Trace Asbestos

“The Untold Story”

Presented by Ken Harenda & Dean Jacobsen

S.A. Herbst & Associates LLC

December 6, 2013

www.saherbst.com

(414) 727-7900

Trace Asbestos

• Regulations

• Bulk Sampling Requirements

• Personal Exposure Monitoring

• Training Requirements

• Personnel Protective Equipment (PPE)

• Work Practices

• Waste Handling

• Recordkeeping

Trace Asbestos

What is the definition of trace asbestos?

Regulations

• NESHAP / NR 447

• AHERA

• OSHA Construction Standard

• OSHA General Industry Standard

• OSHA Hazard Communications

• DHS 159

Regulations

• NESHAP 40CFR 61 Subpart M/NR 447

� Definition

• “ACM” means asbestos−containing material,

containing more than 1% asbestos.

� Sampling Requirements

•Thorough pre-inspection required prior to renovation or

demolition.

•PLM testing. Point Count if PLM less than <1% to

10%.

Regulations

AHERA 40 CFR 763

• Definition

�ACM – Material that contains more than 1% asbestos.

• Sampling Requirements

� Inspect school building to identify all locations of ACBM

� If collecting bulk samples analyze by PLM.

�Not ACM if 1% or less by PLM.

�Requirements for re-inspections and response actions only if proven or assumed ACBM.

Regulations

OSHA Construction Standard 1926.1101

• Regulates asbestos exposure in construction

• Definitions

�Asbestos means any of the 6 asbestos minerals

�ACM means contains more than 1% asbestos

• Sampling Requirements

�(k)(5) Inspect and sample following AHERA to demonstrate that PACM TSI & surfacing does not contain more than 1% asbestos.

�Drywall & Joint Compound are separate materials-must be analyzed separately. OSHA Letter April 1997

Regulations

OSHA General Industry Standard 1910.1001

• Definitions

�Asbestos means any of the 6 asbestos minerals

�ACM means material containing more than 1%

asbestos

• Sampling Requirements

�(j)(8) Inspect and sample following AHERA to

demonstrate that PACM TSI & surfacing does not

contain more than 1% asbestos.

Regulations

OSHA Hazard Communications 1910.1200

• Definition

�Chemical means any substance or mixture of

substances

• Sampling Requirements

�No sampling requirements

Regulations

DHS 159

• Definition

�ACM means material that contains more than 1%

asbestos

• Sampling Requirements

�Bulk sampling is an asbestos management activity

and must be done by certified inspector.

�Exception for single family owner occupied housing

when done by owner

Personal Exposure MonitoringOSHA General Industry Standard 1910.1001

• Part (c) Comply with OSHA PEL 0.1 fibers/cc & EL 1.0 fibers/cc

• Part (d) Initial Exposure Monitoring (PCM)

�Breathing zone air samples

�Employees who are, or may reasonably be expected to be, exposed at or above PEL or EL

�30 Minute Excursion - operations that are most likely to produce exposures above the excursion limit

�8 Hour Time Weighted Average - full-shift exposures representing each shift for each employee in each job classification in each work area.

�Can also use objective data showing material won’t produce asbestos above PEL or EL, or results from previous sampling

Personal Exposure Monitoring

OSHA Construction Standard 1926.1101

• Parts (c) & (f) Comply with OSHA PEL 0.1 fibers/cc & EL 1.0 fibers/cc

�Breathing zone air samples that are representative of exposures

�Immediately before or at start of operation

�30 Minute Excursion - operations that are most likely to produce exposures above the excursion limit

�8 Hour Time Weighted Average – representing each shift for each employee in each work area.

�Can also use objective data showing material won’t produce asbestos above PEL or EL, or results from previous sampling

Personal Exposure Monitoring

• Must be done by a competent person

• Negative Exposure Assessment (PCM)

• Required Reoccurrence of Monitoring

�General Industry (d)(3) – at least every 6 months where exposure do or may exceed PEL and EL and, often enough to represent with reasonable accuracy the levels of exposure of the employees.

�General Industry (d)(4) – Can stop when exposures are below PEL & EL

�Construction (f)(2) – at least every 12 months

�Whenever there has been a change in process, control equipment, personnel or work practices that may result in new or additional exposures above the PEL or EL

Training

• AHERA

• OSHA General Industry

• OSHA Construction Standard

• OSHA Respirator Protection

• OSHA Hazard Communications

• DHS Training

Training

• AHERA Training Requirement

�Inspectors trained according to model accreditation

plan

�Designated person training

�Maintenance and custodial staff only if building

contains ACBM

TrainingOSHA General Industry 1910.1001

• (j)(7) Training if exposure at or above PEL or EL

(A) The health effects associated with asbestos exposure;

(B) The relationship between smoking and exposure to asbestos producing lung cancer:

(C) The quantity, location, manner of use, release, and storage of asbestos, and the specific nature of operations which could result in exposure to asbestos;

(D) The engineering controls and work practices associated with the employee's job assignment;

(E) The specific procedures implemented to protect employees from exposure to asbestos, such as appropriate work practices, emergency and clean-up procedures, and personal protective equipment to be used;

(F) The purpose, proper use, and limitations of respirators and protective clothing, if appropriate;

(G) The purpose and a description of the medical surveillance program

(H) The content of the standard, including appendices.

TrainingOSHA Construction Standard 1926.1101

• (k)(9)(viii) Training if exposure at or above PEL

(A) Methods of recognizing asbestos, including presumed building materials;

(B) The health effects associated with asbestos exposure;

(C) The relationship between smoking and asbestos in producing lung cancer;

(D) The nature of operations that could result in exposure to asbestos, the importance of controls to minimize exposure including, as applicable, engineering controls, work practices, respirators, housekeeping procedures, hygiene facilities, protective clothing, decontamination procedures, emergency procedures, and waste disposal procedures, and any necessary instruction in the use of these controls and procedures;

(E) The purpose, proper use, fitting instructions, and limitations of respirators;

Training

OSHA Construction Standard 1926.1101

• (k)(9)(viii) Training if exposure at or above PEL

(F) The appropriate work practices for performing the asbestos job;

(G) Medical surveillance program requirements;

(H) The content of this standard including appendices;

(I) Smoking cessation information; and

(J) The requirements for posting signs and affixing labels and the meaning of the required legends for such signs and labels.

Training

OSHA General Industry & Construction

• Initial training before or at time of assignment

• Annual training

• Conducted in a manner that the employee is able to

understand

• Employer maintains records for 1 year after last date of

employment

TrainingOSHA Respirator Protection 1910.134 (k)

• Initial and annual training for required and voluntary use of respirators

(i) Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator;

(ii) What the limitations and capabilities of the respirator are;

(iii) How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions;

(iv) How to inspect, put on and remove, use, and check the seals of the respirator;

(v) What the procedures are for maintenance and storage of the respirator;

(vi) How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators; and

(vii) The general requirements of the standard.

TrainingOSHA Hazard Communication 1910.1200

• Applies for General Industry if any amount of asbestos

• Applies for Construction when installing new materials

• Employers provide hazard communication program, labels and other forms of warning, safety data sheets, and information and training

• (h)(3) Initial training at time of assignment

�Methods and observations to detect the presence or release of a hazardous chemical in the work area

�Hazards of the chemical

�Protective measures such as work practices & PPE

�Company’s hazard communication program

�Update training to reflect hazard communication regulation changes-labels and safety data sheets plus new hazards

Training

• DHS Training – Not Required

Personal Protective Equipment

• OSHA General Industry

• OSHA Construction Standard

• OSHA Respiratory Standard

�Respirators & protective clothing required if exposure at or above PEL or EL

�Hygiene facility if exposed at or above PEL or EL

�General Industry (i) - Clean change area, shower

�Construction (j) - Poly drop cloth, HEPA vacuum

Work Practices

OSHA General Industry Standard

• (f) Minimal Requirements above the PEL / EL

�Establish regulated area

�Demarcate area and restrict access

�Post warning sign

�Local exhaust ventilation for tools

�Wet methods

�No compressed air without collection system

�No sanding of flooring

�No employee rotation to reduce exposure

�Written program to reduce exposures below PEL & EL

Work Practices

OSHA General Industry Standard

(k) Minimal Requirements <1%

• Spill clean up as soon as possible

• HEPA vacuums

• No dry sweeping unless wet methods and HEPA vacuums

are not feasible

• Impermeable containers for waste. OSHA label not required

(j)(6)(ii)

Work Practices

OSHA Construction Standard 1926.1101 (g)

Minimal Requirements regardless of level of exposure

• Wet methods for handling, removal, cleanup

• Prompt clean up in leak tight containers

• No high speed saws without point of cut ventilator or HEPA enclosure

• No compressed air without collection system

• No employee rotation to reduce exposure

Work Practices

OSHA Construction Standard 1926.1101 (g)

Minimal Requirements regardless of level of exposure

• No smoking in work area

• (l)(1) When vacuuming use HEPA vacuums.

• See also OSHA 11/24/03 letter

Work Practices

OSHA Construction Standard 1926.1101 (g)

Minimal Requirements above the PEL / EL

• Establish regulated area

• Demarcate work area and restrict access

• Warning Sign

• Local exhaust ventilation equipped with HEPA filter

• Enclosure or isolation of processes producing asbestos dust

Work PracticesFrom DHHS (NIOSH) Publication Number 2003-141 Regarding Vermiculite

• ..”disturbing contaminated vermiculite with less than 1% asbestos can still result in hazardous concentrations of airborne asbestos fibers.”

• Recommended practices

�Avoid handling or disturbing loose vermiculite

�Isolate work areas with temporary barriers or enclosures to avoid spreading fibers

�Use wet methods, if feasible, to reduce exposure

�Never use compressed air for cleaning

�Avoid dry sweeping, shoveling, or other dry clean-up methods

�Use disposable protective clothing or clothing that is left in the workplace. Do not launder work clothing with family clothing

�Use proper respiratory protection.

�Dispose of waste and debris contaminated with asbestos in leak-tight containers in accordance with OSHA and EPA standards.

Work Practices

DHS 159

For renovations always assume vermiculite insulation

contains greater than 1% asbestos

Waste Handling Practices

• WDNR

�Dispose at solid waste or C&D landfill

• OSHA Construction Standard 1926.1101(g)(1)(iii)

�Prompt cleanup and disposal of wastes and debris

contaminated with asbestos in leak tight containers

Record Keeping

OSHA General Industry/ Construction Standards

• Exposure Monitoring – 30 years

• Training – at least 1 year

• Medical Evaluations – 30 years after last date of

employment

• Fit Testing – at least 1 year

Questions

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S.A. Herbst & Associates LLC

www.saherbst.com

(414) 727-7900