HomeMy WebLinkAboutFile Documents.1001 E Cooper Ave.0082.2019.ARBK 1
HealthSafe Inspections Inc
390 Apple Drive
Basalt CO 81621
970-920-2100
Jim Baker
CDPHE Asbestos Building Inspector, Asbestos Air Monitoring Specialist (AMS) &
Project Designer Certification #13437
CDPHE Lead-Based Paint Inspector & Lead Hazard Assessor Certification #23607
ASBESTOS REPORT
DATE
02/15/2019
CLIENT
Richie Pearlstone
c/o Viking Construction, LLC.
127 Aspen Village
Aspen CO 81611
PROPERTY ADDRESS
1001 East Cooper Avenue, The Villager Townhome #2, Aspen, Colorado 81611
02/25/2019
2
CLIENT BACKGROUND & CONCERNS
The Client, Richie Pearlstone, hired HealthSafe Inspections, Inc. (hereinafter,
HealthSafe) to perform an interior unlimited asbestos inspection for a complete gut of the
interior of the two-floor townhome. The inspection exempts exterior materials.
VISUAL INSPECTION & LABORATORY FINDINGS
An inspection was conducted by Jim Baker of HealthSafe on Wednesday, February 13,
2019 with Jay DeWire present during the inspection and sample collecting. All interior
suspect asbestos containing materials (ACM) or suspect asbestos containing building
materials (ACBM) were identified by their respective homogenous materials reflecting
the same in consistency, appearance and application/installation date(s) and sampled
randomly respective to the scope of those materials slated for disturbance-demolition-
disposal (DDD). Those materials collected and analyzed by EPA 600 Method PLM
analysis are the following:
1. Flat-Skim Coat Surfacing Material, a homogeneous trowel-applied surfacing
material/texture [samples 1-7: F-1,2,3,4,5,6,7], collected from the ground-floor
bedroom south wall west side, mid-hallway ground-floor ceiling, ground-floor
NW bedroom west wall, living room east wall north end, second-floor master
closet west wall, kitchen bar north wall and living room east wall south of
fireplace, respectively, using the AHERA random sampling grid #9. This
surfacing material/texture is on ceilings and walls of the entire two-floor interior.
The estimated impact area of DDD is more than 1,000 sf, but less than 5,000 sf,
requiring a minimum of at least five surfacing/texture material samples, but in
case it goes over 5,000 of surface area, seven samples were collected. The PLM
analytical estimated results: NONE DETECTED in six of the seven samples with
<1% Chrysotile asbestos in sample 6 which was reanalyzed using the EPA 400
Point Count method with results of 0.25% Chrysotile asbestos in sample 6.
2. Drywall System Joint Compound: a homogeneous miscellaneous seam taping
compound requiring at least two samples [samples 8-9: F-JC-1,2], collected from
the kitchen doorway outside corner and mid-stairwell outside banister corner,
respectively. This material is applied to the original drywall system during
construction of the unit. The PLM analytical estimated results: NONE
DETECTED.
3. Composite-Layered Drywall System, a homogeneous taped and joint
compounded drywall system (classified as a miscellaneous material as a complete
integral system) [samples 10-11: F-J-1,2], collected from the ground-floor
hallway closet NE inside corner and the second-floor master closet NW inside
corner, respectively. These composite layered taped and joint compounded
drywall materials are on ceilings and walls of the townhome interior with a flat
skim coat applied surfacing material/texture. The estimated impact area of DDD
is more than 1,000 sf, but less than 5,000 sf, requiring a minimum of at least two
02/25/2019
3
composite core samples of all drywall layers from each floor level in conjunction
with the joint compound samples in paragraph #2 above. The PLM analytical
estimated results: NONE DETECTED in sample 10 and <1% Chrysotile asbestos
in sample 11 joint compound with composite results of <0.25% Chrysotile
asbestos.
A total of 11 suspect homogeneous ACM/ACBM bulk samples were collected and 11
samples were analyzed by the EPA 600 method and 1 sample analyzed by the EPA 400
Point Count method by a NVLAP accredited laboratory in accordance with Colorado
State Regulation 8 for the presence of asbestos mineral fibers.
See supporting Hayes Microbial Consulting, Inc. data report #19006172.
HEALTHSAFE CONCLUSIONS
• There is Chrysotile asbestos in one out of seven surfacing material samples with
point count results of 0.25% Chrysotile asbestos and one composite sample with
Chrysotile asbestos in the joint compound with composite results of <0.25%. NO
State permitted asbestos abatement is required, as the drywall materials are below
the CDPHE Regulation 8 trigger level of over 1%. However, since friable
asbestos fibers (during a demolition) are present in some of the drywall materials,
OSHA regulations shall apply, as disturbing, demolishing and disposing of these
materials creates an OSHA Class II Friable Asbestos Work condition. See EPA 40
CFR 763.121 Worker Protection Rule, OSHA 29 CFR 1910.134 Respirator
Protection Standard, OSHA 29 CFR 1910.1001 General Industry Standard and
OSHA 29 CFR 1926.1101 Construction Standard regulations when dealing with
asbestos hazards.
• There were no other suspect asbestos containing building materials identified
inside the townhome.
Sincerely Submitted,
Jim Baker
COLORADO & FEDERAL ASBESTOS REGULATIONS SUMMARY
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4
Regulation No. 8 Part B – Asbestos of the Colorado Department of Public Health and
Environment (CDPHE), Air Quality Control Commission requires a State-certified
Asbestos Building Inspector to inspect and collect bulk samples of all suspect asbestos
containing materials (ACM) or suspect asbestos containing building materials (ACBM)
prior to their disturbance, removal or demolition and disposal. The suspect materials shall
be analyzed by a NVLAP accredited laboratory by polarized light microscopy (PLM)
using EPA 600 analytical method. A material which is estimated to contain more than 1%
asbestos is classified as ACM/ACBM and regulated by the State and Federal
governments. Any friable (able to crush or reduce to powder by finger pressure) asbestos
with trace amounts of asbestos fibers or less than 1% must be point-counted using EPA
400 analytical method to prove that it is indeed less than 1%; if not, it must be classified
as ACM/ACBM and shall be treated as a State and Federal regulated material. Any
friable asbestos containing material (greater than 1% asbestos concentration) or
ACM/ACBM that could be rendered friable during its removal or demolition and disposal
shall require an asbestos abatement by a certified asbestos abatement contractor to
remove and dispose of the material(s).
A Colorado State (CDPHE) issued asbestos abatement permit is required for the
following trigger levels of ACM/ACBM:
1. Residential buildings of four or fewer units--if more than 32 square feet of any
surface coverage (e.g., gypsum wallboard or drywall and associated applied surfacing
materials/textures, acoustic sprays, joint compounds, plaster, etc.), 50 feet of asbestos
covered or asbestos insulated pipe or any material which would fill a 55-gallon drum is
going to be disturbed, removed or disposed of, an asbestos abatement permit is required.
2. Residential complexes with more than four residential units, public access areas to a
residential building, commercial and retail buildings, public and civic buildings,
industrial buildings--if more than 160 square feet of surfacing materials, 260 linear feet
or more than 35 cubic feet (NESHAP) or 55-gallon drum (CDPHE) of suspect
ACM/ACBM is going to be disturbed, removed or disposed of, an asbestos abatement
permit is required under NESHAP and by the CDPHE. See note below on OSHA.
The regulations require an absolute minimum of 3 samples (EPA suggests 9) per
homogenous suspect surfacing and TSI materials and an absolute minimum of 2 samples
of homogenous miscellaneous materials or any number of “samples sufficient to
determine whether a material is ACM” (Reg8.IV.D.3). More samples are required based
on surface area or volume. These are minimums; the asbestos building inspector has the
field responsibility to determine homogenous materials and the number of samples to
collect per material; more than the minimum number of samples may be necessary at the
discretion of the inspector. An assessment of friability and functional space conditions of
the materials are also the inspector’s field responsibilities.
OSHA compliance is required for all employers and employees no matter the
quantity of asbestos present with strict regulations regarding 10 sf or more of TSI or
friable surfacing materials, and therefore it does not matter what the quantity or
State trigger levels are: all suspect ACM/ACBM shall be inspected and tested for
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5
asbestos prior to their disturbance, removal and disposal for worker protection and
safety. See EPA 40 CFR 763.121 Worker Protection Rule, OSHA 29 CFR 1910.134
Respirator Protection Standard, OSHA 29 CFR 1910.1001 General Industry Standard and
OSHA 29 CFR 1926.1101 Construction Standard regulations when dealing with asbestos
hazards.
Note: County or City regulations may be more stringent.
02/25/2019
HMC #19006172
contact@hayesmicrobial.com
http://hayesmicrobial.com/
Analysis Report prepared for
HealthSafe Inspections
390 Apple Drive
Basalt, CO. 81621
Phone: 970-920-2100
Job Name: Richie Pearlstone
1001 E Cooper Ave, #2
Aspen, CO 81611
Date Sampled: 02-13-2019
Date Analyzed: 02-15-2019
Report Date: 02-15-2019
EPA Laboratory ID# VA01419
NVLAP Lab Code: 500096-0 Asbestos License: 300435 License: #PH-0198
Page 1 of 6
02/25/2019
HMC #19006172
HealthSafe Inspections
390 Apple Drive
Basalt, CO 81621
February 15, 2019
Client Job Number:
Client Job Name:Richie Pearlstone
1001 E Cooper Ave, #2
Aspen, CO 81611
Dear HealthSafe Inspections,
We would like to thank you for trusting Hayes Microbial for your analytical needs. On February 14, 2019 we received 12 samples by FedEx for the job
referenced above. 12 samples were received in good condition.
The results in this analysis pertain only to this job, collected on the stated date and should not be used in the interpretation of any other job. This report
may not be duplicated, except in full, without the written consent of Hayes Microbial Consulting, LLC.
This laboratory bears no responsibility for sample collection activities, analytical method limitations, or your use of the test results. Interpretation and
use of test results are your responsibility. Any reference to health effects or interpretation of mold levels is strictly the opinion of Hayes Microbial
Consulting. In no event, shall Hayes Microbial Consulting or any of its employees be liable for lost profits or any special, incidental or consequential
damages arising out of your use of the test results.
Steve Hayes, BSMT(ASCP)
Laboratory Director
Hayes Microbial Consulting, LLC
Page 2 of 6
02/25/2019
HMC #19006172
EPA 600/R-93, M-4/82-020 (PLM)HealthSafe Inspections
390 Apple Drive
Basalt, CO 81621
Phone: 970-920-2100
Job Number:
Collected by:
Email:
Jim Baker
healthsafeinspections@gmail.com
Job Name:Richie Pearlstone
1001 E Cooper Ave, #2
Aspen, CO 81611
Date Collected:
Date Received:
Date Reported:
02/13/2019
02/14/2019
02/15/2019
#Sample Name Description Asbestos Fibers Other Fibers Non- Fibers
1 1 F-1 Brittle / White
(None Detected)
2 % Cellulose fibers
98 %
2 2 F-2 Brittle / White
(None Detected)
2 % Cellulose fibers
98 %
3 3 F-3 Brittle / White/Brown
(None Detected)
10 % Cellulose fibers
90 %
4 4 F-4 Brittle / White/Brown
(None Detected)
10 % Cellulose fibers
90 %
5 5 F-5 Brittle / White/Brown
(None Detected)
10 % Cellulose fibers
90 %
6 6 F-6 Brittle / Tan
<1 % Chrysotile
(None Detected)
100 %
7 7 F-7 Brittle / White
(None Detected)
5 % Cellulose fibers
95 %
8 9 F-JC-1 Joint Compound / White
(None Detected)
(None Detected)
100 %
9 9 F-JC-2 Joint Compound / White
(None Detected)
(None Detected)
100 %
10 10 F-J-1 Drywall / Light Pink/ Brown
(None Detected)
10 % Cellulose fibers
90 %
Layer 2 F-J-1 Joint Compound / White
(None Detected)
(None Detected)
100 %
Signature: Date:02/15/2019 Reviewed by: Date:02/15/2019
Page 3 of 6
02/25/2019
HMC #19006172
EPA 600/R-93, M-4/82-020 (PLM)HealthSafe Inspections
390 Apple Drive
Basalt, CO 81621
Phone: 970-920-2100
Job Number:
Collected by:
Email:
Jim Baker
healthsafeinspections@gmail.com
Job Name:Richie Pearlstone
1001 E Cooper Ave, #2
Aspen, CO 81611
Date Collected:
Date Received:
Date Reported:
02/13/2019
02/14/2019
02/15/2019
#Sample Name Description Asbestos Fibers Other Fibers Non- Fibers
Layer 3 F-J-1 Drywall/J.Compound / White/Brown
(None Detected)
12 % Cellulose fibers
88 %
Notes: Composite of Drywall and Joint Compound.
11 11 F-J-2 Drywall / White/Brown
(None Detected)
12 % Cellulose fibers
88 %
Layer 2 F-J-2 Joint Compound / Tan
<1 % Chrysotile
(None Detected)
100 %
Layer 3 F-J-2 Drywall/J.Compound / Tan/Brown
<0.25 % Chrysotile
(None Detected)
100 %
Notes: Composite of Drywall and Joint Compound.
Signature: Date:02/15/2019 Reviewed by: Date:02/15/2019
Page 4 of 6
02/25/2019
HMC #19006172
EPA 400 Point CountHealthSafe Inspections
390 Apple Drive
Basalt, CO 81621
Phone: 970-920-2100
Job Number:
Collected by:
Email:
Jim Baker
healthsafeinspections@gmail.com
Job Name:Richie Pearlstone
1001 E Cooper Ave, #2
Aspen, CO 81611
Date Collected:
Date Received:
Date Reported:
02/13/2019
02/14/2019
02/15/2019
#Sample Name Description Asbestos Fibers Other Fibers Non- Fibers
6 6 F-6 Brittle / Tan
0.25 % Chrysotile
(None Detected)
99.75 %
Signature: Date:02/15/2019 Reviewed by: Date:02/15/2019
Page 5 of 6
02/25/2019
HMC #19006172
Asbestos - Additional InformationHealthSafe Inspections
390 Apple Drive
Basalt, CO 81621
Phone: 970-920-2100
All samples were received in acceptable condition unless otherwise noted on the report. This report must not be used by the client to claim product certification, approval, or
endorsement by AIHA, NIST, NVLAP, NY ELAP, or any agency. The results relate only to the items tested. Hayes Microbial Consulting reserves the right to dispose of all samples
after a period of 60 days in compliance with state and federal guidelines.
All Polarized Light Microscopy (PLM) results include an inherent uncertainty of measurement associated with estimating percentages by PLM. Measurement uncertainty data can be
provided when requested.
'None Detected' - Below the detected reporting limit of 1% unless point counting is performed, then the detected reporting limit is .25%.
Per NY ELAP198.6 (NOB), TEM is the only reliable method to declare an NOB material as Non-Asbestos Containing.
Any NY ELAP samples that are subcontracted to another laboratory will display the name and ELAP Lab Identification number in the report page heading of those samples. The
original report provided to Hayes Microbial Consulting is available upon request.
Signature: Date:02/15/2019 Reviewed by: Date:02/15/2019
Page 6 of 6
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SUMMARY OF
OSHA ASBESTOS STANDARD
29CFR1926.1101
Contents
(a)Scope and Application ............................................................... 100
(b)Definitions ...................................................................................100
(c)Permissible Exposure Limits ....................................................100
(d)Multi-employer Worksites ..........................................................100
(e)Regulated Areas .........................................................................101
(f)Exposure Assessment and Monitoring ....................................101
(g)Methods of Compliance .............................................................102
(h)Respiratory Protection ...............................................................106
(i)Protective Clothing ....................................................................107
(j)Hygiene Facilities and Practices ...............................................108
(k)Communication of Hazards .......................................................109
(l)Housekeeping .............................................................................112
(m)Medical Surveillance ..................................................................113
(n)Recordkeeping ...........................................................................114
(o)Competent Person .....................................................................115
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(a) Scope and Application
(b) Definitions
Asbestos is defined as including chrysotile, amosite, tremolite asbestos,
anthophyllite asbestos, and actinolite asbestos. In addition, presumed asbestos
containing material (PACM) is also treated as asbestos. PACMs include thermal
system insulation (TSI) and surfacing material found in buildings constructed
no later than 1980.
Negative Exposure Assessment is defined as a demonstration by the employer
that employee exposure during an operation is or will be consistently below the
PELS.
Activities involving exposure to ACMs and PACMs have been divided into four
classifications. They are as follows:
Class I asbestos work means activities involving the removal of TSI and
surfacing ACM and PACM.
Class II asbestos work means activities involving the removal of ACM which is
not thermal system insulation or surfacing material. This includes, but is not
limited to, the removal of asbestos containing wallboard, floor tile and sheeting,
roofing and side shingles, and construction mastics.
Class III asbestos work means repair and maintenance operations, where ACM
is likely to be disturbed.
Class IV asbestos work means maintenance and custodial activities during
which employees contact but do not disturb ACM or PACM, and activities to
clean up dust, waste, and debris result from Class I, II, and III activities.
(c) Permissible Exposure Limits
Permissible Exposure Limit (PEL) – The employer must ensure that no
employee is exposed to airborne concentrations of asbestos greater than 0.1
f/cc as measured over an eight hour time period.
Excursion Limit (EL) – The employer shall ensure that no employee is
exposed to an airborne concentration of asbestos greater than 1.0 f/cc as
measured over a 30 minute period.
(d) Multi-employer Worksites
On multi-employer worksites, an employer performing work requiring the
establishment of a regulated area shall appropriately inform all other employers.
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Employers of employees working adjacent to regulated areas must take
measures on a daily basis to ensure that their employees are not being exposed
to asbestos fibers. All general contractors are responsible for ensuring that the
asbestos contractor is in compliance with the standard.
(e) Regulated Areas
All Class I, II, and III work must be conducted within regulated areas. Other
operations must be conducted within regulated areas whenever airborne
concentrations of asbestos exceed the PEL. Regulated areas must comply with
the following requirements:
Demarcation – Critical barriers, negative-pressure enclosures, and signs may
all serve to demarcate the regulated area.
Access – Only authorized persons shall enter regulated areas.
Respirators – When respirators are required, all persons entering a regulated
area must be supplied appropriate respirators.
Prohibited Activities – The employer shall ensure that employees do not eat,
drink, smoke, chew tobacco or gum, or apply cosmetics in the regulated area.
Competent Persons – The employer shall ensure that all asbestos work
performed within regulated areas is supervised by a competent person.
(f) Exposure Assessments and Monitoring
1. General Monitoring
Employee exposure shall be determined from breathing zone air samples
that are representative of the 8-hour and 30-minute exposures of each
employee.
2. Initial Exposure Assessment
i. competent person shall conduct all exposure assessment immediately
before or at the initiation of the operation to ascertain expected
exposures.
ii. Unless a negative exposure assessment has been made, the initial
exposure assessment shall be based on monitoring results. For Class I
work, the employer shall presume that employees are exposed in excess of
the TWA and excursion limit until monitoring results or a negative
exposure assessment document that the employees on the job will not be
exposed in excess of the PEL.
iii.Negative exposure assessment can be determined by:
A. objective data demonstrating that exposures cannot exceed the PEL/EL;
B. data obtained from previous similar jobs within the last 12 months; or
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C. results of initial exposure monitoring.
3. Periodic Monitoring...
i.Class I and II work – daily monitoring is required unless negative exposure
assessment.
ii. Non-Class I and II work – periodic monitoring where exposures are
expected to exceed the PEL/EL.
iii.Exception to monitoring – when all employees are wearing supplied air
respirators operated in the pressure-demand mode.
4. Termination of Monitoring...
i. allowed if statistically reliable results of monitoring show exposure levels
to be below the PEL/EL.
ii.disallowed whenever there has been a change in process, control
equipment, personnel, or work practices that may result in increased
levels of exposure.
5. Employee Notification of Monitoring Results...
i.employees shall be notified as soon as possible as to monitoring
results.
ii.notification shall be done in writing either individually or by posting at a
centrally located place that is accessible to affected employees.
6. Observation of Monitoring...
i.employees and their representatives have the right to observe any
monitoring.
ii.observers shall be provided with and required to wear any protective
clothing and equipment applicable.
(g) Methods of Compliance
1. The following engineering controls and work practices are required for all
ACM work, regardless of levels of exposure.
i.HEPA-vacuums.
ii.use of wet methods except where such methods create a greater hazard.
iii. prompt clean-up and disposal of waste in leak-tight containers except in
some roofing operations.
2. In order to meet the PEL/EL, the following control methods are also
required.
i.HEPA equipped local exhaust ventilation.
ii.enclosure/isolation of the work area.
iii.ventilation of the regulated area.
iv.other feasible work practices and engineering controls.
v.respirators to be used as supplemental measure.
3. Prohibitions...
i.high-speed abrasive disc saws not equipped with ventilator, or
enclosures without HEPA filtered air.
ii.compressed air, unless used in conjunction with an enclosed ventilation
system designed to capture the dust cloud created.
iii.dry sweeping, shoveling, or other dry clean-up methods.
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iv.employee rotation as a means of reducing employee exposure.
4. Class I Requirements...
i.all work must be supervised by a competent person.
ii.One of the following methods must be used to assure airborne fibers do
not migrate from the regulated area.
A. critical barriers placed over all openings to the regulated area except
in outdoor situations.
B. other verifiable barrier or isolation methods.
iii.HVAC systems shall be isolated in the regulated area by sealing with a
double layer of 6 mil plastic.
iv.impermeable dropcloths shall be placed beneath all removal activity.
5. Specific Control methods for Class I Work...
i.Negative Pressure Enclosure (NPE) systems shall be used whenever
feasible.
A. Specifications...
1. NPE may be of any configuration.
2. minimum of 4 air exchanges per hour.
3. minimum of -0.02 column inches of water pressure differential
must be maintained.
4. NPE shall be kept under negative pressure at all times.
5. air shall be ventilated away from employees toward HEPA device.
B. Work Practices...
1. NPE shall be inspected for breaches and smoke-tested for leaks
before beginning work and at the beginning of each shift.
2. electrical circuits in the enclosure shall be deactivated, unless
equipped with ground-fault circuit interrupters.
ii.Glovebag Systems shall be used for removal from straight runs of piping
and elbows and other connections.
A. Specifications...
1. glovebags shall be made of 6 mil plastic and shall be seamless at
the bottom.
2. glovebags used on elbow and other connections must be designed
for that purpose.
B. Work Practices...
1. glovebag shall completely cover the circumference of the pipe.
2. smoke-testing for leaks is required prior to use.
3. glovebag may only be used once and cannot be moved.
4. glovebag shall not be used on surfaces over 150 F.o
5. prior to disposal, removal of air from glovebag using HEPA-vac is
required.
6. before beginning, loose and friable material adjacent to the work
area shall be wrapped and sealed in two layers of 6 mil plastic.
7. when using an attached waste bag, such a bag shall be connected
to a collection bag using hose or other material which can
withstand the weight of all waste.
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8. a sliding valve or other device shall separate waste bag
from hose to ensure no exposure during disconnection.
9. minimum of two persons shall perform Class I work. Other
systems specified include: negative pressure glovebag; negative
pressure glove box; water spray process; and mini-enclosure.
6. Alternative control methods for Class I work are allowed providing they are
certified by a qualified individual.
7. Work practices and engineering controls for Class II work
i All work shall be supervised by a competent person.
ii.For all indoor Class II jobs without a negative exposure assessment, or
where conditions changed during the job in such a way that the PEL/EL
may be exceeded, or where the material is not removed in a substantially
intact state, the employer shall use one of the following methods:
A. critical barriers shall be used.
B. alternative barrier or isolation methods are allowed as verified by
perimeter area monitoring or clearance monitoring.
C. impermeable drop cloths shall be placed beneath all removal activity.
iii.reserved
iv.applicable work practices and requirements shall be followed.
8. Additional controls for Class II work
i.For removing vinyl and asphalt flooring materials containing ACM/PACM,
the following practices apply...
A. flooring or its backing shall not be sanded.
B. vacuums equipped with HEPA filter, disposable dust bag, and metal
floor tool (no brush) shall be used to clean floors.
C. resilient sheeting shall be removed by cutting with wet methods, rip-
up methods are prohibited.
D. all scraping of residual adhesive and/or backing shall be done using
wet methods.
E. dry sweeping is prohibited.
F. mechanical chipping is prohibited unless done in a negative pressure
enclosure.
G. tiles shall be removed intact, unless employer demonstrates that
intact removal is not possible.
H. when tiles are heated and can be removed intact, wetting may be
omitted.
I. resilient flooring material including its mastic and backing shall be
assumed to be an ACM unless proven otherwise by an industrial
hygienist.
ii.For removing roofing material that are ACM, the following work practices
apply...
A. roofing material shall be removed intact to the extent feasible.
B. wet methods shall be used to remove materials that are not intact, or
will be rendered not intact, unless not feasible or will create safety
hazards.
C. cutting machines shall be continuously misted during use, unless a
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competent person determines that misting substantially decreases
worker safety.
D. all loose dust left by sawing must be HEPA-vacuumed and bagged or
placed in covered containers immediately.
E. ACM from a roof shall not be dropped or thrown to the ground:
1. ACM not intact shall be lowered to the ground as soon as
practicable, no later than the end of the work shift. While on roof it
shall either be kept wet or covered in plastic.
2. intact ACM shall be lowered to he ground as soon as practicable,
no later that the end of the work shift.
F. after being lowered, unwrapped material shall be transferred to a
closed receptacle
G. roof level heating and ventilation air intake sources shall be isolated
or the ventilation system shall be shut down.
H. removal or repair of intact roofing less than 25 square feet in area (per
day) does not require use of wet methods or HEPA vacuuming as long
as material is not rendered non-intact. and no visible dust is created
iii.For removal of cementitious asbestos-containing siding, shingles, or
panels on building exteriors other than roofs, the following work
practices apply...
A. cutting, abrading, or breaking of siding, shingles, or transite panels
shall be prohibited unless employer can demonstrate that other
methods cannot be used.
B. each panel or shingle shall be sprayed wit amended water prior to
removal.
C. unwrapped or unbagged panels or shingles shall be immediately
lowered tot he ground via covered, dust-tight chute, crane or hoist, or
placed in an impermeable waste bag or wrapped in plastic sheeting
and lowered to the ground no later than the end of the work shift.
D. nails shall be cut with flat, sharp instruments.
iv.For removal of gaskets containing ACM, the following work practices
apply...
A. if a gasket is visibly deteriorated and unlikely to be removed intact,
removal shall be done with a glovebag.
B. reserved
C. the wet gasket shall be immediately placed in a disposal container.
D. scraping to remove residue must be performed using wet methods.
v.For removal of any other Class II material, the following work practices
apply...
A. material shall be thoroughly wetted prior to and during removal.
B. material shall be removed intact unless the employer demonstrates
that intact removal is impossible.
C. cutting, abrading, or breaking the material shall be prohibited unless
the employer can demonstrate that other methods are not feasible.
D. material removed shall be immediately bagged, wrapped, or kept
wetted until transferred to a closed receptacle no later than the end of
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the work shift.
vi.Use of alternative work practices and controls are allowed if the following
provisions are complied with...
A. employer shall demonstrate with representative data that employee
exposure will not exceed the PEL/EL under any anticipated
circumstances.
B. a competent person shall evaluate and certify in writing that the
method meets necessary standards of operation.
9. Work practices and engineering controls for Class III work...
i.wet methods shall be used.
ii.whenever feasible, local exhaust ventilation shall be used.
iii.use of impermeable drop cloths and either min-enclosures or glovebags
is required whenever drilling, cutting, abrading, sanding, chipping,
breaking, or sawing TSI or surfacing materials.
iv.containment of work area is required when there is no negative exposure
assessment or monitoring results show the PEL has been exceeded.
v.respirators are required if TSI or surfacing material is being disturbed, or
if there is no negative exposure assessment, or if the PEL has been
exceeded.
10. Class IV work shall be conducted by employees who have completed an
asbestos awareness training program. In addition, Class IV work must be
done using wet methods, HEPA-vac, and prompt clean-up of debris...
i.employees shall wear respirators when working in areas that require
them.
ii.TSI and surfacing material waste and debris shall be assumed to be
asbestos containing.
(h) Respiratory Protection
1. The employer shall provide respirators and ensure that they are used under
the following circumstances...
i.all Class I work
ii.Class II work where the ACM is not removed in a substantially intact
state
iii.Class II and III work performed without using wet methods
iv.Class II and III work where the employer does not produce a negative
exposure assessment
v.Class III work where TSI or surfacing ACM/PACM is disturbed
vi.Class IV work performed in regulated areas where other employees are
required to wear respirators
vii.when employees are exposed above the PEL/EL
viii.in emergencies
2. Respirator Selection
i.When used, appropriately selected respirators are to be provided at no
cost to the employee. The employer shall ensure that the employee uses
the respirator provided.
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ii.Respirators must be approved by the National Institute for Occupational
Health and Safety (NIOSH).
iii.The employer shall provide a tight-fitting PAPR in lieu of any negative-
fitting respirator whenever:
A. an employee chooses to use this type of respirator;
B. the respirator will provide adequate protection; and
C. the employer shall inform any employee required to wear a respirator
of this right
iv.The employer shall provide a non-disposable, half-mask, air-purifying
respirator for Class II and III work where there is no negative pressure
assessment has been produced, and for Class III work where TSI or
surfacing ACM/PACM is disturbed.
v.The employer shall provide a tight-fitting PAPR or supplied-air, pressure-
demand respirator for Class I work without a NEA in which exposure
assessment indicates exposure level will not exceed 1 f/cc. A supplied-air,
pressure-demand respirator is required if the exposure assessment
indicates exposure levels above 1 f/cc.
3. Respiratory Program
i.The employer shall institute a respiratory program whenever respirators
are used.
ii.Employees are permitted to change filters whenever an increase in
breathing resistance is detected.
iii. Employees are permitted to leave work areas to wash their faces and
respirator facepieces whenever necessary to prevent skin irritation.
iv. If an employee’s most recent physical examination indicates that
respirator use would be unsafe, then the employee shall be assigned to
another job of equal pay if such a position is available.
4. Respirator Fit Testing
i.Employer ensures that the respirator issued to the employee fits
properly.
5. Either quantitative (QNFT) or qualitative (QLFT) fit tests are required at the
time of initial fitting and at least annually thereafter for each employee wearing
a respirator. The qualitative fit tests may only be used for fitting half-mask
respirators or full-face respirators where they are worn at levels at which half-
face respirators are permitted.
(i) Protective Clothing
1. Protective clothing is required for employees exposed to airborne asbestos in
excess of the PEL/EL, or where negative exposure assessment is not
produced, and for Class I work involving the removal of over 25 linear or 10
square feet of TSI or surfacing ACM/PACM.
2. Laundering shall be done by an informed individual in a manner that
prevents the release of fibers in excess of the PEL/EL.
3. Contaminated clothing shall be transported in sealed, impermeable bags or
containers and labeled appropriately.
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4. Inspection of Protective Clothing...
i.a competent person shall examine worksuits at least once per workshift.
ii. rips and tears shall be immediately mended or the worksuit shall be
immediately replaced.
(j) Hygiene Facilities and Practices
1. Requirements for Class I work involving over 25 linear or 10 square feet of
TSI or surfacing ACM/PACM...
i.A decontamination area shall be established adjacent and connected to
the regulated area. The employer shall ensure that employees enter and
exit the regulated area through the decon.
A. Equipment (Dirty) Room
B. Shower area shall be located adjacent to the equipment room and the
clean room. If the employer can demonstrate that it is not feasible to
locate a shower there, then the employer must ensure that employees
do not carry asbestos contamination outside the equipment room.
C. Clean change room shall be equipped with separate storage containers
for each employee.
ii.Decontamination Entry Procedures...
A. enter through the clean room.
B. remove and deposit street clothing in lockers
C. put on protective clothing and respirator before leaving clean room.
D. before entering regulated area, employees must pass through the
equipment room.
iii.Decontamination Exit Procedures...
A. before leaving the regulated area, remove all gross. contamination and
debris from protective clothing.
B. remove protective clothing in the equipment room.
C. respirators shall not be removed in the equipment room.
D. employees shall shower prior to entering the clean room.
E. after showering, employees shall enter the clean room before changing
into street clothes.
iv.Lunch Areas...
Whenever food or beverages are consumed at a Class I worksite,
the employer shall provide a lunch area in which airborne concentrations
of asbestos are below the PEL/EL.
2. Requirements for Class I work involving less that 25 linear or 10 square feet
of TSI or surfacing ACM/PACM, and for Class II and Class III work where
exposures exceed the PEL or EL or where the is no negative exposure
assessment prior to operation.
i.Equipment room shall be established adjacent to the regulated area. It
shall consist of an area covered by an impermeable drop cloth.
ii.The area must be large enough to accommodate cleaning of equipment
and removing of personal protective equipment without spreading
contamination.
iii.Work clothing must be cleaned with a HEPA-vacuum before it is removed.
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iv.All equipment and surfaces of containers filled with ACM must be
cleaned prior to removal from the area.
v.Employer shall ensure that employees enter and exit regulated area
through the equipment (dirty) room.
3. Requirements for Class IV work are the same as those for Class I work
involving less than 25 linear or 10 square feet of TSI or surfacing
ACM/PACM unless the area in which the work is being done is part of a
Class I operation involving greater than 25 linear or 10 square feet of TSI or
surfacing ACM/PACM, in which case the more stringent requirements must
be met.
4. No smoking is allowed in the work area.
(k) Communication of Hazards
1. For the purposes of this standard, employers and building owners are
required to treat TSI and sprayed or troweled-on surfacing materials in
buildings as ACM, wit the exception noted in this section. Asphalt and vinyl
flooring material installed no later than 1980 must also considered to be
ACM, unless proven otherwise. PACM is to be identified as ACM.
2. Duties of Building/Facility Owners...
i.determine the presence, location, and quantity of ACM/PACM prior to
work.
ii.written or direct verbal notification as to the presence, location, and
quantity of ACM/PACM must be made to:
A. prospective employers applying or bidding for work whose
employees reasonably can be expected to work in or adjacent to areas
containing such material;
B. employees of the owner who will work in or adjacent to areas
containing such material;
C. on multi-employer worksites, all employers of employees who will be
working within or adjacent to areas containing such material; and
D. tenants who will occupy areas containing such material.
3. Duties of employers whose employees perform work in or adjacent to areas
containing ACM/PACM and duties of building/facility owners whose
employees perform such work as follows:
i.employers shall identify the presence, location, and quantity of ACM/
PACM prior to work;
ii.prior to work, employers shall inform the following persons of the
location and quantity of ACM/PACM and the precautions to be taken –
A. owners of the building/facility
B. employees who will perform such work and employers of employees
who work and/or will be working in adjacent areas – and
iii.employers shall, within 10 days of the completion of work, inform the
building/facility owner and employers of employees who will be working
in the area of the current location and quantity of ACM/PACM remaining
in the area and final monitoring results, if any.
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DANGER
ASBESTOS
CANCER AND LUNG DISEASE HAZARD
AUTHORIZED PERSONNEL ONLY
4. Employers who discover ACM/PACM on a worksite shall inform owners and
other employees working at the site within 24 hours.
5. Criteria to rebut designation of PACM
i.At any time an employer or building owner may demonstrate that PACM
does not contain asbestos. This information does not have to be
communicated; however, the information, data, and analysis supporting
the determination on non-PACM shall be retained.
ii.Means of demonstrating that PACM does not contain more than 1%
asbestos are as follows:
A. having a complete inspection conducted that demonstrates that the
material is not ACM.
B. testing of PACM includes analysis of bulk samples by an accredited
inspector or CIH.
6. Signs shall be posted at the entrance to mechanical rooms/areas containing
TSI, and surfacing ACM/PACM. Signs shall identify the material, its
location, and appropriate work practices to avoid disturbing the material.
The employer shall ensure that signs can be understood by employees.
7. Signs...
i.warning signs shall be posted at an appropriate distance from regulated
areas.
ii.warning signs shall read –
when necessary, signs shall include –
RESPIRATORS AND PROTECTIVE CLOTHING
ARE REQUIRED IN THIS AREA
iii.employer shall ensure that employees comprehend the warning signs.
8. Labels...
i.labels shall be attached to all products containing asbestos and to all
containers holding such products.
ii.labels shall be printed in large, bold letters on a contrasting background.
iii.labels shall read –
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DANGER
CONTAINS ASBESTOS FIBERS
AVOID CREATING DUST
CANCER AND LUNG DISEASE HAZARD
iv.reserved
vi. labels are not required where –
A. asbestos fibers have been modified by a bonding agent, coating,
binder, or other material that will ensure that the PEL/EL will not be
exceeded.
B. asbestos content is less that 1.0 % by weight.
vii.Labels shall be placed where they will clearly be noticed by employees.
Appropriately placed may be posted instead of labels as long asa they
contain all the necessary labeling information. the employer shall
ensure that labels can be understood by employee.
9. Employee Information and Training
i.The employer shall institute, at no cost to the employee, a training
program for all employees who are likely to be exposed in excess of a PEL
and for all employees who install asbestos materials or preform Class I
through asbestos operations. The employer shall ensure employees’
participation.
ii.Training shall be provided prior to or at the time of initial assignment
and annually thereafter.
iii.Training for Class I operations and for Class II operations that require the
use of critical barriers and/or negative pressure enclosures shall be
equivalent to the EPA Model Accreditation Plan (MAP) asbestos
abatement worker training.
iv.Training for other Class II work...
A. Training for work involving ACM such as roofing, flooring, siding, or
transite panels should include all of the elements listed in section
(k)(9)(viii) and in addition, the work practices and engineering controls
set forth in part (g) specific to that generic category. This training shall
include a “hands-on” section and shall take at least 8 hours.
B. Employees working with more than one category of material shall
receive training applicable to each category of material.
C. Employees working with materials not listed in section (k)(9)(iv)(A)
shall be trained on the applicable work methods.
v.Training for Class III employees shall be consistent with EPA
requirements for training local education agency maintenance and
custodial staff as set forth at 40 CFR 763.92(a)(2). This training shall
include a “hands-on” section and take at least 16 hours. At the discretion
of the competent person, greater training requirements may apply.
vi.Training for employees performing Class IV operations shall be consistent
with EPA requirements for training local education agency maintenance
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and custodial staff as set forth at 40 CFR 763.92(a)(1). This course shall
include information as to the location of TSI and ACM/PACM, and
instruction in recognition of damage, deterioration, and delamination of
ACM. This course shall take at least 2 hours.
vii.Training for employees who are likely to be exposed in excess of the
PEL and are not otherwise required to be trained under paragraph
(k)(9)(iii) through (vi) of this section, shall meet the requirements of
paragraph (k)(9)(iii).
viii.Training programs shall be conducted in a manner that the employee
is able to understand. In addition to EPA MAP curriculum, the course
shall include the following information.
A. methods of recognizing asbestos.
B. health effects associated with asbestos exposure.
C. relationship between smoking and asbestos in producing lung cancer.
D. nature of operations that could result in exposure to asbestos, and
the importance of necessary protective controls to minimize exposure.
E. purpose, proper use, fitting instructions, and limitations of
respirators.
F. appropriate work practices.
G. medical surveillance program requirements.
H. content of this standard, including appendices.
I. names, addresses, and phone numbers of public health organizations
which provide information concerning smoking cessation.
J. requirements for posting signs and affixing labels.
10. Access to Training Materials...
i.free, written materials relating to the employee training program.
ii.employer shall provide to the Assistant Secretary and the Director, upon
request, all information and training materials relating to the employee
information and training program.
iii.self-help smoking cessation programs shall be made readily available.
(l) Housekeeping
1. Vacuuming
Vacuums must be HEPA filtered.
2. Waste Disposal
All asbestos wasted and contaminated materials shall be disposed of in
sealed, labeled, impermeable containers except in roofing operations where
the procedures specified in (g)(8)(ii) of this section apply.
3. Care of Asbestos-containing Flooring Material...
i.all vinyl and asphalt flooring shall be maintained in accordance with this
paragraph unless the owner demonstrates that the material is not
asbestos containing.
ii.sanding is prohibited.
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iii.stripping of finishes shall be done using low abrasion pads at speeds
lower than 300 rpm and wet methods.
iv.burnishing or dry buffing may be performed only on flooring which has
sufficient so that the pad cannot contact the flooring material.
4. Waste and debris and accompanying dust in an area with TSI or surfacing
material or visibly deteriorated ACM:
i.shall not be dusted or swept dry, or vacuumed without using a HEPA
filter; and
ii.shall be promptly cleaned up and disposed of in leak-tight containers.
(m) Medical Surveillance
1. General
i.Employees covered...
A. Employers shall institute programs that cover all employees who
spend 30 or more days per year doing Class I, II, or III work; or are
exposed at or above the permissible exposure limit for a combined 30
days or more per year. Any day in which a worker engages in Class II
or Class III work for one hour or less, in accordance with work
practices, shall not be counted.
B. For employees required to a negative pressure respirator, employers
must, under the supervision of a physician, shall ensure employees
are physically able to perform the work and use the equipment.
ii.Examination...
A. must be performed by a licensed physician at no cost to the employee.
B. anyone other than a licensed physician who administers the
pulmonary function test shall complete a training course in
spirometry.
2. Medical Examinations...
i.Examinations are to be conducted:
A. prior to beginning of work with a negative pressure respirator.
B. within 10 working days following the 30 day of exposure at or aboveth
the permissible exposure in one year, or when engaging in Class I, II,
or III work for a combined total of 30 or more days per year.
C. annually after initial exam
D. if the examining physician determines that more frequent
examinations are needed, employer shall provide such examinations.
E. no examination is required if employee records show that last
examination was within the past 1-year period.
ii.Medical examinations shall include:
A. medical and work history with special emphasis on pulmonary,
cardiovascular, and gastrointestinal systems.
B. on initial exam, the standardized questionnaire contained in Part 1 of
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Appendix D; on the annual examination, the abbreviated standardized
questionnaire contained in Part 2 of Appendix D.
C. physical examination directed at the pulmonary and gastrointestinal
systems, and a pulmonary test.
D. any other examinations or tests deemed necessary by the physician.
3. The employer shall provide the following information to the examining
physician...
i.copy of this standard and Appendices D, E, G, and I.
ii.description of the employee’s duties as the relate to his/her exposure.
iii.employee’s representative exposure level or anticipated exposure level.
iv.description of any personal protective and respiratory equipment used.
v.information from employee’s previous medical exams.
4. Physician’s Written Opinion...
i.Physician shall provide the employer with a written opinion
containing the following information:
A. any medical conditions that would place the employee at an increased
risk of material health impairment from exposure to asbestos.
B. any recommended limitations on the employee or on the use of
personal protective equipment.
C. statement that the employee has been informed by the physician of
the results of the examination and of any medical conditions that may
result from asbestos exposure.
D. statement that the employee has been informed by the physician of
the increased risk of lung cancer due to the combined effect of
smoking and asbestos exposure.
ii.The employer shall instruct the physician not to reveal i the written opinion
specific findings or diagnoses unrelated to the occupational exposure to
asbestos.
iii.The employer shall provide a copy of the physician’s written opinion tot he
employee within 30 days of receipt.
(n) Recordkeeping
1. Objective data for negative exposure assessment...
i.When the employer has relied on objective data to demonstrate that a
material and operation are not capable of releasing fibers of asbestos in
concentration greater that the PEL/EL, then such records shall be
maintained for the duration of the employer’s reliance upon such
objective data.
ii.records shall include the following information:
A. product qualifying for exemption;
B. source of the objective data;
C. testing protocol, test results;
D. description of the operation exempted; and
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E. other relevant data.
iii.records shall be maintained for the duration of the employer’s reliance
upon such objective data.
2. Exposure Assessments
Employer shall keep an accurate record of all measurements taken to
monitor employee exposure. These records shall be maintained for the
duration of employment plus 30 years.
3. Medical Surveillance
Employer shall maintain an accurate record of each employee’s
medical surveillance for the duration of employment plus 30 years.
4. Training records shall be maintained for 1 year beyond the last date of
employment.
5. When the employer has relied on data to demonstrate that PACM is not
asbestos-containing material, such data shall be maintained for as long as
they are relied upon.
6. When the building owner has communicated and received information
concerning identification, location, and quantity of ACM/PACM, written
records of such notifications shall be maintained by the building owner for t
he duration of ownership and shall be transferred to successive owners.
7. Availability of Records...
i.upon written request, the employer shall make all records available to
OSHA.
ii.exposure records shall be made available to affected employees, former
employees, and OSHA.
iii.medical records shall be made available to the affected employees and
anyone with written consent from the employee, and OSHA.
8.When employer ceases to do business and there is no successor to receive
and retain the records for the prescribed period, the employer
shall notify OSHA at least 90 days prior to disposal and, upon request,
transmit them to NIOSH.
(o) Competent Person
1. On all construction sites covered by this standard, the employer shall
designate a competent person.
2. Competent person is required to conduct frequent and regular inspections of
job sites, material, and equipment.
3. Class I jobs require on-site inspections at least once during each work shift,
and at any time at employee request. Class II, II, and IV jobs require on-site
inspections at sufficient intervals to assess whether conditions have
changed, and at any reasonable time at employee request.
i. Class I and II worksites require a competent person to supervise the
following duties...
A. set up the regulated area, enclosure, or other containment.
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B. ensure the integrity of the enclosure or containment.
C. set up procedures to control entry and exit from the enclosure and/or
area.
D. supervise all employee exposure monitoring.
E. ensure that employees wear respirators and protective clothing as
required.
F. ensure that employees set up and remove engineering controls, use
work practices and personal protective equipment in compliance with
all requirements.
G. ensure that employees use the hygiene facilities and observe the
decontamination procedures.
H. ensure that engineering controls are functioning properly.
I. ensure that notification requirements are met.
4. Training for the Competent Person...
i.For Class I and II work, training shall meet the criteria of EPA’s MAP (40
CFR 763, Subpart E, Appendix C).
ii.For Class III an d IV work, training shall be consistent with EPA
requirements for training of local education agency maintenance and
custodial staff as set forth in 40 CFR 763.92(a)(2).
Notes and Scribbles
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No more than on item
per respirator. No item
can be used more than
once.
Name ________________ ID#________________
Respirator Hands-on Activity
G Inspection: OK? Yes No If “No”, what is wrong?
A. Dirty
Respirator 1 G G___ B. Missing Inhalation valve
Respirator 2 G G___ C. Missing Exhalation valve
Respirator 3 G G___ D. Torn strap/harness
Respirator 4 G G___ E. Torn Inhalation valve
F. Improper filter pair
G Donning & Doffing: Steps completed:
G Bend head slightly forward, place respirator under chin, and
fasten strap at back of neck – position facepiece over mouth
and nose – pull harness over head with the harness properly
covering the crown of the head and no twisted straps.
G Perform negative seal check twice.
G Perform positive seal check twice.
G Remove or doff respirator by bending head over slightly,
disconnecting the neck strap first, and then pulling harness
over the top of the head – with the respirator resting in one
hand.
G Washing and Storing a Respirator: Steps completed:
G Wash respirator and its parts thoroughly in a proper wash/
rinse sequence.
G Store complete respirator in a bag.
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