Purple Book (Guide for Controlling ACM in Buildings) Part 2 PDF

Friable, cementitious sprayed-on or troweled material (acoustical plaster) Friable, fluffy sprayed-on material Pipe lagging Nonfriable wallboard with friable sprayed-on material behind Figure 1. Examples of asbestos-containing materials found in buildings. 1-3 Figure 2. Comparison of measured...

Friable, cementitious sprayed-on or troweled material (acoustical plaster) Friable, fluffy sprayed-on material Pipe lagging Nonfriable wallboard with friable sprayed-on material behind Figure 1. Examples of asbestos-containing materials found in buildings. 1-3 Figure 2. Comparison of measured airborne asbestos concentrations in three settings.* Asbestos insulation workplaces before 1970 (NIOSH 1972) School buildings (USEPA 1983b, Chesson et al. 1985 a,b) Outdoor ambient air (USEPA 1983b, Chesson et al. 1985 a,b) 0.1 1.0 10 100 1,000 10,000 100,000 1,000,000 10,000,000 Nanograms per cubic meter 25% 75% Percentiles *Levels in asbestos workplaces were derived from measurements using phase contrast microscopy (PCM) while levels in school buildings and outdoors were measured using electron microscopy (EM). PCM and EM measurements are not directly comparable. PCM measures all fibers whereas EM can distinguish between asbestos and nonasbestos fibers. In addition, EM has a better capability than PCM for detecting small fibers. In order to translate the workplace PCM measurements (expressed as fiber counts) into values of asbestos mass (nanograms) that are approximately comparable to EM measurements, 30 fibers were assumed to equal one nanogram. This value is an average obtained from many comparisons of PCM and EM measurements taken at the same location (industrial settings) and time. Values for individual samples range from about 10 fibers per nanogram of asbestos to well over 100 fibers per nanogram, depending on the average size of fibers and the relative number of asbestos and nonasbestos fibers in the air (Versar 1980 and William Nicholson, personal communication, 1982). 1-4 1.4 Federal Regulations Regarding Asbestos in Buildings Both EPA and OSHA have published regulations to reduce asbestos exposure. EPA regulations focus on: (1) application and removal of ACM in new or remodeled buildings, and (2) identification of friable asbestos in schools. EPA also regulates the industrial emission of asbestos fibers and the disposal of asbestos waste. OSHA addresses worker protection in the workplace. The first EPA regulations were issued in 1973 under the National Emission Standards for Hazardous Air Pollutants (NESHAPS), as authorized by the Clean Air Act. The first regulations were directed largely at the asbestos industries, but also partially banned spray-applied ACM in new buildings, and established procedures for handling ACM during demolition. The regulations were revised in 1975 and 1976 to cover building renovations, the use of all types of insulating ACM in new buildings, and asbestos emissions from ACM waste disposal.4 Of particular interest to owners of buildings with ACM are the following regulations: ● When a building is demolished — or more than 260 linear ft. of asbestos pipe insulation or 160 sq. ft. of asbestos surfacing material are removed during renovation — advance notice must be filed with the EPA regional office and/or the state, giving: — — — — — name and address of the building owner or manager; description and location of the building; scheduled starting and completion dates of ACM removal; description of the planned removal methods; and name. address, and location of disposal site. ● ACM can be removed only with wet removal techniques (see Section 5.1). Dry removal is allowed only under special conditions and only with written EPA approval. ● No visible emissions of dust are allowed during removal, transportation, and disposal of ACM. (The wet removal techniques described in Section 5.1 are designed to satisfy this requirement.) The entire text of the NESHAPS regulations appears in Appendix C. Before beginning any ACM removal or building demolition, the building owner should review the NESHAPS requirements in detail. More information can be obtained from the regional NESHAPS contact. Addresses and telephone numbers of the contacts are found in Appendix D. The second set of EPA regulations is in the “Friable Asbestos-Containing Materials in Schools; identification and Notification Rule," (40 CFR Part 763)5 promulgated under the Toxic Substances Control Act. Known as the Asbestos-in-Schools rule, it requires all primary and secondary schools, both public and private, to: ● inspect, sample, and analyze friable materials for asbestos; ● document all findings; and ● inform all school employees and the school’s parent-teacher organization (or parents, if there is no organized group) of the location of friable ACM, and provide each custodial worker with a copy of the EPA publication, “A Guide for Reducing Asbestos Exposure." as published in the FEDERAL REGISTER (40 CFR Part 763). 4 The complete set of regulations was repromulgated on April 5, 1984. 5 The deadline for compliance with the Rule was June 28, 1983. A Copy of the Rule is available from EPA. See Appendix E. 1-5 The OSHA regulations were first issued in 1972 and modified in 1976. They specify airborne exposure standards for asbestos workers, engineering and administrative controls, workplace practices, and medical surveillance and worker protection requirements. In 1982, OSHA announced its intention to tighten the exposure standards. (See the “Calendar of Federal Regulations," published in the FEDERAL REGISTER [47 FR 1807] .)6 The OSHA regulations apply to all workplace activities involving asbestos, including removal of ACM from buildings. Future OSHA regulations may include separate exposure standards for ACM removal operations. The complete text of the OSHA regulations appears in Appendix F. OSHA’S worker exposure standards are inappropriate for nonindustrial settings. First, the standards were set to protect workers only against asbestosis, which does not occur at the lower exposure levels typical of buildings with ACM. Second, the measurement technique that determines OSHA compliance does not distinguish between asbestos and nonasbestos fibers and does not measure the small asbestos fibers typically found in buildings with ACM. The measurement problem is not a major shortcoming in industrial settings where most airborne fibers are expected to be asbestos. However, only a few fibers in building air are asbestos, and the OSHA measurements may be misleading, (Other limitations of the OSHA technique further confound the measurement of airborne asbestos in buildings. See Section 4.1.2 for a more detailed discussion of measuring airborne asbestos.) 6 As of July 1, 1976, the OSHA standards were set at 2 fibers per cubic centimeter averaged over 8 hours and a ceiling level not to exceed 10 fibers per cubic centimeter “at any time.” OSHA is now evaluating the effect of lowering the 8-hour standard to either 0,5 or 0.2 fibers per cubic centimeter in order to protect workers against cancer, as published in the FEDERAL REGISTER (47 FR 1807). 1-6 CHAPTER 2. DETERMINING IF ASBESTOS-CONTAINING MATERIAL (ACM) IS PRESENT IN BUILDINGS To determine if ACM is present in a building, examine construction records and conduct a thorough inspection of building materials. If asbestos is not present, no further action is required. If asbestos is found, however, a control program should be initiated. In either case, workers and other building occupants will be concerned. The building owner must be prepared to explain the purpose of the survey, its results, and plans for controlling ACM if it is present. SUMMARY Planning the Survey: A plan for conducting the ACM survey should include assembling the survey team and gaining cooperation of building management. The plan should also include a public information program. Conducting the Survey: The survey consists of checking building records and inspecting the building for evidence of ACM. Specific procedures differ for the three types of ACM, and may include sampling and analysis of suspect materials. 2.1 Planning the Survey The survey has four components: ● Reviewing building records for references to asbestos used in construction or repairs; ● Inspecting materials throughout the building to identify those that may contain asbestos; ● Sampling suspect materials for laboratory confirmation that asbestos is present; and ● Mapping the locations of all confirmed or suspected ACM. Thorough planning is essential because: ● The survey must provide accurate and reliable information; ● Questions from building occupants or the public about the survey and about asbestos in general must be answered quickly and responsively; ● Complete, accurate, unambiguous documentation of the survey and all test results is critical; and ● If ACM is found, the building owner must be prepared to initiate special operations and maintenance (O&M) practices immediately, and to develop other controls to minimize health risks (see Chapter 3). The importance of a well-planned public communications program cannot be over- emphasized. Asbestos is an exceptionally emotional issue. A building owner must clearly understand the purpose of the survey in order to anticipate and address the concerns of building occupants and the public. 2.1.1 Assembling the Survey Team Owners are ultimately responsible for asbestos-related problems in their buildings. The owner should appoint an asbestos program manager to direct all asbestos-related activities. The asbestos program manager 2-1