Asbestos Awareness OSHA Class IV

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1 Asbestos Awareness OSHA Class IV Stacy Kahatapitiya, CHMM, LEED GA & Peter Nketia-Akonnor Characteristics Naturally occurring mineral found in rock formations Most ACM mined/produced in Canada Comes from the Greek origin - inextinguishable, unquenchable Fire resistant Best known insulator 1

2 Characteristics Good friction and wear characteristics Cannot be easily destroyed or degraded Typically appears as a whitish, fibrous material Usually mixed with other materials to form the product Types of Asbestos Chrysotile - Serpentine Group Amosite - Amphibole Group Crocidolite - Amphibole Group Actinolite - Amphibole Group Anthophylite - Amphibole Group Tremolite - Amphibole Group 2

3 Chrysotile - White Asbestos Chrysotile - Natural State 3

4 Amosite - Brown Asbestos Crocidolite - Blue Asbestos 4

5 Mining and Production of Asbestos Asbestos Thread Making Machine 5

6 Interesting Advertisements Asbestos-Containing Materials (ACM) Any Material containing greater than one percent asbestos. >1% Note: To OSHA any asbestos is a concern 6

Where ACM May Be Found Steel beams Roofing felts Boiler/tank insulation Roofing shingles Pipes

and benches Floor tiles Adhesives for floor tiles and roofing materials Asphalt Exterior building

Wallboard (Transite ) Old fire doors Asbestos cement Believe It or Not Kent micronite filter was

7 Where ACM May Be Found Steel beams Roofing felts Boiler/tank insulation Roofing shingles Pipes (contained in cement matrix) Pipe coverings Pipe elbows Laboratory structures such as fume hoods and benches Floor tiles Adhesives for floor tiles and roofing materials Asphalt Exterior building shingles Gaskets in heating and airconditioning equipment Ceiling panels and ceiling tiles Wallboard (Transite ) Old fire doors Asbestos cement Believe It or Not Kent micronite filter was made with (blue, or crocidolite) asbestos from 1952 to 1956 Was introduced as a way to reduce the risk of cancer 7

Categories of Asbestos-Containing Materials (ACM) Surfacing Materials Thermal System Insulation Miscellaneous Materials Surfacing Materials Sprayed on, trawled on, or otherwise applied to surfaces

8 Categories of Asbestos-Containing Materials (ACM) Surfacing Materials Thermal System Insulation Miscellaneous Materials Surfacing Materials Sprayed on, trawled on, or otherwise applied to surfaces For acoustical, decorative and fireproofing purposes Includes acoustical plaster, wall or ceiling plasters, fireproofing insulation, sprayed on or manually applied thermal material Typically higher friability 8

9 Spray-Applied Fireproofing Applying Fireproofing 9

10 Plaster Decorative Applications 10

11 Thermal System Insulation Used to control heat transfer or prevent condensation Used on pipes, pipe fittings, boilers, breaching, tanks, and ducts Includes pipe lagging, pipe wrap, duct insulation, cements and muds TSI Pipe & Fitting Insulation 11

12 Tank Insulation Damaged Thermal System Insulation 12

13 Miscellaneous Materials All other ACM Mostly non-friable products Floor tile, ceiling tile, construction mastics for floor and ceiling materials, glue dots, fire doors, asbestos cement pipe and board, Transite, wallboard, acoustical wall tile Miscellaneous Materials 13

14 Miscellaneous Materials - Transite How is Asbestos Identified? 14

15 Asbestos Sampling - Bulk Polarized Light Microscopy PLM Transmission Electron Microscopy TEM Polarized Light Microscopy PLM 15

16 PLM - Chrysotile PLM - Amosite 16

17 PLM - Crocidolite Transmission Electron Microscopy - TEM 17

18 TEM - AMOSITE Asbestos Sampling - Air Phase Contract Microscopy PCM Transmission Electron Microscopy TEM 18

meet the counting criteria Does not specifically identify

19 Phase Contrast Microscopy - PCM Can be done on site by a trained person (-) Only identifies and counts fibers that meet the counting criteria Does not specifically identify asbestos Re-occupancy Standard: 0.01 fibers/cc PCM Fibers 19

20 Health Effects of Asbestos Exposure Hazards of Asbestos Exposure Depends on friability, amount of exposure and duration of exposure Sprayed-on and trawled-on materials are highly friable Jacketed materials are friable only if they are deteriorated, water damaged or disturbed by mechanical means 20

Hazards of Asbestos Exposure Miscellaneous materials are usually firmly bound in the matrix A certain amount of asbestos can be found in the air at any given time Highest exposures found in mining

21 Hazards of Asbestos Exposure Miscellaneous materials are usually firmly bound in the matrix A certain amount of asbestos can be found in the air at any given time Highest exposures found in mining and manufacturing operations Hazards of Asbestos Exposure Asbestos breaks in long, thin fibers The size and shape of asbestos fibers allows them to remain airborne for long periods of time The size and shape of the fiber allows it to penetrate deep into the lungs to the gas exchange region Keep exposures as low as possible 21

22 Lungs Defenses Against Asbestos Nose hair Mucus Cilia White Blood Cells Macrophages Asbestos Exposure Can Cause: Asbestosis Mesothelioma Lung Cancer Other Types of Cancer Other Health Effects 22

23 Asbestosis Serious, chronic, non-cancerous respiratory disease Lung tissue scarring Symptoms - shortness of breath, dry crackling lung sounds Can be fatal Lung Cancer Causes the largest number of deaths related to asbestos exposure. Symptoms - coughing, change in breathing, shortness of breath, persistent chest pains, hoarseness, and anemia. Risk can be 90 times higher if you smoke and have asbestos exposure. 23

24 Mesothelioma Rare form of cancer which affects the membrane lining of the lungs, chest & abdomen 200 cases diagnosed/year in the U.S. Almost all cases are linked to asbestos Latency Period Length of time from initial exposure to the onset of an asbestos related disease Asbestosis: years Lung Cancer: Years Mesothelioma: Year (maybe longer) 24

25 Smoking and Asbestos Exposure Smoking and working with asbestos can increase your chances of a lung cancer Up to 90 times greater risk than the normal population Synergistic Effect Asbestos Exposure Risk Factors 1. Fiber size 2. Length of exposure 3. Density of the dust 4. Smoking 5. Personal susceptibility 6. Fiber type 25

26 No Known Safe Level of Asbestos Exposure Permissible Does Not Mean Safe Friable Asbestos ACM that may be crumbled, pulverized, or reduced to powder by hand pressure when dry The more friable, the more fibers can be released into the air 26

27 Non-Friable ACM Can only become friable or damaged by mechanical means Cutting Drilling Pounding Grinding Sanding Machining Friable Floor Tile 27

28 Recognizing ACM Visual determination Microscopic analysis Assume ACM if not sure Ask for a copy of the building s asbestos management plan Keys for Identification Age of building Type of construction Application of material The appearance of the material 28

Age of Building Asbestos pipe and boiler insulation was used until the 1970s Sprayed on fireproofing was banned in 1975 Type of Construction Low-rise residential construction

29 Age of Building Asbestos pipe and boiler insulation was used until the 1970s Sprayed on fireproofing was banned in 1975 Type of Construction Low-rise residential construction Unusually limited to pipe and boiler insulation Structural steel frame buildings Fireproofing Reinforced concrete structures Do not normally require additional fireproofing 29

30 Nature of the Equipment Equipment exposed to extreme conditions High pressure steam lines Hot process piping Refractory linings in furnaces and kilns Appearance of Material Pipe insulation - corrugated type of material ( air-cell insulation ) was made with a significant amount of asbestos Floor tiles - 9 x 9 Fibrous 30

31 How to Identify Surfacing Material Look for fireproofing sprayed onto steel beams or decking Look for fibrous, fluffy surface material on ceilings, pillars and walls Assume that plaster is ACM if installed before 1981 How to Identify Thermal System Insulation Steam pipes, elbows, valves, boilers, hot water tanks and hot water lines Insulation will be wrapped with an external covering such as paint, paper, metal, plastic or fabric Hot water tanks If installed before 1981, presume the covering to be ACM HVAC and cold water systems Thin layer of insulation May be covered with a non-acm material 31

32 How to Identify Resilient Flooring Can t tell by looking at it Before 1981, about half the 12 x 12 and nearly all 9 x 9 tiles contained asbestos Asbestos was also used in the backing material Don t overlook floor tile under floor tile or under carpeting Asbestos Operations and Maintenance Plan O&M Plan 32

Asbestos Operations and Management Plan Must be kept by building owner Identifies where ACM is and the condition of the ACM May overlook abandoned ACM behind walls and under floors Asbestos

33 Asbestos Operations and Management Plan Must be kept by building owner Identifies where ACM is and the condition of the ACM May overlook abandoned ACM behind walls and under floors Asbestos Management Issues Prevent disturbance of ACM Minimize contact with ACM Inform appropriate parties of disturbance/disturbed ACM Inspection and proper removal prior to renovations Observe all notices and signs with regard to asbestos Follow appropriate procedures Don t disturb or handle asbestos if properly trained 33

34 Asbestos Management Issues Project Notification Requirements OSHA Sign posted at entrance to all asbestos removal areas Notify all employees on multi-employer work site of the establishment of an asbestos removal work area Notify all prospective contractors and tenants of quantity and location of ACM or Presumed Asbestos Containing Materials (PACM) in areas where they work (or will work) Employers who will work in areas associated with asbestos shall notify building owner and employees in adjacent areas of location, quantity, and measure to control asbestos. Asbestos Management Issues Project Notification Requirements EPA Building shall provided a 10 working day notification on any job subject to NESHAP Project Notification Requirements State Specific Permit required prior to projects subject to EPA NESHAP regulations 30-day notification to building occupants prior to projects subject to EPA NESHAP regulations Sign posted on building entrances and exits three-days prior to removal of all asbestos projects subject to NESHAP regulations. 34

35 Regulations Regulation Overview EPA AHERA ASHARA NESHAP DOT OSHA State COMAR Virginia Code D.C. 35

NESHAP National Emissions Standards for Hazardous Air Pollutants 40 CFR Part 61, Subpart M NESHAP OVERVIEW Pre RENO/DEMO Inspections Required Remove RACM If Disturbed (some

36 NESHAP National Emissions Standards for Hazardous Air Pollutants 40 CFR Part 61, Subpart M NESHAP OVERVIEW Pre RENO/DEMO Inspections Required Remove RACM If Disturbed (some exceptions) Competent Person Supervises Removal Wet Methods/No Visible Emissions 10-Day EPA Abatement Notification Generator Label on Waste Containers Storage, Transport, Disposal Requirements 36

37 Asbestos Hazard Emergency Response Act 40 CFR 763 AHERA Overview Schools, Public & Private (K-12) Training/Accreditation (Model Plan) Awareness, 16-Hour O&M Training Inspections/Re-inspection Management Plans Inspection Protocol 37

38 OSHA 29 CFR General Industry 29 CFR Construction Industry 29 CFR Shipyard Employment 29 CFR Respiratory (general) 29 CFR HAZCOM Standard Asbestos Regulations - OSHA General Industry, Construction and Maritime Standards Class I, II, III, and IV Worker PACM and Floor Tiles Notifications Labels and Signs 38

39 OSHA Classifies work based on type of material and activities Specific training, work practices and precautions for each class OSHA Permissible Exposure Limit The amount of asbestos that can be inhaled over an eight hour workday PEL = 0.1 fibers per cubic centimeter of air 39

40 OSHA Excursion Limit The amount of asbestos that can be inhaled in a 30 minute period Equals 1.0 fiber per cubic centimeter of air Class I Removal of thermal system insulation and/or surfacing ACM Includes sprayed-on fire proofing, boiler/tank jacketing, pipe covering, and acoustical plaster Requires all OSHA precautions 40

41 Class II Removal of ACM containing wallboard, floor tile, sheeting, roofing shingles and mastics Requirements depend on exposure data If no existing exposure data, all OSHA requirements must be initially implemented Class III Repair and maintenance operations where ACM is likely to be disturbed Requirements depend on exposure data If no existing exposure data, all OSHA requirements must be initially implemented 41

42 Class IV Maintenance and custodial activities where employees may contact ACM Cleaning up of asbestos-contaminated debris Training equivalent to AHERA awareness training This is where you are classified! Asbestos Notifications & Permits U.S. EPA Region III District Department of Columbia Maryland Department of the Environment Virginia Department of Labor and Industry GSA National Capital Region 42

43 District of Columbia Asbestos Abatement Permits & Raze Permits > 18 SF of resilient flooring and NESHAP 10 working days 30 day tenant notification 3 days prior to abatement post notice signs Maryland Asbestos Project Notification NESHAP Courtesy notification if less than NESHAP 10 working days 3 days prior to abatement post notice signs 43

44 Commonwealth of Virginia Permit Application & Notification > 10 LF or >10 SF and all demolition projects 20 calendar days (removal); 10 working days (demo) Not required for non-friable roofing, flooring, or siding Are New Buildings Free of Asbestos? 44

45 EPA Asbestos Ban Many incorrectly believe that all asbestos-containing products are banned for sale or use in the U.S. The 1989 EPA ban Most sprayed-applied surfacing ACM Wet applied and pre-formed pipe insulation Pre-formed ACM for boilers and hot water heaters EPA Asbestos Ban Asbestos products not banned Roofing felt Vinyl floor tile Asbestos corrugated sheeting Shingles Cement pipe Gaskets Mastics Ceiling Tile Drywall 45

46 EPA Asbestos Ban How do you know? Can t rely on MSDS/SDS Can t rely on Spec Sheets Can t rely on word of mouth Have to test Components of Asbestos Abatement Projects 46

47 Decon Chamber 47

48 Negative Air Pressure Isolation Types of Containment Glovebags Full containment Negative Pressure Mini-enclosures Negative Pressure Magic tape Approved variances 48

Exposure Monitoring Air Sampling After Final Cleanup Area air sampling is conducted at the conclusion of an asbestos abatement project to estimate the airborne concentration of residual fibers The

49 Exposure Monitoring Air Sampling After Final Cleanup Area air sampling is conducted at the conclusion of an asbestos abatement project to estimate the airborne concentration of residual fibers The area must pass a thorough visual inspection before final clearance sampling The visual will be done in two phases typically. First an inspector/project monitor determines completeness of the removal and if needed re-clean, once deemed clean, it is re-inspected and final sampling can begin 49

50 Final Clearance Samples Final clearance samples are typically collected with high volume pumps to draw a predetermined volume of air The number of samples depends on the amount of ACM affected by the response action, where it is taking place, and the analytical method being used (PCM)/(TEM 0.01 f/cc (PCM) 70 S/mm2 (TEM) Asbestos in the Recent News World Trade Center Libby Montana (vermiculite mine) Texas Abatement Contractor Latino workforce. No training, respiratory protection or decon procedures. 50

51 Active Canadian Asbestos Mine Questions? 51

Asbestos Management Program April 27, 2017

Asbestos Management Program April 27, 2017 1. INTRODUCTION 1.1. Purpose Indiana University Environmental Health and Safety (IUEHS) has developed this Program to identify practices and procedures for the