Asbestos and Lead Considerations in Construction Projects. Sean Purcer Senior Consultant Anthony Price Senior Consultant

Transcription

1 Asbestos and Lead Considerations in Construction Projects Sean Purcer Senior Consultant Anthony Price Senior Consultant

2 Who We Are History Founded in 1990 by Environmental, Health and Safety (EHS) managers to offer comprehensive EHS management and technical consulting services to the high tech industry In late 90s, successfully diversified our client base into multiple regional and vertical markets across the US and beyond Today 140 employees supporting 450 customers from 5 regional offices in US; HQ in San Jose, CA Multidisciplinary EHS and Sustainability consulting team Well-established partnering arrangements allowing for cost effective and highly responsive international support ISO and OHSAS Certified 2

3 Presenters: Sean Purcer and Anthony Price Sean Purcer 23 years of experience in the environmental industry Includes environmental assessment and remediation, environmental compliance, environmental risk assessment/management, asbestos, lead and mold assessment, management, and abatement project management. Anthony Price 11 years of experience in the environmental industry Includes asbestos and lead surveying, site assessments, regulatory requirements, and project management. Managed asbestos and lead division for the past 5 years. 3

4 Hazardous Materials Hazardous Materials that may be encountered when planning/executing a construction project: Asbestos Lead PCBs (ballasts, transformers and window putty) Mercury (thermostats, switches, lamps) Fluorescent Lamps Mold Miscellaneous Hazardous Materials 4

5 Asbestos Containing Materials 5

6 Asbestos-Containing Materials Regulations Federal U.S. EPA and federal OSHA regulate environmental and occupational exposures to asbestos primarily through three major regulations: National Emission Standards for Hazardous Air Pollutants (NESHAP), promulgated at Title 40 of the Code of Federal Regulations (CFR), Part 61, Subpart M The Asbestos Hazard Emergency Response Act (AHERA), promulgated at CFR 40, Part 763 and The OSHA Construction Industry Standard, promulgated at 29 CFR, Section State Dependent upon the state you live in. Local Local APCDs and Building Codes Dependent upon locality. 6

7 Asbestos-Containing Materials Federal Regulations NESHAP: 40 CFR Part 61, Subpart M National Emission Standard for Asbestos ACM Definitions Materials containing >1% asbestos Requirement to Inspect (a) Prohibits Visible Emissions Analytical Methods Notification Requirements Waste Disposal Requirements 7

8 Asbestos-Containing Materials Federal Regulations AHERA: 40 CFR Part 763 Identification/Inspection/Re-inspection Assessment and Evaluation of ACM Condition Control and Response Actions Asbestos School Hazard Abatement Reauthorization Act (ASHARA): 40 CFR Part 763 Application of AHERA to All Public and Commercial Buildings Detailed a Model Accreditation Plan for Asbestos Training 8

9 Asbestos-Containing Materials Federal Regulations OSHA Construction Industry Standard: 29 CFR Part Defines asbestos as materials containing 1.0% asbestos Definition of Permissible Exposure Levels PEL Definition of Asbestos Work Class I, II, III and IV Exposure Assessment and Monitoring of Workers Employee Protection Measures Training Requirements Medical Surveillance Abatement Work Procedures - Methods of Compliance 9

10 Asbestos-Containing Materials California Regulations California Environmental Protection Agency Cal/EPA regulates asbestos waste and requires manifests for transportation and disposal of hazardous asbestos waste (friable and contains greater than 1 percent asbestos). Cal/EPA also requires waste generators to obtain an identification number. Parts of the California Health and Safety Code require that occupants of buildings and consumers of certain products be notified of their contents and the health effects associated with exposures or consumption. 10

11 Asbestos-Containing Materials California Regulations Cal OSHA Construction Industry Standard: Title 8 California Code of Regulations(CCR) Section 1529 Enforced by the California Department of Occupational Safety and Health (DOSH) Same (nearly) as federal Construction Industry Standard DOSH also requires that asbestos consultants performing work in California be trained and certified by DOSH. Local APCD s enforce provisions of NESHAP 11

12 Asbestos-Containing Materials A. 1 st Step is the Survey The owner has an affirmative obligation to determine the presence of asbestos-containing materials prior to construction or disturbance 12

13 Asbestos-Containing Materials B. Abatement vs. Disturbance There are different requirements for worker training, work area isolation, procedures and clearance 13

14 Asbestos-Containing Materials C. Clearance Visual Clearance Air Clearance (PCM vs. TEM) 14

15 Asbestos-Containing Materials D. Disposal Requirements Dispose of as construction debris if the asbestos concentration is less than 1% Dispose of as hazardous asbestos waste if the asbestos concentration is greater than 1% and the material is friable (thermal system insulation, fireproofing, boiler insulation, etc.) Dispose of as non-hazardous asbestos waste if the asbestos concentration is greater than 1% and the material is non-friable (floor tile, roofing material, etc.) 15

16 Lead Containing Materials 16

17 Lead-Containing Materials Regulations Federal U.S. Department of Housing and Urban Development s (HUD) Guideline Document Lead-Based Paint: Guidelines for Hazard Evaluation and Control of Lead-Based Paint Hazards in Housing, published in the Federal Register, June 1995, Federal EPA Lead Renovation, Repair and Painting Rule Federal OSHA s Lead Exposure in Construction Rule (29CFR Part ) State Dependent upon the state that you are in but in California Cal/OSHA s Lead Exposure in Construction Rule (Title 8 CCR ) 17

18 Lead-Containing Materials A. 1 st Step is the Survey Each employer has an affirmative obligation to survey for the presence of lead if possible employee exposure. The owner has an affirmative obligation to survey for the presence of lead if there is a possibility of child exposure or they are hiring a contractor to perform work for compensation. While XRF can determine if a material contains lead, for OSHA purposes it can not be used to determine that the material is negative for lead. Chip sampling and analysis is required by OSHA for negative lead determinations. 18

19 Lead-Containing Materials B. Abatement vs. Lead-Related Construction Abatement used to eliminate a lead hazard and triggers CDPH notification, CDPH certified workers and clearance wipe sampling is required. Lead Related Construction Work requires less worker training and no CDPH certification. Visual clearance is acceptable. Notification Written notification to Cal/OSHA at least 24 hours before conducting work involving any of the trigger tasks listed below disturbing > 100 square feet or 100 linear feet. 19

20 Lead-Containing Materials C. Trigger Tasks Are defined in federal and Cal OSHA lead regulations. Lowest Exposure Trigger Tasks Assume exposures greater than 50 and up to 500 ug/m3 unless proven otherwise and include: manual demolition, manual scraping, manual sanding, heat gun applications and power tool cleaning with dust collection system. Medium Exposure Trigger Tasks Assume exposures greater than 500 and up to 2,500 ug/m3 unless proven otherwise and include: use of lead-containing mortar, lead burning, power tool cleaning without dust collection systems and abrasive blasting enclosure movement and removal. 20

21 Lead-Containing Materials C. Trigger Tasks continued Highest Exposure Trigger Tasks Assume exposures greater than 2,500 ug/m3 unless proven otherwise and include: abrasive blasting, welding, cutting and torch burning. 21

22 Lead-Containing Materials D. Training Hazard Communication = All workers who work with leadcontaining materials regardless of exposure. 8-Hour Lead Awareness = All workers who are exposed to airborne lead above the action level (30 ug/m3) CDPH Certified = Workers performing abatement or are exposed to airborne lead above the Permissible Exposure Limit (50 ug/m3) 22

23 Lead-Containing Materials E. Worker Protection Requirements Any detection of lead in a material triggers worker protection requirements until worker exposure monitoring results allow downgrade Personal Protective Equipment shall include: appropriate respiratory protection, clean work clothes such as coveralls, gloves, hats, shoes or disposable shoe coverlets, face shields, vented goggles or other appropriate equipment Change areas with separate storage facilities for clean clothes Hand washing facilities must wash hands and face at end of each shift Biological monitoring consisting of initial or baseline blood sampling Training includes Hazard Communication, respirator and lead training 23

24 Lead-Containing Materials F. Initial Exposure Assessment Any detection of lead in a material triggers worker exposure monitoring requirements Employees exposure to airborne lead must be determined by personal air sampling (exposure assessment) Exposure assessment must be performed in all workplaces where employees MAY be exposed to lead Cal OSHA = Action Level (AL) is 30 ug/m3, 8-hour Permissible Exposure Limit (PEL) is 50 ug/m3 Having airborne lead concentrations at or above the AL triggers certain health and safety measures 24

25 Lead-Containing Materials G. Disposal Requirements Lead waste stream analysis flow chart 25

26 Role of Consultant 26

27 Role of Consultant Independent Third Party Provides Protection Against Liability Perform Survey Prepare Specification/Work Plan Bidding Services Abatement / Disturbance Monitoring / Air Monitoring Waste Characterization Clearance Project Documentation 27

28 Thank You! 16