Protection
Tone Sutaunooc
DC 20480
coooao
March 1979
Tcuoc
Asbestos-
Containing
Materials
in School
Buildings:
A Guidance
Document
Parti
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• R H °
A Guidance
Document
Part
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March 16, 1979
Dear School Officials;
Until recently exposure to asbestos was generally
considered an occupational health hazard for asbestos
workers. However, now we have learned of an equally
serious exposure problem that can occur in all types of
buildings in which certain asbestos-containing materials
have been used for fireproofing, insulation, and
decoration. Asbestos can be released from these materials
and contaminate the building environment. Individuals who
are then exposed to the asbestos could develop lung cancer
or cancers of other parts of the body. Unfortunately,
detection of asbestos-related diseases is difficult since
the latency period between exposure and appearance of the
disease is sometimes as many as 20 to 40 years.
Since these materials are found in school buildings, we at
EPA are particularly concerned with the exposure of school
children. EPA has worked with the States to develop a
program that responds to the need for accurate information
and guidance to deal with this difficult problem. The
enclosed manuals are a major part of this program and are
being mailed to all public school districts. They were
prepared to inform you of the health hazards associated
with asbestos and outline the steps you and the schools in
your district can take to identify asbestos-containing
materials and to protect students and school personnel
from exposure.
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Also participating in this EPA program are the Department
of Health, Education, and Welfare, the Occupational Safety
and Health Administration, and the Consumer Product Safety
Commission. Through the Regional Offices located in major
cities across the country, EPA and these Agencies will
provide assistance for the difficulties that you may
encounter in undertaking a control program in your
schools. We are operating several toll-free numbers that
you can call to ask for information and assistance. A
videotape that was prepared to supplement this manual will
also be available for your use.
A survey form is included in this manual. The form asks
questions on the results of the control programs you
conduct in your schools. Your participation in this part
of the EPA program would be appreciated. By completing
the form you will assist us in assessing the extent of the
asbestos-containing material problem in the United States.
I encourage you and your staff to review the enclosed
manuals and inform the schools in your district of the EPA
program. A successful nationwide school asbestos program
depends on your efforts and those of school officials
across the country. We look forward to working with you
in the important weeks and months ahead.
Sincerely,
^s¥evefT*6. Jeilfinek " N
Assistant Administrator
for Toxic Substances
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Table of Contents
Acknowledgements
Preface
Chapter i: Introduction: The Concern 1
Chapter 2: Asbestos and Its Uses 2
Chapter 3: How to Conduct an Asbestos Control
Program 5
Chapter 4: Inspecting for Friable Material 7
Chapter 5: Sampling Friable Material 9
Chapter 6: Analysis of Bulk Samples 11
Chapter 7: Exposure Assessment 13
Chapter 8: Corrective Action 15
Chapter 9: Specifications and Requirements for
Contractors 20
Chapter 10: EPA School Survey 26
Chapter 11: Assistance from Federal and State
Agencies 33
Appendix A: U.S. Environmental Protection Agency
Regulations for Asbestos 35
Appendix B: U.S. Environmental Protection Agency
Regional National Emission Standards for Hazardous
Air Pollutants (NESHAPS) Coordinators 44
Appendix C: U.S. Department of Labor—
Occupational Safety and Health Administration
(OSHA) Asbestos Regulations
45
Appendix D: State Occupational Safety and Health
Program Offices and U.S. Department of Labor—
Occupational Safety and Health Administration
(OSHA) Field Locations 50
Appendix E; U.S. Department of Health, Education,
and Welfare—National Institute for Occupational
Safety and Health (NIOSH) Regional Offices 57
Appendix F: U.S. Department of Health, Education,
and Welfare Regional Health Administrators 58
Appendix G: Toll-Free Information Numbers 58
Appendix H: "Mineral Characterization of Asbestos-
Containing Spray Finishes" 59
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Acknowledgements
We gratefully acknowledge the assistance of the many
individuals who contributed their time and efforts to
the preparation of this manual.
This manual embodies the comments and input of
State and local government officials, environmental and
special interest groups, industry, and interested private
citizens as well as staff in EPA Headquarters and
Regional Offices. The assistance of the Department of
Health, Education, and Welfare (DHEW), the
Occupational Safety and Health Administration, the
Consumer Product Safely Commission, and the
Department of Interior is also gratefully acknowledged.
We are particularly grateful for the assistance and
cooperation of DHEW's National Institute of
Environmental Health Sciences (NIEHS) and the
National Institute for Occupational Safety and Health,
We appreciate the review and comments from the
members of NIEHS's Subcommittee to Coordinate
Asbestos Research of the Committee to Coordinate
Toxicology and Related Programs.
We are indebted to Dr. Robert N. Sawyer of the
Yale University School of Medicine. In his capacity as
the principal technical consultant to the project. Dr.
Sawyer provided his invaluable assistance to the
development of the manual. Dr. Sawyer was also
responsible for generating interest and comments from
individuals who have had experience in dealing with the
asbestos-containing material problem.
Preface
Recently there has been an increasing awareness of the
significance of environmental factors in causing illness.
The fibrous minerals known as asbestos, used in many
different kinds of products and applications, have
entered the environment in both occupational and non-
occupational settings. The lung disease, asbestosis, and
some cancers of the lung, abdomen, and other parts of
the body have been clearly related to asbestos
exposure.
The Environmental Protection Agency (EPA) is
concerned with the disease-causing potential of
intermittent, low-level exposures that can occur in some
school buildings from certain asbestos-containing
materials. EPA has established a guidance program to
inform States and local school officials of the passible
health hazards associated with asbestos. EPA will
provide guidance to schools which undertake programs
to identify and control exposure to these asbestos-
containing materials. Although the EPA program is
specifically directed to schools, information and
assistance will also be available to contractors, workers,
and any individuals who are concerned about exposure
to asbestos in buildings.
EPA's guidance package contains two parts. This
manual, which is Part 1 of the package, is written for
school officials. Part 1 outlines steps that schools can
take to conduct an asbestos control program. Part 2
contains more detailed information on asbestos
identification and control methods. Part 2 will be
particularly useful to school personnel, contractors, and
others involved in actual asbestos inspection and control
activities.
As the lead Agency for the school asbestos program.
EPA will provide additional information and assistance
to the States and school districts through the Agency's
ten Regional Offices located throughout the country.
Each Regional Office will have a Regional Asbestos
Coordinator who will work with the States to assist in
undertaking asbestos control programs.
Other Federal Agencies concerned with the asbestos
problem will also participate in the program. The
Occupational Safety and Health Administration
(OSHA) and the Department of Health, Education,
and Welfare through the National Institute for
Occupational Safety and Health (NIOSH) and the
Public Health Service will provide assistance particularly
in the areas of occupational safety and health. This
assistance will be made available through these
Agencies" Regional Offices.
Questions about the information in these manuals or
about the EPA school asbestos program should be
referred to the EPA Regional Asbestos Coordinators
listed on page 33.
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A Close-up of a Type of Axhestos-Conraining Material Thai Can Be Found in School Buildings
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Chapter 1: Introduction: The Concern
Exposure to asbestos was initially associated with a
chronic and debilitating lung disease called asbestosis.
More recently exposure to asbestos has been associated
with lung cancer, a rare cancer of the chest and
abdominal lining called mesothelioma, and cancers of
the esophagus, stomach, colon, and other organs.
Asbestos also acts as a potent cancer-causing agent in
combination with cigarette smoking. In all asbestos-
related diseases there is a latency or induction period of
many years between initial exposure and appearance of
the disease.
In most cases asbestosis has followed long exposure
to high levels of asbestos fibers. Therefore, asbestosis is
not as significant a concern in schools as cancer risk.
The potential for increasing cancer risk may exist at
much lower and shorter exposures than those for
asbestosis,
Under certain conditions, exposure to fibers released
from asbestos-containing materials in buildings can
reach levels considered potentially hazardous. Some
asbestos levels measured in school buildings have even
been shown to briefly exceed the current Federal
workplace exposure level standards.
Why is there so much concern now?
EPA is concerned in view of the increasing knowledge
of the potential of asbestos as a cancer-inducing agent
at low-level exposures and the asbestos contamination
that has been found in some schools. Another very
important concern is that cigarette smoking can
enhance the disease potential of asbestos exposure.
Is there a safe level of exposure?
EPA and the scientific community believe that any
exposure to asbestos involves some health risk. No safe
level of exposure (or threshold exposure level) has been
established. Further, it is impossible at this time to
confidently estimate the exact degree of risk associated
with low-level exposures.
What is considered the best or safest approach to
asbestos exposure?
Where possible all exposure to asbestos should be
eliminated or controlled.
Are there special concerns about asbestos in schools?
The school children population differs from other non-
occupational populations in age, population density,
and behavior.
The exposure of children and adolescents to asbestos
in the school building occurs early in their life span.
Their remaining life expectancy provides a long
development period for asbestos-related diseases.
A large number of students can be exposed at one
time to asbestos that is released from asbestos-
containing materials present in the school building. The
duration of exposure is of concern since school children
attend school daily for most of the year.
The school population is very active. Certain
asbestos-containing materials can be damaged during
school activities and as a result of the capricious
behavior of students. When the material is damaged,
asbestos fibers are released and exposure can occur.
Many cases of badly damaged asbestos-containing
materials have been found in schools.
Are there any Federal laws or regulations that protect
school children from asbestos exposure in school
buildings?
There are currently no Federal laws or regulations that
protect children in school buildings where asbestos-
containing materials are already present.
Is a medical examination necessary for persons exposed
to asbestos in school buildings?
Medical examinations are not recommended in school
exposure situations. It is difficult to detect asbestos-
related diseases in children due to the long induction
period before the disease appears. Individuals who have
been exposed to asbestos should avoid smoking; and, of
course, medical advice should be obtained for any
specific concerns or symptoms.
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Chapter 2: Asbestos and Its Uses
What is asbestos?
Asbestos is a term for a group of naturally occurring
minerals that separate into fibers. The mineral rock is
mined and then milled for commercial use. Asbestos
fibers are incombustible and have good thermal and
electrical insulating properties. There are six asbestos
minerals that are used commercially:
Chrysotile
Amosite (Cummingtonite-grunerite asbestos)
Crocidolite
Anthophyllite asbestos
Tremolite asbestos
Actinolite asbestos
Chrysotile and amosite are the most frequently found
asbestos minerals in the asbestos-containing materials
used in school buildings.
Why is asbestos a unique environmental contaminant?
The durability of asbestos fibers and their small size
and fibrous shape make asbestos an unusual
environmental contaminant.
Asbestos fibers cannot be easily destroyed or
degraded. The size and shape of these fibers permit
them to remain airborne for long periods of time.
Asbestos fibers that are released from asbestos-
containing materials enter the air and contaminate the
building environment.
When the fibers have entered the air, individuals in
the building can be exposed and inhale the fibers.
Raw Chrysotile Showing Fiber Structure
Although most fibers will not remain in the lungs, those
that are retained will stay indefinitely,
What are some uses of asbestos in school buildings?
Most asbestos products are used in building
construction and many products containing asbestos are
found in buildings. Asbestos has been used in cement
products, plaster, fireproof textiles, vinyl floor tiles,
thermal and acoustical insulation, and sprayed
materials.
Asbestos also is used in automotive brake linings. In
schools that have shops for automotive training,
asbestos contamination can occur as a result of
automotive brake servicing.
For more information on the uses of asbestos, see
pages I-l-l and 1-1-3 of Part 2.
What asbestos-containing materials in school buildings
can create an exposure problem?
Only certain kinds of asbestos-containing materials in
school buildings are considered hazardous. The
potential for release, contamination, and exposure
depends on the condition of the asbestos-containing
material (such as deterioration from age) and the
probability that the material will be damaged.
Hard asbestos-containing materials such as vinyl floor
tile do not generally create exposure problems.
Asbestos fibers are firmly bound or encased in the
material. Sanding, grinding, or cutting will cause
Sample of Friable Material
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asbestos fibers to be released. Therefore, these hard
materials should not be considered hazardous unless
they are machined.
Soft or loosely bound (i.e., friable) asbestos-
containing materials can release asbestos fibers
following only minor disturbance to the material. It is
these soft asbestos-containing materials that can cause
contamination and exposure problems.
What is Triable material?
Friable material is material that can be crumbled,
pulverized, or reduced to powder in the hand. Friable
material may be an asbestos-containing material or it
may be a material that contains other fibers such as
cellulose and glass fibers.
This manual is primarily concerned with identifying
friable asbestos-containing materials in school buildings
and recommending steps to reduce the exposure that they
may cause.
What are friable asbestos-containing materials?
Friable asbestos-containing materials are materials that
were used for fireproofing, thermal and acoustical
insulation, or decoration in building construction and
renovation. The asbestos content of these materials is
usually found in the range of 5% to 50%. These
materials were usually applied by spraying but have also
been applied by troweling. They are friable in varying
degrees depending on the components of the material,
the amount of cement added, and the method of
application. Sprayed material is usually soft.
Cementitious material varies from soft to relatively
hard.
Throughout this manual, both cementitious and
sprayed asbestos-containing materials will be called
asbestos materials.
What is sprayed asbestos material?
Sprayed asbestos material is a mixture of asbestos
fibers, other fibers (cellulose, non-asbestos mineral
fibers) and a binder which has been applied to ceilings,
beams, and other surfaces by spraying. It has been
widely used for fireproofing, thermal and acoustical
insulation, and decoration. Most friable material in
schools is sprayed material.
In 1973 EPA prohibited the spraying of asbestos
material for fireproofing and insulation. EPA
prohibited the application of sprayed asbestos material
for nearly all purposes in 1978.
Where are friable asbestos materials located?
Friable asbestos materials are usually found on
overhead surfaces, steel beams, ceilings, and
occasionally on walls and pipes.
Does all friable material contain asbestos?
Many materials that look like friable asbestos material
do not necessarily contain asbestos. Some friable
material contains glass fibers, cellulose, or other non-
asbestos fibers.
How are asbestos fibers released from friable asbestos
material?
Fibers are released from friable material as a result of a
breakdown in the integrity of the material due to
deterioration or direct contact and damage.
As friable asbestos material ages, it can lose its
cohesive strength and release fibers. Fallout of fibers
from deteriorated material is usually low-level but
continuous.
Fiber release by contact and damage depends on the
accessibility of the material and the degree of
disturbance. Contamination can be very high for brief
periods of time during a disturbance and then gradually
decrease as the fibers settle. Fiber release can occur
Friable Material Showing Water Damage
f-'nable Material Thai Has Been Scraped
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after only minor contact with friable material.
Direct contact or damage to asbestos materials can
occur in a number of ways:
• School Activities—A ball hitting friable material on
a gymnasium ceiling or wall. Hanging pictures or
attaching displays to friable material will cause fiber
release.
• Maintenance Activities—Any maintenance activity
involving intentional or accidental contact with friable
material.
• Vandalism—Material may be scraped, gouged, or
hit.
• Water Damage—Water from roof or plumbing
leaks will cause material deterioration and in some
cases delamination (i.e., breaking away of layers of
material from the underlying surface),
• Vibration—Building vibration from sources within
or outside the building. For example, vibration from
activities on the floor above or vibration from
machinery can cause movement of the friable material
and release fibers.
Fibers that have been released can remain suspended
in the air for many hours. After the fibers settle, they
can be resuspended in the air by disturbances created
by student activities or custodial work such as dusting
or sweeping, Resuspension of asbestos fibers in the air
is called reentrainmcnt. Rcentrainment may cause
repeated exposures after the fibers are released from
the friable asbestos material.
For more information on asbestos contamination, see
pages 1-2-3 to l-2-l 1 of Purl 2,
Is asbestos contamination permanent once it occurs?
Asbestos fibers tend to remain in the building that they
contaminate but can be removed by cleaning. Wet
mopping is recommended since water inhibits fiber
movement, thus preventing reentrainment during the
cleaning process. Dry dusting and sweeping will cause
reentrainment and should be avoided. If wet cleaning is
not feasible, a High Efficiency Paniculate Absolute
(HEPA) filtered vacuum should be used. Conventional
vacuum cleaning equipment normally used in the school
is not equipped with a filter size small enough to collect
asbestos fibers and should not be used to clean in areas
of asbestos contamination. If conventional vacuum
cleaning equipment is used, fibers can be reentrained.
For more information on HEPA filtered vacuums, see
page 11-4-2 of Pan 2.
When should school officials be concerned about
asbestos material?
If friable asbestos material is present in the school
building, an exposure problem may exist. Chapter 3
outlines the recommended steps to identify friable
asbestos material and to undertake a control program
to reduce exposure.
Is pipe covering and boiler lagging of concern?
Friable asbestos material was used for many years in
pipe covering and boiler lagging until EPA prohibited
its application in 1975. Pipe covering and boiler lagging
do not create an exposure hazard unless the friable
insulation material is exposed and damaged.
Pipe covering and boiler lagging should be routinely
inspected. If the insulation material is exposed, retaping
or covering the damaged area will prevent asbestos
fiber release.
Is ceiling tile of concern?
Ceiling tiles are not friable and should be of no
concern.
Damaged Pipe (.'overing Showing Friable Insulation Maieritil
Ceiling Tile
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Chapter 3: How To Conduct an Asbestos
Control Program
An asbestos control program begins with locating
friable material and determining whether the material
contains asbestos. If contamination of the building by
asbestos fibers is occurring or will likely occur,
corrective action should be taken to protect school
children and other users of the building from exposure,
A recommended approach for conducting an asbestos
control program is outlined in the following table.
Conducting an Asbestos Control Program
Xtepx
Inspection:
Sampling:
Analysis:
Exposure Assessment:
Corrective Action:
Locate friable material in the school building.
If friable material is found. Kike a bulk sample of the material.
Send the bulk sample to a laboratory for analysis to determine if
asbestos is present.
If the friable material contains asbestos, assess the exposure potential.
If an exposure problem exists, take a corrective action.
( 'liaplt'r
4
s
7
K
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Friable Material in Machinery Area
Overhead Surface and Steel Beams Covered With Friable
Material
Cafeteria With Friable Material Ceiling Surface
Friable Material on Overhead Surface of Gymnasium
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Chapter 4: Inspecting for Friable Material
All areas including student, administrative.
maintenance, and custodial areas in the building should
be visually inspected for friable asbestos material. If
friable material is located, it must be sampled and
analyzed for asbestos content. The fact that material is
friable does not establish that asbestos is present.
Which schools should be inspected?
Schools built or renovated during the period following
World War II to 1978 should be inspected. Although
the spray application of asbestos materials for
fireproofing and insulation was prohibited in 1973 by
EPA, spray application for nearly all uses of these
materials was not prohibited until 1978,
Where will friable material be found?
Friable material is commonly found on steel support
beams and columns and on ceilings and walls of
classrooms, corridors, auditoriums, cafeterias.
machinery rooms, and storage rooms. It also may be
found on overhead surfaces of indoor pools and
gymnasiums.
What will friable material look like?
Friable material can have the following characteristics:
• Fluffy or spongy appearance (always applied by
spraying)
• Irregular, soft surface (usually applied by
spraying)
• Textured, dense, fairly firm surface (usually
applied by troweling)
If friable material has been damaged or is
deteriorating, the material may be flaking or pieces may
be hanging from the surface of the material-
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Should inspections be made above suspended ceilings?
Inspections should be made above suspended ceilings.
Asbestos material may have been applied to the
original ceiling, steel beams, and other surfaces above
the suspended ceiling.
If the overhead space between the suspended ceiling
and original ceiling is part of the building's air
circulation system, fibers which have been released
from deteriorating or damaged material could travel
throughout the ventilation system to other areas in the
building.
Settled asbestos fibers or fallen ceiling material may
cover the upper surface of the suspended ceiling panels.
In this case moving or removing the panel will cause
fiber release.
When inspecting above suspended ceilings, the
following precautions should be taken:
• The ceiling should be inspected when the area is
not in use,
• If the overhead space is part of the air circulation
system (air plenum), the system should be shut down
during inspection.
• Only persons necessary to assist in the inspection
should be present,
• The National Institute for Occupational Safety and
Health (NIOSH) recommends that the person
inspecting wear an approved respirator. Contact the
NIOSH Regional Offices listed in Appendix E for
information on approved respirators.
Should building records be checked?
Building construction records can be checked as a
supplementary measure to determine if asbestos
materials were listed in the building specifications.
However, since building records may be unreliable,
checking records should not take the place of visually
inspecting school buildings.
What is the next step if friable material is located?
If friable material is located during inspection, a sample
of the material itself should be taken for laboratory
analysis. Chapters 5 and 6 have instructions for
sampling and information on recommended analytical
techniques to identify asbestos fibers in friable material
samples.
What if no friable material is located?
If no friable material is located during visual inspection,
a dated report stating that no material has been located
in the school building should be prepared. The report
should identify which areas of the building were visually
inspected and if the building records were also checked.
A copy of this report should be kept in a school
asbestos program file.
Suspended Ceiling Panel For Inspection
Area Above Suspended Ceiling With Friable Material
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Chapter 5: Sampling Friable Material
The sampling and analysis of friable material are
extremely important. The decision to take corrective
action will depend, in large part, on the results of the
laboratory analysis. It is critical, therefore, that
sampling in schools is carried out properly and that
laboratory analyses are performed accurately.
The sampling procedures outlined in this chapter
should be followed closely. Improper sampling will
result in unreliable analyses and lead to either
unnecessary corrective action or to no action for
potentially hazardous material.
The choice of the analytical technique and an
analytical laboratory are also important. Chapter 6
contains information on analytical techniques and
laboratory selection.
Is sampling and analysis of Triable material necessary?
Friable material should always be sampled and analyzed
for asbestos. Neither visual inspection nor checking
building records establish the presence of asbestos in
friable material. Suspect material could contain glass
fibers, cellulose, or other non-asbestos mineral fibers.
How to take a sample
If friable material is found, a representative sample
should be taken from within the material itself by
penetrating the depth of the material with a sample
container. It is important to penetrate the material
because it may have been applied in more than one
layer or covered with paint or a protective coating. This
kind of sample is called a bulk sample.
Taking a Bulk Sample
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One sample should be taken for approximately every
5.(XX) square feet of material having the same color and
texture (i.e., it is homogeneous in appearance).
Material of a different appearance should be sampled
separately,
Small classrooms, offices, or closets with less than
5,000 square feet of friable material should also be
sampled separately if different material is found.
Sampling is not difficult and can be performed by
school personnel if these procedures are followed:
(1) Use a small container such as a plastic 35 mm
film canister or a small, wide-mouthed glass jar with a
screw-on lid. The container should be dry and clean.
(2) Gently twist the open end of the container into
the material. A core of the material should fall into the
container. A sample can also be taken by using a knife
to cut out or scrape off a small piece of material and
then placing it into the container.
Be sure to penetrate any paint or protective coating
and all the layers of the material. If the sample
container cannot penetrate the material, consider
whether the material is really friable or not.
(3) Tightly close the sample container; wipe the
exterior of the container with a damp cloth to remove
any material which may have adhered to it during
sampling.
(4) Tape the container lid to prevent the accidental
opening of the container during shipment or handling.
(5) Label the sample container. This label should
identify the school and date the sample was taken, and
bear a unique identification (ID) number.
(6) Make a record of each sample by noting the date
the sample was taken, location of material sampled, the
area or room sampled, and the sample ID number.
(7) Send the sample to an analytical laboratory for
analysis (see Chapter 6).
What precautions should be taken during sampling?
To avoid causing unnecessary exposure to asbestos
fibers, the following precautions should be taken during
sampling,
« The material should be sampled when the area is
not in use.
* Only those persons needed for the sampling
should be present.
• The sample container should be held away from
the face during actual sampling.
• Do not disturb the material any more than
necessary.
• The material can be sprayed with a light mist of
water to prevent fiber release during sampling.
• If a large number of samples are taken, NIOSH
recommends that the sampler wear an approved
respirator. Contact the NIOSH Regional Offices listed
in Appendix E for information on approved respirators.
* If pieces of material break off during sampling,
wet mop the floors and areas where they have fallen.
Should the air be sampled?
Air sampling is the counting of fibers suspended in the
air. A known volume of air is pumped through a filter
where all suspended particles are collected. A
standardized air sampling method with specific
equipment and particle counting techniques is used by
the Occupational Safety and Health Administration
(OSHA) and industrial hygienists for evaluation of
airborne asbestos contamination. Unfortunately air
sampling by this standard method cannot show whether
the friable material actually contains asbestos fibers.
The method counts any particle of a certain size and
fibrous shape. The fibers that are counted may or may
not be asbestos.
Bulk sampling and analysis of the friable material
itself is the only method to determine whether or not
asbestos is present in the material.
10
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Chapter 6: Analysis of Bulk Samples
It is important that analyses of bulk samples are
performed by the recommended technique. In choosing
a laboratory, assistance from the State Asbestos
Program contact or the EPA Regional Asbestos
Coordinators is recommended.
What kind of analysis should be requested?
Analysis of friable material bulk samples by the
following techniques should be requested:
I) Polarized Light Microscopy (PLM)
2) X-Ray Diffraction (XRD) as necessary to
supplement the PLM method.
Polarized Light Microscope
Why are PLM and XRD recommended Tor bulk sample
analysis?
Polarized Light Microscopy (PLM) is a technique used
to identify asbestos fibers by their shape and unique
optical properties. It is a relatively inexpensive and
quick method for identifying asbestos in bulk samples.
PLM is particularly suitable for examination of the
complex mixes of friable construction materials.
X-Ray Diffraction (XRD) is recommended where a
second, independent analytical technique is necessary to
confirm an analysis by PLM, It is a more expensive
analytical method than PLM.
For more information on these analytical techniques,
see pages 1—4-2 to 1-4-3 of Part 2.
Is Electron Microscopy recommended Tor bulk sample
analysis?
Electron Microscopy (EM) is not a recommended
analytical technique for bulk sample asbestos analysis.
EM is costly, time-consuming, and limited in
availability,
For more information on Electron Microscopy, see
pages 1—4-3 of Part 2.
Is Phase Contrast Microscopy recommended?
Phase Contrast Microscopy is a technique used to count
fibers present in air samples. It is unacceptable for
identification of asbestos injjulk samples. Do not~
accept analysis of bulk samples by Phase Contrast
Microscop^C
For more information on Phase Contrast Microscopy,
see pages 1—4—5 to 1—4-6 of Part 2.
Is there a standard analytical protocol for bulk sample
asbestos analysis?
A standard protocol for bulk sample analysis is not
currently available. However, guidelines have been
prepared for bulk sample asbestos analysis using PLM
and XRD. These guidelines are included as Appendix
H to this manual and should be made available to the
laboratories which perform the analyses of bulk
samples.
11
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Are any laboratories certified for bulk sample asbestos
analysis with PLM?
No laboratories have been certified for performing bulk
sample analysis with PLM or XRD.
Laboratories which participate in the National
Institute for Occupational Safety and Health (NIOSH)
proficiency analytical testing program (PAT) for
certification by the American Industrial Hygiene
Association may or may not be qualified to perform
bulk sample asbestos analysis with Polarized Light
Microscopy. Typically these laboratories use Phase
Contrast Microscopy, which is inappropriate for the
differentiation of asbestos from other fibrous material
such as cellulose, hair, and glass fibers. Laboratories
proficient in air sample counting using Phase Contrast
Microscopy may lack both the equipment and expertise
to perform PLM identification of asbestos in bulk
samples.
What laboratories perform bulk sample asbestos
analysis?
It is important to select a laboratory competent in bulk
sample asbestos analysis. Since there currently is no list
of certified laboratories, locating a laboratory could be
difficult. The State Asbestos Program Agency or the
EPA Regional Asbestos Coordinator should be
contacted for their assistance and advice in laboratory
selection. The names and addresses of the State
Asbestos Program contacts are available from the EPA
Regional Asbestos Coordinators and on the EPA toll-
free information number (800-424-9065 or 554-1404 in
the Washington, D.C. area). The EPA Regional
Asbestos Coordinators are listed in Chapter 11.
Is guidance available to schools which plan to monitor
laboratory performance?
EPA will provide guidance to schools and school
districts which plan to undertake a program to ensure
good laboratory performance. Information can be
obtained by calling the EPA toll-free technical
assistance number (800-334-8571, extension 6892).
What should the laboratory report?
It is important that a complete written and signed
report of the analytical results be obtained from the
laboratory. The laboratory should report the following
information for each sample submitted:
(1) The sample ID number.
The laboratory results should be reported by
referencing each sample by its ID number.
(2) The analytical method used to analyze the
sample.
The report should name the analytical equipment and
the technique used to perform the analysis.
(3)a. A description of the sample appearance.
Good laboratory procedure requires that the analyst
note whether or not the bulk sample is a uniform
mixture.
(3)b. Whether the sample was homogenized before
analysis.
Asbestos materials were not always uniformly mixed
before application. // a sample is not homogenized prior
to analysis, some materials present in the sample may
not be detected.
(4) Percent of each type of asbestos present,
The analyst should report the types of asbestos
present and the estimated percent present. The estimated
precision associated with the percentage of asbestos
reported for each sample should be specified.
(5) Type and amount of the other fibrous materials
present in the sample.
The analyst should report what non-asbestos fibrous
materials are present in the sample and the percent
present, and provide the basis for that judgment.
Identification of the other fibers present will minimize
the reporting of false results.
(6) Comments on any other materials present,
(7) A description of the laboratory's quality control
program.
Laboratories should indicate (he quality control
procedures followed in their PLM analysis.
Should samples be retained for analysis?
School officials may wish to request that the laboratory
retain the samples for up to six months or return them
to the schools so that they will be available if reanalysis
is necessary.
12
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Chapter 7: Exposure Assessment
If bulk material analysis establishes that asbestos is
present in the sampled friable material, the potential
exposure of students and other users of the building
should be evaluated.
What should be considered in an exposure assessment?
Material condition, building structure characteristics,
and human activity are factors that will have
significance in any potential exposure situation
involving friable asbestos materials. These factors may
act singly or in combination to cause environmental
contamination and exposure of building users.
Experience has shown that eight factors generally
influence exposure potential.
1, Condition of Material; Material condition indicates
the extent of contamination and the likelihood of future
contamination. This factor is a combination of quality
of installation, adhesion of the friable material to the
underlying surface, material deterioration, and damage.
Delamination or deterioration of the material depends
on the characteristics of the material itself (whether it
shows signs of aging or loss of cohesive strength).
Damage is incurred by either accidental or intentional
contact. Evidence of debris can be a good clue to the
condition of material, which may vary from minor
deterioration and damage to widespread and severe
material disintegration.
2, Water Damage: Water can dislodge, delaminate,
and disturb asbestos materials that are otherwise in
excellent condition. Water can carry fibers in the slurry
to other areas in the building where evaporation will
leave a collection of fibers that can become
resuspended in the air. Water damage will have a
significant effect on selection of a corrective method,
essentially eliminating certain types of sealants.
3. Exposed Surface Area: The exposed surface area of
friable material has an effect on potential fiber fallout
levels and the possibility for contact and damage. A
useful criterion to apply for this factor is whether the
friable material is visible.
Asbestos material above suspended ceilings is not
considered as exposed. However, if the ceiling panels are
removed for routine maintenance activities above the
suspended ceiling or are damaged due to vandalism, the
asbestos material should be considered as exposed in that
area. Areas with louvers, grids, or other open ceiling
systems should be considered as exposed. However,
exposed does not mean accessible, which is a separate
factor,
4. Accessibility: If the material can be reached, it is
accessible and subject to accidental or intentional
contact and damage. Accessibility is a good indicator of
possible future exposure caused by contact and damage.
This factor should also include some consideration of
the proximity of friable material to heating, ventilation,
lighting, and plumbing systems requiring maintenance
or repair.
The behavior characteristics of the student population
should be considered in evaluating accessibility. For
example, students involved in sports activities may
accidentally cause damage to asbestos materials on the
walls and ceilings of gymnasiums. Material that is easily
accessible is also subject to damage by vandalism.
5. Activity and Movement: This factor combines the
effects of general causes that may result in contact and
damage of friable material. These causes include
air movement, building vibration from machinery or
any other source, and activity levels of students or
building workers. This factor is also an indicator of
future exposure potential. Its value will be low in
school libraries, offices, and most classrooms; moderate
in some classrooms and in school corridors; and can be
exceedingly high in gymnasiums and cafeterias.
6. Air Plenum or Direct Air Stream: Friable asbestos
material contained within an air plenum or in an air
stream, if undisturbed, has very low potential for
contaminating the building environment. However, it
must be considered since contact and damage may
occur during maintenance, repairs, and renovation. In
dealing with asbestos material located in air plenums,
special attention should be given to the management
system described in Chapter 8.
7. Friability: The asbestos materials can vary in
degree of friability. The more friable the material, the
greater potential for asbestos fiber release and
contamination. Sprayed asbestos material is generally
more friable than most troweled materials.
13
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8. Asbestos Content: The percentage for all the types
of asbestos present should be added for the total
asbestos content. With a high percentage of asbestos,
there are more fibers that can be released and
contaminate the building environment.
Is an exposure assessment straightforward?
Assessing exposure can be difficult. The eight factors
can vary from school to school; from room to room;
and sometimes from one area to another in the same
room. These factors should adequately describe most
situations. They are presented here to provide general
guidance, and exceptions can occur. Unique building
structure characteristics, unusual material condition, or
other considerations can influence the evaluation of
exposure.
How is an exposure assessment carried out?
The following steps are recommended for an exposure
assessment.
(1) Determine whether each factor is applicable in
the area where the asbestos material is present.
(2) If a factor or factors are applicable, note the
actual effects or situation associated with each factor.
For example, if the Accessibility factor is applicable,
consider whether (a) the material is subject to damage
during maintenance or repair work or; (b) the material
is accessible to students who may damage it during
sports activities or who will scrape, gouge, or hit the
material.
(3) Evaluate the exposure potential. Simply, if
asbestos fibers are being released and causing
contamination of the building environment, exposure of
students and other building users is occurring or is
likely to occur.
In carrying out the exposure assessment, it is
important that the factors are uniform throughout the
area being evaluated. If factors differ in one room or in
one area of a room, they are not uniform. In this case,
a separate evaluation should be made. For example, an
auditorium with both an inaccessible ceiling surface in
the stage area and a very accessible and damaged
surface in the audience area constitutes two different
areas.
The above discussion has described the factors relating to
exposure. Is there any system that ties these subjective
factors in a more precise way to aid the school official in
the decisionmaking for an exposure assessment?
EPA has developed a scoring system using a
mathematical formula which can be used as an aid in
assessing exposure and in deciding what kind of
corrective action to take. EPA is currently evaluating
the accuracy of the scoring system through field tests
and statistical analysis. It is EPA's intention to make
this scoring system and instructions for its use available
to school districts through the State Asbestos Program
contacts and through the Regional Asbestos
Coordinators.
Is air sampling necessary to evaluate the exposure
potential?
Air sampling is inappropriate to estimate asbestos
contamination and exposure. In the school
environment, it is virtually impossible to establish
exposure potential using standard air sampling
techniques. Air sample results from monitoring in
school buildings can be misleading if they are compared
to the Federal workplace air concentration levels
established by OSHA.
The standard optical microscopy method (Phase
Contrast Microscopy) used to analyze air samples has
technical restrictions. Only particles of a certain size
and fibrous shape are counted in an air sample. The
fibers that are counted may or may not be asbestos.
More importantly, the low air levels of asbestos that
have been found in school buildings are at the lower
limits of effectiveness for the optical microscopy
technique. Therefore, the results can be misleading.
The Federal workplace air concentration levels do
not apply to children. They were established for
asbestos workers in workplace environments.
Comparing air levels found in school buildings to the
Federal occupational standards is a totally ineffective
method of determining whether an exposure problem
exists.
What is the next step if exposure is occurring?
If exposure is found to be occurring or is likely to
occur, a corrective action may be warranted. This
decision will involve a judgment of the degree of the
exposure problem and what corrective method is
appropriate.
Chapter 8 discusses each of the corrective actions.
The charts on pages 18 and W of Chapter 8 should be
consulted for the advantages and disadvantages of each
corrective method and the conditions where each
method is appropriate or inappropriate.
Is corrective action required if there is no exposure
problem?
If it is determined that the exposure is negligible or that
there is no exposure potential, action can be deferred.
However, a continuing inspection program and
management system as described in Chapter 8 should
be implemented to ensure that if the situation changes,
the necessary steps will be taken to control exposure.
14
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Chapter 8: Corrective Action
If friable asbestos material is present and exposure is
occurring or will likely occur, corrective action should
be considered. The selection of the method or methods
of action should reach the most efficient long-term
solution after consideration of material condition,
location, function, and cost.
There are four approaches to controlling exposure:
(1) Removal: Asbestos material is removed and
disposed of by burial.
(2) Encapsulation: Asbestos material is coated with a
bonding agent called a sealant.
(3) Enclosure: Asbestos material is separated from
the building environment by barriers such as suspended
ceilings.
(4) Deferred action: No action is taken. The area is
inspected periodically for changes in exposure potential.
Removal, encapsulation, and enclosure are corrective
methods and can be used separately or in combination.
Removal completely eliminates the source of exposure
to asbestos and is, therefore, a permanent solution.
Both enclosure and encapsulation are containment
methods.
Since the asbestos material remains within the
building, enclosure and encapsulation should be
considered as temporary control measures. The length
of time before building renovation or demolition is
planned will be a factor in deciding whether to use
either of these methods. If the building is later
renovated or demolished, encapsulated and enclosed
asbestos material must be removed and disposed of
according to the EPA regulations discussed in Chapter
9.
Removal, encapsulation, enclosure, and deferred
action are discussed in the following sections. The chart
on pages 18 and 19 at the end of this chapter outlines
each corrective action, lists advantages and
disadvantages, and notes the conditions under which
each method is appropriate.
Schools that do undertake a corrective action should
refer to Chapter 9 for information on the applicable
Federal regulations and proper work practices that are
required to protect workers and the building from
contamination during removal, encapsulation, or
enclosure.
Removal
For removal, all the asbestos material is taken off the
underlying surface, collected, and placed in containers
for burial in an approved waste disposal site. Removal
may require interruption of building activities. Vacation
periods in schools often provide a convenient time to
carry out the removal operation.
EPA has regulations that cover the removal of
asbestos material. The regulations require wetting of
the material prior to removal. Thoroughly wetting
asbestos material greatly reduces the release of fibers.
As the wet material is removed, only a small number of
fibers will be released and those that are will settle
rapidly to the floor rather than remain suspended in the
air.
Using water that has been amended with a wetting
agent (surfactant) is strongly recommended for all
removal operations. Amended water ensures greater
penetration of the material and reduces the amount of
water needed for the operation.
For more information on wet removal techniques, see
pages 11-4-2 to H-4-3 and E-l to E-5 of Pan 2.
Wetting With Amended Water
Removal of Wet Asbestos Material From Overhead Surfaces
-------
Should consideration be given to the original purpose or
the material?
The original purpose of the material should be
considered when a corrective method is chosen.
Removed fireproofing material should be replaced to
maintain compliance with fire and building codes. It' the
asbestos material served cither an insulating or
acoustical function, a replacement material should have
similar characteristics.
Encapsulation
For encapsulation, the asbestos material is coated with
a bonding agent called a sealant. Sealants penetrate and
harden the asbestos material (penetrants) or cover the
surface of the material with a protective coating
(bridging sealants). The sealant prevents fiber release
from the asbestos material.
Sealants are applied over the surface of the material
Encapsulation of a Ceiling Surface
16
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using airless spray equipment at a low pressure setting.
Airless equipment reduces the pressure of the sealant
spray and the impact upon the friable asbestos material
surface, thus reducing fiber release during application.
Encapsulation should be limited to areas where
contact damage will not occur, a factor which may
preclude encapsulation in many areas of school
buildings because of high activity levels. Encapsulation
should also be limited to asbestos material that still
retains its bonding integrity since the material must
support the additional weight of the sealant.
Encapsulated material should be routinely inspected for
deterioration or damage.
For more information on the encapsulation method,
see pages 11-3-2 to f 1-3-5 of Purl 2.
What sealants are recommended for encapsulation?
An EPA contractor is evaluating sealants for asbestos
material to determine if they meet designated
specifications for flammability, smoke generation,
toxicily, and impact resistance. Until a report of the
sealant study (expected in May 1979) is published, State
Asbestos Program agencies and the EPA Regional
Asbestos Coordinators should be contacted for
information.
Enclosure
For enclosure, a barrier such as a suspended ceiling is
constructed between the asbestos material and the
building environment. Since the asbestos material
remains, fiber release and fallout can continue behind
the barrier, and accumulation of fibers will usually
occur. When the enclosure is damaged or entered for
maintenance, fibers collected behind the enclosure can
be released into the building environment.
For more information on the enclosure method, see
page 11-3-1 of Pan 2,
Constructing a Suspended Ceiling Barrier
Deferred Action
If the exposure potential is considered negligible, action
can be deferred. A continuing inspection program
should be implemented as part of deferred action. The
asbestos material should be routinely checked for
deterioration or damage. If the condition of the
material changes so that fibers are being released and
contaminating the building environment, the exposure
potential should be reevaluated according to the
guidelines set out in Chapter 7.
Asbestos Material Management
Program
Encapsulation, enclosure', and deferred nctiun leave the
asbestos material within the building. Assuming thai the
exposure assessment is accurate and that an appropriate
corrective action has been taken, exposure of building
users will not occur.
The asbestos, however, remains and conditions can
change. For example, asbestos material can be damaged
by inadvertent or uninformed maintenance, repair, or
renovation activities.
Therefore, a management system should be
implemented to control maintenance, renovation, or
repair work by either school personnel or contractors.
These individuals should be informed that asbestos
material is present and trained in proper work
procedures to prevent damage to the material or to the
containment system. Work order procedures and school
building sign-in or entry systems are usually good
methods for alerting workers and school administrative
personnel that work in an area having asbestos material
is planned.
When should a school be closed for corrective action?
Generally, it is not necessary to close a school in order
to take a corrective action. However, a severe exposure
problem may require that the problem areas or rooms
be closed off until a corrective action is taken. Usually
this situation arises when there is a potential for high
contamination levels of asbestos caused by continuing
contact and damage of highly friable material.
Are there Federal regulations that must be followed
when taking a corrective action?
EPA and OSHA have regulations covering removal,
encapsulation, and enclosure of asbestos materials.
Chapter 9 contains a brief summary of these
regulations.
Some States and local governments may also have
regulations covering asbestos removal, encapsulation.
and enclosure. The State Asbestos Program Agency
should be contacted for information on State and local
government regulations.
17
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Selection of a Corrective Action Method
Method
Removal
Advantages of
Method
0 Eliminates asbes-
tos source
0 Ends exposure
Encapsulation
Controls expo-
sure
Usually most
rapid and eco-
nomical method
Disadvantages of
Method
° Usually most costly
and complicated
method
0 Usually most time
consuming method
0 Replacement with
substitute material
may be necessary
0 Higher potential for
worker exposure
0 Asbestos source re-
mains
0 If material is damaged
or deteriorating, addi-
tional weight of the
sealant may cause de-
lamination1
0 Management system
required. Precautions
necessary to prevent
damage during main-
tenance or renovation
0 Continuing inspection
required to check for
damage to encapsu-
lated surface
0 Maintenance on dam-
aged or deteriorating
encapsulated surface
required
0 Encapsulated material
is difficult to remove
When Method ts
Appropriate
0 High exposure
0 Material is dete-
riorating or dam-
aged
0 Material is acces-
sible
0 Flat, open mate-
rial surface
0 Removal not fea-
sible
0 Material still re-
tains bonding in-
tegrity
D Damage to mate-
rial not probable
0 Limited accessi-
bility of material
0 Complex surfaces
to be covered
0 Economic or
time advantage
When Method Is
Inappropriate
° Removal is not feasi-
ble because of cost,
location of material,
and kind of surface to
which material has
been applied (e.g., re-
moval of material
from complex surfaces
such as pipes, lines,
and ducts)
0 Removal feasible
0 Material does not ad-
here well to
substrate,2 Weight of
sealant may cause de-
lamination
0 Material is deteriorat-
ing or damaged
0 Damage to material is
probable
0 Water damage
0 Continuing inspection
and maintenance of
encapsulated material
doubtful
1 Ddamination is the breaking away of layers of material from the underlying surface.
1 Substrate is the surface to which the asbestos material was applied (e.g.. ceilings, stee! beams, pipes).
18
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Method
° Enclosure
Advantages of
Method
0 Controls expo-
sure
Disadvantages of
Method
0 Asbestos source re-
mains
When Method h
Appropriate
0 Removal not fea-
sible
When Method If
Inappropriate
" Removal feasible
May be most
rapid, economi-
cal, uncompli-
cated method
Deferred Action ° No direct cost
0 Fiber fallout contin-
ues behind enclosure
0 May be costly if en-
closure disturbs func-
tions of other systems
{e.g., enclosure may
require lighting
changes)
° Management system
required. Precautions
necessary for entry
into enclosure for
maintenance or reno-
vation
0 Continuing inspection
required to check for
damage to enclosure
system
0 Maintenance on dam-
aged enclosure system
required
0 Potential for exposure
may increase
0 Management system
required. Precautions
necessary to prevent
damage during main-
tenance or renovation
° Continuing inspection
and reevaluation nec-
essary
Disturbance or
entry into en-
closed area not
likely
Economic advan-
tage
Negligible expo-
sure potential
rating material caus-
ing high levels of fiber
fallout
Water damage
Damage to enclosure
likely
Entry into enclosure
probable for repairs
and maintenance
Continuing inspection
and maintenance of
enclosure doubtful
° Definite or question-
able exposure poten-
tial
0 Continuing inspection
doubtful
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Chapter 9: Specifications and Requirements
for Contractors
Removal, encapsulation, and enclosure operations must
he performed carefully. Poorly performed work can
cause a greater exposure problem than it eliminates.
Workers who do not remove asbestos material wet or
who damage the material during encapsulation or
enclosure cause uncontrolled release of asbestos fibers.
If fiber release is not properly contained in the work
area, workers will be exposed and widespread
contamination of the building will occur.
EPA and OSHA have issued regulations which cover
the removal, encapsulation, and enclosure of asbestos
material. Contractors are required to comply with both
regulations. EPA regulations require that removed
asbestos material be properly contained and disposed of
without release of asbestos fibers into the environment.
OSHA regulations require worker protection to prevent
exposure to hazardous levels of asbestos fibers.
It should not be assumed that all contractors will
comply with these regulations. Some contractors may
not know that compliance is required; others may
ignore the regulations in order to save time or money,
The EPA and OSHA regulations do not require
worker decontamination before leaving the job site and
clean-up of the contaminated work area after the job
has been completed. Therefore, school officials should
not only require contractors to comply with the EPA
and OSHA regulations but also require them to take
additional measures to ensure proper work practices
and protection of the building environment. Past
experience has shown that in many cases without
adequate supervision and instruction from supervisors
or management, workers will remove asbestos dry
instead of wet, work without respirators, eat or drink in
the work area, and leave the job site in their
contaminated worksuits and clothing.
For these reasons, there are a number of precautions
that should be taken:
(I) Become familiar with the EPA and OSHA
regulations and any State and local government
regulations that apply to asbestos material removal,
encapsulation, and enclosure.
(2) Require contractors submitting bids to explain in
their bids how they intend to comply with the
applicable regulations.
(3) Include specifications for asbestos fiber
containment, worker protection, and decontamination
of the work area in contracts and enforce the
requirements of the contract.
(4) NIOSH recommends that contractors who submit
bids provide evidence that they and their workers have
attended training courses dealing with occupational
safety and the health hazards associated with asbestos
material removal, encapsulation, and enclosure.
Information on contractor training materials is available
from the OSHA and NIOSH Regional Offices listed in
Appendices D and E.
(5) For any corrective action, notify the nearest
OSHA office listed in Appendix D when work will
begin and let the contractor know thai OSHA will be
notified.
(6) For removal, notify the appropriate EPA
NESHAPS Coordinator listed in Appendix B before
the removal operation is begun.
(7) Recommend that the contractor contact the EPA
Regional Asbestos Coordinator for technical assistance.
The task of finding a qualified contractor may be
complicated by various political and economic
pressures. There may be pressure by people who are
unaware of the hazards of poorly performed work to
take action as soon as possible and as cheaply as
possible. Strict compliance with the EPA and OSHA
regulations and the recommended specifications takes
time and money. Contractors offering the lowest bid
may not be knowledgeable or capable of complying
with these regulations.
Short summaries of the EPA and OSHA asbestos
regulations follow. The full texts of these regulations
are printed in Appendices A and C. Recommended
specifications for removal, encapsulation, and enclosure
contracts are also included in this chapter. These
specifications can be used to guide school officials in
negotiating contracts which will ensure proper work
practices and a protected building environment.
EPA Regulations
EPA regulates the removal and disposal of asbestos
materials from ceilings, walls, pipes, and other surfaces
in buildings. The regulations were issued under the
EPA National Emissions Standards for Hazardous Air
Pollutants (NESHAPS). Written notification to the
NESHAPS Coordinator is required before asbestos
material can be removed.
The regulations require wetting of the asbestos
material before, during, and after stripping to prevent
dust emissions. The regulations use "stripping" to refer
20
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to taking asbestos off the ceilings, walls, pipes, etc.;
and "removal" to refer to taking stripped asbestos
material out of the building for disposal. If material
cannot be removed wet because of freezing
temperatures or damage to equipment by water, the
EPA NESHAPS Coordinator should be'notified. In
some eases dry removal of asbestos material requires
written permission from EPA.
Stripped asbestos material must be placed in leak-
tight containers while siill wet before removal from the
building. Containers of asbestos material may not be
dropped out of windows or down from one floor to the
next. Asbestos material must be transported within the
building in containers or dust-tight chutes.
Containers must be marked with a warning label (use
the OSHA label on page and be buried in a waste
disposal site meeting the requirements of Section 61.25
of the EPA regulations. In most cases a State-approved
sanitary landfill will be an acceptable disposal site.
Before contractors begin any asbestos removal
operation, they must send a written notification to the
EPA NESHAPS Coordinator before starting the
removal operation. The notification must contain the
following information;
(1) Name and address of the contractor.
(2) Address and description of the building, including
size, age, and prior use of the building and amount of
friable asbestos material present (square feet).
(3) Scheduled starting and completion dates for
removal.
(4) Procedures that will be employed to comply with
the regulation.
(5) The name and address of the waste disposal site
where the asbestos waste will be deposited.
When contractors send in notification of an asbestos
removal operation to EPA, the EPA NESHAPS
Coordinator will notify the OSHA office for that area
that a removal operation is planned.
See Appendix A for the full text of the EPA asbestos
regulations. Questions about the regulations and
compliance problems can be answered by the NESHAPS
Coordinator listed in Appendix B.
OSHA Regulations
OSHA regulates workplace practices and the airborne
concentration levels to which asbestos workers can be
exposed. The OSHA regulations apply to removal,
encapsulation, and enclosure operations involving
asbestos materials.
OSHA has established limits on the amount of
airborne asbestos to which a worker may be exposed on
a daily basis. Over an 8-hour period the average
airborne asbestos concentration level (also known as
the time weighted average (twa)) to which a worker
may be exposed may not exceed two fibers longer than
five micrometers per cubic centimeter of air (2f/cc). At
no time during the 8-hour period may the airborne
concentration exceed 10 fibers longer than 5
micrometers per cubic centimeter of air (l()f/cc): The
lOf/ce concentration is called the ceiling concentration.
NIOSH has recommended lowering the 8-hour twa to
0.1 fibers per cubic centimeter (O.lf/cc).
Contractors must use air monitoring to determine
whether the airborne concentration of asbestos exceeds
these exposure limits. The regulations prescribe the
method to be used for air monitoring and where and
how often air samples must be taken.
If the airborne concentration does exceed the
specified exposure limits (either the 8-hour twa or the
ceiling concentration), then the contractor performing
removal, encapsulation, or enclosure must:
(1) Provide employees with approved respirators. The
OSHA regulations require different types of respirators
under different conditions. The OSHA Regional Offices
listed in Appendix D can provide information on
respirator requirements. The NIOSH Regional Offices
listed in Appendix E can provide information on
approved respirators.
(2) Provide change rooms and two separate lockers
or storage containers so that employees can keep street
clothes and work clothes separate.
In addition, if the ceiling concentration is exceeded, the
contractor must provide his employees with protective
clothing.
The regulations require contractors to place caution
signs inside and immediately outside of the work area.
The signs must advise people entering the area of the
hazards of exposure to asbestos.
Containers of waste asbestos material must be
marked with a warning label which states:
CAUTION
CONTAINS ASBESTOS FIBERS
AVOID CREATING DUST
BREATHING ASBESTOS DUST MAY CAUSE
SERIOUS BODILY HARM
See Appendix C for the full text of the OSHA asbestos
regulations. Questions about the regulations and
compliance problems can be answered by the OSHA
Regional Offices listed in Appendix D. Information on
contractor training and occupational safety is also
available from these OSHA offices and the NIOSH
Regional Offices listed in Appendix E.
Contract Specifications
The following general specifications are recommended
for removal and encapsulation contracts. Some of these
specifications are also appropriate for enclosure
contracts. If these recommended specifications are
incorporated into contracts and strictly enforced, the
building environment will be protected against
contamination.
21
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Contractors should he encouraged to receive training
and to train their workers in safe work practices and in
proper removal, encapsulation, and enclosure methods,
Contractor and worker training can be required in the
contract.
1. Regulations
Contractors shall comply with the requirements of the
EPA regulations. National Emission Standards for
Asbestos, and the OSHA regulations on asbestos.
Section 1910.1001 [and any applicable State and local
government regulations] which are incorporated by
reference.
2. Scope of Work
A. The Contractor shall furnish all labor, materials,
services, insurance, and equipment necessary to carry
out the [removal operation, encapsulation operation] in
accordance with the EPA and OSHA regulations [and
any applicable State and local government regulations].
B. The Contractor shall be responsible for obtaining
approval for a waste disposal site in compliance with
Section 61.25 of the EPA regulations.
C. Contractors shall post the EPA and OSHA
regulations [and any applicable State and local
government regulations] at the job site,
3. Worker Protection
A. The Contractor shall provide workers with
approved respirators. The Contractor shall provide a
sufficient quantity of filters approved for asbestos so
that workers can change filters during the work day.
Filters shall not be used any longer than one (1) work
day. The respirator filters shall be stored at the job site
in the change room and shall be totally protected from
exposure to asbestos prior to their use.
B. Workers shall always wear a respirator properly
fitted on the face in the work area.
C. Contractors shall instruct and train workers in
proper respirator use.
D. Workers shall wear disposable, full-body coveralls
and disposable head covers and footwear in the work
area. Footwear may be disposable. Non-disposable
footwear shall be left in the work area at all times until
disposal at job completion.
E. The Contractor shall set up a change room and a
shower outside of the work area.
F. All workers without exception shall:
(I) Remove street clothes in the change room and
put on the disposable coveralls and head covers, and
respirator before entering the work area.
(2) Remove the disposable coveralls, head covers.
and footwear in the work area before leaving the work
area. Still wearing their respirators, proceed to the
showers and remove their respirators while showering
with soap and water.
(3) Shower at the end of each day's work before
entering the change room to change into street clothes.
G. Workers shall not eat. drink, smoke, chew gum.
or chew tobacco in the work area. To eat, drink, or
smoke, workers shall remove the disposable work
clothes and footwear in the work area before leaving
the work area. Still wearing their respirators, workers
shall proceed to the showers and remove their
respirators while showering with soap and water.
Workmen shall then dress into a new, clean disposable
coverall to eat, smoke, or drink. The new coverall can
be worn to reenter the work area.
H. The Contractor shall provide a respirator and
disposable coveralls, headcover, and footwear to any
official representative of the school who inspects the
job site.
I. All persons entering the work area shall wear an
approved respirator and disposable coveralls, head
cover, and footwear.
Worker Dressed in Protective Clothing
-------
4. Work Area Preparation
A. The Contractor shall set up a decontamination
facility outside of the work area which will consist of a
change room, shower area, and equipment area. The
decontamination facility shall be subject to the approval
of the official representative of the school,
B, The Contractor shall isolate the work area for the
duration of the work by completely sealing off all
openings and fixtures in the work area including, but
not limited to, heating and ventilation ducts, doorways.
corridors, windows, skylights, and lighting with plastic
sheeting taped securely in place.
C. The Contractor shall build double barriers of
plastic sheeting at all entrances and exits to the work
area so that the work area is always closed off by one
barrier when workers enter or exit.
D. All floor and wall surfaces in the work area shall
be covered with plastic sheeting taped securely in place
to protect from water damage [or damage by sealants],
E, Before the work is begun, the Contractor shall
wet clean all removable items and equipment not
located on the asbestos material, remove them from the
work area, and then return these items and equipment
to the work area after the job has been completed and
the area has been decontaminated.
F. The Contractor shall cover all non-removable
items and equipment in the work area with plastic
sheeting taped securely in place.
G. After work area isolation, the Contractor shall
take out all detachable electrical, heating, ventilation
equipment, and other items located on the asbestos
material, clean them before covering with plastic
sheeting taped securely in place, and return them to
their proper place after the job has been completed and
the work area has been decontaminated.
H. The Contractor shall remove all heating,
ventilation, and air conditioning system filters, pack
them in scalable plastic hags (6-mil minimum) for burial
in the approved waste disposal site and replace them
with new filters,
1. The contractor shall establish emergency and fire
exits from the work area. Emergency procedures shall
have priority.
5. Method of Removal
A. The asbestos material shall be sprayed with water
containing a wetting agent to enhance penetration. The
wetting agent shall be 50% polyoxyethylene ester and
50% polyoxyethylene ether (Aqua-GRO*), or the
equivalent, in a concentration of one (I) ounce in five
(5) gallons of water, A fine spray of the amended water
* Mention of irailc names or specific products does not constitute
endorsement hv EPA,
shall be applied to reduce fiber release preceding the
removal of the asbestos material. The material shall be
sufficiently saturated to prevent emission of airborne
fibers in excess of the exposure limits prescribed in the
OSHA regulations referenced in these specifications.
B. The asbestos material shall be removed in small
sections by two-man teams on staging platforms. Before
beginning the next section, the material shall be packed
while still wet into scalable plastic bags (6-mil
minimum) and placed into fiber or metal drums or skips
for transport. Bags, drums, and skips shall be marked
with the OSHA label prescribed by the OSHA
regulations referenced in these specifications, The
outside of all containers shall be clean before leaving
the work area.
C, All plastic sheeting, tape, cleaning material,
clothing, and all other disposable material or items used
in the work area shall be packed into scalable plastic
bags (6-mil minimum) and placed into metal or fiber
drums or skips for transport. The drums and skips shall
be marked with the OSHA label prescribed by the
OSHA regulations referenced in these specifications.
D. The Contractor shall transport the sealed drums
or skips to the approved waste disposal site. The sealed
plastic bags may be dumped from the drums into the
burial site unless the bags have been broken or
damaged. The damaged bags shall be left in the drum
and the entire contaminated drum shall be buried.
Uncontaminated drums may be recycled.
6. Decontamination of Work Area
A. The Contractor shall clean all surfaces in the work
area with water and/or with a High Efficiency
Particulate Absolute (HEPA) filtered vacuum. (A
HEPA vacuum will fail if used on wet material.) After
cleaning the work area, the Contractor shall wait 24
hours to allow for settlement of dust, and then wet-
clean all surfaces in the work area again. After
completion of the second cleaning operation, the
Contractor shall perform a complete visual inspection of
the work area to ensure that the work area is dust free.
The Contractor shall take two air samples within 48
hours after completion of all cleaning work. (Minimum
volume of air sample is 240 L).
B. If the official representative of the school finds
that the work area has not been decontaminated, the
Contractor shall repeat the cleaning and air monitoring
until the work area is in compliance.
C. After the work area is found to be in compliance,
all entrances and exits are unsealed and the plastic
sheeting, tape, and any other trash and debris is
disposed of in scalable plastic bags (6-mil minimum)
and buried in the approved waste disposal site.
23
-------
Removal, Disposal, and Clean Up Procedures
-------
7. Air Monitoring
A. Throughout the entire [removal, encapsulation]
and cleaning operations, air monitoring shall be
conducted to ensure that the Contractor is complying
with the EPA and OSHA regulations [and any
applicable State and local government regulations). The
school shall provide an air monitoring technician to
take air samples at the job site at no cost to the
Contractor.
B. Air monitoring will be conducted according to the
method prescribed by Section 1910.1001(0 of the
OSHA regulations.
C. Air monitoring shall be performed to provide the
following samples during the period of asbestos
[removal, encapsulation]:
Arra\ >" be Sampled
Work Area
Outside Work Area
Outside Building
Mi it nun in
.VlHH/l/l'l l"l
{•liu-li H'urA An
2
1
I
\lllllHIUIH
IWllHH 1 ,'• '
120 L
120 L
240 L
D. Samples should only be taken iit'ter actual
[removal, encapsulation] work has proceeded.
Removed Material in Drum With Plastic Liner
25
-------
Chapter 10: EPA School Survey
EPA plans to assess the extent of the asbestos material
problem in schools and to determine the need for
further Federal action to control exposure to asbestos
in school buildings. To aid in this evaluation, EPA
encourages school districts to complete the survey form
at the end of this chapter.
What information does the form request?
The form asks questions about the results of (I)
inspection for friable materials and (2) sampling and
laboratory analysis of friable materials for asbestos. It
also asks what kind of corrective action (removal,
encapsulation, enclosure, or deferred action) has been
or will be taken to control exposure to friable asbestos
material.
Where to send the form
School districts (or individual schools, if the school
district does not plan to file a report) should send a
copy of the completed survey form to their EPA
Regional Asbestos Coordinator. The Coordinators are
listed on the back of the survey form. In States which
have an Asbestos Program Agency, the school district
should contact the agency to determine whether the
reporting form should also be sent to the State. The
names and addresses of these State contacts are
available from the EPA Regional Asbestos Coordinator
and by calling the EPA toll-free information number
listed below:
800-424-9065
(in the Washington, D.C. area: 554-1404)
A copy of the reporting form should be kept by
school districts in an asbestos control program file.
When to complete the form
The survey form should be completed as soon as
information is available from schools. Since asbestos
control programs in schools may begin at different
times, school districts may want to file more than one
form.
If possible, officials should mail completed survey
forms before September 1, 1979.
Additional Reporting Forms
Additional reporting forms can be obtained by calling
the EPA toll-free information number (800-424-9065 or
554-1404 in the Washington, D.C. area).
Will reports on the survey results be available?
Depending on the data received, EPA will compile
monthly reports for the Regional Asbestos
Coordinators. EPA will also publish an interim status
report in September 1979 and a final report in February
1980. These reports will summarize the data received
and will contain nationwide projections on the extent of
the asbestos problem in schools and efforts to control
it. These reports will be available to the States and
local school officials upon request from the Regional
Asbestos Coordinators.
26
-------
xvEPA
U.S. ENViRONMENTAL PROTECTION AGENCY
ASBESTOS SURVEY REPORT
(Survey of Activities to Control
Asbestos—Contn tnin£ Matentilx in School Buildings)
Form Approved
OMB No. 158-R-Q165
GENERAL
This information is collected under the authority of the Toxic Substances Control Act^ Sections 6 and 8. f£PA is compiling information
on the progress of State and local programs to control exposure to asbestos—containing materials in schools. This form should be used
to periodically report information concerning the asbestos control activiHes in your school district To obtain more forms, call this
toll-free number: 800—424—9065 or in the Washington, D.C. area, call 554—1404. Data collected in this survey will be subject lo the
provisions of the Freedom of Information Act ( 5 t/.S.C. 552).
MAILING INSTRUCTIONS
MAIL ONE COPY TO:
The EPA Regional Asbestos Coordinator
for your Region. (For names ,fnd ac/drex^
*ee reverse side.)
ALSO, please mail a copy to your official State asbestos program
contact (for name and address, call this toll — free number; 800—
•124-9065 or if in the Washington, D.C. area, call 554-1404).
IDENTIFICATION
1 SCHOOL DtSTRICT INFORMATION
2. PERSON TO CONTACT REGARDING THIS REPORT
NAME OF SCHOOL DISTR1C"
AME (last, first, & middle
CITY OR COUNTY
JOB TITLE
Zip CODE
HONE MO. fared code &
DATE: {mo., a
SPECIFIC QUESTIONS
3. Has the school district submitted an EPA Asbestos Survey
Report before?
YES
UNKNOWN
4. How many schools in the district were built or renovated
between 1945 and 19785
NUMBER O~F SCHOOLS'" — —— — — — — — — — — — —
As of fVno./yr.j, how many schools in the district
have been inspected for the presence of friable asbestos—
containing materials? rN-M-e-Q- S-H-Q-S• - -
6. How many schools had bulk samples analyzed for asbestos with
the EPA recommended technique of Polarized Light Microscopy
NUMBER OF SCHOOLS
7. As of.
w(mo,/yr. of
for how many schools
in the district was friable ma-
terial analyzed as containing
asbestos?
(a) In how many schools was friable asbestos—containing material determined to present
an exposure problem?
(b) Approximately how many square feet of this material were found?
(c) Estimate the number of children per school year exposed to this material. (Multiply
the percent of children exposed by the total number of enro/ie*f students, e.^.f An
exposure problem in five classrooms may involve 15% of the tots! population of 700
students; 15% x 700 equals 105 students exposed.)
(d) Have the names of the children been recorded and retained for future reference?
NUMBER OF SCHOOLS
a. NO OF SCHOOLS
). SQUARE FEET
C. NO, OF CHILDREN
d. NAMES RECORDED
YES ~: NO
'Questions 9 through 11 refer to the friable asbestos—containing material that presents an exposure prohlem in Question 8.
9. (a) Approximately how many square feet of this material have
been or will be removed?
(b) What is the estimated total cost, of removal?
a. SQUARE FEET
b.
COST: $
10. (a) Approximately how many square feet of this material have
been or will be encopsuiated?
(b) What is the estimated total cost of encapsulation5
a. SQUARE FEE!
b.
COST: $
I 1. (a) Approximately how many square feet of this material have
been or will be enclosed?
(b) Wha( is (he estimated total cost of enclosure?
12. (a) For approximately how many square feet of asbestos-
containing material was action deferred?
(b) Will this material be inspected periodically to de-
termine if an exposure problem exists?
a. SQUARE FEET
T
a. SQUARE FEET
COST: S
b. PERIODIC INSPECTION
13, What, is the source of funding for the asbestos control
activities in your district?
14, When did for ivilf) the asbestos control activities in the
district begin and end?
FUNDING SOURCE
BEGINNING YEAR
ENDING YEAR
COMMENTS
EPA Form 7710-29 (3-79)
27
-------
REGIONAL OFFICES
Region 1
Mr, Paul Heffernan
Asbestos Coordinator
Air & Hazardous Materials Div.
Pest. & Toxic Substances Br,
EPA Region I
JFK Federal BIdg.
Boston, MA 02203
(617) 223-0585
Region 2
Mr, Marcus Kantz
Asbestos Coordinator
EPA Region II
Room 802
26 Federal Plaza
New York, NY 10007
(212) 264-9538
Region 3
Mr, Fran Dougherty
Asbestos Coordinator
EPA Region III
Curtis Building
Sixth & Walnut Streets
Philadelphia, PA 19106
(215) 597-8683
Region 4
Mr. Dwight Brown
Asbestos Coordinator
EPA Region IV
345 Courtland Street
Atlanta, GA 30308
(404) 881-3864
Region 5
Dr. Lyman Condie
Asbestos Coordinator
EPA Region V
230 S. Dearborn St.
Chicago, 1L 60604
(312) 353-2291
Region 6
Dr. Norman Dyer
Asbestos Coordinator
EPA Region VI
First Internal! Bldg.
1201 Elm Street
Dallas, TX 75270
(214) 767-2734
Region 7
Mr. Wolfgang Brandne
Asbestos Coordinator
EPA Region VII
324 East 11 Street
Room 1500
Kansas City, MO 64KM
(816) 374-3036
Region 8
Mr. Ralph Larsen
Asbestos Coordinator
EPA Region VIII
I860 Lincoln Street
Denver, CO 80295
(303) 837-3926
Region 9
Mr. John Yim
Asbestos Coordinator
EPA Region IX
215 Fremont Street
San Francisco. CA 941(
(415) 556-3352
Region 10
Ms. Margo Partridge
Asbestos Coordinator
EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-5560
28
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
© IUO/k ASBESTOS SURVEY REPORT
^^j^J^Hfjfa^ (Survey of A cti viti?& ti't Control
Asht-'atau—Coi-itainin!?. Wafena/s in School Buildings)
Form Approved
OMB No. 158-R-0165
GENERAL
This information is collected under tho authority of the Toxic Substances Control Acf? Sections 6 snd B- EPA is compiling information
on the progress of State and local programs to control exposure to asbestos — containing materials in schools* This form should be used
to periodically report information concerning the asbestos control activities in your school district. Tu obtain more form's, call this
toll — free number: 800— 424— Q0f>5 or in the Washington, D.C, area, t all 55-? — 1404, Data collected in this survey will be subject to the
provisions of the Freedom of Information Act ( 5 U.S.C. .55-.').
MAILING INSTRUCTIONS
MAIL ONE COPY TO: The EPA Regional Asbestos Coordinator
for your Region. ("For ntimi-s ^nrf uddrfUfKuK
see rever.se s-icfe.)
1 SCHOOL DISTRICT INFORMATION
MA ML OF SCHOOL DISTRICT
CITY OR CQU N TV
G T A t t: Z I P C 6 L- 1
ALSO, please mail a copy to your official State asbestos program
conUict ^for nanir and Qdcffe.v.s, r£J// this toll — /rc*e ntimhct; SQ(J—
4J4—VQ65 nr if in the Washington, D.C. area, call 534-1404),
IDENTIFICATION
2. PEFSON TO CONTACT REGARDING THIS REPORT
NAM£ fla&t, Irrsf, & mjtfdle initial)
OFFIC ALJf'B T!TI E
^VtLEPHO-JE ?JG, mm ccj'i*? ^ nu. ihet • OA
. : "-'.--'•
-•.••.
SPECIFIC QUESTIONS
3. Has the school district submitted an EPA Asbestos Survey
Report before?
'•'"'. YES :~;NO fj UNKNOWN
5, As of ..,._. (mo.fyr,), how many schools in the district
have been inspected for the presence of friable asbestos—
containing materials? [NUMBER OF SCHOOLS
I
7. As of , r(mo./yr. oi K.
analysis) for how many schools
in the district was friable ma-
terial analyzed as containing
asbestos'
NUMBER OF SCHOOLS a. NC
4. How many schools in the otis
between 1945 and 1Q78^
^ fnro,, <;svk ^, vp
-------
REGIONAL OFFICES
Region 1
Mr. Paul Heffernan
Asbestos Coordinator
Air & Hazardous Materials Div,
Pest. & Toxic Substances Br.
EPA Region 1
JFK Federal Bidg.
Boston, MA 02203
(617) 223-0585
Region 2
Mr, Marcus Kantz
Asbestos Coordinator
EPA Region II
Room 802
26 Federal Plaza
New York, NY 10007
(212) 264-9538
Region 3
Mr. Fran Dougherty
Asbestos Coordinator
EPA Region III
Curtis Building
Sixth & Walnut Streets
Philadelphia, PA 19106
(215) 597-8683
Region 4
Mr. Dwight Brown
Asbestos Coordinator
EPA Region IV
345 Courtland Street
Atlanta, GA 30308
(404) 881-3864
Region 5
Dr. Lyman Condie
Asbestos Coordinator
EPA Region V
230 S. Dearborn St.
Chicago, IL 60604
(312) 353-2291
Region 6
Dr. Norman Dyer
Asbestos Coordinator
EPA Region VI
First Intemat'1 Bldg.
1201 Elm Street
Dallas, TX 75270
(214) 767-2734
Region 7
Mr. Wolfgang Brandner
Asbestos Coordinator
EPA Region VII
324 East 1I Street
Room 1500
Kansas City, MO 64106
(816) 374-3036
Region 8
Mr. Ralph Larsen
Asbestos Coordinator
EPA Region VIII
1860 Lincoln Street
Denver, CO 80295
(303) 837-3926
Region 9
Mr. John Yim
Asbestos Coordinator
EPA Region IX
215 Fremont Street
San Francisco, CA 94105
(415) 556-3352
Region 10
Ms. Margo Partridge
Asbestos Coordinator
EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-5560
-------
vvEPA
U.S. ENVIRONMENTAL PROTECTION AGENCY
ASBESTOS SURVEY REPORT
(Survey of Activities to Control
b?5tos~~Cont&ining Wfl/err/j/s in School Buildi
Form Approved
OMB No. 15S-R-0165
GENERAL
J
This information is collected under the authority of the Toxic Substances Control Act, Sections 6 and 8. EPA is compiling information
on the progress of State and local programs to control exposure to asbestos—containing materials in schools. This form should be used
to periodically report information concerning the asbestos control activities in your school district. To obtain more forms, call thus
toll—free number: 800—424—9065 or in the Washington, D.C. area, call 554—1404. Data collected in this survey will be subject to the
provisions of the Freedom of Information Act ( 5 U.S.C. 552).
MAILING INSTRUCTIONS
MAIL ONE COPY TO:
The EPA Regional Asbestos Coordinator
for your Region, (For names and address
ALSO, please mail a copy to your official State asbestos proj
contact (for name .**n<^ address, call this toll-.fret* rmm&er; Ht
.(24-9065 or if in the Washington, D.C. area, call S54-1404).
IDENTIFICATION
1 SCHOOL DISTRICT INFORMATION
2, PERSON TO CONTACT REGARDING THIS REPORT
NAME OF SCHOOL DISTRICT
CITV OR COUNTV
JOB TITLE
EP'HON'ir'N'O. fareyV cofcfe
DATE (mo
SPECIFIC QUESTIONS
3. Has the school district submitted an EPA Asbestos Survey
Report before3
I YES
'• NO
I!UNKNOWN
4, How many schools in the district were built or renovated
between 1945 and 1978?
NUMBER OF TciToOLS~" ~~~~ — — — — — — — _ _
5. As of
_(mo,/yr.), how many schools in the district
have been inspected for the presence of friable asbestos—
containing materials' CN-M-E-0-
6, How many schools had bulk samples analyzed for asbestos wish
the EPA recommended technique of Polarized Light Microscopy
NUMBER or SCHOOLS
7. As of_
.fmo./yr, of
Cor how many schools
in the district was friable ma-
terial analyzed as containing
asbestos?
8. (a) In how many schools was friable asbestos—containing material determined to present
an exposure problem*
(b) Approximately how many square f«?et of this material were found?
(c) Estimate the number of children per school year exposed to this material. fWu/fjp/v
rhe percenf of children exposed by the total number ol" enroll>*,-1 students, e.g., An
exposure problem in five classrooms may involve 15% of the total population of 700
students; 15% x 700 equals 105 students exposed.)
(d) Have the names of the children been recorded and retained for future reference'
NUMBER OF SCHOOLS
a. NO. OF SCHOOLS
b, SOU APE FEFT
C. NO, OF CHILDREN
d. NAMES RECORDED
"i YES "\ HO
Questions 9 through 11 refer to the friable asbestos—containing material that presents an exposure problem tn Question
10. (a) Approximately how many square feet of this material have
been or will be encapsulated?
(b) What is the estimated total cost of encapsulation5
9. (a) Approximately how many square feet of this material have
been or will be removed?
(b) What is the estimated total cost of removal?
a. SQUARE FEET
b.
COST: S
a. SQUAPE FEET
COST: S
1 1. (a) Approximately how many square feet of this material
been or will be enclosed^
(b) What, is the estimated lota! cost of enclosure?
12. (a) For approximately how many square feet of asbestos-
containing material was action deferred?
(b) Will this material be inspected periodically to de-
termine if an exposure problem exists?
a. SQUARE FEET
T
a. SQUARE FEET
COST: $
b. PERIODIC INSPECTION
n
13. What is the source of funding for the asbestos control
activities in your district?
14, When did for wilt} the asbestos control activities in the
district begin and end?
FUNDING SOURCE
BEGINNING YEAS
ENDING YEAR
COMMENTS
EPA Form 7710-29 (3-79)
31
-------
REGIONAL OFFICES
Region 1
Mr. Paul Heffernan
Asbestos Coordinator
Air & Hazardous Materials Div,
Pest, & Toxic Substances Br.
EPA Region I
JFK Federal Bldg.
Boston, MA 02203
(617) 223-0585
Region 2
Mr. Marcus Kant/
Asbestos Coordinator
EPA Region II
Room 802
26 Federal Plaza
New York, NY 10007
(212) 264-9538
Region 3
Mr. Fran Dougherty
Asbestos Coordinator
EPA Region III
Curtis Building
Sixth & Walnut Streets
Philadelphia, PA 19106
(215) 597-8683
Region 4
Mr. Dwight Brown
Asbestos Coordinator
EpA Region IV
345 Courtland Street
Atlanta, GA 30308
(404) 881-3864
Region 5
Dr. Lyman Condie
Asbestos Coordinator
EPA Region V
230 S, Dearborn St.
Chicago, IL 60604
(312) 353-2291
Region 6
Dr. Norman Dyer
Asbestos Coordinator
EPA Region VI
First internal! Bldg.
1201 Elm Street
Dallas, TX 75270
(214) 767-2734
Region 7
Mr. Wolfgang Brandner
Asbestos Coordinator
EPA Region VII
324 East 11 Street
Room 1500
Kansas City, MO 64106
(816) 374-3036
Region 8
Mr. Ralph Larsen
Asbestos Coordinator
EPA Region VIII
I860 Lincoln Street
Denver, CO 80295
(303) 837-3926
Region 9
Mr. John Yim
Asbestos Coordinator
EPA Region IX
215 Fremont Street
San Francisco. CA 941(15
(415) 556-3352
Region 10
Ms. Margo Partridge
Asbestos Coordinator
EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-5560
-------
Chapter 11: Assistance From Federal and State
Agencies
The EPA Regional Asbestos Coordinators will
coordinate the EPA school asbestos program with the
States in their Regions. The other Federal agencies
participating in the program will provide assistance to
the States on matters of worker protection, contractor
training, and safety and health. Several toll-free
numbers will be operated by EPA and the Consumer
Product Safety Commission. The numbers are listed in
this chapter and in Appendix G,
Assistance From EPA
The EPA Regional Asbestos Coordinators can provide
information and assistance to the States. The
Coordinators are listed in this chapter. They will be
available to meet with State and local officials to discuss
the asbestos material problem and to answer questions
about the EPA school asbestos program.
A videotape supplementing the information contained
in this manual will be available to schools from the
EPA Regional Offices. The videotape will show how to
inspect schools and how to sample friable material, and
will also show removal, encapsulation, and enclosure
operations. The EPA Regional Asbestos Coordinators
should be contacted for copies of the videotape.
As part of the school asbestos program EPA will
conduct training sessions in the Regional Offices for
State and local officials and other interested individuals
and provide technical assistance to schools and their
contractors who undertake corrective actions. The
Regional Asbestos Coordinators should be contacted
for information on scheduling of training sessions and
the technical assistance program.
EPA Regional Asbestos
Coordinators
The following persons are the Regional Asbestos
Coordinators in each of the ten EPA Regional Offices.
The map on this page shows which States are in each of
the ten Regions.
REGIONAL OFFICES
Region 1
Mr. Paul Heffernan
Asbestos Coordinator
Air & Hazardous Materials Div.
Pest. & Toxic Substances Br.
EPA Region I
JFK Federal Bldg.
Boston, MA 02203
(617) 223-0585
Region 2
Mr. Marcus Kantz
Asbestos Coordinator
EPA Region II
Room 802
26 Federal Plaza
New York, NY 10007
(212) 264-9538
Region 3
Mr. Fran Dougherty
Asbestos Coordinator
EPA Region III
Curtis Building
Sixth and Walnut Streets
Philadelphia, PA 19106
(215) 597-8683
Region 4
Mr. Dwight Brown
Asbestos Coordinator
EPA Region IV
345 Courtland Street
Atlanta, GA 30308
(404) 881-3864
Region 5
Dr. Lyman Condie
Asbestos Coordinator
EPA Region V
230 South Dearborn Street
Chicago, IL 60604
(312) 353-2291
Toll-free numbers
Illinois: 800-972-3170
Indiana, Michigan,
Minnesota, Ohio
Wisconsin: 800-621-3191
Region 6
Dr. Norman Dyer
Asbestos Coordinator
EPA Region VI
First Internationa] Bldg.
1201 Elm Street
Dallas, TX 75270
(214) 767-2734
Region 7
Mr. Wolfgang Brandner
Asbestos Coordinator
EPA Region VII
324 East llth Street
Room 1500
Kansas City, MO 64106
(816) 374-3036
Toll-Free Action Line
(Leave name and number
ask to have your call
returned)
Missouri: 800-892-3837
Iowa, Nebraska, Kansas:
800-821-3714
33
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Region 8
Mr. Ralph Larsen
Asbestos Coordinator
EPA Region VIII
1860 Lincoln Street
Denver, CO 80295
(303) 837-3926
Region 9
Mr. John Yim
Asbestos Coordinator
EPA Region IX
215 Fremont Street
San Francisco, CA 94105
(415) 556-3352
Region 10
Ms. Margo Partridge
Asbestos Coordinator
EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-5560
EPA Toil-Free Numbers
Copies of the guidance package, additional survey
forms, or other information on the EPA school
asbestos program is available by calling:
800-424-9065
(in the Washington. D.C. area: 554-1404)
Information on sampling and analysis is available by
calling:
800-334-8571, extension 6892
Assistance From State Asbestos
Program Contacts
Many States have programs or are developing programs
to control asbestos materials in schools and other
buildings. The names of persons who have been
designated by the Governors as the Asbestos Program
contact for each State are available on the EPA toll-
free information number. The Regional Asbestos
Coordinators can also be contacted for the names of
the State Asbestos Program Agencies,
School officials should check with their State Agency
before beginning a school asbestos control program.
Some States may already have an asbestos program and
will want schools to follow certain procedures for
inspecting, sampling and analysis, and taking corrective
actions.
Assistance From Other Federal
Agencies
Other Federal agencies can provide assistance to
schools which have questions about consumer products
containing asbestos and matters of occupational safety
and health.
(1) Consumer Product Safety Commission
The U.S. Consumer Product Safety Commission
(CPSC) operates a toll-free information number. School
districts with questions about consumer products that
contain asbestos can call:
800-638-8326
(in Alaska, Hawaii, Puerto Rico, Virgin Islands:
800-638-8333)
(in Maryland: 800-492-8363)
(2) Occupational Safety and Health Administration
The Occupational Safety and Health Administration
(OSHA) has regulations covering safe workplace
practices that must be followed during removal,
encapsulation, and enclosure of asbestos materials.
These regulations are summarized in Chapter 9 and art
printed in Appendix C.
Some States have assumed responsibility for
development and enforcement of their own
occupational safety and health standards following
approval from OSHA, A complete list of the approved
State Program Offices and Federal OSHA field
locations is included as Appendix D. Questions about
proper worker protection and respirator requirements
should be referred to the appropriate State Program
Office or Federal OSHA Offices listed in Appendix D.
To assist small business employers in meeting the
requirements of the Occupational Safety and Health
Act of 1970 Congress has authorized a joint federal
OSHA-State on-site consultation program. For
information on this free consulting service, employers
should contact the nearest State or Federal OSHA
Office listed in Appendix D.
(3) Department of Health, Education and Welfare
(DHEW)
A .National Institute for Occupational Safety and Health
The National Institute for Occupational Safety and
Health (NIOSH) can provide assistance on selection of
approved respirators and answer questions on
occupational safety and health. The NIOSH Regional
Consultants are listed in Appendix E,
B. Regional Health Administration
The Regional Health Administrators listed in
Appendix F can provide information on the health
problems associated with asbestos exposure.
34
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Appendix A: U.S. Environmental
Agency Regulations for
(Code of Federal Regulations Title 40, Part 61, Subparts A and B)
PART 61— NATIONAL EMISSION STAND-
ARDS FOR HAZARDOUS AIR POLLUTANTS
Subpirt A— Central Provliloni
See,
81 01 Applicability.
Ei 02 Definitions.
8! .",3 Abbreviation*.
81,04 Addreao-
«.OS Prohibited actlvtttea.
Bl.OS Determination of construction or
modification.
81.07 Application for approval of construc-
tion or modification.
61.08 Approval by Administrator*.
81 .09 Notification of startup.
•1.10 Source reporting and W&ITBT requeot-
91.lt WaUer of compliance,
01.13 Emission tests and monitoring.
61.13 Waiver of emission tests
81.14 Source test and analytic*! methods.
61.15 A v a U abll 1 ty of information.
61. 18 State authority.
61.17 Circumvention.
Subp»rl B — NabonBl Emlnlon Standard for
61.20 Applicability.
01 Jl Definitions.
81.22 Emission standard.
61.23 Alr-cleanlng-
BeportLng.
Wast* disposal Bites,
rT: Section 112 of the Cleaa Air
Act as added by sec, 4 "Administrator" means the Ad-
ministrator of the Environmental Pro-
tection Agency or bis authorized repre-
sentative.
(c) "Alternative method" means any
method of sampling and analyzing for
an air pollutant which Is not a reference
method or an equivalent method but
which has been demonstrated to the
Administrator's satisfaction to produce.
in specific cases, results adequate for
his determination of compliance.
(d) "Commenced" means that an own-
er or operator has undertaken a con-
tinuous program of construction or
modification or that an owner or operator
has entered Into a contractual obligation
to undertake and complete, within a rea-
sonable time, a continuous program of
construction or modification.
(e) "Compliance schedule" means the
date or dates by which a source or cate-
gory of sources Is required to comply with
the standards of this part and with any
Steps toward such compliance which are
set forth In a waiver of compliance under
161.11.
(f) "Construction" means fabrication.
erection, or Installation of a stationary
source.
(g> "Effective date" la the date of
promulgation In the FEDERAL RSGISTER
of an applicable standard or other regu-
lation under this part.
(h) "Equivalent method" means any
method of sampling and analyzing for
&n a!r pollutant which has been demon-
strated to the Administrator's satisfac-
tion to have a consistent and quantita-
tively known relationship to the reference
method, under specified conditions.
(I) "Existing source" means any sta-
tionary source which Is not a new source.
(j) "Modification" means any physical
change In, or change In the method of
operation of, a stationary source which
Increases the amount of any hazardous
air pollutant emitted by such source or
which results In the emission of any
hazardous air pollutant not previously
emitted, except that:
(1) Routine maintenance, repair, and
replacement shall not be considered
physical changes, and
(2) The following shall not be con-
sidered a change in the method of
operation:
fl) An Increase In the production rate.
If such Increase does not exceed the op-
erating design capacity of the stationary
source;
(U' An Increase In hours of operation.
(k) "New source" means any stationary
lource, the construction or modification
of which Is commenced after the publi-
cation In the FEDERAL RieisTza of pro-
posed national emission standards for
hazardous air pollutants which will be
applicable to such source.
0) "Owner or operator" means any
person who owns, leases, operates, con-
trols, or supervises a stationary source.
(m) "Reference method" means any
method of sampling and analyzing for an
air pollutant, as described in Appendix
B to this part.
(n) "Startup" means the setting in
operation of a stationary source for any
purpose.
(o) "Standard" means a national
emission standard for a Hazardous air
pollutant proposed or promulgated under
this part.
-------
in—Inch.
1—Liter,
ml—Milliliter,
M—Molar.
m1—Cubic meter,
run—Nanometer.
oz~Ounces.
v/v—Volume per volume.
yd'—Square yards.
w.g.—Water gage.
InHg—Inches of mercury.
InH-O—Inches of water,
g—Grams.
m g—Mil 11 gr ams.
N—Normal.
*E—Degree Ranking.
min—Minute
sec—Second.
avg.—Average.
I.D.—Inside diameter,
O.D.—Outside diameter,
p.%—Mlcrograms (10"°gram).
%—Percent.
Hg—Mercury.
Be—Beryllium.
§ 61.04 Address.
(a) All requests, reports, application*.
submittals. and other communications to
the Administrator pursuant to this part
shall be submitted In duplicate and ad-
dressed to the appropriate Regional Of-
f.ce of the Environmental Protection
Agency, to the attention of the Director,
Enforcement Division. The regional of-
fices are as follows:
Region I (Connecticut, Maine. New Hamp-
shire. Massachusetts, Rhode Island, Ver-
mont), John P. Kencedy Federal Building,
Boston, Massachusetts 02203.
Region II (New York, New Jersey, Puerto
Rico, Virgin Islands), Federal OSes Build-
Ing, 28 Federal Plaza (Foiey Square), New
Tork, N.Y. 10007.
Region in (Delaware. District of Columbia,
Pennsylvania, Maryland, Vlrglc'.i, West Vir-
ginia), Curtis Building. Sixth and Walnut
Streets, Philadelphia, Pennsylvania 19108.
Region TV (Alabama, Florida, Georgia, Mis-
sissippi. Kentucky, North Carolina, South
Carolina, Tennessee), Suite 300. 1421 Peach-
tre* Street, Atlanta, Georgia 30309.
Region V (Illinois, Indiana, Minnesota,
Michigan, Ohio, Wisconsin), 230 South Dear-
born Street. Chicago, Illinois 60604.
Region VI (Arkansas. Louisiana, New
Mexico, Oklahoma, Texas), 1600 Patterson
Street, Dallas, Texas 75201.
Region VII (Iowa. Kansas, Missouri, Ne-
braska) . 1735 Baltlmora Street, Kansas City,
Missouri 03108.
Region VXn (Colorado, Mantua. North Da-
kota, South Dakota, Utah, Wyoming), 188
Lincoln Towers, 1860 Llneola Street, Denver,
Colorado 80203.
Hegloa IX (Arizona. California, Hawaii.
Nevada, Guam, American Satr.oa). 100 Cali-
fornia Street. San Francisco, California 94111.
Region X (Washington, Oregon, Idaho,
Alaska), J200 Sixth Avenue, Seattle. Wash-
ington aaioi.
r.o. CA 03702.
HumboUl: County Air Pollution Control
District. 5600 S. Broadway. Eureka, CA 95501.
Kern Countj- Air Pollution Control Dis-
trict, 17CO Flo-.ver Street (P.O. Box 097)"
BakersSeld. CA 93362,
Madera Cour.'." Air Pollution Control Dis-
trict. 135 W. Ycseinite Avenue, Madera, CA
93637.
Mendecirso County Air Pollution Centre!
District. Count*.- Courthouse. Uklah, CA
95482.
Monterey Bay Unified Air Pollution Con-
trol District, 420 Church Street (P.O. Bos
487). Salinas, CA 93001.
Northern Sonoma County Air Pollution
Control District, 33!3 Chan;ite Road, Santa
Rosa, CA 95404
Sacrirr.er.to County Air Pollution Control
District. 3701 Brunch Center Road, Sacra-
mento. CA 9582T.
San Diego County Air Pollution Control
District. 9150 Chesapeake Drive. San Diego.
CA 92123.
San Jo&quln County Air Pollution Control
District. 1611 E, Hn/elton Street (P.O. Bo*
2009), Stockton. CA 93201,
Santa Barbara Air Pollution Control Dis-
trict. 4440 Calle Seal. Saata Barbara CA
93110.
StanlsTius Count'.- Atr PolluM-in Control
District. 820 Scenic Drive, Motl*«:o. CA W>35n.
Trinltv Coun:v Air PolIutLin Central Dis-
trict. Bo>; AJ, Weavervllle. CA 9J093.
Ventura Cou:;tv Air Pollution Contra! Dis-
trict. G25 E S?.r.;a Ciara Street. Wntura. CA.
93001.
(G> State of Colorado. Colorado Air Pol-
hi (ton Control Division. 4310 Fast llth Ave-
nue. Denver. Colorado 80220.
(HI State of Connecticut. Department
of Environmental Protection. State oace
Building. Hartford, Connecticut 08115.
(I)-(K) (Reserved)
(L) State of Georgia. Environmental Pro-
tection Division. Department of Natural Re-
sources. 270 Washington Street, S.W.. At-
lanta. G?or0a 3033-1.
(M|-(Oi | Reserved |
(P) State of Indiana, Indiana Air Pollu-
tion Control Board. 1330 West Michigan
Street, Indianapolis. Indiana 46206.
(Q)-(T| [Reserved!
(TJ) State of Maine. Department ot En-
vironmental Protection. State House. Au-
gusta. Maine 04330.
(V) [Reserved)
(W) Massachusetts Department of Envi-
ronmental Quality Engineering. Division of
Air QaaU-y Control. 600 Washington Street.
Boston. Massachusetts 0211!.
(X) State of Michigan. Air Pollution Con-
trol Dlrfslor, Michigan Department of Natu-
ral Resources. Stevens T. Mason Building.
8th Floor. Lansing. Michigan 48926.
(Vl-(Z) (Reserved]
(AA)-(DDI | Reserved |
(BE) New Hampshire Air Pollution Con-
trol Agency. Department of Health and wel-
fare. State Laboratory Building, Hazen Drive,
Concord, New Hampshire 03301.
tFF)-(GG) [Reserved)
(HH) New York: New York State Depart-
ment of Environmental Conservation, 50 Wolf
Road, Albany, New York 12233, attention:
Division of Air Resources,
(II) North Carolina Environmental Man-
agement Commission, Department of Natural
and Economic Resources. Division of Envi-
ronmental Management. P.O. Box 27637. Ra-
leigh. North Carolina 27611. Attention; Air
Quality Section.
(JJ) State of North Dakota, State De-
partment of Health, State Capitol, Bismarck,
North Dakota 58501.
{KK)-(LL) [Reserved!
(MM) State of Oregon, Department of
Environmental Quality. 1234 SW Morrison
Street. Portland. Oregon 87205.
(KN)(a) Commonwealth of Pennsylvania
(except for City of Philadelphia and AV;-
gheny County) Pennsylvania Department of
Environmental Resources, Bureau of Atr
Quality and Noise Control, Post OfSce Box
2063, Harrisburg, Pennsylvania 17120.
(b) City of Philadelphia. Philadelphia De-
partment of Public Health Air Management
Services, 801 Arch Street. Philadelphia, Penn-
sylvania 19107.
(OO) [Reserved]
(PP) State of South Carolina. Off.ce of En-
vironmental Quality Control. Department
of Health and Environmental Control, 2600
Bull Street, Columbia. South Carolina 292n|.
(QQ)-(TT) [Reserved]
(UU) State of Vermont. Agency of Envi-
ronmental Protection, Box 480. Mon'pelier.
Vermont 05602,
(W) Commonwealth of Virginia, Vlrg'.cia
State Air Pollution Control Board. Room
1106, Ninth Street Office Building. Richmond.
Virginia 23219.
(WW) (t) Washington: State of Washing-
ton, Department of Ecology, Olynspla, Wash-
ington 98504.
(11) Northwest Air Pollution Authority,
207 Pioneer Building. Second and Pi a*
Streets. Mount Vemoa. Washington £-8273
(111) Pxtget Sound Air Pollution Control
Agency. 410 West Harrison Street. Seattle,
Washington 98119.
(tv) Spokane County Air Pollution Coa-
trol Authority, North 811 Jefferson, Spokane,
Washington 99201.
(v) Yaklrna County Clean Air Authority,
County Courthouse, Takima. Washington
98901.
(vl) Olympic Air Pollution Control Au-
thority. 120 East State Avenue. Olympla,
Washington 98501.
(vtl) Southwest Air Pollution Control Au-
thority. Suite 7601 H. NE Hazel Dell Avenue,
Vancouver. Washington 98665.
36
-------
M;»nds Department of Conserva-.lon ar. 2
Cultural Affair",. P.O. Box 578. Char".•>:••?
Anialle. St. Thomas, U.S. Virgin Iilar.ui
00301.
iSees. 101. 110, HI, 112 and 301 of ;be CT.eaa
Air Act, as amended. 42 U.S.C. 1857, 1837.--
5, 6,7 and 1857g.)
NOTE: For amendments to I 65 0-4 see :i»
List of CFH Sections A.tecied tn bid; el :::.»
volume.
§61.05 Prohibited activities.
(a) After the effective date of azy
standard prescribed under this part, no
owner or operator shall construct or m: c* ibs
act,
(c) Ninety days after the eCeciive dite
of any standard prescribed under This
part, no owner or operator shaH operate
any existing stationary source In vk'.a-
tlon of such standard, except under a
waiver granted by the Adm.ir.Lstra'.c: in
accordance with this subpart or ur,der
an exemption granted by the President
under section I12(c) (2) of the act.
(d) No owner or operator subject to
the provisions of this part shall fall to
report, revise reports, or report scarce
test results as required under this part.
§ 61.06 Determination of construction
or modi firot ion.
Upon written application br an c^T.er
or operator, the Administrator *111 d2ke
a determination of whether actions tsiaa
or Intended to be taken by su:h c—?r
or operator constitute construct!;n or
modification or the commfr.rement
thereof within the meaning of this part.
The Administrator will within 30 days
of receipt of sufficient Information to
evaluate an application, notify the owner
or operator of his determination.
§ 61.01 Application for approval of
construction or modification.
(a) The owner or operator of any new
source to which a standard prescribed
under this part is applicable shall, prior
to the date on which construction or
modification Is planned to commence, or
within 30 days after the effective date
In the case of a new source that already
has commenced construction or modifi-
cation and has not begun operation, sub-
mit to the Administrator an application
for approval of such construction or
modification. A separate application shall
be submitted for each stationary source.
(b) Each application shall include:
(1) The name and address of the ap-
plicant.
(2) The location or proposed location
of the source.
(3) Technical Information describing
the proposed nature, size, design, operat-
ing design capacity, and method of oper-
ation of the source, including a descrip-
tion of any equipment to be used for
control of emissions. Such technical In-
formation shall Include calculations of
emission estimates In sufficient detail to
permit assessment of the validity of such
calculations,
§ 61.08 Approval by Administrator.
(a) The Administrator will, within 60
days of receipt of sufficient Information
to evaluate an application under | 61.07.
notify the owner or operator of approval
or Intention to deny approval of con-
struction or modification.
(b) If the Administrator determines
that a stationary source for which an
application pursuant to I 61.07 was sub-
mitted will, if properly operated, not
cause emissions In violation of a stand-
ard, he will approve the construction or
modification of such source.
(c) Prior to denying any application
for approval of construction or modifica-
tion pursuant to this section, the Admin-
istrator will notify the owner or operator
making such application of the Admin-
istrator's Intention to issue such denial.
together with:
(1) Notice of the information and
findings on which such Intended denial
is based, and
(2) Notice of opportunity for such
owner or operator to present, within such
time limit as the Administrator shall
specify, additional information or argu-
ments to the Administrator prior to final
action on such application.
(d> A final determination to deny any
application for approval will be In writ-
ing and will set forth the specific grounds
on widen such denial is based. Such final
determination will be made within 60
days of presentation of additional infor-
mation or arguments, or 60 days after
the final date specified for presentation.
if no presentation is made.
(e) Neither the submission of an ap-
plication for approval nor the Admin-
istrator's granting of approval to con-
struct or modify shall:
(1) Relieve an owner or operator of
legal responsibility for compliance with
any applicable provision of this part or
of arty other applicable Federal. State.
or local requirement, or
(2) Prevent the Administrator from
Implementing or enforcing this part or
taking any other action under the act.
| (it.09 Notification of startup.
(a) Any owner or operator of a source
which has an initial startup after the
effective date of a standard prescribed
under this part shall furnish the Admin-
istrator written notification as follows:
(1) A notification of the anticipated
date of initial startup of the source not
more than 60 days nor less than 30 days
prior to such date
(2) A notification of the actual date
of Initial startup of the source within 15
days after such date.
§ 61.10 Source reporting nnil waiver rt-
quest.
(a) The corner or operator of any
existing source, or any new source to
which a standard prescribed under this
part is applicable which had an Initial
startup which preceded the effective date
of a standard prescribed under this part
shall, within 90 days after the effective
date, provide the following information
In writing to the Administrator:
(1) Name and address of the owner
or operator.
(2) The location of the source.
(3) The type of hazardous pollutants
emitted by the stationary source.
(4) A brief description of the nature,
size, design, and method of operation of
the stationary source Including the op-
erating design capacity of such source.
Identify each point of emlss'.on for each
hazardous pollutant,
(5) The average weight per month of
the hazardous materials being processed
by the source, over the last 12 months
preceding the date of the report.
(6) A description of the existing con-
trol equipment for each emission point.
(1) Primary control devlce(s) for each
hazardous pollutant.
(11) Secondary control devlcefs) for
each hazardous pollutant.
(Ill) Estimated control efficiency (per-
cent) for each control device.
(7) A statement by the owner or oper-
ator of the source as to whether he can
comply with the standards prescribed in
this part within 90 days of the effective
date.
(b) The owner or operator of an C5dst-
Ing source unable to operate In compli-
ance with any standard prescribed under
this part may request a waiver of com-
pliance with such standard for a period
not exceeding 2 years from the effective
dat«. Any request shall be in writing and
shall Include the following information:
(1) A description of the controls to
be Installed to comply with the standard.
(2) A compliance schedule, Including
the date each step toward compliance will
be reached. Such list shall Include as a
minimum the following dates:
(1) Date by which contracts for emis-
sion control systems or process modifica-
tions will be awarded, or date by which
orders wUl be Issued for the purchase
of component parts to accomplish emis-
sion control or process modification;
(11 > Date of Initiation of onstte con-
37
-------
structlon or installation of emission con-
trol equipment or process change;
(ill) Date by which onslte construc-
tion or installation of emission control
equipment or process modification Is to
be completed; and
(iv) Date by which ftnal compliance Is
to be achieved.
(3) A description of interim emission
control steps which will be taken during
the waiver period.
(c) Changes in the Information pro-
vided under paragraph fa) of this section
shall be provided to the Administrator
within 30 days after such change, except
that if changes will result from modifica-
tion of the source, as defined in § 61.02
(j), the provisions of § 61,07 and § 61.08
are applicable.
(d) The format for reporting under
this section is Included as Appendix A of
this part. Advice on reporting the status
of compliance may be obtained from the
Administrator.
§61.11 Wuivcr of compliance.
(a) Based on the Information provided
In any request under | 61.10, or other in-
formation, the Administrator may grant
a waiver of compliance with a standard
for a period not exceeding 2 years from
the effective date of such standard,
tb) Such waiver will be In writing and
will:
(1) Identify the stationary source
covered.
!2> Specify the termination date of
the waiver. The waiver may be termi-
nated at an earlier dale If Iha conditions
specified under paragraph (b) (3) of this
section are not met.
(3) Specify dates by which steps to-
ward compliance are to be taken; and
^mpos^ such additional conditions as tha
Administrator determines to be neces-
sary to assure installation of the neces-
sary control within the wp.lver period,
and to assure protection of the health
of persons during the waiver period.
and 5 61 42
(b).
fc) The Administrator may, after no-
tice to the owner or operator, withdraw
approval of an alternative method
granted under paragraphs Ca), "Asbestos material" means R5-
bestos or any material containing Sc-
bestos.
(c) "Participate asbestos material"
means finely divided particles of asbestos
material.
id» "Asbestos tailings" means any
solid waste product of asbestos mining or
milling operations which contains as-
bestos.
"Outside air" means the aJr out-
side buildings and structures.
"Visible emissions" means any
emissions which are visually detectable
without the aid of instruments and which
contain particulate asbestos material.
38
-------
(g) "Asbestos mill" means any facility
engaged In the conversion or any Inter-
mediate step In the conversion of asbestos
ore Into commercial asbestos. Outside
storage of asbestos materials Is not con-
sidered a part of such faculty.
(h) "Commercial asbestos" means any
variety of asbestos which Is produced by
extracting asbestos from asbestos ore.
(i) "Manufacturing" means the com-
bining of commercial asbestos, or In the
case of woven friction products the com-
bining of textiles containing commercial
asbestos, with any other material(s). In-
cluding commercial asbestos, and the
processing of this combination Into a
product as specified in § 6L22{c).
(j) "Demolition" means the wrecking
or taking out of any load-supporting
structural member and any related re-
moving or stripping of friable asbestos
materials,
(k) "Friable asbestos material" means
any material that contains more than 1
percent asbestos by weight and that can
be crumbled, pulverized, or reduced to
powder, when dry, by hand pressure.
(I) "Control device asbestos waste"
means any asbestos-containing waste
material that is collected in a pollution
control device,
(m) "Renovation" means the remov-
ing or stripping of friable asbestos ma-
terials used on any pipe, duct, boiler,
tank, reactor, turbine, furnace, or
structural member. Operations to
which load-supporting structural
members are wrecked or taken out are
excluded.
(n) "Planned renovation" means a
jenovation operation, or a number of
such operations, in which the amount.
of friable asbestos material that will be
removed or stripped within a given pe-
riod of time can be predicted. Operations
that are individually non-scheduled s.i2
included, provided a number of such op -
orations can be predicted to occur during
a given period of time based on opera'tiny
experience.
(o) "Emergency renovation" means a
renovation operation that results from a
sudden, unexpected event, and is not a
planned renovation. Operations necessi-
tated by non-routine failures of equip-
ment are included.
(p) "Adequately wetted" means suf-
ficiently mixed or coated with water or
an aqueous solution to prevent dust
emissions.
(q) "Removing" means taking out
friable asbestos materials used on any
pipe, duct, boiler, tank, reactor, tur-
bine, furnace, or structural member
from any building, structure, facility,
or installation,
(r) "Stripping" means taking off fri-
able asbestos materials from any pipe,
duct, boiler, tank, reactor, turbine, fur-
nace, or structural member.
(s) "Fabricating" means any process-
ing of a manufactured product contain-
ing commercial asbestos, with the ex-
ception of processing at temporary sites
for the construction or restoration of
buildings, structures, facilities or instal-
lations.
(t) "Inactive waste disposal site"
means any disposal site or portion
thereof where additional asbestos-con-
taining waste material will not be depos-
ited and where the surface is not dis-
turbed by vehicular traffic.
(u) "Active waste disposal site" means
any disposal site other than an inactive
site.
(v) "Roadways" means surfaces on
which motor vehicles travel including,
but not limited to, highways, roads.
streets, parking: areas, and driveways.
(w) "Asbestos-containing waste mate-
rial" means any waste which contains
commercial asbestos and is generated by
a source subject to the provisions of this
subpart, including asbestos mill tailings,
control device asbestos waste, friable as-
bestos waste material, and bags or con-
tainers that previously contained com-
mercial asbestos.
(x) "Structural member" means any
load-supporting member, such as beams
and load-supporting walls; or any non-
load-supporting member, such as ceilings
and non-load-supporting walls.
(38 FR 8828, Apr. 8, 1973, B3 amended at 39
FE 15398. May 3, 1974; 40 FR 48299, Oct. 14,
1975; 42 FR 12127. Mar. 2. 1977]
§ 61.22 Emission standard.
(a) Asbestos mills: There shall be no
visible emissions to the outside air from
any asbestos mill except as provided In
paragraph (f) of this section.
;b> Roadways: The surfacing of road-
ways with asbestos tailings or with as-
bestos-containing waste that is gener-
ated by any source subject to paragraphs
«^>, (d), (e) or (h) of this section is
prohibited, except for temporary road-
ways on an area of asbestos ore deposits.
The deposition of asbestos tailings or as-
bestos-containing waste on roadways
covered with snow or ice is considered
--urfacing."
(c> Manufacturing; There shall be no
visible emissions to the outside air, ex-
cept as provided in paragraph (f) of this
section, from any of the following op-
erations if they use commercial asbestos
or from any building or structure in
which such operations are conducted.
(1) The manufacture of cloth, cord,
wicks, tubing, tape, twine, rope, thread,
yarn, roving, lap, or other textile ma-
terials.
(2) The manufacture of cement prod-
ucts.
(3) The manufacture of flreprooflng
and insulating materials,
(4) The manufacture of friction
products.
(5) The manufacture of paper, mill-
board, and felt.
(6) The manufacture of floor tile.
<7) The manufacture of paints, coat-
togs, caulks, adheslves, sealants.
(0) The manufacture of plastics and
rubber materials.
(9) The-manufacture of chlorine.
(10) The manufacture of shotgun
shells.
(II) The manufacture of asphalt con-
crete.
(d) Demolition and renovation. The
requirements of this paragraph shall
apply to any owner or operator of a
demolition or renovation operation
who Intends to demolish any institu-
tional, commercial, or Industrial build-
ing (including apartment buildings
having more than four dwelling units),
structure, facility, installation, or por-
tion thereof which contains any pipe,
duct, boiler, tank, reactor, turbine, fur-
nace, or structural member that is cov-
ered or coated with friable asbestos
materials, except as provided in para-
graph (d)(l) of this section; or who in-
tends to renovate any institutional,
commercial, or industrial building,
structure, facility, installation, or por-
tion thereof where more than 80
meters (ca. 260 feet) of pipe covered or
coated with friable asbestos materials
are stripped or removed, or more than
15 square meters, (ca. 160 square feet)
of friable asbestos materials used to
cover or coat any duct, boiler, tank, re-
actor, turbine, furnace, or structural
member are stripped or removed.
(1) (0 The owner or operator of a
demolition operation is exempted from
the requirements of this paragraph:
Provided, (A) The amount of friable
asbestos materials in the building or
portion thereof to be demolished is
less than 80 meters (ca. 2CO feet) used
on pipes, and less than 15 square
meters (ca. 160 square feet) used on
any duct, boiler, tank, reactor, turbine,
furnace, or structural member, and (B)
the notification requirements of para-
graph (dKlKii) are met.
(ii) Written notification shall be
postmarked or delivered to the Admin-
istrator at least 20 days prior to com-
mencement of demolition and shall in-
clude the information required by
paragraph (d/(2) of this section, with
the exception of the infonnation re-
39
-------
quired by paragraphs Written notice of intention to de-
molish or renovate shall be provided to
the Administrator by the owner or opera-
tor of the demolition or renovation oper-
ation. Such notice shall be postmarked
or delivered to the Administrator at least
10 days prior to commencement of demo-
lition, or as early as possible prior to
commencement of emergency demolition
subject to paragraph (d) (6) of this sec-
tion, and as early as possible prior to
commencemer.t of renovation. Such no-
tice shall Include the following informa-
tion:
(i> Name of owner or operator.
fit) Address of owner or operator.
to be em-
ployed.
of this section.
(viii) The name and address or loca-
tion of the waste disposal site where the
friable asbestos waste will be deposited.
-------
a ale asbestos materials that have been
removed or stripped;
(iv) The portion of the st-teture being
demolished that contains friable 'isbe.^-
tos materials shall be adequately wetted
daring the wrecking operation.
(e) Spraying. There shall be no visi-
ble emissions to the outside air from
the spray-on application of materials
containing more than 1 percent asbes-
tos, on a dry weight basis, used on
equipment and machinery, except as
provided in paragraph (f) of this sec-
tion. Materials sprayed on buildings,
structures, structural members, pipes,
and conduits shall contain less than 1
percent asbestos on a dry weight basis,
fl> Sources subject to this paragraph
are exempt from the requirements of
|61.05(a>. S 61.07, and 161.09.
(2) Any owner or operator who in-
tends to spray asbestos materials
which contain more than 1 percent as-
bestos on a dry weight basis on equip-
ment and machinery shall report such
intention to the Administrator at least
20 days prior to the commencement of
the spraying operation. Such report
shall include the following informa-
tion:
(1) Name of owner or operator.
(ii) Address of owner or operator.
(Ill) Location of spraying operation.
f iv) Procedures to be followed to meet
the requirements of this paragraph.
(3) The spray-on application of ma-
terials in which the asbestos fibers are
encapsulated with a bituminous or re-
sinous binder during spraying and
which are not friable after drying is
exempted from the requirements of
paragraphs (e) and (e)<2) of this sec-
tion.
(f) Rather than meet the no-visible-
emission requirements as specified bv
paragraphs ia), (c), td), (e). (h), (j)~,
ar.d (k) of this section, an owner or op-
erator may elect to use the methods spec-
ified by § 61.23 to clean emissions con-
taining participate asbestos material be-
fore such emissions escape to, or are
vented to. the outside air,
(g) Where the presence of uncombined
water Is the sole reason for failure to
meet the no-visible-emission require-
ment of paragraphs fa), , (d). (e),
(h), (j), or (k) of this section, such fail-
ure shall not be a violation of such emis-
sion requirements.
(h) .Fabricating: There shall be no
visible emissions to the outside air, ex-
cept as provided ia paragraph (f) of this
section, from any of the following op-
erations if they use commercial asbestos
or from any building or structure to
which such operations are conducted.
(1) The fabrication of cement building
products.
(2) The fabrication of friction prod-
ucts, except those operations that pri-
marily install asbestos friction materials
on motor vehicles.
(3) The fabrication of cement or sili-
cate board for ventilation hoods; ovens;
electrical panels; laboratory furniture;
bulkheads, partitions and ceilings for
marine construction; and flow control
devices for the molten metal industry.
(i) Insulating: Molded insulating ma-
terials which are friable and wet-applied
Insulating materials which are friable
after drying, installed after the effective
date of these regulations, shall contain
no commercial asbestos. The provisions
of this paragraph do not apply to insu-
lating materials which are spray applied;
such materials are regulated under
661.22(e).
(]) Waste disposal for manufacturing,
fabricating, demolition, renovation and
spraying operations: The owner or op-
erator of any source covered under the
provisions of paragraphs (c), (d), (e),
or (h) of this section shall meet the fol-
lowing standards:
(1) There shall be no visible emissions
to the outside air, except as provided in
paragraph (j)(3) of this section, dur-
ing the collection; processing, including
incineration; packaging; transporting;
or deposition of any asbestos-containing
waste material which is generated by
such source.
(2) All asbestos-containing waste ma-
terial shall be deposited at waste dis-
pos^l sites which are operated in accord-
ance with the provisions of I 61.25.
(3) Rather than meet the requirement
of paragraph (j) (1) of this section, an
owner or operator may elect to use
either of the disposal methods specified
under (j)(3)(i) and (ii) of this section,
or an alternative disposal method which
has received prior approval by the Ad-
ministrator:
(i> Treatment of asbestos-containing
waste material with water:
(A) Control device asbestos waste shall
be thoroughly mixed with water into a
slurry and other asbestos-containing
waste material shall be adequately
wetted. There shall be no visible emis-
sions to the outside air from the collec-
tion, mixing and wetting operations, ex-
cept as provided in paragraph (f) of this
section.
(B) After wetting, all asbestos-con-
taining waste material shall be sealed
Into leak-tight containers while wet. and
such containers shall be deposited at
waste disposal sites which are operated
in accordance with the provisions of
I 61.29.
(C) The containers specified under
paragraph (j) (3) Ci» (B) of this section
shall be labeled with a warning label
that states:
CAUTION
Contains Asbestos
Avoid Opening or Breaking
Breathing Asbestos :s Hazardous
to Sour Health
Alternatively, warning labels specified
by Occupational Safety and Health
Standards of the Department of Labor,
Occupational Safety and Health Admin-
istration (OSHA) under 29 CFR 1910.-
93a(g) (2) (ii) may be used.
(11) Processing of asbestos-containing
waste material Into non-friable forms:
(A) AH asbestos-containing waste
material shall be formed into non-friable
pellets or other shapes and deposited at
waste disposal sites which are operated
in accordance with the provisions of
§ 61.25.
(B) There shall be no visible emis-
sions to the outside air from the collec-
tion and processing of asbestos-
containing waste material, except as
specified in paragraph (f) of this section.
(4) For the purposes of this para-
graph (j), the term all asbestos-con-
taining waste material as applied to
demolition and renovation operations
covered by paragraph (d) of this sec-
tion includes only friable asbestos waste
and control device asbestos waste.
(k) Waste disposal for asbestos mills:
The owner or operator of any source
covered under the provisions of para-
graph Ca) of this section shall meet the
following standard:
(1) There shall be no visible emis-
sions to the outside air, except as pro-
vided in paragraph (k) (3) of this section,
during the collection, processing, pack-
aging, transporting or deposition of
any asbestos-containing waste mate-
rial which is generated by such source.
(2) All asbestos-containing waste ma-
terial shall be deposited at waste
disposal sites which are operated in ac-
cordance with the provisions of § 61.25.
(3) Rather than meet the requirement
of paragraph (k) (1) of this section, an
owner or operator may elect to meet
the following requirements in para-
graphs (k)(3) (1) and (ii), or use an
alternative disposal method which has
received prior approval by the Admin-
istrator :
(I) There shall be no visible emissions
to the outside air from the transfer of
control device asbestos waste to the
tailings conveyor, except as provided in
paragraph (f) of this section. Such waste
shall be subsequently processed either
as specified in paragraph (k) (3) (ii) of
this section or as specified in paragraph
(j)(3) of this section.
(ii) All asbestos-containing waste
material shall be adequately mixed, with
a wetting agent recommended by the
manufacturer of the agent to effectively
wet dust and tailings, prior to deposition
at a waste disposal site. Such agent shall
41
-------
be oed as recommended for the partic-
ular dust by the manufacturer of the
agent. There shall be no discharge of
visible emissions to the outside atr from
the wetting operation except as specified
in paragraph of this section, an
owner may elect to meet the rcqulre-
i.ients of this paragraph or may use an
alternative control method for emissions
from inactive waste disposal sites which
has received prior approval by the
Administrator.
(1) The asbestos-containing wcste
material shall be covered with at least
15 centimeters (ca. 6 Inches) of com-
pacted non-aabestos-containing mate-
rial, and a cover of vegetation shall be
grown and maintained on the area ade-
quate to prevent exposure of the asbes-
tos-containing waste material; or
(li) The asbestos-containing waste
material shall be covered with at least 60
centimeters (ca, 2 feet) of compacted
non-asbestos-containing material and
maintained to prevent exposure of the
asbestos-containing waste; or
(111) For Inactive waste disposal sites
for asbestos tailings, a resinous or petro-
leum-based dust suppression agent which
effectively binds dust and controls wind
erosion shall be applied. Such agent shall
be used as recommended for the partic-
ular asbestos tailings by the dust sup-
pression agent manufacturer. Other
equally effective dust suppression agents
may be used upon prior approval by the
Administrator. For purposes of this para-
graph, waste crankcase oil Is not con-
sidered a dust suppression agent.
(38 FB 8826, Apr. e, 1973. KS amended at 39
PR 15398. May 3, 1974; 40 PR 48299, Oct. 14,
1075J
§ 61.23 Air-dean ing.
If air-cleaning is elected, as permit-
ted by |§61.22(f) and 61.22 A brief description of each process
that generates asbestos-containing waste
material.
(2) The average weight of asbestos-
containing waste material disposed of,
measured in kg/day.
<3> The emission control methods
used in all stages of waste disposal.
(4) The type of disposal site or Incin-
eration site used for ultimate disposal,
the name of the site operator, and the
name and location of the disposal site.
(d) For sources subject to | 61.22(1):
<1) A brief description of the site.
(2) The method or methods used to
comply with the standard, or alternative
prccedures to be used.
Such information shall accom-
pany the information required by f 61.10.
The information described in this section
shall be reported using the format of
Appendix A of this part.
[38 FK E828, Apr. 8. 1973, as emended at
40 FB 483C2, Oct. 14, 1975]
§ 61.25 Waste disposal sites.
In order to be an acceptable site for
disposal of asbestos-containing waste
material under §61.22 (j) and «k), an
active m-aste disposal site shall meet the
requirements of this section.
(a) There shall be no visible emissions
42
-------
to the outside air from any active waste
disposal site where asbestos-containing
waste material has been deposited, except
as provided in paragraph
-------
Appendix B: U.S. Environmental Protection
Agency Regional National Emissions
for Hazardous Air Pollutants (NESHAPS)
REGIONAL OFFICES
Region 1
Marcia Spink
Air & Hazardous Materials Div,
USEPA, Room 1903
JFK Federal Bldg.
Boston, MA 02203
(617) 223-4448
Region 2
Marcus Kantz
Air & Hazardous Materials Div.
USEPA, Room 802
26 Federal Plaza
New York, NY 10007
(212) 264-9538
Region 3
Abraham Ferdis
Enforcement Division
USEPA, Curtis Bldg.
6th and Walnut Sts.
Phila., PA 19106
(215) 597-9401
Region 4
Thomas A, Gibbs
Air & Hazardous Materials Div,
USEPA
345 Courtland St. N.E,
Atlanta, GA 30308
(404) 881-4552
Region 5
Bruce Varner
Enforcement Division
USEPA
230 S. Dearborn St.
Chicago, IL 60604
(312) 353-20B6
Region 6
Martin Brittain
Enforcement Division
USEPA, 1201 Elm Street
First Internal'1 Bldg.
Dallas, TX 75270
(214) 767-2755
Region 7
Peter Culver
Enforcement Division
USEPA
324 East llth St.
Kansas City, MO 64106
(816) 374-2576
Region 8
Clifford Blackwell
Enforcement Division
USEPA
1860 Lincoln St.
Denver, CO
(303) 837-5914
Region 9
Paula Bisson
Enforcement Division
USEPA
215 Fremont Street
San Francisco, CA 94105
(415) 556-3450
Region 10
David Bray
Enforcement Division
USEPA
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-1230
44
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Appendix C: U.S. Department of Labor -
Occupational Safety and Health
(OSHA) Asbestos Regulations
(Code of Federal Regulations Title 29, Part 1910)
Section 1910.1001
(a) Definitions.
For the purpose of this section.
(1) "Asbestos" includes chrysotile, amosite,
crocidolite, tremolite, anthophyllite, and
actinolite.
(2) "Asbestos fibers" means asbestos fibers
longer than 5 micrometers,
(b) Permissible exposure to airborne concen-
trations of asbestos fibers.
(I) Standard effective July 7, 1972. The 8-hour
time-weighted average airborne concentra-
tions of asbestos fibers to which any
employee may be exposed shall not exceed
five fibers, longer than 5 micrometers, per
cubic centimeter of air, as determined by
the method prescribed in paragraph (e) of
this section.
(2) Standard effective July 1, 1976. The 8-hour
time-weighted average airborne concentra-
tions of asbestos fibers to which any
employee may be exposed shall not exceed
two fibers, longer than 5 micrometers, per
cubic centimeter of air, as determined by
the method prescribed in paragraph (e) of
this section.
(3) Ceiling concentration. No employee shall be
exposed at any time to airborne concentra-
tions of asbestos fibers in excess of 10 fibers,
longer than 5 micrometers, per cubic cen-
timeter of air, as determined by the method
prescribed in paragraph (e) of this section.
(c) Methods of compliance.
(I) Engineering methods.
(ij Engineering controls. Engineering con-
trols, such as, but not limited to, isolation,
enclosure, exhaust ventilation, and dust
collection, shall be used to meet the
exposure limits prescribed in paragraph
(b) of this section.
(ii) Local exhaust ventilation.
(a) Local exhaust ventilation and dust
collection systems shall be designed,
constructed, installed, and maintained
in accordance with the American
National Standard Fundamentals
Governing the Design and Operation of
Local Exhaust Systems, ANSI
Z9.2-1971, which is incorporated by
reference herein.
(b) See § 1910.6 concerning the availabil-
ity of ANSI Z9.2-1971, and the mainte-
nance of a historic file in connection
therewith. The address of the American
National Standards Institute is given
in S 1910.100.
(iii) Particular tools. All hand-operated and
power-operated tools which may produce
or release asbestos fibers in excess of the
exposure limits prescribed in paragraph
(b) of this section, such as, but not limited
to, saws, scorers, abrasive wheels, and
drills, shall be provided with local exhaust
ventilation systems in accordance with
subdivision (ii) of this subparagraph.
(2) Work practices.
(i) Wet methods. Insofar as practicable,
asbestos shall be handled, mixed, applied,
removed, cut, scored, or otherwise worked
in a wet state sufficient to prevent the
emission of airborne fibers in excess of
the exposure limits prescribed in para-
graph (b) of this section, unless the use-
fulness of the product would be dimin-
ished thereby.
(ii) Particular products and operations. No
asbestos cement, mortar, coating, grout,
plaster, or similar material containing
asbestos shall be removed from bags, car-
tons, or other containers in which they
are shipped, without being either wetted,
or enclosed, or ventilated so as to prevent
effectively the release of airborne asbes-
tos fibers in excess of the limits prescribed
in paragraph (b) of this section.
45
-------
(iii) Spraying, demolition, or removal.
Employees engaged in the spraying of
asbestos, the removal, or demolition of
pipes, structures, or equipment covered
or insulated with asbestos, and in the
removal or demolition of asbestos insula-
tion or coverings shall be provided with
respiratory equipment in accordance
with paragraph (d)(2)(iii) of this section
and with special clothing in accordance
with paragraph (d){3) of this section.
(d) Personal protective equipment.
(1) Compliance with the exposure limits pre-
scribed by paragraph (b) of this section may
not be achieved by the use of respirators
or shift rotation of employees, except:
(i) During the time period necessary to
install the engineering controls and to
institute the work practices required by
paragraph (c) of this section;
(ii) In work situations in which the
methods prescribed in paragraph (c) of
this section are either technically not
feasible or feasible to an extent insuf-
ficient to reduce the airborne concentra-
tions of asbestos fibers below the limits
prescribed by paragraph (b) of this sec-
tion; or
(iii) In emergencies.
(iv) Where both respirators and personnel
rotation are allowed by subdivisions (i),
(ii), or (iii) of this subparagraph, and both
are practicable, personnel rotation shall
be preferred and used.
(2) Where a respirator is permitted by sub-
paragraph (1) of this paragraph, it shall be
selected from among those approved by the
Bureau of Mines, Department of the
Interior, or the National Institute for Occu-
pational Safety and Health, Department of
Health, Education, and Welfare, under the
provisions of 30 CFR Part 11 (37 F.R. 6244,
Mar. 25, 1972), and shall be used in
accordance with subdivisions (i), (ii), (iii),
and (iv) of this subparagraph.
(i) Air purifying respirators. A reusable or
single use air purifying respirator, or a
respirator described in subdivision (ii) or
{iii) of this subparagraph, shall be used
to reduce the concentrations of airborne
asbestos fibers in the respirator below the
exposure limits prescribed in paragraph
(b) of this section, when the ceiling or the
8-hour tinie.-weighted average airborne
concentrations of asbestos fibers are
reasonably expected to exceed no more
than 10 times those limits.
(ii) Powered air purifying respirators. A full
facepiece powered air purifying
respirator, or a powered air purifying
respirator, or a respirator described in
subdivision (iii) of this subparagraph,
shall be used to reduce the concentrations
of airborne asbestos fibers in the
respirator below the exposure limits pre-
scribed in paragraph (b) of this section,
when the ceiling or the 8-hour time-
weighted average concentrations of
asbestos fibers are reasonably expected
to exceed 10 times, but not 100 times,
those limits.
(iii) Type "C" supplied-air respirators, continuous
flow or pressure-demand class. A type"C"con-
tinuous flow or pressure-demand,
supplied-air respirator shall be used to
reduce the concentrations of airborne
asbestos fibers in the respirator below the
exposure limits prescribed in paragraph
(b) of this section, when the ceiling or the
8-hour time-weighted average airborne
concentrations of asbestos fibers are
reasonably expected to exceed 100 times
those limits,
(jv) Establishment of a respirator program.
(a) The employer shall establish a
respirator program in accordance with
the requirements of the American
National Standard Practices for Res-
piratory Protection, ANSI Z88.2-1969,
which is incorporated by reference
herein,
(b) See § 1910.6 concerning the availabil-
ity of ANSI Z88.2-1969 and the mainte-
nance of an historic file in connection
therewith. The address of the American
National Standards Institute is given
in § 1910.100.
(c) No employee shall be assigned to
tasks requiring the use of respirators
if, based upon his most recent examina-
tion, an examining physician deter-
mines that the employee will be unable
to function normally wearing a
respirator, or that the safety or health
of the employee or other employees will
be impaired by his use of a respirator.
Such employee shall be rotated to
another job or given the opportunity to
transfer to a different position whose
duties he is able to perform with the
-------
same employer, in the same geographi-
cal area and with the same seniority,
status, and rate of pay he had just prior
to such transfer, if such a different posi-
tion is available.
(3) Special clothing: The employer shall pro-
vide, and require the use of, special clothing:,
such as coveralls or similar whole body
clothing, head coverings, gloves, and foot
coverings for any employee exposed to air-
borne concentrations of asbestos fibers,
which exceed the ceiling level prescribed in
paragraph (b) of this section.
(4) Change rooms:
(i) At any fixed place of employment
exposed to airborne concentrations of
asbestos fibers in excess of the exposure
limits prescribed in paragraph (b) of this
section, the employer shall provide
change rooms for employees working reg-
ularly at the place,
(it) Clothes lockers: The employer shall
provide two separate lockers or con-
tainers for each employee, so separated
or isolated as to prevent contamination
of the employee's street clothes from his
work clothes.
(iii) Laundering:
(a) Laundering of asbestos con-
taminated clothing shall be done so as
to prevent the release of airborne asbes-
tos fibers in excess of the exposure limits
prescribed in paragraph (b) of this sec-
tion.
(b) Any employer who gives asbestos-
contaminated clothing to another per-
son for laundering shall inform such
person of the requirement in (a) of this
subdivision to effectively prevent the
release of airborne asbestos fibers in
excess of the exposure limits prescribed
in paragraph (b) of this section.
(c) Contaminated clothing shall be
transported in sealed impermeable
bags, or other closed, impermeable con-
tainers, and labeled in accordance with
paragraph (g) of this section.
(e) Method of measurement.
All determinations of airborne concentra-
tions of asbestos fibers shall be made by the
membrane filter method at 400-450 x (mag-
nification) (4 millimeter objective) with
phase contrast illumination.
(I) Monitoring.
(1) Initial determinations. Within 6 months of
the publication of this section, every
employer shall cause every place of employ-
ment where asbestos fibers are released to
be monitored in such a way as to determine
whether every employee's exposure to
asbestos fibers is below the limits prescribed
in paragraph (b) of this section. If the limits
are exceeded, the employer shall
immediately undertake a compliance pro-
gram in accordance with paragraph (c) of
this section.
(2) Personal monitoring.
(i) Samples shall be collected from within
the breathing zone of the employees, on
membrane filters of 0.8 micrometer poros-
ity mounted in an open-face filter holder.
Samples shall be taken for the determina-
tion of the 8-hour time-weighted average
airborne concentrations and of the ceiling
concentrations of asbestos fibers.
(ii) Sampling frequency and patterns. After the
initial determinations required by sub-
paragraph (1) of this paragraph, samples
shall be of such frequency and pattern
as to represent with reasonable accuracy
the levels of exposure of employees. In
no case shall the sampling be done at
intervals greater then 6 months for
employees whose exposure to asbestos
may reasonably be foreseen to exceed the
limits prescribed by paragraph (b) of this
section.
(3) Environmental monitoring.
(i) Samples shall be collected from areas
of a work environment which are rep-
resentative of the airborne concentra-
tions of asbestos fibers which may reach
the breathing zone of employees. Samples
shall be collected on a membrane filter
of 0.8 micrometer porosity mounted in an
open-face filter holder. Samples shall be
taken for the determination of the 8-hour
time-weighted average airborne concen-
trations and of the ceiling concentrations
of asbestos fibers.
(ii) Sampling frequency and patterns. After the
initial determinations required by sub-
paragraph (1) of this paragraph, samples
shall be of such frequency and pattern
as to represent with reasonable accuracy
the levels of exposure of the employees.
In no case shall sampling be at intervals
greater than 6 months for employees
47
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whose exposures to asbestos may reason-
ably be foreseen to exceed the exposure
limits prescribed in paragraph (b) of this
section,
(4) Employee observation of monitoring. Affected
employees, or their representatives, shall
be given a reasonable opportunity to
observe any monitoring required by this
paragraph and shall have access to the
records thereof.
(g) Caution signs and labels.
(1) Caution signs,
(i) Posting. Caution signs shall be provided
and displayed at each location where air-
borne concentrations of asbestos fibers
may be in excess of Che exposure limits
prescribed in paragraph (b) of this section.
Signs shall be posted at such a distance
from such a location so that an employee
may read the signs and take necessary
protective steps before entering the area
marked by the signs. Signs shall be posted
at all approaches to areas containing
excessive concentrations of airborne
asbestos fibers.
|ii) Sign specification*, The warning signs
required by subdivision (i) of this sub-
paragraph shall conform to the require-
ments of 20" x 14" vertical format signs
specified in § I910.145(d)(4), and to this
subdivision. The signs shall display the
following legend in the lower panel, with
letter sizes, and styles of a visibility at
least equal to that specified in this sub-
division.
Asbestos
Dust Hazard
Legend
ng Dust . . - -
d Protective Equip-
Notation
I" Sans
Serif,
Gothic
or Block.
3it " Sans
Serif,
Gothic
or Block.
14" Gothic.
14" Gothic.
ment.
Do Not Remain In Area Unless %" Gothic.
Your Work Requires It
Breathing Asbestos Dust May Be 14 point
Hazardous To Your Health. Gothic.
Spacing between lines shall be at least
equal to the height of the upper of any
two lines.
(2) Caution labels.
(i) Labeling. Caution labels shall be affixed
to all raw materials, mixtures, scrap,
waste, debris, and other products contain-
ing asbestos fibers, or to their containers,
except that no label is required where
asbestos fibers have been modified by a
bonding agent, coating, binder, or other
material so that during any reasonably
foreseeable use, handling, storage, dis-
posal, processing, or transportation, no
airborne concentrations of asbestos
fibers in excess of the exposure limits pre-
scribed in paragraph (b) of this section
will be released.
(ii) Label specifications. The caution labels
required by subdivision (i) of this sub-
paragraph shall be printed in letters of
sufficient size and contrast as to be read-
ily visible and legible. The label shall
state:
CAUTION
Contains Asbestos Fibers
Avoid Creating Dust
Breathing Asbestos Dust May Cause
Serious Bodily Harm
(h) Housekeeping.
(1) Cleaning. All external surfaces in any
place of employment shall be maintained
free of accumulations of asbestos fibers if,
with their dispersion, there would be an
excessive concentration.
(2) Wa*te disposal. Asbestos waste, scrap,
debris, bags, containers, equipment, and
asbestos-contaminated clothing, consigned
for disposal, which may produce in any
reasonably foreseeable use, handling, stor-
age, processing, disposal, or transportation
airborne concentrations of asbestos fibers
in excess of the exposure limits prescribed
in paragraph (b) of this section shall be col-
lected and disposed of in sealed imperme-
able bags, or other closed, impermeable con-
tainers.
(i) Recordkeeping.
(1) Exposure records. Every employer shall
maintain records of any personal or environ-
mental monitoring required by this section.
Records shall be maintained for a period of at
least 20 years and shall be made available
upon request to the Assistant Secretary of
Labor for Occupational Safety and Health,
the Director of the National Institute for
Occupational Safety and Health, and to au-
thorized representatives of either.
141 F.R, 11504, Mareh 19, 1976,1
48
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(2} Employee access. Every employee and
former employee shall have reasonable
access to any record required to be main-
tained by subparagraph (1) of this para-
graph, which indicates the employee's own
exposure to asbestos fibers,
(3) Employee notification. Any employee found
to have been exposed at any time to airborne
concentrations of asbestos fibers in excess
of the limits prescribed in paragraph (b) of
this section shall be notified in writing of
the exposure as soon as practicable but not
later than 5 days of the finding. The
employee shall also be timely notified of the
corrective action being taken.
(|) Medico! examinations.
(!) General. The employer shall provide or
make available at his cost, medical examina-
tions relative to exposure to asbestos
required by this paragraph.
(2) Pntplacement, The employer shall provide
or make available to each of his employees,
within 30 calendar days following his first
employment in an occupation exposed to air-
borne concentrations of asbestos fibers, a
comprehensive medical examination, which
shall include, as a minimum, a chest roent-
genogram (posterior-anterior 14 x 17
inches), a history to elicit symptomatology
of respiratory disease, and pulmonary func-
tion tests to include forced vital capacity
(FVC) and forced expiratory volume at 1 sec-
ond (PEVi.ii).
(3) Annual examinations. On or before January
31, 1973, and at least annually thereafter,
every employer shall provide, or make avail-
able, comprehensive medical examinations
to each of his employees engaged in occupa-
tions exposed to airborne concentrations of
asbestos fibers. Such annual examination
shall include, as a minimum, a chest roent-
genogram (posterior-anterior 14 x 17
inches), a history to elicit symptomatology
of respiratory disease, and pulmonary func-
tion tests to include forced vital capacity
(FVC) and forced expiratory volume at I sec-
ond (FEVi.o).
(4) Termination of employment. The employer
shall provide, or make available, within 30
calendar days before or after the termina-
tion of employment of any employee
engaged in an occupation exposed to air-
borne concentrations of asbestos fibers, a
comprehensive medical examination which
shall include, as a minimum, a chest roent-
genogram (posterior-anterior 14 x 17
inches), a history to elicit symptomatology
of respiratory disease, and pulmonary func-
tion tests to include forced vital capacity
(FVC) and forced expiratory volume at 1 sec-
ond (FEVi.o).
($) Recent examinations. No medical examina-
tion is required of any employee, if adequate
records show that the employee has been
examined in accordance with this para-
graph within the past 1-year period.
(6) Medical records.
(i) Maintenance. Employers of employees
examined pursuant to this paragraph
shall cause to be maintained complete and
accurate records of all such medical
examinations. Records shall be retained
by employers for at least 20 years.
(ii) Access. The contents of the records of
the medical examinations required by
this paragraph shall be made available,
for inspection and copying, to the
Assistant Secretary of Labor for Occupa-
tional Safety and Health, the Director of
NIOSH, to authorized physicians and
medical consultants of either of them,
and, upon the request of an employee or
former employee, to his physician. Any
physician who conducts a medical exami-
nation required by this paragraph shall
furnish to the employer of the examined
employee all the information specifically
required by this paragraph, and any other
medical information related to occupa-
tional exposure to asbestos fibers.
49
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Appendix D: State Occupational Safety and
Health Program Offices and U.S. Department
of Labor-Occupational Safety and Health
Administration (OSHA) Field Locations
REGIONAL OFFICES
REGION 1
USDOL-OSHA
BOSTON REGIONAL OFFICE
U.S. Department of Labor—OSHA
JFK Federal Building
Room 1804—Government Center
Boston, Massachusetts 02203
(617) 223-6712/3
State Program Offices
Connecticut
Peter A, Riley, Commissioner
Connecticut Department of Labor
200 Folly Brook Boulevard
Wcthersfield, Connecticut 06109
(203) 566-5123
Vermont
Joel Cherington, Commissioner
Department of Labor and Industry
Montpelier, Vermont 05602
(802) 832-2286
USDOL-OSHA Area Offices
John V. Fiatarone. Area Director
U.S. Department of Labor—OSHA
400-2 Tot ten Pond Road—2nd Floor
Walt ham, Massachusetts 02154
(617) 890-1239
Francis R, Amiraull, Area Director
USDOL—OSHA—FB/Rm, 334
55 Pleasant Street
Concord, New Hampshire 03301
(603) 224-1995
Harold R, Smith. Area Director
USDOL—OSHA—MDC Bldg.—2nd
Floor
555 Main Street
Hartford, Connecticut 06103
(203) 244-2294
Linda Anku, Area Director
USDOL—OSHA/Rm. 204
Federal Building and U.S. Post Office
Providence, Rhode Island 029(0
(401) 528-4466
Rudolph Bayerlc Jr., Area Director
U.S. Department of Labor—OSHA
1200 Main Street—Suite 513
Springfield, Massachusetts 01103
(413) 781-2420 Ex!. 522
REGION 2
USDOL-OSHA
NEW YORK REGIONAL OFFICE
Alfred Barden, Regional Administrator
U.S. Department of Labor—OSHA
1515 Broadway (1 Astor Plaza)—Room
3445
New York, New York 10036
(212) 399-5754
Slate Program Offices
Puerto Rico
Carlos S. Quires, Secretary of Labor
Commonwealth of Puerto Rico
414 Barbosa Avenue
San Juan. Puerto Rico 00917
(809) 765-3030
Virgin Islands
Richard Upson. Commissioner of Labor
Government of Virgin Islands
Christiansted/Box 890
St. Croix. Virgin Islands 00820
USDOL-OSHA Area Offices
Nicholas DiArchangel. Area Director
U.S. Department of Labor—OSHA
90 Church Street—Room 1405
New York, New York 10007
(212) 264-9840
Irving Kingsley. Area Director
U.S. Department of Labor—OSHA
185 Montague Street—2nd Floor
Brooklyn. New York 11201
(212) 330-7667
William Dreeland, Area Director
U.S. Department of Labor—OSHA
200 Mamaroneck Avenue—Room 302
White Plains, New York 10601
(914)946-2510
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James Epps, Area Director
U.S. Department of Labor—OSHA
WO Westbury Rd.
Westbury, New York 11590
(516) 334-3344
Howard Edelson, Area Director
U.S. Department of Labor—OSHA
136-21 Roosevelt Avenue—3rd Floor
Flushing, New York 11354
(212) 445-5005
Charles Meistcr. Area Director
U.S. Department of Labor—OSHA
970 Broad Street—Room 1435C
Newark, New Jersey 07102
(201) 645-5930
James Conlon, Area Director
U.S. Department of Labor—OSHA
Building T3/Belle Mead GSA Depot
Belle Mead, New Jersey 08502
(201)359-2777
Harry Ailendorf, Area Director
U.S. Department of Labor—OSHA
2101 Ferry Avenue—Room 403
Camden. New Jersey 08104
(609) 757-5181
Richard Paimieri, Area Director
U.S. Department of Labor—OSHA
2E Blackwell Street
Dover. New Jersey 07801
(201)361-4050
Robert Hallock, Area Director
U.S. Department of Labor—OSHA
377 Route 11, Room 206
Hasbrouck Heights, New- Jersey 07604
(201)288-1700
Francisco Encarnacion-Rosa. Area
Director
U.S. Department of Labor—OSHA
Carlos Chardon—Room 555
Halo Key, Puerto Rico 00918
(809) 753-4457/4072
Chester Whitesidc. Area Director
U.S. Department of Labor—OSHA
100 So. Clinton St.—Room 1267
Syracuse, New York 13202
(315) 423-5188
P. Charles Schwendcr. Area Director
U.S. Department of Labor—OSHA
Clinton Avenue & North Pearl Street-
Room 132
Albany, New York 12207
(518) 472-6085
David Bernard, Area Director
U.S. Department of Labor—OSHA
111 W. Huron Street—Room 1002
Buffalo, New York 14202
(716) 846-4881
Joseph Rufolo, Area Director
U.S. Department of Labor—OSHA
Federal Office Bldg., Room 600
Rochester. New York 14614
(716) 263-6755
REGION 3
USDOL-OSHA
PHILADELPHIA REGIONAL
OFFICE
David H. Rhone, Regional
Administrator
U.S. Department of Labor—OSHA/
Suite 2100
3535 Market Street
Philadelphia, Pennsylvania 19104
(215) 596-1201
State Program Offices
Maryland
Harvey A. Epstein, Commissioner
Department of Licensing and
Regulation
203 E. Baltimore Street
Baltimore, Maryland 21202
(301) 383-2251
Virginia
Robert F. Beard, Jr., Commissioner
Department of Labor and Industry
P.O. Box 12064
Richmond, Virginia 23241
(804) 786-2376
Dr. James B. Kcnley. Commissioner,
State Dept. of Health
ATTN: Dr. Robert Jackson, Deputy
Commissioner
James Madison Building/109 Governor
Street
Richmond, Virginia 23219
(804) 936-4265
Area Offices, District Offices & Field
Stations
Walter E. Wilson. Area Director
U.S. Department of Labor—OSHA
600 Arch Street—Room 4256
Philadelphia, Pennsylvania 19106
(215)597*4955
Charles A. Straw, Area Director
U.S. Department of Labor—OSHA
400 Penn Center Blvd.—Suite 600
Pittsburgh, Pennsylvania 15235
(412)644-2905
Maurice Daly. Area Director
U.S. Department of Labor—OSHA
147 W. 18th Street
Erie, Pennsylvania 16501
{814)453-4351
James W. Stanley, Area Director
U.S. Department of Labor—OSHA
49 N. Progress Avenue/Progress Plaza
Harrisburg, Pennsylvania 17109
(717) 782-3902
Harry Cavuto. Safety Specialist
U.S. Department of Labor—OSHA
802 New Holland Avenue
Lancaster, Pennsylvania 17604
(717) 394-7722
U.S. Department of Labor
OSHA
Armenara Office Center/Suite 470
State College, Pennsylvania 1681)1
(814) 234-6695
Leo Carey, Area Director
U.S. Department of Labor—OSHA,
20 N. Pennsylvania Ave./Room 3107
Wilkes-Barre, Pennsylvania 18701
(717) 826-6538
Lee O'Brian, Safety Specialist
U.S. Department of Labor—OSHA
940 Hamilton Mall
Allentown, Pennsylvania 18101
(215) 434-0181, Ext. 266
Byron R. Chadwick, Area Director
U.S. Department of Labor—OSHA
31 Hopkins Plaza, Rm. 1110
Baltimore, Maryland 21201
(301) 962-2840
Alonzo L. Griffin, Safety Engineer
U.S. Department of Labor—OSHA
844 King Street, Room 3007
Wilmington. Delaware 19801
(303)573-6115
51
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Stanley Elliot, Area Director
U.S. Department of Labor—OSHA
700 Virginia Street, Room 1726
Charleston, West Virginia 25301
(304) 343-6181, Ext. 420/429
James Troy, Safety Specialist
U.S. Department of Labor—OSHA
Chapline & 12th Streets/Room 411
Wheeling, West Virginia 26003
(304) 232-8044
U.S. Department of Labor—OSHA
Federal BIdg. & U.S.P.O.—Rm 317
P.O. Box 1427
Elkins, West Virginia 26241
(304) 636-6224
Warren Wright, Area Director
U.S. Department of Labor—OSHA
Federal Building (P.O. Box 10186)
Room 6226
Richmond, Virginia 23240
(804) 782-2864/5
Farris S. Anderson, Safety Specialist
U.S. Department of Labor—OSHA
3661 Virginia Beach Blvd./Room 111
Norfolk, Virginia 23502
(804) 441-8381
U.S. Department of Labor—OSHA
Falls Church Office Building, Room
107
9(1) S. Washington Street
Falls Church, Virginia 22046
(703) 557-1330
U.S. Department of Labor
OSHA
210 Franklin Road, S.W./Box 2828
Roanoke, Virginia 24011
(703) 982-6342
Gilbert L. Esparza, Area Director
U.S. Department of Labor—OSHA
400 First Street, N.W./Roorn 602
Washington, D.C. 20215
(202) 523-5224/5
REGION 4
USDOL-OSHA
ATLANTA REGIONAL OFFICE
Robert A. Wendell. Regional
Administrator
U.S. Department of Labor—OSI IA
1375 Peachtree Street. N.E.—Suite 587
Atlanta. Georgia 30309
(404) 881-3573
State Program Offices
Kentucky
James R. Yocum. Commissioner
Kentucky Department of Labor
Capitol Plaza Towers—12th Floor
Frankfort, KY 40601
(502) 564-3070
North Carolina
John C. Brooks, Commissioner
North Carolina Department of Labor
11 West Edenton Street/Box 27407
Raleigh. NC 27611
(919) 733-7166
Tennessee
James G. Nccley. Commissioner
ATTN: Robert Taylor/Tennessee Dept.
of Labor
505 Union BIdg./Suite A/2nd Floor
Nashville, Tennessee
(615) 353-2582
South Carolina
Edgar L. McGowan, Commissioner
South Carolina Department of Labor
Box 11329/3600 Forest Drive
Columbia, South Carolina 29211
(803) 758-2851
USDOL-OSHA Area Offices and Field
Stations
Joseph L. Camp, Area Director
USDOL—OSHA/Bldg. 10/Suite 33
La Vista Perimeter Office Park
Tucker, Georgia 30084
(404) 939-8987
G.L. Wyatt, Area Director
U.S. Department of Labor—OSHA
2047 Canyon Road/Todd Mall
Birmingham, Alabama 35216
(205) 822-7100
Laury K. Weaver
U.S. Department of Labor—OSHA
426 Spring Street
Florence, Alabama 35630
(205) 383-0010
Roy M. Hirano
U.S. Department of Labor—OSIIA
1129 Noble Street—Rm MI04/Box 1788
Anniston, Alabama 36201
(205)237-4212
Robert S. Krueger
LJ.S. Department of Labor—OSHA
Suite 103 W. Clinton Building
Huntsville, Alabama 35807
(205) X95-5268
Raymond G, Finney. Area Director
U.S. Department of Labor—OSHA
2711 Middleburg Drive/Suite 102
Columbia, South Carolina 29204
(803) 765-5904
Willie H. Joiner
U.S. Department of Labor—OSHA
334 Meeting Street, Room 312. 6th
Floor
Charleston. South Carolina 29403
(803) 577-2423
Jose Sanchez. Area Director
U.S. Department of Labor—OSHA/
Room 204
3200 E. Oakland Park Boulevard
Fort Lauderdale. Florida 33308
(305) 566-6547
A. dejcan King. Area Director
U.S. Department of Labor—OSHA
Frontage Road East—5760 1-55 N.
Jackson, Mississippi 39211
(601) 969-4606
William Holden
U.S. Department of Labor—OSHA
500 West Main Street
Tupelo, Mississippi 38801
(601) 844-5191
Bruce Hard in
U.S. Department of Labor—OSHA
2301 14th Street/Room 811
Gulfport, Mississippi 39501
(601) 864-7150
William Gordon, Area Director
U.S. Department of Labor—OSHA
2809 Art Museum Drive/Suite 4
Jacksonville, Florida 32207
(904) 791-2895
Robert K. Scarborough
USDOL—OSHA—Box 12212
100 North Palafax Street—Rm B-16
Pensacola. Florida 32581
(904) 438-2543
Howard Gillingham
U.S. Department of Labor—OSHA
1300 Executive Center Drive
Tallahassee. Florida 32301
(904) 877-3215
52
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F. Patrick Flanagan, Area Director
U.S. Department of Labor—OSHA
600 Federal Place/Suite 554-E
Louisville, Kentucky 402(12
(502) 582-6111/2
Edward G. Savage, Area Director
U.S. Department of Labor—OSHA
152 New Street
Macon, Georgia 31201
(912) 746-5143
Charles J. Anderson, Area Director
USDOL—OS H A/Room 600
118 North Royal Street
Mobile, Alabama 36602
(205) 690-2131
Donald Wren
USDOL—OSHA/FB Courthouse
100 W. Troy Street/Room 314
Dothan, Alabama 36303
(205) 794-7158
John Hall
USDOL—OSHA—Aronov Bldg.
474 South Court Street, Room 329
Montgomery, Alabama 36103
(205) 832-7159
Eugene Light, Area Director
U.S. Department of Labor—OSHA
1600 Hayes Street
Suite 302
Nashville, Tennessee 37203
(615) 251-5313
Ouinton Haskins, Area Direetor
U.S. Department of Labor—OSHA
310 New Bern Avenue/Room 406
Raleigh, North Carolina 27601
(919) 755-4770
Richard Dayouh, Area Director
U.S. Department of Labor—OSHA
6605 Abereorn Street/Suite 210A
Savannah, Georgia 31405
(912)354-0733
Harold Monegue, Area Director
U.S. Department of Labor—OSHA
700 Twiggs Street, Rm. 624
Tampa, Florida 33602
(813)228-2821
Thomas Bowles
USDOL/OSHA/Federal Bldg.
80 N. Hughey Street/Room 419
Orlando."Florida 32801
REGION 5
USDOL-OSHA
CHICAGO REGIONAL OFFICE
Ronald McCann, Acting Regional
Administrator
U.S. Department of Labor—OSHA
32nd Floor—Room 3263
230 South Dearborn Street
Chicago, Illinois 60604
(312) 353-2220
State Program Offices
Indiana
William Lunum, Commissioner
Indiana Division of Labor
1013 State Office Building
Indianapolis, Indiana 46204
(317) 633-4473
Michigan
C. Patrick Babcock, Director
Michigan Department of Labor
309 N. Washington, Box 30015
Lansing, Michigan 48909
(517) 373-9600
Maurice S. Reizen, M.D., Director
Michigan Department of Public Health
3500 North Logan Street
Lansing, Michigan 48914
(517) 373-1320
Minnesota
E.I. Malone, Commissioner
Dept. of Labor & Industry
Space Center Bldg.. 5th floor
444 Lafayette Road
St. Paul. Minnesota 55101
(612) 296-2342
L'SDOL-OSHA Area Offices and District
Offices
William E, Funcheon, Jr., Area
Director
U.S. Department of Labor—OSHA
1400 Torre nee Avenue. 2nd Floor
Calumet City, Illinois 60409
(312) 891-3800
Morlev Brick man. Area Director
U.S. Department of Labor—OSHA
6000 W. Touhy Avenue
Niles, Illinois 60648
(312) 631-8200/8535
Ken Bowman, Area Director
U.S. Department of Labor—OSHA
344 Smoke Tree Business Park
North Aurora. Illinois 60542
(312) 896-8700
U.S. Department of Labor—OSHA
Federal Office Building—Room 4028
550 Main Street
Cincinnati, Ohio 45202
(513) 684-2354
Kelly Meyer, Area Director
USDOL/OSHA/Fed. Office Bldg.
1240 East Ninth Street/Room 847
Cleveland, Ohio 44199
(216) 522-3818
Tom Lcvenhagen. Area Director
USDOL/OSHA/Fed. Office Bldg
200 North High Street/Room 634
Columbus, Ohio 43215
(614) 469-5582
J. Fred Kcppler, Area Director
USDOL—OSHA/USPO & Courthouse
46 East Ohio Street/Room 423
Indianapolis, Indiana 46204
(317) 269-7290
Robert Hanna, Area Director
USDOL—OSHA—Clark Bldg.
633 West Wisconsin Avenue/Room 400
Milwaukee, Wisconsin 53203
(414) 224-3315/6
Robert Levand, District Supervisor
U.S. Department of Labor—OSHA
2934 Fish Hatchery Road/Suite 220
Madison, Wisconsin 53713
(608) 252-5388
Vernon Fern, Area Director
U.S. Department of Labor—OSHA
110 South Fourth Street—Room 437
Minneapolis, Minnesota 55401
(612) 725-2571
Frank Memmott, Area Director
U.S. Department of Labor—OSHA
228 N.E. Jefferson—3rd Floor
Peoria, Illinois 61603
(309) 671-7033
Lawrence Olsen, District Supervisor
U.S. Department of Labor—OSHA
305 S. Illinois Street
Belleville, Illinois 62220
(618) 277-5300
-------
Glenn Butler. Area Director
USDOL—OSHA/Federal Office Bklg.
234 North Summit Street/Room 734
Toledo, Ohio 43604
(419) 259-7542
Mary Fulmer. Area Director
U.S." Department of Labor—OSHA
231 West Lafayette. Room 628
Detroit. Michigan 48226
(313) 226-6720
John Lewis, Area Director
U.S. Department of Labor—OSHA
2618 North Ballard Road
Applelon, Wisconsin 54911
(414) 734-4521
U.S. Departmenl of Labor—OSHA
Federal Bldg.—U.S. Courthouse
500 Barstow Street, Rm. B-9
Eau Claire. Wisconsin 54701
(715) 832-9019
REGION 6
USDOL-OSHA
DALLAS REGIONAL OFFICE
Gilbert J. Saulter, Regional
Administrator
U.S. Department of Labor—OSHA
555 Griffin Square Bldg.—Room 602
Dallas. Texas 75202
(214) 767-4731
State Program Offices
New Mexico
Thomas E. Baca
Environmental Improvement Division
Health and Environment Department/
Box 968
Santa Fe, NM 87503
(505) 827-5273
USDOL-OSHA Area Offices, District
Offices and Field Stations
Lloyd A. Warren, Area Director
U.S. Department of Labor—OSHA
1425 W, Pioneer Drive
Irving, Texas 75061
(214) 749-7555
Charles M. Freeman. Area Director
Fort Worth Federal Center/Box 6892
4900 Hemphill Building 24—Room 145
Fort Worth, Texas 76115
(817) 334-5274
Robert B. Simmons, Area Director
USDOL— OSHA/FOB-USPO &
Courthouse
211 W. Ferguson Street/Room 208
Tyler, Texas 75701
(214) 595-1404
James T. Knorpp, Area Director
USDOL—OSHAAVeslern Bank Bldg.
505 Marquette Avenue, N.W./Room
1125
Albuquerque, New Mexico 87102
(505) 766-3411
Herbert M. Kurtz, Area Director
USDOL-—OSHA/Am. Bank Tower
221 W, 6th Street/Suite 310
Austin, Texas 78701
(512) 397-5783
U.S. Departmenl of Labor—OSHA
1015 Jackson Keller Road—Room 215
San Antonio, Texas 78213
(512) 229-5410
James E. Powell, Area Director
U.S. Department of Labor—OSHA
2156 Wooddale Boulevard/Suite 200
Baton Rouge, Louisiana 70806
(504) 923-0718 Ext. 474
U.S. Department of Labor—OSHA
New Federal Office Building—Rm.
8A09
500 Fannin Street
Shreveport, Louisiana 71101
(318) 226-5360
Thomas Curry, Area Director
U.S. Department of Labor—OSHA
S. 77 Sunshine Strip. Suite 9
Harlingen, Texas 78550
(512) 425-6811/12
Harry J. Ahlf, District Supervisor
U.S. Department of Labor—OSHA
811 N. Carancahua Street
Corpus Christ!, Texas 78474
(512) 888-3257
Gerald Baty, Area Director
U.S. Department of Labor—OSHA
2320 La Branch Street. Room 2118
Houston, Texas 77004
(713)226-5431
Mike Shopenn, District Supervisor
USDOL/OSHA/Prof. Bldg.
2900 North Street/Suite 300
Beaumont, Texas 77702
(713) 838-0271 Ext. 258/9
R. Davis Layne, Area Director
U.S. Department of Labor—OSHA
1100 #505 NASA Road I
Houston, Texas 77058
(713) 226-4357
Robert A. Griffin, Area Director
USDOL—OSHA/West Mark Bldg.
4120 West Markham/Suite 212
Little Rock, Arkansas 72205
(501) 378-6291
John K. Parsons, Area Director
U.S. Department of Labor—OSHA—
FOB
1205 Texas Avenue/Rm. 421
Lubbock, Texas 79401
(806) 762-7681
Carlos Gonzales, Senior Compliance
Officer
U.S. Department of Labor—OSHA
1515 Airway Blvd.—-Room 3
El Paso, Texas 79925
(915) 543-7828
Marvin Schierman, Area Director
U.S. Department of Labor—OSHA
546 Carondelet Street—Room 202
New Orleans, Louisiana 70130
(504) 589-2451/2
Dan Cook, Acting Area Director
U.S. Department of Labor—OSHA
717 South Houston, Suite 304
Tulsa, Oklahoma 74127
(918) 581-7676
William W. White, Jr., Area Director
U.S. Department of Labor—OSHA
50 Penn Place—Suite 408
Oklahoma City, Oklahoma 73118
(405) 231-5351
REGION 7
USDOL-OSHA
KANSAS CITY REGIONAL OFFICE
Vernon A. Strahm, Regional
Administrator
U.S. Department of Labor—OSHA
911 Walnut Street—Room 3000
Kansas City, Missouri 64106
(816) 374-5861
54
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State Program Offices
Iowa
Allen J, Meier, Commissioner
Bureau of Labor/State House
East 7th and Court Avenue
Des Moines, Iowa 50319
(513) 281-3606
USDOL-OSHA Area Offices
Robert Borehardt, Area Director
U.S. Department of Labor—OSHA
1150 Grand Avenue—6th Floor
Kansas City, Missouri 64106
(816) 374-2756
Frederick Dempsey. Area Director
U.S. Department of Labor—OSHA
210 Walnut Street—Room 815
Des Moines. Iowa 50309
(515) 284-4794
Carmine A. Barone, Acting Area
Director
U.S. Department of Labor—OSHA
113 West 6th Street—Second Floor
North Platte, Nebraska 69101
(308) 534-9450
Lapsley C. Ewing, Area Director
USDOL—OSHA/Ovcrland—Wolf
Bldg.
6910 Pacific Street/Room 100
Omaha, Nebraska 68106
(402) 221-9341
Bernard D. Olson, Area Director
U.S. Department of Labor—OSHA
210 North 12th Boulevard—Room 520
St. Louis, Missouri 63101
(314) 425-5461
Jeff Spahn. Area Director
U.S. Department of Labor—OSHA
216 North Waco—Suite B
Wichita, Kansas 67202
(316) 267-6311, Ext. 644
RKGION 8
USDOt.-OSHA
DEKVl-fi RfidlOMAL OFFICE
Curtis Foster, Regional Administrator
USDOL. OSHA/FB
Room 1554/1961 Stout Street
Denver. Colorado 80294
(303) S37-3883
State Program Offices
Wyoming
Donald Owsley. Administrator
Occupational Health and Safety
Department
200 East Eighth Avenue/Box 2186
Cheyenne, Wyoming 82002
(307) 777-7786
Utah
Carlylc F, Gronning. Chairman
Utah Industrial Commission
350 East 5th South
Salt Lake City. Utah 84111
(801) 533-4000
I'SDOL-OSHA Area Offices
Harry Hutton, Area Director
USDOL—OSHA/Petroleum Bldg.
2812 1st Avenue North/Suite 525
Billings, Montana 59101
(406) 245-6711 Ext. 6640/9
Donald Kurbink, Acting Area Director
U.S. Department of Labor—OSHA
Russet Bldg./Highway 83 N. Rte 1
Bismarck, North Dakota 58501
(701) 255-4011 Ext. 521
William E, Corrigan, Area Director
U.S. Department of Labor—OSHA
10597 W. 6th Avenue/Office Bldg. "V
Lake wood. Colorado 80215
(303) 234-4471
Ernest Yanni, Acting Area Director
USDOL—OSHA/USPOB/Rm 451
350 South Main Street
Salt Lake City. Utah 84101
(801) 524-5080
Charles Mines. Area Director
U.S. Department of Labor—OSHA
300 North Dakota Avenue/Room 408
Sioux Falls. South Dakota 57102
(605) 336-2980 Ext. 425
REGION 9
USDOL-OSHA
SAN FRANCISCO REGIONAL,
OFFICE
Gabriel Gillotti, Regional
Administrator
USDOL/OSHA/9470 Federal Building
450 Golden Gate Avenue—P.O. Box
36017
San Francisco, California 94102
(415) 556-0586
State Program Offices
Arizona
Donald G. Wiseman, Director
Occupational Safety and Health
Division
Industrial Commission of Arizona/Box
19070
Phoenix, Arizona 85005
(602) 271-5795
California
Donald Vial, Director
Department of Industrial Relations
455 Golden Gate Ave.
San Francisco, CA 94102
(916)445-1935
Hawaii
Joshua C. Agsalud
Director of Labor and Industrial
Relations
825 Mililani Street
Honolulu, Hawaii 96813
(808) 548-3150
Nevada
Ralph Langley, Director
Dept. of Occupational Safety and
Health
Nevada Industrial Commission/515 E.
Musser Street
Carson City, Nevada 89714
(702) 885-5240
55
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USDOL-OSHA Area Offices and Field
Stations
Carrol Burtner, Area Director
U.S. Department of Labor—OSHA
211 Main Street
San Francisco, California 94105
(415) 556-7260
Merle Annis, Safety Specialist
U.S. Department of Labor—OSHA
2110 Merced Street—Room 202
Fresno, California 93721
(209) 487-5454
John Williams. Safety Specialist
U.S. Department of Labor—OSHA
2800 Cottage Way—Room 1409
Sacramento, California 95825
(916) 484-4363
Ivan Schulenburg, Area Director
U.S. Department of Labor—OSHA
1100 East William Street, Suite 222
Carson City, Nevada 89701
(702) 883-1226
Robert B. Boucher, Safety Specialist
USDOL—OSHA/Box 16048
300 Las Vegas Blvd. South—Room 1-
620
Las Vegas, Nevada 89101
(702) 385-6570
Paul Haygood, Area Director
USDOL—OSHA/Box 50072
300 Ala Moana Blvd.—Suite 5122
Honolulu, Hawaii 96805
(808)546-3157
Bernard Tibbetts. Area Director
U.S. Department of Labor—OSHA
400 Oceangate, Suite 530
Long Beach, California 90802
(213) 432-3434
Gilbert Garcia, Area Director
USDOL—OSrWAmerco Towers
2721 North Central Avenue/Suite 300
Phoenix, Arizona 85004
(602) 2614858
Donald Fischer, Safety Specialist
U.S. Department of Labor—OSHA
301 W. Congress Street/Room 3-1
Tucson, Arizona 85701
(602) 792-6286
REGION 10
USDOL-OSHA
SEATTLE REGIONAL OFFICE
James W. Lake, Regional
Administrator
USDOL/OSHA/FOB
909 First Avenue/Room 6048
Seattle, Washington 98174
(206) 442-5930
State Program Offices
Alaska
E. Orbeck, Commissioner
Alaska Department of Labor
Post Office Box 1149
Juneau, Alaska 99801
(907) 465-2700
Oregon
Roy G. Green. Director
Workers Compensation Department
Labor and Industries Building
Salem, Oregon 97310
(503) 378-3302
Washington
Byron Swigart, Acting Director
Department of Labor and Industries
General Administration Bldg., Room
344
Olympia, Washington 98504
(206) 753-6307
USDOL-OSHA Area Offices and Field
Stations
Ronald T. Tsunehara, Acting Area
Director
U.S. Department of Labor—-OSHA
P.O. Box 2915
Anchorage, Alaska 99510
(907) 265-5341
Richard Beeston, Area Director
U.S. Department of Labor—OSHA
121-l07th Street, N.E.
Bellevue, Washington 98004
(206) 442-7520
Richard Jackson, Area Director
U.S. Department of Labor—OSHA/Box
9207
1315 West Idaho Street
Boise, Idaho 83707
(208) 384-1867
U.S. Department of Labor—OSHA
205 North 4th Street
P.O. Box 1549
Coeur D'Alene, Idaho 83814
Clarence Hanson, Safety Specialist
U.S. Department of Labor—OSHA
1618 Idaho Street/Box 1223
Lewiston, Idaho 83501
(208) 743-2589
U.S. Department of Labor—OSHA
Yellowstone Plaza Bldg.. Suite B
475 Yellowstone Avenue
Pocatello, Idaho 83201
(208) 233-6374
Eugene Harrower, Area Director
USDOL—OSHA/Rm. 640
1220 Southwest Third Street
Portland, Oregon 97204
(503) 221-2251
56
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Appendix E: U.S. Department of Health,
Education, and Welfare-National Institute for
Occupational Safety and Health (NIOSH)
Regional Offices
REGIONAL OFFICES
Region i
Wes Straub
Regional Consultant, NIOSH
DHEW, Region I
Gov't Center (JFK Fed. Bldg.)
Boston, Massachusetts 02203
(61?) 223-6668
Region 2
Mary L. Brown, R.N.
Regional Consultant, NIOSH
DHEW, Region II^Fed. Bldg.
26 Federal Plaza
New York, New York 10007
(212) 264-2485
Region 3
William E. Shoemaker
Regional Consultant. NIOSH
DHEW, Region HI
P.O. Box 13716
Philadelphia, Pennsylvania 19101
(215) 596-6716
Region 4
Paul Roper
Regional Consultant, NIOSH
DHEW, Region IV, Div. of
Preventive Health Services,
101 Marietta Tower/Suite 502
Atlanta, Georgia 30303
(404) 221-2396
Region 5
Richard Kramkowski
Regional Consultant, NIOSH
DHEW, Region V
300 South Wacker Drive, 33rd PI.
Chicago, Illinois 60606
(312) 886-3881
Region 6
George L. Pettigrew
Regional Consultant, NIOSH
DHEW, Region VI
1200 Main Tower Bldg., Rm. 1700-A
Dallas, Texas 75202
(214) 767-3916
Region 7
Ralph Bicknell
Regional Consultant, NIOSH
DHEW, Region VII
601 East 12th Street
Kansas City, Missouri 64106
(816) 374-5332
Region 8
Stanley J. Reno
Regional Consultant, NIOSH
DHEW/PHS/PREVENTION—Region
VIII
11037 Federal Building
Denver, Colorado 80294
(303) 837-3979
Region 9
Mel Okawa
Regional Consultant, NIOSH
DHEW, Region IX
50 United Nations Plaza
San Francisco, California 94102
(415) 556-3781
Region 10
Walter E. Ruch, Ph.D.
Regional Consultant, NIOSH
DHEW, Region X
1321 Second Ave. (Arcade Bldg.)
Seattle, Washington 98101
(206) 442-0530
57
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Appendix F: U.S. Department of Health,
Education, and Welfare Regional
Health Administrators
REGIONAL OFFICES
Region 1
Edward J, Montminy
Regional Health Admin.
(Acting)
DHEW, Region I
Gov't Center (JFK Fed. BIdg.
Boston, Massachusetts 1)2203
(617) 223-6827
Region 2
Nicholas H. Galluzzi, M.D.
Regional Health Admin,
DHEW, Region II—Fed. Bldg
26 Federal Plaza
New York, New York 10007
(212) 264-2560
Region 3
H. McDonald Rimple, M.D.
Regional Health Admin.
DHEW, Region III
P.O. Box 13716
Philadelphia, PA 19101
(215) 569-6637
Region 4
George A. Reich, M.D.
Regional Health Admin,
DHEW, Region IV
Suite 107
101 Marietta Tower
Atlanta, GA 30303
(404) 221-2316
Region 5
E. Frank Ellis, M.D.
Regional Health Admin.
DHEW, Region V
300 South Wacker Drive
Chicago, IL 60606
(312) 353-1385
Region 6
Floyd A. Norman, M.D,
Regional Health Admin.
DHEW, Region VI
1200 Main Tower Building
Dallas, Texas 75202
(214) 655-3879
Region 7
Hoiman R. Wherritt, M.D.
Regional Health Admin.
DHEW, Region VII
601 East 12th Street
Kansas City. MO 64106
(816) 374-3291
Region 8
Hilary H, Connor, M.D.
Regional Health Admin.
DHEW, Region VIII
11037 Federal Building
Denver, Colorado 80294
(303) 837-4461
Region 9
Sheridan L, Weinstein. M.D.
Regional Health Admin.
DHEW. Region IX
50 United Nations Plaza
San Francisco, CA 94102
(415) 556-5810
Region 10
David W. Johnson, M.D,
Regional Health Admin,
DHEW, Region X
1321 2nd Ave./Arcade Bldg.
Seattle, WA 98101
(206) 442-0430
Appendix G: Toll-Free Information Numbers
ENVIRONMENTAL PROTECTION AGENCY
The following numbers are 10 he used for general
information on the EPA school asbestos program and to
request additional reporting forms or copies of the guidance
manuals:
XIX j—424-9065
(554-141)4 in Washington, D.C.)
The following number is to be used for technical assistance
in sampling and analysis of asbestos materials;
800—334-8571, extension 6892
CONSUMER PRODUCT SAFETY COMMISSION
The following numbers are to be used for information about
asbestos in consumer products:
800—638-8326
8(K)—492-8363 (Maryland)
800—638-8333 (Alaska, Hawaii.
Puerto Rico. Virgin Islands)
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Appendix H: "Mineral Characterization of
Asbestos-Containing Spray Finishes"
by Arthur N, Rohl1, Arthur M. Langer,1 and Ann G. Wylie
Composition of Insulation
Materials
Asbestos minerals are a common constituent of
sprayed-on materials including 1) fire proofing, thermal
and acoustical insulation and 2) decorative and
textured-spray finishes. In the first category, the
asbestos mineral most commonly used is chrysotile and
less frequently amosite and crocidolite. The three
asbestos minerals may be found singly, or mixed in
varying proportions. The formulations used by spray-
insulation contractors in the United States have varied
considerably depending on cost, availability, purpose
and other factors.
Many insulation materials consist of a mixture of
asbestos and rock wool fibers, the latter usually being
the major constituent. In other formulations non-
fibrous binders such as plaster of Paris, vermiculite,
perlite and clay are used. Wood pulp and paper fibers
are also commonly found,
Decorative and Textured-Spray
Finishes or Paints
Decorative and textured-spray finishes or paints are
frequently sprayed on walls and ceilings of multiple
dwellings, hotels, motels and public buildings. They are
commonly white, brown, gray, or blueish, generally
stuccoed in appearance with a "textured" surface. It
may appear to be fine-grained and compacted, in
contrast to untamped thermal and fireproofing
insulation. Textured-spray finish may be comprised of
mixtures of crystalline filler matcriais, which may
include the following:
I. Rnvironrru:n!al Scienees Laboratory
Department of Community Medicine
Mount Sinai School of Medicine
New York. New York KKI29
2, Department of Cicology
Univcrsilv of Maryland
College Park. Maryland 2(174(1
This manuscript was prepared under N1LHS Grant No. GS7II ft 10 the
Environmental Sciences Laboratory, Mount Sinai School of Medicine.
Carbonate minerals, usually calcite and/or dolomite;
Talc, often containing various concentrations of
tremolite, anthophyllite and serpentine minerals. This
latter mineral group may include chrysolite asbestos;
Fine-grained chrysotile asbestos ("floats'" or "fines"),
may also be added to their formulations. Gray or
brownish colored finishes may contain amosite and
blueish finishes may contain crocidolite. Both
amphibole asbestos varieties may be found together as
well. The total asbestos mineral content may be as high
as 50 percent by weight, in these materials;
Mineral-, rock-, .slag-wool or fibrous glass;
Various clay minerals and micas, such as kaolin,
vermiculite, chlorite, etc.;
Plaster of Paris, gypsum, quartz, organic binders and
thickeners are added to the above inorganic materials
to form a substance which can be trowelled or sprayed
on.
The mineralogical characterization of these asbestos-
containing spray finishes involves analysis of
assemblages which are mixtures of various materials
which never occur together naturally. Analysis of these
complex mixtures is. therefore, hindered in that the
"process of elimination" used to define "difficult
minerals" in natural assemblages, is lost to the analyst.
Methods and Problems of
Analysis
The inorganic constitutents of asbestos-containing
insulation generally are of such large particle size, are
present in sufficient quantities, possess such unique
optical properties, that the use of the petrographic light
microscope as an analytical tool is acceptable and
justified. Yet, one should say at the outset that the
identification of the fibrous minerals in these materials
may be difficult because of a number of confounding
factors. Small particle sizes, changes in retardation
effects (interference colors) in small-sized particles,
difficulties in obtaining clear Becke lines (especially for
thin fibers), and complexity and range in chemical
compositions, often mitigate against the use of the
59
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polarizing microscope. Even in these cases, particles
such as carbonates, fibrous glass, perlite. vermiculite,
etc., may he quite readily identified on the basis of
optical characteristics. Identification of the asbestos
minerals may he difficult largely due to the effect of
fiber size, or, more specifically fiber diameter. Fibers
with diameters of <0.5u.m will almost certainly limit the
usefulness of this technique as a definite identification
method. Yet, some optical properties which can be
determined on larger fibers, may be used to distinguish
between these iruiteruils. These are as follows:
I. To properly characterize spray materials by polarized
light microscopy, the following instrumentation and
accessories are required:
1. A polarizing microscope with a rotating stage and
360° marked scale;
2. The microscope should be equipped for visualization
of objects at magnification in the following range; 35X.
IOOX, 250X, 440X.
3. Standard equipment should include a substage
polarizer, and analyzer, and the following accessories:
rnica plate, gypsurn plate, quartz wedge. (One of us
[AGW] suggests that the quartz wedge is not really
necessary in the study of amphiboles or serpentine
minerals. Their intrinsic birefringence is not high
enough to require the accurate determination of the
order of interference color present. Again, the most
important controlling factor in retardation is size of the
particle.);
4. A set of immersion oils, with indices of refraction in
increments of 0.002, from 1.400 to 1.800;
5, A refractometer, suitable for accurate measurement
of indices of refraction, in the range as stipulated
above. It is suggested that a spindle stage may be
extremely useful in studying fibers which are large
enough to isolate approximately 0.5u.m in diameter.
The technique has recently been described in detail by
Bloss (American Mineralogist, 1978, Vol. 63. page
433).
II. Materials for Which Optical Characteristics Should
be Known:
Optical characteristics should be known for the
different asbestos varieties (ehrysotile, amosite,
crocidolhe), for acicular cleavage fragments of
anthophyllite and tremolite, and for the range of man-
made insulating fibers (fibrous glass, rock-wool.
mineral-wool, slag-wool). We are stressing the
importance of determining the inorganic mineral phases
for which biological potential has been established. In
addition, the complete analysis of these asbestos-
containing materials would require knowledge
concerning the optical characteristics of the more
common mineral components, clay, talc, mica, kaolin,
vermiculite, chlorite, gypsum, bassanite (plaster of
Paris), quartz, etc.
Ill, The Optical Characteristics to be Determined, and
Measured with Accuracy, Should Include the Following:
I. FIBROUS GLASS AND ROCK-WOOL
Form:
Normally forms straight rods, with parallel sides. Ends
of fibers may be fractured or tapered, especially if
fibers are derived from one of the "wool" varieties.
Wools of all varieties may form bulbous ends, blebs,
and "shot". A range of shapes may exist for glassy
components of the wool varieties (see discussion and
figures in McCrone's Particle Atlas). Dimensions of
length and diameter may range considerably; diameters
normally 8-13n,m, "shot" up to 100p.m. Several
varieties of fibrous glass may have diameters down to
< 1p.m. Diameters and length may be highly variable,
even for a fiber population from the same sample.
Color:
These amorphous fibers may be transparent, so that
fibers which lie beneath them are clearly visible.
Occasionally they may be "tinted", commonly brownish
(common in rock, slag, and mineral wools). Colors may
be visible, including yellow, pink, and reddish,
reflecting binders and/or resins (commonly observed on
fibrous glasses).
Birefringence:
These synthetic insulating fibers possess no birefringent
characteristics between crossed nicols. Fibers remain
dark in all orientations between crossed polarizer and
analyzer, indicating their amorphous character (optical
isotropy). Occasionally, a birefringence effect may be
observed on the edges of the glass fibers, attesting to
"strain birefringence; which may occur when the fiber
has been bombarded by particulate debris in the air
stream (as in glass fibers in filters).
Extinction:
No extinction characteristics are observable because of
the isotropic character of the materials.
Indices of Refraction:
There is only one index of refraction, which is the same
for all directions in relation to fiber morphology.
Refractive index may range from 1.53 to 1.62. as
related to the chemistry of the fiber. Most glass fibers
have an index of refraction <1.53, with most slag.
mineral, and rock wool >1.53.
60
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General Remarks:
The fiber form, transparency and lack of birefringence,
are the most characteristic features which distinguish
these man-made inorganic fibers from the asbestos
mineral fibers. No internal structure is visible, as
contrasted with the asbestos fibers which clearly show
the presence of internal fibrils or fiber sub-units.
2. CHRYSOTILE
Form:
Fibers occur as bundles of fibril units. The length: width
ratio usually exceeds 10:1, although short bundles may
be observed. Fibers may consist of "silky", undulating
fibrils which splay at the ends like an "unraveled" rope.
Kink bands may be present along the fibers which are
easily visualized between crossed nicols. Care should be
exercised in labeling blocky serpentine fragments as
chrysotile. Antigoritc fragments, one of the major
constitutents of serpentine, may appear to be composed
of fibers due to the peculiar extinction and growth
characteristics it displays (herring bone growth).
Normally, in spray finishes, only chrysotile fiber is used
in a relatively pure form. Therefore we caution against
the use of these characteristics for the examination of
materials which may come directly from natural
sources, e.g., from rock quarry specimens.
Color:
Chrysotile fibers are normally colorless, but may appear
brownish in specimens derived from sources in which
the fiber was heated (e.g., steam pipes). Although
chrysotile displays no pleochroism, slight changes in
relief on rotation, especially in heated samples may
reflect itself as a "pseudopleochroic" change. This
characteristic is true for all of the birefringent asbestos
fibers, that is, for amosite, crocidolite, tremolite, and
anthophyllite. Occasionally, fibers may be somewhat
coated with organic resins, or a cementitious agent,
which may alter its characteristic color. Large fiber
bundles may contain intergrowths or coatings of opaque
iron oxide (magnetite).
Birefringence:
Chrysotile is birefringent, with thicker fibers showing
straw-yellow first-order colors. Although birefringence
is a crystal-chemical controlled constant, the displayed
colors are thickness dependent and are, therefore,
variable. One should, therefore, consult a standard
retardation color chart, so that one may derive an
estimate of mineral thickness based on observed
retardation color. Therefore, the observed retardation
color is highly variable and related to fiber diameter.
For example, first-order yellow-orange colors may be
seen on large fibers, as well as purple-blue colors.
However, very small fibers may show very slight
retardation, displaying a white-gray first-order effect.
To properly see these fibers between crossed nicols,
conoscopic light should be employed.
Extinction:
Extinction is normally parallel to the fiber length.
However, an "undulatory" extinction may occur,
especially if the fiber is curved and/or kinked. Use of an
accessory plate, when the fiber is turned 45° from its
extinction position, indicates the optical sign of
elongation is positive (length slow).
Indices of Refraction:
Most of the chrysotile used in fireproofing, thermal or
ornamental sprays is from Canada. The index of
refraction of light vibrating parallel to the fiber length
(Nz) is approximately 1.556. with indices increasing
proportionately with iron and nickel content of the
mineral. Some indices have been measured as high as
1.560, but these values are rare for chrysotile. The
birefringence (defined by Nz-Nx) averages about 0.008
for Canadian fibers. Therefore, on thick fibers, the use
of calibrated immersion oils will clearly show
differences in the two vibration directions.
General Remarks:
Chrysotile is by far the asbestos mineral most often
found in insulation materials. The fibers that are most
frequently confused with chrysotile are paper or cotton
fibers (cellulose). Fire retardant (borax) treated
cellulose is commonly used as fireproofing insulation. In
addition, since paper and cotton fibers are commonly
found in dust, casual observation may cause difficulty in
distinguishing between these fibers and chrysotiie.
However, internal structure, extinction characteristics,
and indices of refraction, when carefully measured, will
clearly distinguish between cellulose and chrysotile. In
addition, since cellulose is combustible, this can be used
to distinguish between the two.
3. AMOSITE (ASBESTIFORM GRUNERITE)
Form:
Amosite fibers, unlike single crystals of grunerite, are
composed of microscopic crystals, with the long fiber
axis in common alignment. These parallel crystals have
often been referred to as "fibrils" or "units" which
implies that they represent the smallest particles of
amosite. This is clearly fallacious since both amosite
and crocidolite form particles with fiber dimensions
only 600 angstroms in diameter. By light microscopy
one may clearly observe the "polyfilamentous"
character of the amphibole asbestos varieties, but the
investigator should be cautious in referring to these
features as "fibrils". Normally the fibers are straight
61
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and "splintery" with fewer curves and "kinks" than
observed for chrysotile. The length:width ratio tends to
he greater than chrysotile, with ratios of 10:1 or
greater. When fiber ratios increase up to 50:1 or
greater, curvature may be pronounced.
Color;
Amosite fibers tend to be brownish in most sections,
and may even show suggestions of pleoehroism in
thicker fibers. Again, as with chrysotile, some suggested
change in "color" may be brought about by changes in
relief on rotation of the fiber. Opaque inclusions are
common, and principally consist of iron oxides
commonly associated with the fiber in the banded
ironstone ores.
Birefringence:
Amosite is birefringent, with high second-order colors
commonly observed. Again, this is primarily due to the
thick fibers one commonly encounters in spray
materials. Fibers* with dimensions approaching the
30u,m standard thickness show the more "normal"
retardation effects cited in the literature. Occasionally.
on very thick fibers, the brown color may mask the
interference colors.
Indices of Refraction;
The index of refraction measured parallel to the fiber
axis normally ranges from 1.696 to 1.710 (Nz). The
index of refraction measured across the fiber diameter
varies from the indices anticipated for a single gruncrite
crystal. X-ray diffraction evidence supports the
contention that the crystal units parallel to the fiber axis
are disoriented in the ah plane. Amosite fibers will
therefore not show indices characteristic of the
grunerite mineral. One of us [AGW] suggests that the
two measured indices {parallel and perpendicular to the
fiber axis) be designated NX,, Nz,. This would more
correctly indicate that the disoricntalion of the small
crystals, which constitute the fiber bundle, may form a
"pseudo-indicatrix". Therefore, the indices measured
will be different from those of a "normal" grunerite.
The values observed across the fiber axis will tend to
range around 1.670 to 1.680. It is important to note
that amosite is often contaminated with other
amphiboles. Amosite from the Transvaal, South Africa,
tends to be contaminated with crocidolite. More
commonly, however, actinolite or anthophyllitc fibers
may be observed. This has been the case in
characterizing some standards used in a number of
laboratories for biological purpose (seen by AGW and
AML).
General Remarks:
Amosite is considered to be the asbestiform variety of
grunerite. Optical properties, based on analogues with
grunerite indicates that amosite consists of intergrowths
of disoriented crystallites with only the c-axis in
common alignment. Therefore, the extinction
characteristics, range of refractive indices, and sorption
characteristics, recorded for grunerite, are not identical
for amosite.' Normally, the high range of indices of
refraction, and the brown coloration, and the presence
of sub-unit crystals, indicate a positive identification for
amosite.
4. CROCIDOLITE
Form:
Both crocidolite and amosite fibers tend to be more
straight and "splintery" than chrysotile asbestos. Fiber
composites, making up the fiber bundle, are clearly
visible and fibers with great length: width ratio tend to
curvilinear.
Color;
Thick fibers tend to be blueish or purple-blue in color.
Rotation of the stage shows these colors change in
intensity and hue. Standard color absorption
characteristics are available in optical mineralogy text
books, e.g., Kerr's Optical Mineralogy.2
Birefringence:
Although crocidolite is birefringent, the color of the
mineral is so intense thai the interference color is often
obscured. The differences in the velocities of the
slowest and fastest rays are such that the birefringence
is extraordinarily small so that the color masks most
interference color effects.
Extinction:
Extinction is parallel to the fiber length, indicating the
average effect of the aggregates of crystal composites.
Measurement of sign of elongation indicates that it is
negative, with the fast ray (indicating the smallest index
of refraction) parallel to the fiber length.
Indices of Refraction:
Measurement of the indices of refraction of the
crocidolite shows that most fibers have maximum values
slightly less than those measured for amosite. The
maximum value, measured across the fiber diameter, is
close to 1.700.
General Remarks;
The blue color of crocidolile, the highest index of
refraction, close to 1.700 and its polyfilumcntous
character, are diagnostic for this mineral fiber.
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Crocidolitc is less commonly found in spraycd-on
materials than chrysotile and amosite^ However, the
presence of amositc, should lead the analyst to look
further for crocidolite. as they may occur together.
General Characteristics of Other
Amphiboles
Although anthophyllitc and tremolite are not
incorporated in these mixtures as commercial asbestos
minerals, they may occur as contaminants in talc. One
of the most common constituents of tcxlured-spray
finishes is finely pulverized talc. Whereas amosite and
crocidolite asbestos possess the optical characteristics of
composite fibers, anthophyllitc and tremolite appear,
on the most part, as single crystals, forming acicular
cleavage fragments when comminuted. Acicular
cleavage fragments generally possess optical continuity.
and do not possess splayed ends or internal sub-unit
fibrils. These materials are rectilinear, will tend to show
uniform extinction and possess optical properties
consistent with single crystals (correct extinction angles
will be present, especially true for tremolite acicular
cleavage fragments). Single acicular cleavage fragments,
will show "normal"" amphibole cleavage parallel to
(HO) or (210). Aspect ratios of such cleavage fragments
are generally less than 10:1. Tremolite tends to display
characteristics of single crystals (acicular cleavage
fragments), whereas anthophyllitc appears more often
to be composed of composite fibers. This characteristic
of anthophyllite may be related to both its intcrgrowth
with talc and its intrinsic ashcstiform morphology. The
differences in asbestiform characteristics are more
evident when examining such minerals by transmission
electron microscopy than by optical microscopy.
5. ANTHOPHYLLITE AND TREMOLITE
Form and Color:
Anthophyllite fibers are usually colorless but sometimes
light brown. Some appear to be single crystals whereas
others, generally large fibers, appear to be fiber
composites or bundles. Tremolite is usually colorless or
very pale green color.
Birefringence:
Anthophyllite and tremolite are bircfringcnt with larger
fibers displaying moderate (second-order) interference
colors. Again, the retardation is enhanced because fiber
diameters are commonly in excess of the 30u,m
reference thickness. Most anthophyllite fibers found as
contaminants in "fibrous talcs" tend to be long and thin
and of such a diameter as to preclude the acquisition of
good birefringence characteristics. Tremolite more
commonly occurs as short, wide particles, with
prismatic terminations.
Extinction:
The extinction for anthophyllite is parallel to the fiber
length with a positive elongation (length slow),
Tremolite possesses angular extinction, with maximum
extinction achieved at an angle of 10-15° with the long
cleavage fragment edge. The indices of refraction of
anthophyllite fibers tend to range considerably. Their
values are consistently less (parallel to the fiber length)
than that observed for either amosite or crocidolite.
General Remarks-
It anthophyllite is present with thin fibers of tremolite
there may be difficulties in distinguishing between these
two mineral phases, Acicular cleavage fragments of
tremolite, present as a single crystal rather than
composites, may be distinguished from anthophyllite on
the basis of their angular extinction (about 10-15° with
the fiber edge). If tremolite is composed of
polyfilamentous fibers, then x-ray diffraction may be
used to distinguish between these phases. It is
important to note that the mineral talc may occasionally
occur in fibrous habit. Some talc mines contain large-
proportion of talc fiber. These fibers may be
distinguished from the amphibole fibers on the basis of
indices of refraction and by birefringence. The general
statement may be made that all talc indices of
refraction are less than 1.6(K). whereas the indices of
refraction of amphiboles, commonly associated with
talc, possess indices greater than 1,600.
X-Ray Diffraction Analysis
X-ray diffraction analysis may be required to
differentiate among some of the mineral phases which
may be present in these materials. Using an x-ray
diffraction unit, equipped with an appropriate x-ray
detector, scanning goniometer, suitable x-ray target, an
x-ray pulse discrimination device, suitable data output
equipment, step-scanning Geneva gears, spray materials
may be pulverized by mechanical mills, and prepared
for examination by x-ray powder diffractometry. These
materials may be also examined in the continuous scan
mode of operation at a rate of one degree two theta per
minute. This rapid method may be useful for
determining the presence of amosite, crocidolite. the
serpentine minerals, talc, tremolite, and anthophyllite if
these materials are present in amounts of some 3-5 rY
or more by weight. It should be noted that the
continuous scan x-ray diffraction method is not specific
for chrysotile since reflection for this mineral cannot be
distinguished from those of non-fibrous serpentine
minerals (antigorite, lizardite) nor from kaolin and
some varieties of chlorite and vermiculitc. Also,
asbestiform varieties of the amphiboles cannot be
distinguished from ordinary cleavage fragments of the
same minerals.
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Studies have shown (e.g., Rohl, et.aL, 1976)3 that x-
ray diffraction, using a step-scan mode of analysis, can
be used to detect tremolite and anthophyllite (when
present in a matrix of talc), in amounts as low as 0.1
and 2 percent by weight, respectively. Under most
conditions, serpentine minerals (including chrysolite
asbestos) can be distinguished from kaolin and chlorite
using the same analytical modalities. However, we
stress that the presence of sub-microscopic chrysotiie
fibers must be confirmed by transmission electron
microscopy and selected area electron diffraction, since
x-ray diffraction techniques cannot.
The use of polarized light microscopy, immersion
oils, and standard accessory devices, may be used as a
basic tool characterizing the mineral assemblages of
asbestos-containing spray finishes. X-ray diffractometry
and electron beam techniques may be employed as
ancillary methods as well.
References
1. A.G. Wylie, Proceedings of the New York
Academy of Sciences, Workshop No. 1. Scientific Basis
for the Public Control of Environmental Health
Hazards. June 1978. In press.
2. Paul Kerr, Optical Mineralogy, 4th ed., McGraw
Hill, New York (1977).
3. A.N. Rohl, A.M. Langer, I.J. Seticoff, A. Tordini,
R. Klimentidis, D.R, Bowes and D.L. Skinner,
Consumer Talcums and Powders: Mineral and Chemical
Characterization. J. Tox. Enviro. Health, 2, 255-284
(1976).
64
*U.S. GOVERNMENT PRINTING OFFICE; )'"'!> 391-M,",
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