Purple Book (Guide for Controlling ACM in Buildings) Part 10 PDF

Armholes and an inside pouch for tools let the worker remove insulation without exposure to asbestos fibers. A sealed side port also can be constructed to allow access for wetting the asbestos and evacuating the bag with a HEPA-filtered vacuum.6 Workers who use containment bags should still wear res...

Armholes and an inside pouch for tools let the worker remove insulation without exposure to asbestos fibers. A sealed side port also can be constructed to allow access for wetting the asbestos and evacuating the bag with a HEPA-filtered vacuum.6 Workers who use containment bags should still wear respirators in case a bag leaks. To remove individual pipe sections or an entire pipe network, a small section (about 6 inches wide) of insulation should be removed. The pipe then can be cut into manageable lengths with a saw or torch. Exposed ends of the insulating material should be sealed with plastic and tape. If the remaining insulation is not in good condition, the entire pipe should be wrapped in 6 mil plastic. Disposal of insulation material must follow EPA procedures discussed earlier for ACM disposal (Sections 1.4 and 5.1). More information on pipe and pipe insulation removal will be provided in a future technical bulletin. Figure 14. Custom containment bags for repairing or removing pipe insulation. 5.3. Abatement Methods for Other Types of ACM Additional corrective action generally is not needed for other types of ACM. The special O&M program should continue until building renovation or maintenance requires ACM removal. The ACM should then be removed following the guidelines for surfacing materials (i.e., worker protection and work area containment). Removed ACM should be wrapped in 6 mil plastic sheets or placed in plastic bags, labeled as asbestos waste, and transported to a solid waste site. Unless these materials are friable, OSHA and NESHAPS regulations covering removal operations do not apply. 6 Seals can be checked with a flashlight and smoke from a smoke tube. 5-10 CHAPTER 6. CONDUCTING ABATEMENT PROJECTS Because efforts to treat ACM may be hazardous to abatement workers and building occupants, careful planning and diligent implementation of the project are essential. Removal, enclosure, or encapsulation of surfacing materials and removal or repair of pipe and boiler insulation may cause large-scale fiber release if proper procedures are not followed. As a result, asbestos levels in the building may increase rather than decrease. For this reason, key elements of the abatement project include comprehensive and precise contract specifications, workers specially trained in asbestos abatement, rigorously applied worker protection and site containment measures, and the regular monitoring of the work site. When abatement activity is complete, the entire work site should be thoroughly cleaned. The contractor should be released only after the work site has passed visual inspection and a test for airborne asbestos. SUMMARY Who Should Do the Work: Usually a contractor is hired to conduct abatement work that goes beyond special O&M. Occasionally, a large school district or an owner of many buildings will train and dedicate an in-house asbestos abatement team. Selecting a Contractor: Steps in selecting a contractor include checking references, conducting interviews, reviewing insurance coverage, and writing precise contract specifications. Note that the most cost-effective contractor is not necessarily the lowest bidder. Managing the Work: ● Regular on-site inspections will assure conformance with work specifications and avoid costly and hazardous errors. ● Before the contractor is released, the work site should pass both a visual inspection and an air test for asbestos fibers to be sure the site has been adequately cleaned. From a technical point of view, the TEM method is preferred for the air test. Although the PCM method is not as specific for asbestos nor as sensitive to thin fibers as the TEM method, it is frequently more available and easier to implement. 6.1 Who Should Do the Abatement Work Employees involved in the abatement work must be specially trained and committed to quality work. Training should: ● Familiarize workers with the general problems of airborne asbestos; ● Teach them to handle ACM safely and prevent unnecessary fiber release; and ● Explain how to interpret asbestos abatement work orders. Either in-house staff or outside contractors can conduct asbestos abatement work. The decision depends primarily on training, equipment, and experience. 6-1 In most cases, the in-house maintenance staff will not have enough time to master asbestos abatement methods for surfacing materials—removal, enclosure, and encapsulation. However, some school districts with many buildings containing surfacing ACM have formed asbestos abatement teams whose sole responsibility is control of ACM. These in-house teams can thoroughly learn the requirements and methods of asbestos abatement. With this training and knowledge of the buildings, an in-house team may be the most effective. More typically, however, an outside contractor specializing in asbestos abatement is hired for specific abatement projects. Building maintenance workers accustomed to repairing equipment with insulation are frequently trained to undertake abatement actions involving pipe and boiler insulation. However, outside contractors are typically hired to remove extensive amounts of insulation or to remove both pipe and insulation. 6.2 Selecting a Contractor Selecting a competent contractor is the first step toward successful abatement. EPA’s experience with asbestos abatement and comments from technical advisors suggest that many contractors cannot properly conduct abatement projects. Several contractors, awarded jobs based on responsive and reasonable cost bids, proved unable or unwilling to follow contract specifications. Suggestions to help building owners avoid these situations are as follows: ● Assign the technical advisor who will monitor the abatement work to assist in writing job specifications and selecting the contractor. The advisor should not be employed by an abatement contractor. ● Require evidence of prospective contractors’ experience and/or training in asbestos abatement. ● Check references, including other building owners for whom contractors have worked. (See Appendix K for an example checklist of contractor qualifications.) ● Ask for detailed written descriptions of how bidders will satisfy the project specifications. ● Interview bidders regarding their work, worker protection, and site containment plans. A statement that the contractor will comply with all EPA, OSHA, and state regulations is not sufficient. Ask bidders for copies of their standard operating procedures and employee protection plans, specifically their OSHA medical monitoring and respirator training program. The interview is invaluable for evaluating each contractor’s capabilities and understanding of the problem. ● Obtain documentation of each contractor’s fiscal qualifications, including financial performance, assets, liabilities, legal judgments, and insurance. ● Be sure that the contractor selected has adequate liability insurance. Some forms of insurance may not provide enough long-term protection against inadequate abatement work. The building owner’s attorney and insurance advisor should determine if coverage is adequate. ● Be specific about what constitutes successful job completion. A thorough visual inspection to insure adequate cleaning is an absolute necessity. Air monitoring is also recommended (see Section 6.4). The person carrying out the air monitoring should not be employed by the abatement contractor. ● Require evidence of worker certification or have the contractor conduct an on-site training program for workers. 6-2 ● Encourage bidding competition, since prices can vary greatly. Multiple bids are desired, but too many can confuse the selection process. Remember that successful abatement, not cost minimization, is the goal. ● If possible, avoid contracting for abatement work during the summer. Many school projects are conducted during that season, taxing the limited number of competent contractors. Appendix L contains a list of organizations that have prepared model contract specifications for asbestos removal. Together with the above suggestions, these models can serve as the basis for writing specifications tailored to individual projects. Remember that EPA’s RAC can provide additional information and suggestions. 6.3 Managing the Work As in all construction jobs, the program manager or the manager’s representative (frequently the technical advisor) should visit the abatement work site often (no less than four times per day) to insure that all plans and procedures are properly implemented. The work site monitor should: ● Be sure the workers follow specifications; ● Confirm compliance with worker protection requirements; and ● Assure that the containment barriers around the work site are properly constructed and maintained. By carefully monitoring the abatement work, the asbestos program manager can correct errors quickly. Work site inspections are most effective if the manager can refer to a detailed workplan containing specific work practices. Where work does not follow specifications, the project should be stopped immediately. The abatement contractor, the asbestos program manager, and the work site monitor (if different from the program manager) should then identify the problems and take steps to correct them. The need for worker protection (protective clothing, respirators, and change facilities) was discussed in Section 5.1. Although contractors are responsible for their employees, a building owner’s concern for the safety of everyone in the building extends to the abatement workers. Work area containment is essential for all types of abatement and for both surfacing material and pipe and boiler insulation. Once abatement begins, all persons not directly involved in the work should be barred from the area. The work site monitor should make sure plastic barriers are in place (see Section 5.1) and that warning signs are posted at least 20 ft. in front of the work site entrance. If abatement activity is limited to repair or minor removal of pipe and boiler insulation, containment bags will probably be used (see Section 5.2). The monitor should inspect the construction and use of the bags. Warning signs should be posted outside the work site. The monitor should also check the air lock at the entrance to the work site. If a negative pressure system is not used, the air lock (and the entire containment system) should be airtight. If a negative pressure system is used (as recommended), the air lock must allow air from the building to enter the work site to replace the contaminated air that is filtered and exhausted outside. When inspecting the work in progress, the monitor’s specific checklist will depend on the type of abatement. Abatement inspection for surfacing materials and pipe and boiler insulation should be based on guidelines and precautions described in Chapter 5 (Sections 5.1 and 5.2, respectively). Work site inspections greatly increase an abatement project’s likelihood of success. The importance of doing the job right the first time cannot be over-emphasized. Tests must be performed when the work is 6-3 finished to determine if the project has been conducted properly and the work site adequately cleaned (described in 6.4.) However, if the workers have not been diligent throughout the project, proper cleaning of the work site may not be possible. 6.4 Releasing the Contractor An asbestos abatement project is successful when the source of fiber release has been controlled and airborne asbestos generated during abatement has been reduced to an acceptable level. As discussed earlier in this chapter, success can be built into the project with a sound work plan and constant monitoring of the work area to insure proper implementation. All workers must be trained and must follow stipulated work practices. Also, it is important to use negative air pressure ventilation to capture asbestos fibers generated during all types of abatement, and to continually remove debris from the site. When the abatement project is completed, the entire site should be cleaned at least twice. Success is confirmed with a final evaluation at each work area. The evaluation consists of visual inspection and air testing. Visual inspection is used to determine if the work has been performed properly and to check for debris and other obvious signs of poor cleaning. Air testing helps confirm that the work site has been adequately cleaned. Only then is the contractor released. 6.4.1 Visual Inspection The primary test for releasing the contractor is a thorough visual inspection of the work site. The inspection should be conducted before the containment barriers have been taken down but after the plastic sheets have been cleaned with damp mops and cloths or a HEPA vacuum cleaner. Since elevated levels of airborne asbestos may still be present, the inspector should wear a respirator (see Section 5.1). First, the inspector should confirm job completeness. If ACM has been removed, substrate surfaces should be checked to be sure no ACM remains. Special attention should be given to pipes, beams, and irregular surfaces that may have corners and hard-to-reach areas. If the materials were enclosed, check the area for tight construction (e.g., no stray drill holes or openings at corners). Inspect encapsulated surfaces to insure that the right amount of sealant has been used: there should be no holes, voids, or cracks. Check surfaces behind obstructions (e.g., pipes or ducts) for these signs. Next, the inspector should determine that the work site has been adequately cleaned. Any activity that disturbs ACM will release fibers. Therefore, work site cleanup after removal, repair, enclosure, or encapsulation is critical. Examine all surfaces for dust and debris, especially overhead areas like tops of suspended light fixtures. Use a damp cloth to collect dust from these surfaces and then inspect the cloth for evidence of dust. This is a practical way to establish that the “no dust” requirement has been met. A more sensitive test for dust is to darken the room and shine a flashlight so that the beam just glances any smooth horizontal surface. Run your finger across the illuminated area. If a line is left on the surface, or if airborne particles shine in the light, dust is still present. If dust is found by either of the two tests, the entire work area should be recleaned and the tests repeated. 6.4.2 Air Testing Conduct air monitoring only after the site has passed visual inspection. First, remove all plastic sheets covering floors, walls, and other surfaces. (The plastic barriers separating the site from the rest of the building 6-4