Purple Book (Guide for Controlling ACM in Buildings) Part 3 PDF

must be able to identify and assess the expertise of the diverse personnel required for an effective team. The asbestos program manager should communicate directly with the building owner. In addition, if ACM is present, the asbestos program manager will oversee the development of the asbestos contr...

must be able to identify and assess the expertise of the diverse personnel required for an effective team. The asbestos program manager should communicate directly with the building owner. In addition, if ACM is present, the asbestos program manager will oversee the development of the asbestos control program, and provide information to the public. The manager needs to become familiar with the use of ACM in buildings, the potential for building contamination by airborne asbestos, the health risks to building occupants, and options for controlling ACM. The manager needs a general understanding of all the issues in order to review technical tasks and judge whether they are being performed properly. If the building owner has no experienced person on his staff, he should consider hiring a qualified consultant. The program manager’s responsibilities include: ● Implementing a training program for the ACM survey if the survey is to be conducted in-house; ● Selecting a technical advisor to conduct the ACM survey if an outside consultant is needed; ● Selecting a laboratory to analyze samples of material from the building; ● Designing a system to document all information about asbestos in the building; and ● Developing a communications package for discussions with building occupants and others. If ACM is found, the asbestos program manager should also be prepared to initiate special operations and maintenance (O&M) practices (see Chapter 3), assess the need for other control measures (see Chapters 4 and 5), and oversee abatement projects if additional corrective action is necessary (see Chapter 6). The duties and responsibilities of the manager continue until all ACM is removed from the building. An asbestos survey team should be assembled under the direction of the asbestos program manager. Figure 3 illustrates the organization of the team. The building architect, the facilities (or physical plant) manager, and the head of building maintenance are obvious choices due to their knowledge of building records and facilities. Maintenance and engineering staffs may also be team members since they likely will conduct the survey. If an outside technical advisor is hired to conduct the survey, he or she would be a member of the team. Other team members acting primarily as special advisors would include an attorney and a risk manager (i.e., a person responsible for insurance). As indicated by Figure 3, the asbestos program manager should seek advice from the EPA Regional Asbestos Coordinator (RAC). (Addresses and telephone numbers for the 10 RACs are listed in Appendix D.) The RAC has information on ACM surveys, technical advisors, consultants, laboratories for analyzing samples of building materials, training programs, and abatement contractors. The asbestos program manager should attend one of the asbestos control training courses offered by universities and private organizations. Currently, EPA-sponsored programs are offered in conjunction with Georgia Institute of Technology, Kansas University and Tufts University. The RAC is the best source of further information regarding these programs and others which may be available in each Region. If a technical advisor will be hired to conduct the survey, the asbestos program manager should require evidence of experience and/or training. Examine references, especially those provided by other building owners. Be sure the advisor has a reputation for being thorough. Most survey errors involve overlooking building areas where there could be ACM. Asbestos control advisors include specially trained engineers, architects, and industrial hygienists. If ACM is found, the technical advisor may assist with the continuation of the control program. In that case, the advisor should also have experience in developing a special O&M program, assessing the need for additional corrective action, and monitoring abatement projects. Additional information on selecting technical advisors is provided in Chapters 3 and 4. 2-2 Advisors ● Attorney ● Risk Manager -------------- Facilities Manager Asbestos Program Manager -------------- Building Architect Maintenance Director Survey Staff (in-House or Outside Technical Advisor) Figure 3. Composition of the ACM survey team. EPA Regional Asbestos Coordinator 2.1.2 Obtaining Cooperation An ACM survey will be successful only if everyone in building management cooperates. Most importantly, the building owner must be convinced that exposure to asbestos is potentially a serious problem, and that a careful survey for ACM is needed. The asbestos program manager and the building owner must have a close working relationship. Beyond this, cooperation must be obtained from building maintenance, operations, and planning personnel. A survey for ACM can disrupt normal building activities. Occupants will be concerned and curious. The survey team must be prepared to discuss the purpose of the survey in a way that is realistic, yet does not cause undue anxiety. Questions requiring a lengthy response should be referred to the program manager. 2.2 Conducting the Survey The survey involves a review of building records and an inspection of the building for friable materials. The inspection is the more important component of the survey since building records are often incomplete and unreliable. Whenever the presence of asbestos is in doubt, prudence is recommended: treat the material as if it contains asbestos. 2.2.1 General Survey Elements Figure 4 illustrates the survey steps. Begin by reviewing building records to see if ACM was specified at any stage. Although building records are often unreliable, they are a useful starting point. Check the original plans, shop drawings, remodeling records, and work change orders. Appendix A is a list of the most common uses and types of ACM in buildings since 1960. If any of these items appears in the records, assume that asbestos is in the building. Identify ACM mentioned in building records by type: (1) troweled-or sprayedon surfacing material, (2) pipe and boiler insulation, or (3) other miscellaneous ACM. Next, inspect the building for ACM identified in the building records. Determine if the materials are friable and record the findings. They may be sampled and analyzed to confirm the presence of asbestos. Thoroughly inspect all areas of the building for friable materials and sample them. The specific procedures for inspection and sampling vary depending on which of the three types of material are involved. The sampler of building materials should wear a respirator to prevent inhalation of fibers. (See Section 5.1 for information on respirators.) 2.2.2 Procedures for Sprayed- or Troweled-on Surfacing Materials Surfacing materials can be friable or nonfriable. Friable forms are either very fibrous and fluffy (sometimes like cotton candy) or granular and cementitious (review Figure 1). Since friable materials are more likely than nonfriable materials to release fibers when disturbed, the first priority is to identify those friable surfacing materials that contain asbestos. As shown in Figure 5, the first step is to locate ACM specified in building records and determine its friability. Then, identify all friable surfacing materials in the building and take samples to be analyzed for asbestos. 2.2.2.1 Surfacing Materials identified as ACM in Building Records Begin by locating any acoustical plaster or other surfacing materials that, according to building records, contain asbestos. Rub these materials to see if they crumble or produce a light powder. If so, consider them friable. (When disturbing material that may contain asbestos, the inspector should wear protective equipment.) Either assume that these materials contain asbestos, or sample and analyze them, as discussed below. Record the location and degree of friability. 2-4 Figure 4. Initial Steps in an ACM Survey. 2.2.2.2 Other Surfacing Materials That May Contain Asbestos Conduct a thorough building inspection for friable materials on walls, ceilings, beams, ducts, and any other surface. Rub the material to see if it is friable. FolIowing Figure 5, group any friable material into “homogeneous” areas for further study.1 A homogeneous area contains friable material that seems by texture and color to be uniform. If materials appearing uniform were installed at different times, designate the two materials as distinct homogeneous areas. Once homogeneous areas of friable materials have been delineated and recorded on floor plans, collect samples of the materials and send them to a qualified laboratory. Sampling and analysis should be conducted according to the following guidelines:2 ● Appoint a coordinator to oversee the entire sampling and analysis operation and quality assurance program. The asbestos program manager or technical expert may assume this role. ● Choose a qualified laboratory to analyze the samples (see Appendix G.2). The approved method of bulk sample analysis for asbestos is polarized light microscopy. In certain cases, X-ray diffraction may be required to confirm the presence of asbestos. ● Collect at least three core samples of material in each homogeneous sampling area. Select sampling locations that are representative of the homogeneous area. (Either select locations evenly distributed throughout the area or choose the locations by a random selection method such as the one described in USEPA 1980a. It is important that three samples not be collected in the same location.) Remember that everyone taking samples should wear a respirator. ● Collect at least 1 quality control (QC) sample per building or 1 QC sample per 20 samples, whichever is larger. A QC sample is taken from the area abutting a regular sample. (The two samples are referred to as “side-by-side samples.”) The QC sample should be analyzed at a second laboratory to confirm the results of the primary laboratory. ● Label all samples with an identifying code and keep a code log. To avoid bias, the laboratory analyst should not know the origin of the samples. ● Asbestos is present if the material analyzed is more than one percent asbestos by weight. Record the results of the sampling and analysis program and save the records indefinitely. If no asbestos is found in these materials, no further action is necessary for this category of ACM. If asbestos is present, then an asbestos control program should be developed as described in Chapters 3 and 4. 2.2.3 Procedures for Pipe and Boiler Insulation Asbestos-containing insulation is found on equipment containing hot air or liquid — pipes, boilers, tanks, and sometimes ducts. These insulation materials may be a chalky mixture of magnesia and asbestos, preformed fibrous asbestos wrapping, asbestos fiber felt, corrugated paper, or insulating cement. In most cases, the insulating material is covered with a protective jacket of cloth, tape, paper, metal, or cements 1 The Asbestos-in-Schools rule allows schools to skip the sampling and analysis steps by assuming that any friable materials found in the building contain asbestos. The location of all friable materials must be documented and all affected parties must be notified whether asbestos is assumed to be present or confirmed by laboratory analysis. Nonfriable materials are not addressed by the Asbestos-in-Schools rule. 2 Specific procedures for sampling and analyzing friable materials in schools were presented in the Asbestos-inSchools rule. These procedures are consistent with the guidelines presented here. 3 ACM sprayed on ducts should be considered surfacing material. 2-6