.154?
or
ii. at an EPA-approved site that converts asbestos-containing waste into non-
asbestos (asbestos-free) material in accordance with Sec. 61.155?
1997 C-10
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WASTE DISPOSAL FOR ASBESTOS MILLS
All asbestos-containing waste material must be deposited at a waste disposal site operated in accordance with the
provisions of Sec. 61.154.
Describe waste materials:
2. Describe waste handling procedures:
3. Emission control
a. Which of the following has the facility chosen to do?
i. Discharge no visible emissions to the outside air
from the transfer of control device asbestos waste to
the tailings conveyor
ii. Use a fabric filter collection device
iii. Use an Administrator-approved wet collector
iv. Use a HEPA filter certified to be 99.97%
efficient for 0.3 micron particles
v. Use other Administrator-approved filtering equipment
Yes No
b Is the asbestos waste from control devices handled in accordance with Sec.
61 150(a) (See Item 3 on the checklist for WASTE DISPOSAL FOR
MANUFACTURING AND FABRICATING OPERATIONS) or 61.149(c)? (See
Item 4 of this checklist).
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Yes No
4. a. Has the facility chosen to discharge no visible emissions to the outside air
during the collection, processing, packaging, or on-site transporting of
any asbestos-containing waste material?
or
b. Does the facility use a wetting agent as follows?
i. Adequately mix all asbestos-containing waste material with a wetting
agent to effectively wet dust and tailings before depositing the material at
a waste disposal site.
Is the wetting agent being used as recommended
by the manufacturer?
ii. Discharge no visible emissions to the outside air from the wetting
operation; or
Use the methods specified in Sec. 61.152 to clean emissions containing
paniculate asbestos material before they escape to, or are vented to, the
outside air.
or
c. Does the facility use an alternative emission control and waste treatment method
that has received prior written approval from the Administrator.
5. Are wetting operations conducted at the site?
If "yes",
Have wetting operations at the waste disposal site ever been suspended due to
temperatures <-9.5ฐC(15ฐF)?
If "yes",
a. Has the temperature been recorded at least at hourly intervals, and
b. Have records been kept in a form suitable for inspection for at least two years?
6. Record any visible emissions observed.
1997 C-12
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OFF-SITE TRANSPORT REQUIREMENTS FOR DISPOSAL OF ACWM
FROM MILLING, MANUFACTURING AND FABRICATING OPERATIONS
Yes No
Are vehicles used to transport ACWM marked as follows during the loading and unloading of
waste? 6
DANGER
ASBESTOS DUST HAZARD
CANCER AND LUNG DISEASE HAZARD
Authorized Personnel Only
2. Are Waste Shipment Records (WSRs) with the following minimum information maintained?
a. Name, address, and telephone number of the waste generator.
b. Name and address of the local, State, or EPA Regional office responsible for
administering the asbestos NESHAP program.
c. The approximate quantity in cubic meters (cubic yards).
d. The name and telephone number of the disposal site operator.
e. The name and physical site location of the disposal site.
f. The date transported.
g. The name, address and telephone number of the transporters).
h. A certification that the contents of the consignment are fully and accurately
described by proper shipping name and are classified, packed, marked, and labeled
and are in all respects in proper condition for transport by highway according to
applicable international and government regulations.
Comments:
3. Is a copy of the WSR provided to the disposal site owner at the time of delivery of the
asbestos-containing waste to the disposal site?
1997 C-13
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Yes No
4. Have signed WSRs been returned by the waste disposal site within 35 days of the date the
initial transporter accepted the waste?
If "no",
a. Was the initial transporter and/or the owner/operator of the waste disposal site
contacted to determine the status of the waste shipment?
b. If a signed copy of the WSR was not received within 45 days of the date the initial
transporter accepted the waste, was the agency which administers the asbestos
NESHAP program for the waste generator notified in writing?
If "yes", was the following information submitted?
i. A copy of the WSR for which a confirmation of delivery was not
received;
and
ii. A cover letter signed by the waste generator explaining the efforts to
locate the asbestos waste shipment and the results of those efforts.
5. Are copies of the WSRs signed by the owner or operator of the waste disposal site maintained
for at least two years?
Comments:
1997 C-14
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REPORTING REQUIREMENTS FOR MILLING, MANUFACTURING
AND FABRICATING FACILITIES
Yes No NA
Has the source submitted information to the Administrator as required
by Sec. 61.153 (Reporting)?
If "yes", examine the source information submitted and indicate whether the
following required items are present:
a. A description of the emission control equipment used for each process.
b. Fabric filter information:
i. If the fabric device uses a woven fabric, the airflow permeability in
m3/min/min2 (ft3/min/ft2).
ii. If the fabric is synthetic fabric, whether the fill yarn is spun or not spun,
iii. If the fabric filter uses a felted fabric:
the density in g/m2 (oz/yd2),
the minimum thickness in mm (inches), and
the airflow permeability in m3/min/m2 (ft3/min/ft2). .
c. A copy of the certified efficiency of the HEPA filter used.
d. A brief description of each process that generates asbestos-containing waste
material.
e. The average volume of asbestos-containing waste material disposed of, measured in
mVday (ydVday).
f. The emission control methods used in all stages of waste disposal.
g. The type of disposal site or incineration site for ultimate disposal.
1997
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h. Disposal site or incineration site information:
i. Name of operator
ii. Name of disposal site_
iii. Location
Yes No
2. Is this facility a new source (i.e., construction commenced before 01/10/89)?
If "yes",
a. Did the source have an initial startup date before November 20, 1990?
If "yes", did the source provide source information in Item 1 to the
Administrator by February 18, 1991?
If "no",
What was the startup date?.
ii. Was the information submitted within 90 days?
3. Is the facility an existing source?
a. Has the source previously supplied this information to the Administrator?
If "no", was the information submitted by February 18, 1991?
4. New/existing sources:
a. Have there been any changes in the information submitted?
If "yes", has the Administrator been informed in writing within 30
days of these changes?
b. For new/existing sources with an initial startup date before November 20. 1990, has
the following information been submitted to the Administrator by February 18,
1991?
i. Name and address of the owner or operator.
ii. The location of the source.
iii. The type of hazardous pollutants emitted by the source.
1997 C-16
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Yes No
iv. A brief description of the nature, size, design and operation of the source
(include operating design capacity and identify each point of emission for
each hazardous pollutant).
v. The average weight per month of the hazardous pollutant.
vi. A description of the existing control equipment.
A statement by the owner or operator as to whether the source can comply
with the standards within 90 days of the effective date of the regulation.
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V. POST INSPECTION INTERVIEW:
Summary of facility inspection:
Summary of recommendations/discussion with owner/operator:
Additional comments:
Inspector signature Date
1997 C-18
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ASBESTOS WASTE DISPOSAL SITE
INSPECTION CHECKLIST
Site Name:
Site Address:
Landfill Identification Number (Agency Assigned):
Inspector(s):
Date of Inspection: Time of Inspection:
Weather Conditions:
I. PRELIMINARY INTERVIEW
1. Owner Name:
2. Site Contact:
a. Title:
b. Affiliation:
c. Mailing Address:
d. Telephone Number:
YES NO NA
3. Is the landfill approved by the State? _ _ _
If yes, Operating Permit No.:__
Effective date:. through _
II. RECORDS INSPECTION
1. Are waste shipment records maintained? [ง61.l54(e)(l)]
Where are WSRs filed? _
A92-1495.1an
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YES NO NA
Do these records contain the following information?
a. Waste generator's information [ง6l.l54(e)(l)(i)J:
1) name _ _
2) address _ _
3) telephone number _ _
b. Transporter's information [ง61.l54(e)(l)(ii)]:
1) name _ _
2) address _ _
3) telephone number _ _
4) signature _ _
c. Quantity of ACWM (cubic yards or meters)
d. Presence of improperly enclosed or uncovered
waste, or any ACWM not sealed in leak-tight
containers [ง61.154(e)(l)(iv)]:
Has the landfill operator reported to the EPAป in
writing, by the following day, the presence of a
significant amount of improperly enclosed or
uncovered waste? (Record or photocopy WSRs
indicating improperly enclosed or uncovered waste.)
e. Date of receipt [ง61. 154(e)(l)(v)]
f. Comments: _
2. Have signed copies of waste shipment records been sent
to the waste generator as soon as possible, but no longer
than 30 days after receipt of the waste? [ง61.154(e)(2)]
Comments:
A92-1495.1an D-2
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YES NO NA
3. Has the landfill operator attempted to reconcile differences
between the quantity of waste designated on the waste
shipment record and the quantity actually received?
[ง61.154(e)(3)]
Explain:
If the discrepancy is not resolved within 15 days after receiving
the waste, has a report been filed immediately with the
government agency responsible for administering the asbestos
NESHAP program for the waste generator
and
if different, the government agency responsible for
administering the asbestos NESHAP program for the
disposal site?
4. Are copies of all required records and reports retained for
2 years? [ง61.l54(e)(4)]
5. Is a map or diagram of the disposal area being maintained?
[ง61.154(f)]
Does the map or diagram contain the following ACWM
information?
location
depth
area
quantity (cubic yards or meters)
6. Upon closure, has the disposal site operator informed
EPA as to the location and amount of waste? [ง61.154(g)]
7. Upon closure, has a notification concerning the presence of
asbestos waste been placed on the deed to the property?
[ง6U54(a)J
A92-1495.lan
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YES NO NA
8. Are records available for inspection? [ง61.154(i)J
9. Has the Administrator been notified in writing at least
45 days prior to excavating or otherwise disturbing any
ACWM already deposited and covered? [ง61.154(j)] _ _ __
Does the notice include:
scheduled starting or completion dates?
reason for distributing the waste?
emission control procedures?
location of temporary/final disposal site?
Has notice of a new start date been provided to the
Administrator at least 10 working days before excavation
begins? (Note: The new start date cannot be earlier than
the original date.)
10. Has a stationary source report been filed with the
Administrator or government agency responsible for
administering the asbestos NESHAP program? [งง61.153.(a),
61.10] _
Does the report include:
brief description of site?
methods used to comply with the asbestos NESHAP?
name/address of owner/operator?
location of source?
type of hazardous pollutant emitted?
description of nature, size, design of stationary source?
average weight/month processed over preceding 12
months?
A92-1495.1an D-4
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YES NO NA
III. SITE OPERATION
Determine the following at the disposal site. Collect
samples and take photographs as necessary to document
noncompliance with the provisions of the asbestos NESHAP.
1. Is the disposal site operated in compliance with one of the following
site requirements? (ง61.154) _ _
a. No visible emissions [ง61.154(a)] and
warning signs and fencing, or natural barrier
[ง61.154(b)] _ _
b. 6-inch cover within 24 hours [ง61.154(c)(l)] _ _
c. Dust suppressant within 24 hours [ง61.154(c)(2)] and _ _
warning signs and fencing, or natural barrier
[ง61.154(b)] _ _
d. Administrator approved alternative method [ง61.154(d)J
If yes, explain:
Comments:
A92-1495.1an D-5
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2. If necessary draw a diagram of the waste disposal site to illustrate possible violations.
Note compass directions, site entrance and boundaries, roadways, direction of prevailing
wind, land use surrounding site, sample and photograph locations, etc.
Comments:
YES NO NA
3. Is there any ACWM visible at the site?
a. Was it deposited within the past 24 hours?
[ง61.154(c)(2)] _ _
A92-1405.Ian D-6
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YES NO NA
b. Is it sealed in leak-tight containers or wrapping?
[ง61.150(a)(l)J
If no, is the ACWM exempt from packaging
requirements for one of the following reasons?
ordered demolition
discovered after demolition began
encased in concrete
Category I nonfriable (not in poor condition,
not friable)
Category II nonfriable which is not RACM
4. Are vehicles seen unloading ACWM?
If yes, are they marked with the following information?
easy to read legend
20" x 14" upright format sign
asbestos hazard warning
Does the transporter possess a properly completed waste
manifest?
If not, determine as many of the following as possible:
transporter company name
address
telephone no.
generator's name
address
telephone no.
location where ACWM is being collected
A92-1495.1an
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IV. POST INSPECTION INTERVIEW
Summary of Recommendations/Discussions with Site Operator.
V. ADDITIONAL COMMENTS
Inspector's signature: Date:
A92-1495.lan D-8
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Site Code:
SAMPLE COLLECTION LOG
Date:
Sample Number
Sample Location
Sample Description
Comments
A92-1495.scl
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PHOTO IDENTIFICATION LOG SHEET
Site Code: Date:
Inspector/Photographer:
Frame Sample
Photo No. Time Description No.
1 SITE IDENTIFICATION
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
A92-1495.pil
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Frame Sample
Photo No. Time Description No.
19 _
20
21
22
23 ;
24
25
26
27
28 ,
29
30
31
32
33
34
35
36
A92-1495.pil F-2
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AHERA COMPLIANCE CHECKLIST
A. LOCAL EDUCATION AGENCY
1. Name:
2. Address:
B. SCHOOL
1.. Name:
2. Address:
C. DESIGNATED PERSON
1. Name:
2. Telephone number:
3. Description of training acquired:
D. ABATEMENT PROJECT
1. Dimensions of functional space:
2. Project description:
E. PROJECT SUPERVISOR
1. Accredited? Yes __ No
a. Accreditation number:
b. Date of accreditation:
A92-1495.ahc
G-l
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c. Original certification on site? Yes
d. Refresher certification on site? Yes
2. Was supervisor on site?
F. PROJECT WORKERS
Names
State of
Accred.
G. INITIAL CLEANING
1. Date:
Accred.
Number
Yes
Diite of
Accred.
No
No
No
Original
Certificate
On Site?
Yes No
Refresher
Certificate
On Site?
Yes No
2. Person(s) who performed initial cleaning:
3. Locations cleaned:
4. Cleaning methods used:
H. VISUAL INSPECTION BEFORE FINAL CLEARANCE
1. Who will inspect the functional space?
A92-14')S.;ihc
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2. Employer:
a. name:
b. address:
c. telephone number:
I. AIR CLEARANCE
1. Was air clearance in progress? Yes No
If "Yes",
a. Was the functional space dry? Yes No _
b. Were critical barriers in place? Yes No _
c. Was the local exhaust ventilation
system operating during the
sampling period? Yes No _
d. Was a 1 H.P. leaf blower used to
dislodge fibers from horizontal
surfaces? Yes No _
e. Were fans in operation during
the sampling period? Yes No _
If "Yes",
1) How many fans were used in each functional space?
2) What was the orientation of the fans?
2. If air clearance was not in progress,
a. Who will conduct the air clearance?
b. Employer:
1) name:
2) address:
A92-1495.ahe
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3) telephone number:
c. When will air clearance begin?
d. When will air clearance end? _
J. AIR SAMPLE ANALYSIS
1. Analytical Laboratory
a. Name:
b. Address:
c. Telephone:
2. Analytical Method: TEM PCM
If TEM, did the air sampling technician have a sealed blank on site?
Yes No
3. Sampling Procedures
a. How many samples were collected outside the functional space?
b. How many field blanks were taken?
c. Were sampling pumps randomly located throughout the functional space to
be representative of the area? Yes No
d. Where were the outside samples collected?
K. MANAGEMENT PLAN
1. Was the management plan available to review? Yes No
2. Location of plan: LEA School
Inspector's signature: Date:
A92-1495.ahe G-4
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WORKER PROTECTION RULE CHECKLIST
Date of Inspection:
Inspection Site:
1. Is asbestos abatement work being done? (Abatement means activity involving the
removal, enclosure or encapsulation of friable asbestos material.)
Yes No
2. Is abatement work performed by State and local public employees not covered by
the OSHA asbestos standard?
Yes No .
3. Does the work involve more than 3 linear feet or 3 square feet?
Yes No
4. Has the employer notified the EPA Regional Asbestos Coordinator (or other
delegated agency) that an abatement project subject to the provisions of the WPR
will be performed by public employees?
Yes No
If yes,
a. When was notification submitted?
b. When did the abatement project begin?
Notes:
Inspector's Signature
A92-1495.wpr
Date
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A92-1495.wpr
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GLOSSARY
A new "asbestos abatement" industry has developed over the past two decades in
response to the EPA and OSHA regulations concerning demolition and renovation of
buildings containing asbestos. With this industry come many unique or unusual terms
and acronyms, some derived from the field of medicine, others from equipment names,
etc. For convenience, this glossary has been divided into "acronyms", "governmental
agencies", "legislation", and "general terms" sections.
ACRONYMS
ABPO
ACGIH
ACM
ACWM
AHERA
AIA
AISRule
ANSI
ASHAA
ASHAJU
ASTM
CAA
CERCLA
COC
DHHS
DOL
AM-1495.glO
Asbestos Ban and Phaseout Rule
American Conference of Governmental Industrial Hygienists
Asbestos-Containing Material
Asbestos-Containing Waste Material
Asbestos Hazard Emergency Response Act
Asbestos Information Act
Asbestos in Schools Rule
American National Standards Institute
Asbestos School Hazard Abatement Act
A chestos School Hazard Reauthorization Act
American Society for Testing Maซ*<-
Clean Air Act
Comprehensive Environmental Response, Con,r-nsationAfld Liability Act
Chain of Custody
Department of Hcahh and Human Services.
Department of Labor.
1-1
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DOT Department of Transportation.
EPA Environmental Protection Agency
F/CC Fibers/Cubic Centimeter
FEVj Forced Expiratory Volume in 1 second
FVC Forced Vital Capacity
HEPA High Efficiency Particulate Air
HVAC Heating, Ventilation, and Air Conditioning
LEV Local Exhaust Ventilation
MAP Model Accreditation Plan
NARS National Asbestos Registry System
NESHAP National Emission Standards for Hazardous Air Pollutants
NIOSH National Institute for Occupational Safety and Health
fffsy National rnsutuie roirr*umaairc!s anU Technology
OSHA
PAPR
PCM
PEL
rf
PFT
PLM
NVLAP National Voluntary Laboratory Accreditation Program
OPTS Office of Pesticides and Toxic Substances
Occupational Safety and Health Administration
Powered Air Purifying Respirator
Phase Contrast M;~ ^y
..ussible Exposure Iwiift
Protection F~lOr
* uimonary Function Test
Polarized Light Microscopy
AW-149S.gk>
1-2
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PPE Personal Protective Equipment
PVC Polyvinyl Chloride
QC Quality Control
RACM Regulated Asbestos-Containing Material
RCRA Resource Conservation and Recovery Act
RQ Reportable Quantity
SARA Superfund Amendments and Reauthorization Act
SCBA Self Contained Breathing Apparatus
SDWA Safe Drinking Water Act
SEM Scanning Electron Microscopy
SHEMD Safety, Health and Environmental Management Division
SOPs Standard Operating Procedures
SSCD Stationary Source Compliance Division
TEM Transmission Electron Microscopy
TLV Threshold Limit Value
TSCA Toxic Substances Control Act
TWA Time-Weighted Average
VE Visible Emissions
WPR Worker Protection Rule
WSR Waste Shipment Record
AM-
I495.glo
1-3
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GOVERNMENTAL AGENCIES
Environmental Protection Agency (EPA) - The organization within the Federal
government which is ultimately responsible for enforcing the asbestos NESHAP in order
to protect people who work or live near potential asbestos release areas such as
buildings undergoing demolition or renovation.
National Institute of Occupational Safety and Health (NIOSH) Tests respirators and acts
as the research arm for OSHA.
Occupational Safety and Health Administration (OSHA) Protects worker health.
Office of Pesticides and Toxic Substances (OPTS) - The group within EPA which is
responsible for implementing and carrying out programs to enforce the TSCA
regulations.
Safety, Health and Environmental Management Division (SHEMD) The group within
EPA that is responsible for developing health and safety guidance specific to EPA
employees.
Stationary Source Compliance Division (SSCD) - The group within EPA that is
responsible for implementing and carrying out a program to assure that the regulated
community complies with the asbestos NESHAP.
LEGISLATION
Asbestos Ban and Phaseout Rule (ABPO) - Prohibited at staged intervals the future
manufacture, importation, processing, and distribution of almost all asbestos-containing
products; partially overturned by U.S. Court of Appeals; currently bans new uses of
asbestos and products (>7/12/89). 40 CFR Part 763 Subpart I. 1989.
Asbestos-Containing Materials (ACM) in Schools Rule - Created in response to AHERA
mandate. Often referred to as "AHERA". Requires schools to inspect for asbestos,
implement response actions, submit asbestos management plans to states, and re-inspect
every three years. Specifies use of accredited inspectors, air sampling methods, and
waste disposal procedures. 40 CFR 763, Subpart E. 1987.
Asbestos Hazard Emergency Response Act (AHERA) - Required EPA and the states to
address the potential problems of asbestos-containing materials in schools. 15 U.S.C.
2641. 1986.
J-4
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Asbestos Information Act (ALA) - Required former and current manufacturers and
processors of certain asbestos products to submit information identifying their products
to EPA. (1988) Public Law 100-577.
Asbestos in Schools (AIS) Rule - Required public and private schools to inspect for
friable suspect ACM and provide notification to parents and building occupants. (1979)
40 CFR Part 763 Subpart F.
Asbestos NESHAP Asbestos National Emission Standards for Hazardous Air Pollutants.
The specific portion of Section 112 of the CAA that addresses asbestos. (1984) 40 CFR
Part 61, Subpart M.
Asbestos School Hazard Abatement Act (ASHAA) - Provides funding for schools having
justifiable need for asbestos abatement. (1984) Public Law 101-637.
Asbestos School Hazard Reauthorization Act (ASHARA) Reauthorized funding for
schools in need and mandated revisions to EPA's MAP developed under AHERA
(1990) Public Law 101-637.
Clean Air Act (CAA) - Legislation that provides EPA with authority to regulate sources
of air pollution. (1970) 42 U.S.C. ง7401 et seq.
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) -
Addresses problems associated with actual or potential release of hazardous substances
into the environment. (1980) 42 U.S.C 9601 et seq.
Model Accreditation Plan (MAP) Established training requirements for asbestos
inspectors, management planners, project designers, contractors/supervisors, and
abatement workers in schools; mandated by AHERA. (1987) 40 CFR Part 763 Subpart
E Appendix C. (Revision: Asbestos Model Accreditation Plan; Interim Final Rule
published in 59 FR 5236, February 3, 1994).
National Emission Standards for Hazardous Air Pollutants (NESHAP) - Current NESHAP
regulations address stationary sources of arsenic, asbestos, benzene, beryllium, coke oven
emissions, mercury, radionuclides, and vinyl chloride.
Resource Conservation and Recovery Act (RCRA) - Regulates management of hazardous
waste ("cradle to grave"). (1976) 42 U.S.C. 6901 et seq.
Safe Drinking Water Act (SDWA) - Established a program to require compliance with
national drinking water standards for contaminants, focused on removal of contaminants
from water supplies, and established programs intended to protect underground sources
of drinking water. (1974) 42 U.S.C 300.
A94-U95.gJo
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Superfund Amendments and Reauthorization Act (SARA) - Clarified the authority of
CERCLA. Public Law 99-499. 1974.
Toxic Substances Control Act (TSCA) - Permits EPA to identify and evaluate potential
hazards from chemical substances and regulate the production, use, distribution and
disposal of hazardous chemical substances. 15 U.S.C. 2601, et seq. 1976.
Worker Protection Rule (WPR) - TSCA regulation which protects public employees
performing asbestos abatement work in states not covered by asbestos standards. 40
CFR 763, Subpart G. 1987.
GENERAL TERMS
Action level - An airborne concentration of asbestos of 0.1 f/cc of air calculated as an 8-
hour, time-weighted average. Attaining the action level triggers exposure monitoring,
medical surveillance, and employee information and training requirements.
Adequately wet - To sufficiently mix or penetrate with liquid to prevent the release of
particulates. If visible emissions are observed coming from asbestos-containing material,
then that material has not been adequately wetted. However, the absence of visible
emissions is not sufficient evidence of being adequately wet.
Aggressive air sampling - Air sampling which takes place after final cleanup while the air
is being physically agitated with leaf blowers and fans to produce a "worst case" situation.
Air cell insulation - A type of insulation that looks like corrugated paper and is usually
light to medium gray in color.
Air lock - A system of enclosures consisting of two polyethylene curtained doorways at
least 3 feet apart that should permit air movement from clean to contaminated areas.
Air locks are usually part of a decontamination chamber attached to an abatement area
which is under reduced pressure.
Air monitoring The process of measuring the airborne fiber concentration in a specific
quantity of air over a given amount of time.
Alveolar macropHages Highly specialized mobile cells in the lungs that attempt to engulf
and digest sue.*: iung intruders as dusts or fibers.
Alveoli Microscopic sacs in the lungs where the exchange of oxygen and carbon dioxide
occurs.
-------
Amended water - Water to which a chemical wetting agent (surfactant) has been added to
improve penetration of the water into asbestos-containing materials that are being
removed.
Amphibole asbestos - Hydrated silicate forms of asbestos; includes crocidolite,
anthophyllite, amosite, actinolite and tremolite.
Area air monitoring - Air sampling conducted in an area representative of the overall
area under investigation; used for hazard assessment, ambient and background surveys,
and monitoring during and after abatement actions.
Asbestiform - Fibrous minerals which, due to their crystalline structures and chemical
composition, can be classified as a form of asbestos.
Asbestos - The asbestiform varieties.of serpentinite (chrysotile), riebeckite (crocidolite),
cummingtonite-grunerite, anthophyllite, and actinolite-tremolite.
Asbestos abatement Procedures used to control fiber release from asbestos- containing
materials in buildings; includes removal, encapsulation, enclosure or repair of ACM.
Asbestos-containing waste materials (ACWM) - Mill tailings or any waste that contains
commercial asbestos and is generated by a source subject to the provisions of this
subpart. This term includes filters from control devices, friable asbestos waste material,
and bags or other similar packaging contaminated with commercial asbestos. As applied
to demolition and renovation operations, this term also includes regulated asbestos-
containing material waste and materials contaminated with asbestos including disposable
equipment and clothing.
Asbestos fibers Fibers with a length greater than 5 microns and a minimal length to
width ratio of 3:1 generated from an asbestos-containing material.
Asbestosis - A non-malignant, progressive, irreversible lung disease caused by the
inhalation of asbestos dust and characterized by diffuse fibrosis and rales.
Atmosphere-supplying respirator - Respiratory protection devices which exclude workplace
air altogether and provide clean air from some independent source, (i.e., SCBA and
Type C SAR).
Background air monitoring - Air sampling done to determine existing levels of airborne
asbestos prior onset of abatement activities.
Cancer-A cellular tumor which normally leads to premature death of its host unless
controlled.
'VM.U95.iiU-
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Category I nonfriable ACM - Asbestos-containing packings, gaskets, resilient floor
covering (and mastic), and asphalt roofing products containing more than 1 percent
asbestos as determined using the method specified in Appendix A, Subpart F, 40 CFR
Part 763, Section 1, Polarized Light Microscopy.
Category II nonfriable ACM - Any material, excluding Category I nonfriable ACM,
containing more than 1 percent asbestos as determined using the methods specified in
Appendix A, Subpart F, 40 CFR Part 763, Section 1, Polarized Light Microscopy that,
when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.
Chain of custody (COC) form - Documentation used to track samples from the point of
collection through receipt by the analytical laboratory (and, potentially, back to the
inspector).
Chrysotile (white asbestos) The only asbestiform mineral of the serpentine variety; fibrils
resemble a cylindrical scroll or tube; fiber length determined by crystallization
conditions; most common form of asbestos used in buildings.
Cilia - Tiny, hair-like, mucus-coated structures in the windpipe and bronchi of the lung
passages that help force undesirable particles up and out of the lungs.
Clean room/area - The first stage or room of the decontamination enclosure system in
which workers prepare to enter the work area. <
Clearance air monitoring - Air sampling done at a project's completion to determine if
airborne levels of asbestos are at an acceptable level; done before critical barriers are
removed.
Commercial asbestos - Any material containing asbestos that is extracted from ore and
has value because of its asbestos content.
Competent person - One who is capable of identifying existing asbestos hazards in the
workplace, and who has the authority to take prompt corrective measures to eliminate
them. The competent person has specific duties as outlined in 1926.32(f).
Continuous flow airline respirator A respirator that maintains a constant airflow to the
wearer.
Critical barrier - Plastic, foam, duct tape, plywood, sheetrock, etc. used to seal
penetrations into the worksite to help prevent the release of asbestos fibers into the
environment.
Cutting - To penetrate with a sharp edge instrument. This includes sawing, but does not
include shearing, slicing, or punching.
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Decontamination enclosure system A series of connected chambers (separated by
polyethylene-curtained doorways) which prevent contamination of areas adjacent to the
work area. Usually comprised of a clean room, shower and equipment (dirty) room.
Demolition - the wrecking or taking out of any load-supporting structural member of a
facility together with any related handling operations or the intentional burning of any
facility.
Emergency renovation operation - A renovation operation that was not planned, but
results from a sudden, unexpected event that, if not immediately attended to, presents a
safety or public health hazard, is necessary to protect equipment from damage, or is
necessary to avoid imposing an unreasonable financial burden. This term includes
operations necessitated by nonroutine failures of equipment.
Encapsulation - Treatment of ACM with a material that surrounds or embeds the ACM
in an adhesive matrix. "Penetrating" encapsulants soak into ACM and bind together all
fibers. "Bridging" encapsulants coat the ACM to prevent fiber release.
Enclosure - Permanent barrier which prevents the migration of fibers from ACM.
i
Equipment/dirty room - The last stage or room of the decontamination system before
entering the work area.
Facility - Any institutional, commercial, public, industrial, or residential structure,
installation, or building (including any structure, installation, or building containing
condominiums or individual dwelling units operated as a residential cooperative, but
excluding residential buildings having four or fewer dwelling units); any ship; and any
active or inactive waste disposal site. For purposes of this definition, any building
structure, or installation that contains a loft used as a dwelling is not considered a
residential structure, installation, or building. Any structure, installation, or building that
was previously subject to this subpart is not excluded, regardless of its current use or
function.
Facility component Any part of a facility including equipment.
Fibrosis - A iun^ condition marked by the presence of scar tissue caused by the
inhalation of exce^ne amounts of fibrous dust.
Fit factor The rjt.o of challenge agent concentration outside and inside the respirator
facepiece deterrr.ned during quantitative fit testing; specific to the individual and model
of respirator
Forced expiratory volume - 1 second (FEVJ - The maximum volume of air that can be
farced from an individual's fully inflated lungs in 1 second.
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Forced vital capacity (FVC) - The part of a pulmonary function test which measures the
quantity of air that can be forcibly exhaled from a person's lungs after full inhalation.
Friable asbestos material Any material containing more than 1 percent asbestos as
determined using the method specified in Appendix A, Subpart F, 40 CFR Part 763
Section 1, Polarized Light Microscopy, that, when dry, can be crumbled, pulverized, or
reduced to powder by hand pressure. If the asbestos content is less than 10 percent as
determined by a method other than point counting by polarized light microscopy (PLM),
verify the asbestos content by point counting using PLM.
Full-face respirator - A respirator which covers the wearer's entire face from across the
forehead, around the temples, along the cheek bones to below the chin.
Glove bag - A sealed compartment with attached inner gloves used for the handling of
asbestos-containing materials. Properly installed and used, glove bags provide a small
work area enclosure typically used for small-scale asbestos stripping operations.
Information on glove bag installation, equipment and supplies, and work practices is
contained in OSHA's final rule on occupational exposure to asbestos (Appendix G to 29
CFR Part 1926.58).
Grinding To reduce to powder or small fragments. This includes mechanical chipping
or drilling.
Half-mask respirator - A respirator which covers one-half of the wearer's face from the
bridge of the nose across the cheeks to below the chin.
Heat cramps A form of heat stress resulting in painful spasms of heavily-used skeletal
muscles such as hands, arms, legs, and abdomen, sometimes accompanied by dilated
pupils and weak pulse resulting from depletion of the salt content of the body.
Heat exhaustion - A form of heat stress resulting from dehydration and/or salt depletion
characterized by cold, clammy skin, profound weakness, and a pale appearance. Other
symptoms include nausea, headache, giddiness, vomiting, muscle cramps, and diarrhea.
Heat stroke - The most severe form of heat stress disorder resulting from the loss of the
body's ability to sweat; characterized by hot dry skin, dizziness, nausea, severe headache,
confusion, delirium, loss of consciousness, convulsion, and possibly coma and death.
HEPA vacuum - A vacuum system equipped with a HEPA filter.
High efficiency paniculate air (HEPA) - Filter rated capable of trapping and retaining
99.97% of all panicles larger than 0.3 microns.
Homogeneous - Evenly mixed and similar in appearance and texture throughout.
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Inactive waste disposal site - Any disposal site or portion of it where additional
asbestos-containing waste material has not been deposited within the past year.
In poor condition - Means that the binding of the material is losing its integrity as
indicated by peeling, cracking, or crumbling of the material.
Installation - Any building or structure or any group of buildings or structures at a single
demolition or renovation site that are under the control of the same owner or operator
(or owner or operator under common control).
Kleenguard* - A triple-layer nonwoven polypropylene fabric which is durable, chemically
inert, lightweight, and breathable. Kleenguard is relatively inexpensive and often used
for disposable garments.
Leak-tight - Means that solids or liquids cannot escape or spill out. It also means
dust-tight.
Local exhaust ventilation (LEV) unit Machine designed to mechanically remove air
contaminants from a point of operation.
Lung cancer - An uncontrolled growth of abnormal cells in the lungs which normally
results in the death of the host.
Medical history - A record of a person's past health record, including all of the hazardous
materials that they have been exposed to and any injuries or illnesses which might
affect/dictate their future health status.
Mesothelioma - A relatively rare, incurable form of cancer of the membrane which lines
body cavities and covers body organs.
Micron - One-millionth of a meter.
"Mil" - Prefix meaning one-thousandth; commonly used to describe thickness of
polyethylene sheeting (6 mil poly = 0.006" thick.)
National Asbestos Registry System (NARS) - A national electronic database system used to
track notifications, inspections, and enforcement responses.
Natural barrier - A natural object that effectively precludes or deters access. Includes
physical obstacles such as cliffs, lakes or other large bodies of water, deep and wide
ravines and mountains. Remoteness by itself is not a natural barrier.
Nomex* - A woven fabric of polyamide fibers which is very durable, chemical-, acid-, and
flame-resistant. Nomex will not continue to burn once the source of flame is removed.
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Nonfriable asbestos-containing material Any material containing more than one percent
asbestos as determined using the method specified in Appendix A, Subpart F, 40 CFR
Part 763, Section 1, Polarized Light Microscopy that, when dry, cannot be crumbled,
pulverized, or reduced to powder by hand pressure.
Nonscheduled renovation operation - A renovation operation necessitated by the routine
failure of equipment, which is expected to occur within a given period based on past
operating experience, but for which an exact date cannot be predicted.
Outside air - The air outside buildings and structures, including, but not limited to, the
air under a bridge or in an open-air ferry dock.
Owner or operator of a demolition or renovation activity - Any person who owns, leases,
operates, controls or supervises the facility being demolished or renovated or any person
who owns, leases, operates, controls, or supervises the demolition or renovation
operation, or both.
Peritoneum - The thin membrane that lines the surface of the abdominal cavity.
Permissible exposure limit (PEL) - Amount of an airborne contaminant thought to have
no deleterious effect when encountered for an entire work day; the PEL for asbestos is
0.2 f/cc.
Personal air monitoring Air sampling conducted in the "breathing zone" of a worker
during his/her normal work schedule; used to determine personal exposure to airborne
asbestos.
Personal protective equipment (PPE) - Any material or device worn to protect a worker
from exposure to, or contact with, any harmful material or force. May include a
respirator, coveralls, hard hat, steel toed shoes, safety glasses, etc.
Phase contrast microscopy (PCM) - An optical microscopic technique used for counting
fibers in air samples, but which does not distinguish asbestos fibers.
Pipe lagging - The insulation or wrapping around sections of pipes.
Planned renovation operation - A renovation operation, or a number of such operations,
in which some RACM will be removed or stripped within a given period of time and that
can be predicted. Individual nonscheduled operations are included if a number of such
operations can be predicted to occur during a given period of time based on operating
experience.
Pleura - The thin membrane surrounding the lungs which also lines the internal surface
of the chest cavity.
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Pleural plaque - Diffuse area of scar tissue that may form on the mesothelium of the
chest cavity or (rarely) on the pericardium; indicative of asbestos exposure.
Point counting - A technique used to determine the relative projected areas occupied by
separate components in a microscope slide preparation of a sample. For asbestos
analysis this technique is used to determine the relative concentrations of asbestos
minerals to nonasbestos sample components.
Polarized light microscopy (PLM) - An optical microscopic technique used to distinguish
between different types of fibers based on their shapes and unique optical properties;
commonly used to determine the presence of asbestos in bulk samples of suspected
asbestos- containing materials.
Polyethylene (poly) - Plastic sheeting often used to seal off an area in which asbestos
removal is taking place; used to prevent contamination of other areas.
Pofyvinyl chloride (PVC) - A commonly used material which is resistant to acids but will
allow permeation and retention of traces of contamination.
Pre-molded. insulation - Insulation used on pipes that is formed in half circles. It is
usually held in place by steel bands and/or canvas wrap.
Pressure-demand airline respirator - A respiratory protection device which has a regulator
and valve designed to maintain positive pressure in the facepiece at all times.
Protection factor (PF) - Amount of protection provided by a respirator; determined by
dividing the airborne fiber concentration outside of the mask by the concentration inside
the mask. Protection factors have been assigned to classes of respirators (i.e., half-face,
full-face, etc.).
Protective clothing - Protective, lightweight garments worn by workers performing asbestos
abatement to keep gross contamination off the body.
Pulmonary Junction test - A part of the medical examination required to determine the
health of a person's lungs.
Qualitative fit test - A method of testing a respirator's face-to-facepiece seal using a
challenge material of irritant smoke, banana oil or saccharin. Successful qualitative fit
tests confer a minimum protection factor of 10 according to OSHA regulation 29 CFR
Part 1910.134 Appendix C.
Quality control (QC) samples - Bulk samples used to determine both sampling and
analytical precision.
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Quantitative fit test - A method of testing a respirator's face-to-facepiece seal which
involves measuring the relative amounts of a challenge substance both inside and outside
the mask. Quantitative fit testing results in the establishment of a numerical fit factor.
Rales - A dry crackling sound heard posteriorly in the bases of the lungs; common
symptom of asbestosis.
Reduced pressure atmosphere - An atmosphere created in a work area enclosure such that
airborne fibers will tend to be drawn through the filtration system rather than leak out
into the surrounding areas. The air pressure inside the work area is less than that
outside the work area.
Regulated area - Established by the employer to demarcate areas where airborne
concentrations of asbestos, tremolite, anthophyllite or actinolite exceed, or can
reasonably be expected to exceed, the permissible exposure limit.
Regulated asbestos-containing material (RACM) - (a) Friable asbestos 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, or (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 regulated by this subpart.
Remove - To take out RACM or facility components that contain or are covered with
RACM from any facility.
Renovation Altering a facility or one or more facility components in any way, including
the stripping or removal of RACM from a facility component. Operations in which
load-supporting structural members are wrecked or taken out are demolitions.
Repair - Overhauling, rebuilding, reconstructing or reconditioning.
Reportable quantity (RQ) Minimal amount of hazardous material subject to the
requirements of CERCLA; the RQ for asbestos is one pound.
Resilient floor covering Asbestos-containing floor tile, including asphalt and vinyl floor
tile, and sheet vinyl floor covering containing more than 1 percent asbestos as
determined using polarized light microscopy according to the method specified in
Appendix A, Subpart F, 40 CFR Part 763, Section 1, Polarized Light Microscopy.
Respirator program - A written program established by an employer which provides for
the safe use of respirators on the job site.
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Saranex* - A thermoplastic material used to coat protective clothing to provide
resistance to PCBs and solvents.
Scanning electron microscopy (SEM) A method of microscopic beam directed at the
sample and then collects the beams that are reflected to produce an image from which
fibers can be identified and counted.
Self-contained breathing apparatus (SCBA) - A respirator with air provided by a tank
worn by the user; provides the highest level of protection; can be used when a
contaminant's concentration is unknown.
Standard operating procedures (SOPs) A body of information which helps ensure
consistency in a particular activity.
Strip - To take off RACM from any part of a facility or facility components.
Structural member Any load-supporting member of a facility such as beams and
load-supporting walls; or any nonload-supporting members, such as ceilings and
nonload-supporting walls.
Surfactant - A chemical wetting agent added to water to improve its penetration into
asbestos-containing materials.
Threshold limit value (TLV) - Level of contaminant to which it is believed workers can be
exposed with minimal adverse health effects; established by the American Conference of
Governmental Industrial Hygienists (ACGIH).
Tune-weighted average (TWA) - Technique used when determining average exposure to
airborne asbestos during a specified length of time. For example, the PEL for asbestos
is 0.2 f/cc as an 8-hour TWA. If an individuals's exposure to asbestos is limited to 1.0
f/cc for one half-hour period during an 8-hour workday, the person's 8-hour TWA would
be 0.063 f/cc (1.0 f/cc + 16 half-hour periods), well below the PEL.
Transmission electron microscopy (TEM) - A method of microscopic analysis in which an
electron beam penetrates (transmits through) a thin sample and produces an image on a
fluorescent screen from which samples can be identified and counted; typically used to
identify and quantify asbestos in air samples.
Type C supplied-air respirator - A respirator which supplies air to the wearer from an
outside source such as a compressor; designed to provide a very high level of protection.
Tyvek* - A non-woven fabric of spun-bonded olefin fibers which is tear-resistant,
relatively inexpensive, resistant to paniculate penetration, and often used for disposable
garments. Tyvek's melting point is 270ฐF.
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Visible emissions (VE) Any emissions (excluding condensed uncombined water vapor)
visually detectable without the aid of instruments, coming from RACM or
asbestos-containing waste material or from any asbestos milling, manufacturing or
fabricating operation.
Waste generator - Any owner or operator of a source covered by this subpart whose act or
process produces asbestos-containing waste material.
Waste shipment record (WSR) - The shipping document, required to be originated and
signed by the waste generator, used to track and substantiate the disposition of
asbestos-containing waste material.
Wetting agents - Materials (such as surfactants) that are added to water which is used for
wetting the asbestos-containing material in order for the water to penetrate more
effectively.
Working day - Monday through Friday including holidays that fall on any of the days
Monday through Friday.
260/160/35 - 260 linear feet (80 linear meters) of ACM on pipes, 160 square feet (15
square meters) of ACM on other facility components, or 35 cubic feet of ACM off
facility components where the amount of ACM previously on pipes and other facility
components is unknown. These figures form the basis of applicability in the asbestos
NESHAP standard.
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LIST OF AVAILABLE REFERENCES
The following publications may be available from the EPA Regional Offices or from the
Asbestos and Small Business Ombudsman, OSDBU A-149-C, Washington, DC 20460.
Telephone: (800) 368-5888; for DC and VA: (703) 305-5938. Information may also be
obtained by calling the TSCA Hotline (202) 554-1404. For information regarding the
Asbestos in Schools Program, call (800) 835-6700.
Piper, S.G., and Ford P. 1988 NESHAPs Asbestos Demolition and Renovation Inspection
Workshop - Final Report. Alliance Technologies Corporation. EPA Contract No.
68-02-4465, Work Assignment No. 21, March 1988.
Piper, S.G. and Lebedzinski N. 1989 Demolition and Renovation Inspection and Safety
Procedures Workshop - Final Report. Alliance Technologies Corporation. EPA Contract
No. 68-02-4465, Work Assignment No. 89-112, July 1989.
Chesson J., Hatfield J., Schultz B., Dutrow E., Blake J. Airborne Asbestos in Public
Buildings. Environ Res 51(1):100-107,1990.
Airborne Asbestos Levels in Schools. U.S. EPA Office of Toxic Substances, Washington,
DC. EPA-560/5-83-003, June 1983.
American National Standard Commodity Specification for Air. Compressed Gas
Association, Inc., Arlington, VA. Pamphlet G-7.1, ANSIฎ Z86.1 -1973.
American National Standard for Respiratory Protection - Respirator Use - Physical
Qualifications for Personnel. American National Standards Institute, Inc., New York, NY.
ANSIฎ Z88.6-1984.
American National Standard Practices for Respiratory Protection. American National
Standards Institute, New York, NY. ANSIฎ Z88.2 -1980.
Applicability of the Asbestos NESHAP to Asbestos Roofing Removal Operations -
Guidance Manual. EPA 340-B-94-001, August 1994.
Asbestos. Occupational Safety and Health Administration, Labor. 29 CFR Part 1926.1101
(Construction Standard).
Huff, J.E. Asbestos: A Perspective To An Overview. Toxicology Information Response
Center, Oak Ridge, TN, March 1978.
1979
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Asbestos Abatement and Management in Buildings - Guide Specifications. National
Institute of Building Sciences (NIBS), Washington, DC. 1988.
Asbestos Contamination of the Air in Public Buildings, U.S. EPA Office of Air Quality
Planning and Standards, Research Triangle Park, NC. EPA-450/3-76-004, October 1975.
Asbestos Content in Bulk Insulation Samples: Visual Estimates and Weight Composition.
U.S. EPA Office of Pesticides and Toxic Substances, Washington, DC. EPA-560/5-88-011,
September 1988.
Asbestos Demolition and Renovation Civil Penalty Policy (Revised), U.S. EPA Office of
Enforcement and Stationary Source Compliance Division, Office of Air Quality Planning and
Standards, May 1992.
Asbestos Demolition and Renovation Enforcement Strategy. U.S. EPA Stationary Source
Compliance Division, Office of Air Quality Planning and Standards. Washington, DC, April
1984.
Asbestos Demolition and Renovation Enforcement Strategy (Revised). U.S. EPA
Stationary Source Compliance Division, Office of Air Quality Planning and Standards,
Washington, DC, March 31, 1988.
Asbestos Exposure Assessment in Buildings. Inspection Manual. U.S. EPA Region VII.
October 1982.
Asbestos in Buildings: A National Survey of Asbestos-Containing Friable Materials. U.S.
EPA Office of Toxic Substances, Washington, DC. EPA-560/5-84-006, October 1984.
Asbestos in Buildings: Simplified Sampling Scheme for Friable Surfacing Materials.
U.S. EPA Office of Pesticides and Toxic Substances, Washington, DC. EPA-560/5-85-030a,
October 1985. (Pink Book).
Asbestos in Public and Commercial Buildings: A Literature Review and Synthesis of
Current Knowledge. Health Effects Institute - Asbestos Research (HEI-AR), Cambridge,
MA, 1991.
The Asbestos Informer. U.S. EPA, Air and Radiation (EN-341), Washington, DC. EPA
340/1-90-020, December 1990.
Asbestos Model Accreditation Plan. U.S. Environmental Protection Agency. 40 CFR Part
763, Subpart E, Appendix C.
1979 J-2
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Asbestos NESHAP Inspection and Safety Procedures Workshop (Student Manual). U.S.
Environmental Protection Agency, Office of Air Quality Planning and Standards, Research
Triangle Park, NC. EPA 455/B-93-001a, Revised August 1997.
Piper, S.G., et al. Asbestos NESHAP Inspector Safety Workshop - Draft Final Report.
Alliance Technologies Corporation. EPA Contract No. 68-02-4465, Work Assignment No.
40, June 1988.
Asbestos Procedures and Programs for Employees (Draft). EPA Safety, Health, and
Environmental Management Division, March 1997.
Natale, A. and Levins, H.J. Asbestos Removal and Control, An Insider's Guide to the
Business. Levins Design, Inc. ISBN 0-917097-00-9. 1984.
Asbestos Waste Management Guidance. U.S. EPA Office of Solid Waste, Washington, DC.
EPA-530-SW-85-007, May 1985. (Little Blue Book).
Asbestos-Containing Materials in School Buildings: A Guidance Document, Parts 1 and
2. U.S. EPA Office of Toxic Substances, Washington, DC. EPA-450/2-78-014 (OAQPS
No. 1.2-094), March 1978. (Orange Book).
Asbestos-Containing Materials in School Buildings, Guidance for Asbestos Analytical
Programs. U.S. EPA Office of Toxic Substances, Washington, DC. EPA-560/13-80-017A,
December 1980.
Asbestos/NESHAP Adequately Wet Guidance. U.S. EPA Air and Radiation (EN4341W),
Washington, DC. EPA 340/1-90-019, December 1990.
Asbestos/NESHAP Regulated Asbestos Containing Materials Guidance. U.S. EPA Air and
Radiation (EN4341W), Washington, DC. EPA 340/1-90-018, December 1990.
Assessing Asbestos Exposure in Public Buildings, U.S. EPA Office of Toxic Substances,
Washington, DC. EPA-560/5-88-002, 1988.
Common Questions on the Asbestos NESHAP. U.S. EPA Air and Radiation (EN-341),
Washington, DC. EPA 340/1-90-021, December 1990.
Control of Asbestos Exposure During Brake Drum Service. U.S. Department of Health and
Human Services, Cincinnati, OH. DHHS (NIOSH) Publication No. 89-121, August 1989.
Controlling Asbestos Contamination with Negative Air Filtration Systems. Source Finders,
Voorhees, N.J. ISBN 0-917097-01-7- 1984.
1979
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Electron Microscope Measurement of Airborne Asbestos Concentrations: A Provisional
Methodology Manual. U.S. EPA Office of Research and Development, Research Triangle
Park, NC. EPA-600/2-77-178, Revised June 1978.
EPA Course #350, Asbestos NESHAP Inspection and Safety Procedures, Reference
Materials - Volume I. U.S. EPA Office of Air Quality Planning and Standards, Research
Triangle Park, NC. EPA 455/B-93-001d, Revised June 1993.
EPA Course #350, Asbestos NESHAP Inspection and Safety Procedures, Reference
Materials - Volume II. U.S. EPA Office of Air Quality Planning and Standards, Research
Triangle Park, NC. EPA 455/B-93-001e, Revised March 1994.
EPA Demolition & Renovation Inspection Procedures. U.S. EPA Stationary Source
Enforcement Division, Washington, DC, S.22, October 1975.
EPA Study of Asbestos-Containing Materials in Public Buildings - A Report to Congress.
U.S. EPA, Washington, DC, February 1988.
Evaluation of Asbestos Abatement Techniques, Phase 1: Removal. U.S. EPA Office of
Toxic Substances and Environmental Monitoring Systems Laboratory, Washington, DC.
EPA-560/5-85-019, October 1985.
Evaluation of Asbestos Abatement Techniques, Phase 2: Encapsulation with Latex Paint.
U.S. EPA Office of Toxic Substances, Washington, DC. EPA 560/5-86-016, July 1986.
Evaluation of Encapsulants for Sprayed-On Asbestos-Containing Materials in Buildings.
U.S. EPA Office of Research and Development, Cincinnati, OH. 1981.
An Evaluation of Glove Bag Containment in Asbestos Removal, U.S. Department of Health
and Human Services, Cincinatti, OH. DHHS (NIOSH) Publication No. 90-119, October
1990.
Evaluation of the Asbestos-in-Schools Identification and Notification Rule. U.S. EPA
Office of Toxic Substances, Washington, DC. EPA-560/5-84-005, October 1984.
Guidance for Controlling Asbestos-Containing Materials in Buildings. U.S. EPA Office of
Pesticides and Toxic Substances, Washington, DC. EPA-560/5-85-024, June 1985. (Purple
Book).
Guidance for Controlling Friable Asbestos-Containing Materials in Buildings. U.S. EPA
Office of Pesticides and Toxic Substances, Washington, DC. EPA-560/5-83-002, March
1983. (Blue Book).
1979
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Guidance for Preventing Asbestos Disease Amang Auto Mechanics, U.S. EPA Office of
Pesticides and Toxic Substances, Asbestos Action Program, Washington, DC, June 1986.
(Yellow Book),
A Guide to Normal Demolition Practices Under the Asbestos NESHAP. U.S. EPA Office
of Air Quality Planning and Standards, Washington, DC. EPA-340/1-92-013, September
1992.
A Guide to the Asbestos NESHAP as Revised November 1990. U.S. EPA Air and Radiation
(EN-341), Washington, DC. EPA 340/1-90-015, November 1990.
A Guide to Respiratory Protection for the Asbestos Abatement Industry. U.S. EPA Office
of Pesticides and Toxic Substances, Washington, DC. EPA-560-OPTS-86-001, April 1986.
(White Book).
Guide Specifications for the Abatement of Asbestos Release from Spray- or
Trowel-Applied Materials in Buildings and Other Structures. The Foundation of the Wall
and Ceiling Industry, Washington, DC, December 1981.
Guidelines for Asbestos NESHAP Demolition and Renovation Inspection Procedures.
U.S. EPA Office of Air Quality Planning and Standards, Washington, DC. EPA-340/1-90-
007, Revised November 1990.
Guidelines for Asbestos NESHAP Landfill Recordkeeping Inspections. U.S. EPA Office
of Air Quality Planning and Standards, Washington, DC. EPA-340/1-92-012, March 1992.
Guidelines for Catastrophic Emergency Situations Involving Asbestos. U.S. EPA Air and
Radiation (EN-341 W), Washington, DC. EPA 340/1-92-010, February 1992.
Health and Safety Guidelines for EPA Asbestos Inspectors (Revised). U.S. EPA Office of
Administration and Resources Management, Washington, DC, March 1991.
Inspector's K.I.S.S. Manual. U.S. EPA Region 10, Seattle, WA, January 1992. (Revised
January 1993.)
Managing Asbestos in Place-A Building Owner's Guide to Operations and Maintenance
Programs for Asbestos-Containing Materials. U.S. EPA Pesticides and Toxic Substances
(TS-799), Washington, DC. 2OT-2003, July 1990. (Green Book)
Measurement of Asbestos Air Pollution Inside Buildings Sprayed with Asbestos. U.S. EPA
Office of Pesticides and Toxic Substances, Washington, DC. EPA-560/13-80-026, August
1980.
1979 J'5
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Measuring Airborne Asbestos Following an Abatement Action. Environmental Monitoring
Systems Laboratory, Research Triangle Park, NC and U.S. EPA Office of Pesticides and
Toxic Substances, Washington, DC. EPA 600/4-85-049; November 1985. (Silver Book)
Methodology for the Measurement of Airborne Asbestos by Electron Microscopy (Draft
Report), U.S. EPA. July 1984.
National Emission Standards for Hazardous Air Pollutants. 40 CFR Part 61, Subpart A -
General Provisions; Subpart M - National Emission Standard for Asbestos.
National Emission Standards for Hazardous Air Pollutants; Asbestos NESHAP Revision;
Final Rule. Environmental Protection Agency, 40 CFR Part 61 (FR 55: 48406, November
1990.)
National List of Asbestos Landfills. U.S. EPA Office of Air Quality Planning and
Standards, Washington, DC. EPA-340/1-92-011, March 1992.
NIOSH Certified Equipment List. U.S. Department of Health and Human Services,
Morgantown, WV. DHHS (NIOSH) Publication No. 94-104, September 1993.
NIOSH Guide to Industrial Repiratory Protection. U.S. Department of Health and Human
Services, Cincinnati, OH. DHHS (NIOSH) Publication No. 87-116, September 1987.
NIOSH Guide to the Selection and Use of Paniculate Respirators (Certified Under 42
CFR 84). U.S. Department of Health and Human Services, Cincinnati, OH. DHHS
(NIOSH) Publication No. 96-101, January, 1996.
NIOSH Respirator Decision Logic, U.S. Department of Health and Human Services,
Cincinnati, OH. DHHS (NIOSH) Publication No. 87-108, May 1987.
Pocket Guide to Chemical Hazards. U.S. Department of Health and Human Services,
Cincinnati, OH. DHHS (NIOSH) Publication No. 94-116, July 1996.
Project Protocol for Control Technology Assessment of Asbestos Removal Processes.
National Institute for Occupational Safety and Health, February 1985.
Selikoff I.J., Levin S.M. Radiological Abnormalities and Asbestos Exposure Among
Custodians of the New York Board of Education. Report to the New York Board of
Education. New York, NY, March 30, 1990.
Recommended Contract Specifications for Asbestos A batement Projects. Maryland
Department of Health and Mental Hygiene, April 1985.
1979 J-6
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Recommended Work Practices for the Removal of Resilient Floor Coverings. Resilient
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Reporting and Recordkeeping Requirements for Waste Disposal - A Field Guide. U.S.
EPA, Air and Radiation (EN-341), Washington, DC. EPA 340/1-90-016, November 1990.
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Association. Prepared by L.R. Binkner, Department of Environmental Health and Safety
Affairs, NY, 1980.
Respiratory Protective Devices. Department of Health and Human Services, Public Health
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Revised Asbestos NESHAP Implementation Strategy. U.S. EPA Office of Air Quality
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Solid Waste Landfill Design and Operation Practices. U.S. EPA. Contract No.
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Standard for Asbestos. U.S. EPA Office of Air Quality Planning and Standards, Research
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1979
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"INSPECTIONS AND REPORT WRITING: FOR THE FUN OF IT"
May 19, 1988 Karen A. Meyer and Dana J. Stotsky
ASBESTOS NESHAP FACT PATTERN
You are a highly trained and skilled EPA NESHAP asbestos inspector. One afternoon you get
a telephone call at your desk and a frantic and hushed voice at the other end of the line asks,
"Are you with EPA?".
The person tells you that she works at the First National Bank in downtown Duke City and that
she is worried about some construction work going on at the bank. She tells you that there is
white dust flying all around the bank lobby and that she and her co-workers have been coughing
a lot since the work began. She tells you that when she told her supervisor she was worried
about the renovation project, her supervisor told her that there was nothing to worry about. She
tells you that she took a sample of the white dust to a lab that a friend of hers runs and that her
friend told her the material was asbestos. She refuses to give you her name.
You get your respirator and suit and go down to the bank. When you arrive in your
decontamination suit, the bank manager and the foreman of the construction site quickly greet
you with a barrage of questions. You present your EPA credentials and tell the manager and
foreman that you are there to take a look at the renovation project in the bank lobby. They ask
if they have to let you in, and you tell them you can always go back to the office and get a
search warrant They let you in. When you enter the bank lobby this is what you see:
The bank lobby is huge. It appears to be 200 feet long and 100 feet wide. The renovation work
involves the ceiling, which appears to be 30 feet from the floor. There is scaffolding going up
to the ceiling and twelve men standing on it are scraping a white, fluffy material off the ceiling.
The men are dressed in T-shirts and jeans. The workers, scaffolding, and the floor below are
covered with white dust. The bank lobby is full of bank patrons, lined up to conduct last-minute
transactions before the bank closes. There is a sign posted near the tellers' counter which says
"PLEASE EXCUSE THE DUST. WE ARE MAKING THE BANK MORE BEAUTIFUL FOR
ALL OF YOU!".
(For non-Air people, the asbestos NESHAP requires the following:
1. Notification to the State or EPA on a planned renovation or demolition project involving
friable (crumbly) asbestos-containing material.
2. Wet removal of asbestos if over 160 square feet, 260 linear feet, or 35 cubic feet
3. Bagging and proper disposal of asbestos materials.
A92-1495.nis
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ASHARA COMPLIANCE REFERRAL FORM
BUILDING LOCATION,
CITY
STATE
ZIP
CORPORATE NAME OF BUILDING OWNER
ADDRESS
CITY
STATE
ZIP
RESPONSIBLE PERSON
PHONE
SECTION I
ABATEMENT PROJECT DESCRIPTION
[PROJECT DESCRIPTION
LINEAR FEET SQUARE FEET
SECTION II
CONTRACTOR_
ADDRESS
CITY
STATE
ZIP
TELEPHONE
JL
Was an inspection conducted to identify where asbestos is located?
If yes, is a copy of the building inspection survey available?
ACCREDITED BUILDING INSPECTOR
COMPANY
ADDRESS
CURRENT STATE
LICENSE NUMBER
Yes
Yes
No.
No
CURRENT STATE
LICENSE NUMBER
CITY
STATE
ZIP
NESHAP INSPECTOR
DATE
IF ANY INFORMATION UNOBTAINABLE, BRIEFLY EXPLAIN WHY_
AFTER COMPLETING FORM, FORWARD TO:
1997
L-l
CHIEF
ASBESTOS CONTROL SECTION
U.S. EPA
ADDRESS
CITY, STATE, ZIP
-------
1997
L-2
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STATE WORKER ACCREDITATION
WORKER NAME
j
-
STATE ISSUING
LICENSE
_ _ ._
TYPE
-
_.. .._
EXPIRATION
NUMBER DATE
-i
I
1
I
i
j
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,
1997
L-3
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1997
L-4
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