United States Office of Administration March 1991
Environmental Protection and Resources
Agency Management
&EPA Health and Safety
Guidelines for
EPA Asbestos
Inspectors
(Revised)
Printed on Recycled Pape
Office of Administration
Safety, Health, and Environmental Management Division
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
PROl*
MAR 2 9 ISi'l
and Safety
OFFICE OF
ADMINISTRATION
AND RESOURCES
MANAGEMENT
for Asbestos
Division
MEMORANDUM
SUBJECT: Revised Health
Inspectors
FROM: Julius C. Jimeno, Director
Safety, Health and Environmental Man
TO: Regional Administrators
Assistant Administrators
Laboratory Directors
The attached "Health and Safety Guidelines for EPA Asbestos
Inspectors," revised in March 1991, were developed for use by EPA
employees in carrying out the Agency's various missions to control
asbestos exposures through inspection activities.
The two primary objectives for the Guidelines are:
0 to provide for the health and safety of asbestos
inspectors based on the best currently available
information;
0 to reduce the likelihood of significant asbestos
exposures to the public through enhanced inspector
guidance.
We will continue to analyze asbestos inspector health and safety
issues and will develop revised guidelines in the future, as
warranted.
The Safety, Health and Environmental Management Division (SHEMD),
Office of Administration, is the lead office for development of
these guidelines. Please keep Howard 0. Wilson, Chief, Technical
Assistance and Evaluation Branch or David Scott Smith, Chief,
Policy and Resources Development Branch, SHEMD, advised of your
experiences using the Guidelines. Your constructive comments on
inspector health and safety issues are welcomed, and we encourage
your input as additional experience is gained with our new
guidance. Our FTS number is 382-3640.
Attachment
"Health & Safety Guidelines for EPA Asbestos Inspectors"
cc: Occupational Health and Safety Managers
Printed on Recycled Paper
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HEALTH AND SAFETY GUIDELINES
FOR EPA ASBESTOS INSPECTORS
Revised March, 1991
Safety, Health and Environmental Management Division
United States Environmental Protection Agency
Headquarters
401 M Street, Southwest
Washington, District of Columbia
20460
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PREFACE
These Guidelines were devloped by the Safety, Health, and
Environmental Management Division for employees of the United
States Environmental Protection Agency. They apply to EPA
employees who manage or supervise EPA asbestos inspectors, and to
EPA employees who perform asbestos inspections.
Beginning in 1989 and continuing through 1990, drafts of
this document were circulated within EPA for internal review and
comment. A number of changes to this document were made in
response to questions and comments received from the reviewers.
EPA Offices which were offered an opportunity to review and
comment on the draft Guidelines included:
1) Office of Administration and Resources Management;
2) Office of Air and Radiation;
3) Office of Pesticides and Toxic Substances;
4) Office of Solid Waste and Emergency Response;
5) Office of Enforcement.
In addition, on March 4, 1991 the Environmental Assistance
Division (EAD) (TS-799), Office of Toxic Substances (OTS)
provided further comments about these Guidelines. In response to
EAD's comments, the the following language is hereby incorporated
into these Guidelines:
"EPA recognizes that its safety and health managers, and
other managers, have a responsibility to establish
protective - yet practical - respiratory protection programs
for their workers who engage in asbestos-related inspection
activities. EPA managers are expected to: 1) ensure that
EPA's asbestos inspectors and their supervisors are aware of
their obligations to meet applicable OSHA requirements, and
to ensure that their workers are properly trained,
certified, and equipped; 2) establish respiratory
protection programs for their asbestos inspectors which are
consistent with the EPA asbestos program's (TS-799) policy,
as described in the NIOSH/EPA "white book."
EPA managers are encouraged to provide maximum levels of
respiratory protection during asbestos-related work."
Questions about the Guidelines should be directed to:
Chief, Technical Assistance and Evaluation Branch
Safety, Health, and Environmental Management Division (PM-273)
United States Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Telephone: (202) 382-3640
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TABLE OF CONTENTS
Health and Safety Guidelines for EPA Asbestos Inspectors
Page
INTRODUCTION 1
A. GENERAL REQUIREMENTS 1
1. Asbestos Inspector's Health and Safety Plan 1
a. Emergency Procedures 1
b. Personal Protective Equipment 2
c. Operational Practices 2
2. Evaluation 2
3. Incident Reporting and Response 2
4. Training 2
5. Medical Monitoring 3
6. Protective Clothing 3
7. Respiratory Protective Equipment 3
8. Other Personal Protective Equipment 7
9. Prohibited Practices 7
10. Personal Hygiene 7
B. PROTECTIVE EQUIPMENT GUIDELINES FOR REMOVAL, DEMOLITION,
AND RENOVATION INSPECTIONS 7
1. Protective Clothing 7
2. Respiratory Protection 8
a. No Respiratory Protection Required (outside
containment) 8
b. No Respiratory Protection Required (inside
containment) 8
c. Air-Purifying Respirators 9
d. Self-Contained Breating Apparatus (SCBA) 9
C. PROTECTIVE EQUIPMENT GUIDELINES FOR ASBESTOS MANUFACTUR-
ING AND FABRICATING INSPECTIONS 10
1. Protective Clothing 10
2. Respiratory Protection 10
D. PROTECTIVE EQUIPMENT AND PROCEDURAL GUIDELINES FOR
COLLECTING BULK SAMPLES 11
1. Protective Clothing 11
2 . Respiratory Protection 11
3. Procedural Guidelines 11
a. Preliminary Steps 11
b. Sampling Procedures 12
c. After Sampling 13
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TABLE OF CONTENTS (CONTINUED)
E. PROTECTIVE EQUIPMENT GUIDELINES FOR INSPECTING ASBESTOS
WASTE DISPOSAL AND STORAGE SITES 13
1. Protective Clothing 13
2. Respiratory Protection 14
a. No Respiratory Protection Required 14
b. Air-Purifying Respirators 14
c. Self-contained Breathing Apparatus (SCBA) 14
F. PROTECTIVE EQUIPMENT GUIDELINES FOR INSPECTING EMERGENCY
REMOVAL OPERATIONS AT SUPERFUND SITES 14
1. Protective Clothing 14
2. Respiratory Protection 15
a. No Respiratory Protection Required 15
b. Air Purifying Respirators 15
c. Self-Contained Breathing Apparatus (SCBA) 15
G. PROTECTIVE EQUIPMENT GUIDELINES FOR INSPECTING AN
ABANDONED BUILDING 16
1. Protective Clothing 16
2. Respiratory Protection 16
a. No Respiratory Protection Required 16
b. Air Purifying Respirators 16
H. OPERATIONAL PRACTICES FOR ENTERING AND EXITING SITES 16
1. Wearing SCBA When a Three-Stage Decontamination System
is Present 16
2. Wearing an SCBA When a Shower is Not Present 19
3. Wearing an Air-Purifying Respirator When a Three-Stage
Decontamination System is Present 20
4. Wearing an Air-Purifying Respirator When a Shower is
Not Present 22
ii
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Health and Safety Guidelines for EPA Asbestos Inspectors
INTRODUCTION
These Guidelines are based on good health and safety
practices and are designed to minimize the likelihood of illness
or injury to EPA's asbestos inspectors. No set of guidelines can
anticipate every situation or substitute for the sound judgment
of properly trained professionals. However, these guidelines can
be an effective tool for assuring that the Agency's mandate to
conduct asbestos inspections is safely conducted.
Asbestos inspections are performed to determine compliance
with environmental regulations including the National Emissions
Standards for Hazardous Air Pollutants (NESHAP), Asbestos-in-
School Toxic Substance Control Act (TSCA), and Worker Protection
(TSCA). EPA inspectors who perform asbestos inspections may be
involved in a variety of activities including: inspecting
removal, demolition, distribution and abatement sites; inspecting
manufacturing and fabricating operations; collecting bulk
samples; inspecting emergency removals at Superfund sites; and
inspecting abandoned buildings, among others.
These guidelines were prepared by the EPA's Safety, Health
and Environmental Management Division (SHEMD) for EPA employees
who are involved with EPA asbestos inspections. The SHEMD has no
authority over contractors, contractor agents, assigns or
employees; State agents, assigns or employees; or local
government agents, assigns or employees in matters pertaining to
asbestos exposures. However, the SHEMD encourages EPA program
offices to include these Guidelines as minimum conditions of
health and safety terms for contracts pertaining to asbestos
inspection services, and as recommended guidelines for
collaborating State and local government asbestos inspectors.
A. GENERAL REQUIREMENTS
1. Asbestos Inspector's Health and Safety Plan. A general
Asbestos Inspector's Health and Safety Plan must be prepared by
each EPA Regional Office and other EPA organizations involved in
asbestos inspections. At a minimum, the Plan must include
emergency procedures, personal protective equipment, and
operational practices. The Plan must be transmitted to the
appropriate safety committee for review and approval and then to
the safety program manager and senior management official (e.g.,
the Regional Administrator) for their review and approvals.
a. Emergency Procedures. The Plan must include procedures
to be followed in: 1) medical emergencies, 2) accidental
releases of asbestos, and 3) other emergency situations.
For medical emergencies, the Plan must include the locations
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and telephone numbers of the nearest medical emergency
facilities and ambulance services. For asbestos releases,
the plan must include procedures for notifying responsible
building officials, as well as affected building occupants.
For other emergency situations, the Plan must include
provisions for identifying the emergency and non-emergency
local phone numbers for the police department, the local
fire department, and the nearest 24-hour poison control
center. In all cases, the location of the nearest phone
should be included to make the general plan site specific.
The use of an inspection kit containing cards with phone
numbers should be considered.
b. Personal Protective Equipment. The Plan must specify
protective equipment requirements, including respiratory
protection and protective clothing. The protective
equipment required may vary depending on the type of
inspection. For example, an inspector performing a NESHAP
inspection at an abatement site may be required to wear
self-contained breathing apparatus (SCBA) and a full body
disposable suit. On the other hand, an inspector performing
an Asbestos-in-Schools visual walk-through may not be
required to wear any protective equipment because measurable
exposure would be unlikely in situations in which no
asbestos-containing materials (ACM) have been disturbed and
where no asbestos-containing debris is present. The Plan
must specify protective equipment recommendations for each
type of inspection likely to be performed.
c. Operational Practices. The Plan must specify
operational practices for each type of inspection likely to
be performed. The operational practices may vary depending
on the activities performed during the inspections.
2. Evaluation. The senior management official should
assure that these Asbestos Inspectors' Health and Safety
Plans are reviewed and revised as necessary at least
annually.
3. 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. Chapter 3 of the EPA's
Occupational Health and Safety Manual details these
reporting requirements and procedures [EPA #1440].
4. Training. All EPA 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
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refresher training annually. These, and additional
requirements are described in EPA Order 1440.2, "Health and
Safety Requirements for Employees Engaged in Field
Activities." All EPA employees required to wear respirators
must receive six hours of approved respiratory protection
training, must be fit-tested at least semi-annually, and
must receive approved refresher training annually, as
described in EPA Order 1440.3. All EPA employees requested
to enter hazardous waste sites or Superfund sites must
receive the necessary training required under OSHA's
regulation 29 CFR 1910.120.
5. Medical Monitoring. All EPA employees routinely
engaged in field activities which are likely to result in
exposure to toxic substances, or which require the use of
respiratory protective equipment must be included in the
Agency's Occupational Medical Monitoring Program. EPA Order
1440.2 requires that all EPA employees engaged in field
activities be included in the medical monitoring program.
EPA Order 1440.3 requires that all employees who wear
respiratory protection be determined to be medically fit to
wear respiratory protection.
6. Protective Clothing. The protective clothing needed
may vary with the type of inspection and with the level of
anticipated asbestos contamination. Personal protective
clothing may not be needed for some inspections, such as a
visual walk-through of a school where no abatement action is
underway. On the other hand, a disposable suit, along with
disposable gloves, head, and foot coverings may be needed
where contamination of clothing is anticipated. Maneuvering
into crawlspaces and inspecting asbestos removal operations
inside the work area are examples of activities requiring
such clothing.
After the inspection, the disposable suit, gloves, and
head and foot coverings should be disposed of properly. If
the site has a method for disposing of contaminated
protective clothing, and the site manager agrees, disposal
of contaminated clothing can be done at the site. If the
site does not have an adequate method for disposing of
contaminated materials, or if the site manager does not
allow the EPA to dispose of materials at the site, then they
must be sealed in properly labeled plastic bags and removed
for proper disposal elsewhere. Disposable protective
clothing must never be reused. Proper disposal of
protective clothing prevents the spread of asbestos
contamination to other areas.
7. Respiratory Protective Equipment. To provide asbestos
inspectors with appropriate respiratory protection,
respirators must be selected on the basis of the anticipated
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levels of exposure that meet all OSHA requirements. 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.
Fortunately, much is known about the exposure
conditions encountered at sites that are in compliance with
current OSHA asbestos standards. When such circumstances
are encountered by an inspector, they permit the initial
selection o an air purifying respirator. The lowest
acceptable level of respiratory protection to be used is
that afforded by a NIOSH-approved full facepiece air-
purifying respirator with HEPA filtration or any approved
tight-fitting (i.e., having a tight face-to-facepiece seal)
powered air-purifying respirator (PAPR) with High Efficiency
Particulate Air (HEPA) filtration.
To assist in determining when air-purifying respirators can
safely be used in conducting asbestos inspections, a study of
exposure levels at renovation sites was conducted by Alliance
Technology Corporation under contract to EPA. The study reviewed
over 4000 air monitoring samples taken at renovation sites where,
for the most part, OSHA requirements were met. It was undertaken
to determine the parameters that had to be met to ensure that
asbestos inspectors would be provided adequate protection when
using air-purifying respirators.
The results of the study indicated that 95 percent of the
time, when the OSHA asbestos standards for renovations conducted
in schools, residential buildings, hospitals, offices, and
industrial buildings were followed, no airborne concentrations in
excess of 0.82 f/cc were present in the removal areas during
active abatement i.e., the study that showed that the
concentration would not exceed 0.82 f/cc 95% of the time. The
data was based on Phase Contrast Microscopy (PCM) analyses. The
OSHA 8-hour time-weighted-average (TWA) permissible exposure
limit is 0.2 f/cc and the NIOSH-recommended exposure limit is 0.1
f/cc. Thus, before entering the envelope, if asbestos inspectors
can make a determination of a project's OSHA compliance, an air-
purifying respirator can be selected as shown in the following
paragraph
The EPA's recommendations for respirator selections found in
these Guidelines are intended to limit inspectors' exposures
to asbestos to below 0.01 f/cc as an 8-hour time-weighted-
average (TWA). These recommendations are based, in part, on
expected inspection patterns such as not being in the
envelope for more than two hours per day. The use of full
facepiece air-purifying respirators or tight-fitting PAPRs
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can provide such protection when used at sites that are in
compliance with the OSHA asbestos standard and when
inspectors spend no more than 2 hours per day inside the
containment envelope. This conclusion is based on the
following assumptions:
o exposures at renovation sites that are in compliance
with the OSHA asbestos standard do not exceed 2.0 f/cc
more than 95% of the time (2.0 f/cc is the maximum
level for which full facepiece APRs can reduce
inspectors exposures to below 0.01 f/cc) lasting no
more than a 2 hour exposure;
o full facepiece air-purifying respirators (and tight-
fitting PAPRs) provide a protection factor of SOX;
o inspectors will not be in the asbestos enclosure
envelope for more than two hours per day.
A SOX protection at a concentration up to 2.0 f/cc for two
hours would result in an 8-hour TWA exposure of 0.01 f/cc.
Actually, most exposures would be far less than 0.01 f/cc, since
most individuals get much more than a SOX protection from full
facepiece respirators (and PAPRs}, and often they will not be in
the envelope for two hours. Therefore, by following these
recommendations, inspectors will have a high protection level
because their exposure will most often be much less than 0.01
f/cc.
An abatement project's compliance with the OSHA asbestos
standards can be gauged by findings that:
1) records on or off-site show that all employees have
been trained as required by OSHA standards. When
records are kept off-site, the inspector will request
the supervisor to state that proper records exist and
are available for review at a later date. [Passing an
approved AHERA class is desirable but not required for
buildings not covered by the AHERA regulations.
Compliance with state and local training requirements
should be checked.];
2) records (that can be made available at a later date)
show that project employees have been given medical
exams, including a determination that they are
medically fit to wear respirators;
3) amended water is being used to wet the asbestos-
containing material (ACM), [check to see that amended
water is on-site outside the envelope];
4) no power tools are being used to remove ACM
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5) the envelope is secure and no dust or debris appears to
be coining from the removal area;
6) warning signs and adequately labeled containers are
being used to remove the ACM;
7) a permit for disposal has been obtained from the state
or local government;
8) employees are carefully removing ACM and are not
dropping materials on the floor;
9) decontamination accommodations, including shower
facilities, are in place;
10) existing monitoring data indicates that asbestos fibers
in the work area do not exceed 2.0 f/cc as an 8-hour
TWA;
11) there is a written respiratory protection program and
respirators are being used;
12) a removal plan can be made available for review.
Determining that air-purifying respirators will provide
adequate protection requires a certain degree of judgment. The
ability to make such determinations must be obtained through both
classroom and on-the-job training.
The buddy system is required in situations in which the
SCBA-user is in an atmosphere that is either oxygen-deficient or
is highly toxic and would be life-threatening in case of a
respirator failure. Activities which would not result in a life-
threatening or permanent injury situation would generally not
require using the buddy system. A buddy system or appropriately
outfitted assistant may be required in certain decontamination
procedures. The decision to require a buddy system for
decontamination would have to be made on a case-by-case-basis.
A Respirator Protection Program must be established in
accordance with the OSHA standard for respiratory protection, 29
CFR 1910.134, the OSHA standards for asbestos, 29 CFR 1926.58 and
29 CFR 1910.1001, and EPA Order 1440.3 "Respiratory Protection".
Air-purifying respirators include Powered Air-Purifying
Respirators (PAPR). These guidelines assume that tight-fitting
PAPRs do not provide greater protection than do other air-
purifying respirators due to the possibility that over-breathing
(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 based on workplace
protection factors for PAPRs determined by NIOSH. This guideline
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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 they are shown to have
higher protection factors in the future, appropriate changes will
be made regarding selection of respiratory protection in this
section.
EPA EMPLOYEES MAY NOT WEAR RESPIRATORS UNTIL THEY HAVE BEEN
DETERMINED TO BE MEDICALLY FIT TO WEAR RESPIRATORY PROTECTION.
EPA EMPLOYEES SHOULD USE ONLY EPA-OWNED RESPIRATORY PROTECTIVE
EQUIPMENT THAT THEY HAVE BEEN SPECIFICALLY TRAINED AND FIT-
TESTED TO USE.
8. Other Personal Protective Equipment (PPE1. It is
recommended that eye protection be worn at all times in eye
hazard areas (refer to EPA's Eye Protection Program
Guidelines). Safety shoes or hard hat protection must be
used where head or foot injury hazards can occur.
9. Prohibited Practices. Smoking, eating, drinking,
chewing gum or tobacco, and applying makeup are prohibited
in asbestos-contaminated areas.
10. Personal Hvaiene. Personnel who have been in asbestos-
contaminated areas must remove contaminated clothing, and
other articles. Disposables should be properly bagged and
discarded in landfills that are equipped to accept
asbestos-containing materials. Personnel must wash their
hands and faces thoroughly, or shower as appropriate.
Employees should never eat, drink, apply makeup, chew gum or
tobacco, or smoke before completing the decontamination
process.
B. PROTECTIVE EQUIPMENT GUIDELINES FOR REMOVAL. DEMOLITION. AND
RENOVATION INSPECTIONS.
EPA Asbestos Inspectors are required to inspect removal,
demolition, and renovation sites under the National
Emissions Standards for Hazardous Air Pollutants (NESHAP)
and the Asbestos Abatement Worker Protection Rule and other
regulations.
1. Protective Clothing. EPA inspectors entering a
removal, demolition, or renovation area should wear the
following protective clothing:
o a disposable, full-body, hooded, outer coverall (e.g.,
a Saranex-coated Tyvek suit or equivalent). A coverall
with an expandable back should be worn when SCBA is to
be used;
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o a bathing suit (or equivalent) or an inner disposable
coverall (when possible, particularly when a changing
area 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. In situations where removing all street
clothing is not possible, the inspector should roll up
pants legs and sleeves and don an inner disposable
coverall. The outer coverall is then worn over the
bathing suit or inner coverall.);
o disposable gloves (taped to the outer coverall);
o disposable inner booties (e.g., Tyvek or equivalent);
o disposable outer booties (taped to the outer coverall).
2. Respiratory Protection. EPA inspectors entering a
removal, demolition, or renovation area should select the
appropriate respiratory protection according to the
following locations and conditions:
a. No respiratory protection is required outside of the
asbestos area-enclosing envelope when:
o inspecting office area 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; and
o 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;
o materials removed from the envelope have been
cleaned and the pathway for removal of bags and
equipment is clear and clean; and
o all ventilation systems in the envelope are off
and sealed (this does not include negative
pressure systems designed for the removal
project); and
o wet methods are being used.
b. No respiratory protection is required inside the
containment envelope when:
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o inspecting any restricted area that has already
passed an appropriate clearance test (minimum of
aggressive sampling demonstrating a concentration
below 0.01 f/cc by PCM);
o no removal work has begun and all ACM is intact,
not disturbed, not damaged, and no debris is
present.
c. Full facepiece air-purifying respirators or tight-
fitting PAPRs shall be worn by inspectors when:
o inspecting outside the barrier, and workers
outside the barrier are wearing air-purifying
respirators;
o inspecting outside the barrier where the barrier
is not complete and/or asbestos-containing debris
is present;
o inspecting inside the envelope when an inspection
of the operation shows it to be in compliance with
the OSHA asbestos standards. 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;
o inspecting inside the barrier and no active
removal or disturbances have occurred in the past
24 hours and the inspection will not disturb any
ACM.
d. Atmosphere-Supplying Respirators are required when:
o performance of the asbestos abatement project is
not in accordance with OSHA standards;
o materials are being removed which are not being
properly wetted, or removal causes the generation
of significant levels of dust;
o 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;
o others at the site are wearing atmosphere-
supplying respirators.
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C. PROTECTIVE EQUIPMENT GUIDELINES FOR ASBESTOS MANUFACTURING
AND FABRICATING INSPECTIONS.
EPA asbestos inspectors are required to inspect asbestos
manufacturing operations under the National Emissions
Standards for Hazardous Air Pollutants (NESHAP).
1. Protective Clothing. The following protective clothing
is recommended for EPA inspectors at manufacturing operations to
prevent contamination of their street clothing:
o a disposable, full body, hooded coverall (e.g., a Tyvek
suit or equivalent) or a disposable, full body, hooded
coverall with an expandable back to cover the air tank
(if SCBA is required);
o disposable shoe coverings;
o a hard hat (if applicable);
o eye protection (when respirators are not used); and
o safety shoes (if applicable).
2. Respiratory Protection. EPA inspectors at
manufacturing and fabricating operations should select
respiratory protection based on employers' airborne fiber
monitoring data (if available at the site). For exposure levels
up to 2.0 f/cc, full facepiece air-purifying respirators or
tight-fitting PAPRs shall be used for up to two hours of
inspection time/day. If monitoring data is not available, the
site is considered to be in violation of the OSHA standards. SCBA
shall be used when the inspector cannot determine that exposures
are likely to remain below 2.0 f/cc during the inspection.
Situations where excessive exposures may occur include:
o loose asbestos materials are handled outside of an
exhausted enclosure;
o observing the accumulation on walls or surfaces, of any
debris that may consist of friable asbestos-containing
materials;
o uncontrolled dumping, cutting, mixing, bagging,
packaging, grinding operations or any type of
fabrication where asbestos fibers may be emitted into
the general air; and
o in-plant transport of friable asbestos-containing
materials that are not completely sealed.
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Not all situations where the potential exists for excessive
emissions of asbestos can be listed. Therefore, the inspector
will have to use professional judgment to determine if an air-
purifying respirator will provide adequate protection.
D. PROTECTIVE EQUIPMENT AND PROCEDURAL GUIDELINES FOR
COLLECTING BULK SAMPLES.
EPA asbestos inspectors are required to collect bulk samples
under the Asbestos-in-Schools Rule, Asbestos Worker
Protection Rule, and the National Emissions Standards for
Hazardous Air Pollutants.
1. Protective Clothing. EPA inspectors should wear the
following protective clothing over their street clothes when
collecting bulk samples (Note: when samples can be taken without
any significant chance of releasing fibers, this clothing may not
be necessary. Professional judgment must be used in such unusual
cases.):
a disposable, full body, hooded coverall (e.g., a Tyvek
suit or equivalent);
- eye protection (if no full facepiece respirator is
used);
disposable shoe coverings;
hard hat (if applicable); and
disposable gloves.
2. Respiratory Protection. EPA inspectors collecting bulk
samples should wear full facepiece air-purifying respirators with
HEPA filter cartridges (this includes NIOSH-approved tight-
fitting PAPRs equipped with HEPA filters).
3. Procedural Guidelines. These procedural guidelines are
for inspectors who collect bulk samples in non-contaminated areas
(e.g., Asbestos-in-Schools inspectors). These practices should
be followed to minimize fiber release and building occupant
concern.
a. Preliminary Steps.
- 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.
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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 PPE, 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 PPE would be required in the event of an
accident, under what conditions it will be worn
and by whom.
b. Sampling Procedures.
Sampling procedures must minimize the amount of
the inspector's personal exposure to the asbestos.
Also, these procedures must minimize the amount of
disturbance of the asbestos material.
Don appropriate protective clothing and
respiratory protective equipment.
Before the sample is collected, 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 (e.g., use a hand-held plant
mist sprayer).
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- Sampling equipment, in most cases, will consist of
plastic containers or empty film canisters and a
sharp instrument such as a knife or scalpel. Once
the samples have been obtained, the sampling
equipment must be wiped thoroughly with a damp
cloth. The outsides of the film canisters must be
damp-wiped before being placed into the plastic
bag. Whatever is chosen to wipe the sampling
equipment and sample containers must be properly
disposed of in plastic bags that are properly
labeled. An encapsulant should be used to seal
the hole made by the inspector while extracting
the sample. The sampled surface should not be
left in a worse condition than before sampling was
done.
c. After Sampling.
- Wet-wipe the outside of the coveralls and shoe
coverings. Remove coveralls, shoe covers, and
gloves and dispose of them and the wipe down
cloths as asbestos-contaminated wastes.
Spray the respirator and respirator HEPA filters
with water and dispose of the filters as asbestos
waste.
- Dispose of all asbestos-contaminated materials
properly.
- The asbestos samples must be packaged and shipped
in a manner that assures that the sample
containers will not release asbestos during
transportation. [Make sure the sample vials are
securely taped shut and well-cushioned to prevent
breakage.]
E. PROTECTIVE EQUIPMENT GUIDELINES FOR INSPECTING ASBESTOS
WASTE DISPOSAL AND STORAGE SITES.
EPA Asbestos Inspectors are required to inspect asbestos
waste disposal and storage sites under the National
Emissions Standards for Hazardous Air Pollutants (NESHAP).
Before entering these sites, inspectors must have completed
all OSHA training required as cited in 29 CFR 1910.120.
1. Protective Clothing. EPA inspectors should wear the
following protective clothing over their street clothes when
inspecting asbestos waste disposal and storage sites:
a disposable, full body, hooded coverall (e.g., Tyvek
or equivalent);
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disposable gloves; and
disposable boots.
2. Respiratory Protection. EPA inspectors at asbestos waste
disposal and storage sites should select respiratory protection
based on the requirements of the approved site safety plan. This
assumes that an approved site safety plan has been implemented.
When no approved site safety plan is in place, the inspector
must have reviewed an appropriate generic site inspection plan
for the site being inspected.
The absence of a site safety plan should be reported to
appropriate persons in charge and possibly to the local OSHA area
office.
a. No respiratory protection is required when:
all disposal trenches have been covered for a
minimum of 24 hours, no asbestos-containing
materials are visible at the disposal site.
b. Full facepiece Air-Purifying Respirators or tight-
fitting PAPR should be worn when:
- trenches are being dug at the disposal site and
airborne dust is not visible;
- asbestos materials are visible on the ground or
floor of the site, or bags or drums containing
asbestos are damaged but airborne dust is not
visible; and
- inspecting a storage site, as long as airborne
dust is not present.
c. Atmosphere-Supplying Respirators (e.g., SCBA or
supplied air respirators (SAR) should be worn when:
- others at the site are wearing atmosphere-
supplying respirators; or
- airborne dust is visible at the site.
F. PROTECTIVE EQUIPMENT GUIDELINES FOR INSPECITNG EMERGENCY
REMOVAL OPERATIONS AT SUPERFUND SITES.
EPA inspectors are required to inspect emergency removals at
Superfund sites under CERCLA.
1. Protective Clothing. EPA inspectors should wear the
following protective clothing while inspecting emergency removal
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operations at Superfund sites:
- a disposable, full body, hooded, outer coverall (e.g.,
a Saranex-coated Tyvek suit or equivalent). A coverall
with an expandable back should be worn with SCBA;
- a bathing suit (or equivalent) or an inner, full body,
inner coverall. (When possible, particularly when a
changing area 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. In situations where removing all
street clothing is not possible, the inspector should
roll up pants legs and sleeves and don an inner
disposable coverall. The outer disposable coverall is
then worn over the bathing suit or inner coverall;
- disposable gloves (taped to the outer coverall);
eye protection (when no full facepiece respirators are
worn);
disposable inner booties;
disposable outer boots (taped to the outer coverall);
and
hard hat (if applicable).
2. Respiratory Protection. EPA inspectors at an emergency
removal operation should select the appropriate respiratory
protection according to the following conditions:
a. No Respiratory Protection is required when:
- in the Support Zone (i.e., the noncontaminated or
clean area).
b. Air-Purifying Respirators should be worn when:
in the Exclusion Zone or the Contamination
Reduction Zone, when acceptable to the On-Scene-
Coordinator (OSC) and no airborne dust is visible.
c. Atmosphere-Supplying Respirators should be worn when:
airborne dust is visible, for example during windy
conditions or during operations that disrupt the
asbestos; or
- others at the site are wearing atmosphere-
supplying respirators.
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G. PROTECTIVE EQUIPMENT GUIDELINES FOR INSPECTING AN ABANDONED
BUILDING.
1. Protective Clothing. EPA personnel should wear or carry
with them the following protective clothing while inspecting an
abandoned building:
- a disposable, full body, hooded coverall (e.g., a Tyvek
suit or equivalent);
disposable shoe coverings;
eye protection (if no full facepiece respirators are
worn);
disposable gloves; and
- hard hat (if applicable).
If any suspect materials are visible on floors or surfaces,
the protective clothing should be worn.
2. Respiratory Protection. EPA personnel inspecting an
abandoned building should select the appropriate respiratory
protection according to the following conditions:
a. No Respiratory Protection is required when:
- no suspect materials are present;
- intact suspect materials are present and no debris
from those materials is observed.
b. Air-Purifying Respirators should be worn when:
suspect materials are visible on the floors or
surfaces;
- collecting bulk samples. (See Section D for
specific guidelines for collecting bulk samples.)
H. OPERATIONAL PRACTICES FOR ENTERING AND EXITING SITES.
Although the operational practices in this section are aimed
primarily at removal, demolition, and renovation sites,
these practices can be easily modified to fit the conditions
for other types of inspections.
1. Wearing an SCBA When a Three-Stage Decontamination System is
Present. The three-stage decontamination system discussed here
consists of a clean room, a shower area, and an equipment room
(or equivalent). A detailed description of this type of
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decontamination system, commonly used in the asbestos abatement
industry, can be found in the OSHA asbestos regulation, 29 CFR
1926.58, Appendix F.
a. Before entering the Clean Room:
Make sure SCBA is operating properly;
- Make sure you have all materials necessary to
conduct the inspection safely (e.g., duct tape,
disposable towels, protective clothing,
respirator, extra plastic bags, spray bottle,
etc.) All materials that must be carried into the
contaminated area should be sealed in a plastic
bag to minimize contamination;
- If you take a camera into the contaminated area,
precautions must be taken to minimize
contamination or to decontaminate the camera.
Possible solutions include using a waterproof
camera or sealing a conventional camera in an
impermeable clear camera box. Both of these
methods are used by SCUBA divers.
b. In the Clean Room:
- Remove all street clothing including socks and
underwear and store them in a clean, sealed
plastic bag. The bag should be placed in a
secured area. If desired, don a bathing suit (or
equivalent) and inner booties. [Inspectors may
prefer to have the bathing suit on before going to
the site.];
- With the air flow valve closed, don SCBA; let the
respirator facepiece hang from the neck with the
aid of a strap;
- Don disposable outer coveralls with expandable
back, but do not zip it;
- Don disposable outer boots. Use duct tape to
attach the boots to the legs of the outer
coveralls;
- Fit the respirator facepiece to the face, tighten
the facepiece straps, and check seal;
- Connect hose to regulator and turn air valve on;
- Fit the coverall hood snugly around the respirator
facepiece;
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Zip up the suit;
Don the disposable gloves. Use duct tape to
attach the gloves to the sleeves of the outer
coveralls;
Proceed to the Shower Area.
c. In the Shower Area:
Leave disposable towels (sealed in a plastic bag)
near the shower.
Proceed to the contaminated area and perform
inspection.
d. Before leaving the contaminated area:
HEPA vacuum (if possible) and wet wipe all visible
debris from protective clothing. (Use a spray
bottle and disposable towels to wet wipe the
suit.) Proceed to the equipment room.
e. In the Equipment Room:
- Seal all contaminated nondisposable materials in a
plastic bag and remove them for decontamination at
a later time.
Remove outer protective clothing including boots,
gloves, and coverall and place them in a proper
container for disposal.
- With SCBA, bathing suit, and inner booties still
on, proceed to the Shower Room.
f. In the Shower Area:
Thoroughly shower down with the SCBA, bathing
suit, and inner booties still on. Once totally
wet, remove the respirator, turn off the air
supply valve, clean the respirator, and place the
respirator outside the shower on the clean side;
Continue showering. While in the shower, remove
inner booties and place them in a proper container
for disposal. Next, remove bathing suit,
thoroughly rinse it, and place it in a plastic
bag. Finish showering by thoroughly washing the
entire body with soap and water;
Proceed to the Clean Room.
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g. In the Clean Room:
Dress into street clothes. All disposables should
be given to the site operator if she/he will
accept them and if they will be disposed of in an
approved landfill. Otherwise, place the
disposables in labeled plastic bags and remove
them for proper disposal.
2. Wearing an SCBA When a Shower is Not Present or Available.
a. Before entering the contaminated area:
Make sure SCBA is operating properly;
Make sure materials necessary to conduct the
inspection safely (e.g., disposable towels, extra
plastic bags, spray bottle, etc) are on hand. All
materials that must be carried into the work area
should be sealed in a plastic bag to minimize
contamination;
If a camera is to be taken into the contaminated
area, precautions must be taken to minimize
contamination or to decontaminate the camera.
Possible solutions include using a waterproof
camera or sealing a conventional camera in an
impermeable box. Both of these methods are used
by SCUBA divers;
Leave all street clothing on. (Short sleeved
shirts and short pants are preferable to long
sleeved shirts and long pants. If wearing long
pants or long sleeves, roll them up.);
Don an inner disposable coverall and inner booties
(e.g., a Tyvek suit or eguivalent) over street
clothes;
- With the air flow valve closed, don the SCBA; let
the respirator facepiece hang from the neck with
the aid of a strap;
Don disposable outer coverall with expandable
back, but do not zip it up;
Fit the respirator facepiece to the face, tighten
the facepiece straps and check face seal;
Connect hose to regulator and turn on air valve;
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Fit the coverall hood snugly around the respirator
facepiece;
Zip up suit;
Don the disposable gloves. Use duct tape to
attach gloves to the sleeves of the outer
coverall;
Proceed to the contaminated area and perform
inspection.
b. Before leaving the contaminated area:
Standing near the exit, HEPA vacuum (if possible)
and wet wipe all visible debris from the outer
protective clothing. (Use a spray bottle
containing water and disposable towels to wet wipe
the suit; use plenty of water.) Place all
disposable materials in a proper container for
disposal. Standing at the doorway inside the work
area, remove outer protective clothing and
immediately step outside the area.
c. Outside the contaminated area:
Once outside, thoroughly wet wipe and mist spray
the SCBA and inner protective clothing. Move away
from the doorway and remove the SCBA and the inner
protective clothing. Place all disposable
materials in a proper container for disposal.
Seal all contaminated nondisposable materials in a
plastic bag and take them with you for decontam-
ination at a later time.
3. Wearing an Air-Purifvinq Respirator When a Three-Stage
Decontamination System is Present. The three-stage
decontamination system discussed here consists of a clean room, a
shower area, and an equipment room (or equivalent). A detailed
description of this type of decontamination system, commonly used
in the asbestos abatement industry, can be found in the OSHA
asbestos regulation, 29 CFR 1926.58, Appendix F.
a. Before entering the Clean Room:
- Make sure that all materials necessary to conduct
the inspection safely. (e.g. duct tape,
disposable towels, protective clothing,
respirator, extra plastic bags, spray bottle,
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etc.) have been obtained. All materials that must
be carried into the contaminated area should be
sealed in a plastic bag to minimize contamination;
If a camera is to be taken into the contaminated
area, precautions must be taken to minimize
contamination or to decontaminate the camera.
Possible methods include using a waterproof camera
or sealing a conventional camera in an impermeable
clear camera box. Both of these methods are used
by SCUBA divers.
b. In the Clean Room:
Remove all street clothing including socks and
underwear and store them in a clean, sealed
plastic bag. If desired, don a bathing suit (or
equivalent) and inner booties. Inspectors may
prefer to have the bathing suit on before going to
the site;
Don disposable, full body, hooded coverall. Do
not put the hood on yet. Do not zip up suit, yet.
Don other appropriate protective clothing. Use
duct tape to attach the boots to the outer
coveralls;
Don respirator. The respirator straps should be
worn under the hood. Perform positive and
negative pressure checks as appropriate;
Fit the coverall hood snugly around the
respirator; zip up suit; attach gloves with duct
tape;
Proceed to the Shower Area.
c. In the Shower Area:
Leave disposable towels (sealed in a plastic bag)
near the shower.
Proceed through the equipment room to the
contaminated area and perform the inspection.
d. Before leaving the Contaminated Area:
HEPA vacuum (if possible) and wet wipe all visible
debris from protective clothing. (Use a spray
bottle and disposable towels to wet wipe the
suit.) Proceed to the equipment room.
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e. In the Equipment Room:
Seal all contaminated nondisposable materials in a
plastic bag and remove them for decontamination at
a later time;
Remove protective clothing and place it in a
proper container for disposal. Keep wearing the
respirator;
With respirator on, proceed to the shower area.
f. In the Shower Area:
- Thoroughly shower down with the respirator and
bathing suit on. Remove respirator and clean it.
Place it outside the shower on the clean side.
- Remove inner booties and place them in a proper
container for disposal.
- Remove bathing suit, thoroughly rinse it, and
place it in a plastic bag. Finish showering by
thoroughly washing the entire body with soap and
water.
Dispose of towels as asbestos contaminated waste.
- Proceed to the clean room.
g. In the Clean Room
- Dress into street clothes.
- All disposables should be given to the site
operator if she/he will accept them and if they
will be disposed of in an approved landfill.
Otherwise, place the disposables in labeled
plastic bags and remove them for proper disposal.
4. Wearing an Air-Purifying Respirator When a Shower is
Not Present or Available. Follow the guidelines listed in
section 2, "Wearing a SCBA When a Shower is Not Present",
substituting appropriate procedures for air-purifying
respirators.
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References
The following references provide additional information on
the safe handling of asbestos.
1. A Guide to Respiratory Protection for the Asbestos
Abatement Industry. EPA 560-OPTS-86-001, April 1986.
2. Guidance for Controlling Asbestos-Containing Materials
in Buildings. EPA 560/5-85-024, June 1985.
3. Asbestos Fact Book. EPA, A-107/86-002 , June 1986.
4. Guidance for Preventing Asbestos Disease Among Auto
Mechanics. EPA, Office of Pesticides and Toxic
Substance, Asbestos Action Program, June 1986.
5 . Measuring Airborne Asbestos Following an Abatement
Action. EPA 600/4-85-049, November 1985.
6. Guidance for Controlling Friable Asbestos-Containing
Materials in Buildings. EPA 560/5-83-002, March 1983.
7. Asbestos-Containing Materials in School Buildings; A
Document Parts 1 and 2 . EPA
8. Quantification of Asbestos Airborne Emissions
Associated with Renovation Projects. EPA Contract No.
68-02-4465 Alliance Technologies 1988 Draft Final
Report .
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