Transcript Asbestos Regulatory Overview

REGULATORY OVERVIEW
FEDERAL ASBESTOS
REGULATIONS
OSHA
OSHA 29
•OSHA
29CFR
CFR1926.1101
1926.1101
•OSHA 29 CFR 1910.1001
•RESPIRATORY PROTECTION 29 CFR 1910.134
EPA
NESHAP 40
•NESHAP
40CFR
CFR61,
61,Subpart
SubpartM
M
AHERA 40
•AHERA
•AHERA
40 CFR
CFR 763,
763, Subpart
Subpart E
E
•WORKER PROTECTION 40 CFR 763, Subpart G
•ASHARA (Model Accreditation Plan)
SCOPE OF FEDERAL REGULATIONS
OSHA: Work Site Procedures For
Worker Protection
NESHAP: Waste Generation and
Management
AHERA: Identification and
Management in Buildings
MAP: Certification of Persons
SCOPE & APPLICABILITY OF
OSHA
•Applies wherever a worker works who may be exposed to
asbestos
• Requires employers to protect employees
• The building owner is an employer
• A notification regulation for building owners
• A specification regulation for contractors
•Generally applies even when EPA does not
OSHA DOES NOT REQUIRE THE WORK TO BE DONE,
BUT REGULATES THE WORK PROCEDURES IF AN
EMPLOYEE DISTURBS OR CONTACTS ASBESTOS.
OSHA GIVES US WORK PRACTICES!
CLASSES OF WORK
DEFINITIONS
Class I Work
The removal of TSI,
fireproofing or popcorn
Class II Work
The removal of anything else
Class III Work
The small scale, short duration
disturbance of ACM
Class IV Work
Contact, but no disturbance,
or cleanup of previously
generated debris
CLASSES OF WORK
APPLICATION
Class I Work
Requires NPE, shower decon,
full PPE, certified people, air
monitoring, NEA
Class II Work
No initial NPE, NEA exemptions for
shower decon, PPE, certified
workers, air monitoring. One day
training.
Class III Work
Requires PPE for TSI & Surfacing,
NEA exemptions for all other ACM.
Two day training. SS, SD only.
Class IV Work
Requires NEA, all exemptions
allowed, 2 hour training required.
SCOPE & APPLICABILITY OF
NESHAP
Applies to all facilities except single residential buildings
having 4 living units or less.
REQUIRES A THOROUGH INSPECTION BEFORE
DISTURBANCE
•Requires controlled removal of RACM about to be
disturbed by DEMOLITION or RENOVATION
•Requires prior notification to EPA
•Requires proper management thru & after disposal
•No visible emissions
NESHAP REQUIRES CONTROLLED REMOVAL OF ASBESTOS, BY
REGULATING THE GENERATION, MANAGEMENT AND DISPOSAL
OF THE WASTE. NESHAP IS ASBESTOS WASTE MANAGEMENT!
Applicability (a)
61.145 Standard for Demolition and Renovation
(a) Applicability. To determine which requirements of
paragraphs (a), (b) and (c) of this section apply to the
owner or operator of a demolition or renovation activity
and prior to the commencement of the demolition or
renovation, thoroughly inspect the affected facility or part
of the facility where the demolition or renovation operation
will occur for the presence of asbestos, including Category
I and Category II nonfriable ACM.
(a) Applicability
(b) Notification Requirements
(c) Procedures for Asbestos Emission Control
Definitions (cont.)
Regulated Asbestos Containing Material (RACM)
a) Friable asbestos containing material
b) Category I nonfriable ACM that has become friable
c) Category I nonfriable ACM that will be or has been
subjected to sanding, grinding, cutting or abrading
d) Category II nonfriable ACM that has a high
probability of becoming or has become crumbled,
pulverized, or reduced to powder by the forces
expected to act on the material in the course of
demolition or renovation operations
e) EPA says that the material is RACM
Definitions (cont.)
Nonfriable ACM Categories
Category I nonfriable ACM: asbestos-containing packings, gaskets,
resilient floor covering and asphalt roofing products containing more
than 1% asbestos. IN GOOD CONDITION.
Category II nonfriable ACM: any material, excluding Category I
nonfriable ACM, containing more than 1% asbestos that when dry,
cannot be crumbled, pulverized or reduced to powder by hand
pressure. IN GOOD CONDITION.
Rule of Thumb: a material would not be Category I or II non-friable
ACM if it cannot be removed without significant breakage
(i.e. rendered friable). The material would be RACM.
SCOPE & APPLICABILITY OF
AHERA
 Applies in schools
 Requires identification of all ACBM
 Requires safe management of ACBM
 Industry standards for identification & management
Contains the Model Accreditation Plan (appendix C)
AHERA TELLS US WHAT IS ASBESTOS AND WHAT IS
NOT, AND REQUIRES THAT ACBM BE MANAGED
SAFELY IN OCCUPIED SCHOOL BUILDINGS. AHERA
DOES NOT REQUIRE REMOVAL !
MAJOR OBJECTIVES OF AHERA
•IDENTIFICATION OF ALL ACBM
•EVALUATION OF HAZARDS
•SAFE MANAGEMENT OF ACBM
AHERA FACILITIES
SCHOOLS
•KINDERGARTEN - 12
•PUBLIC AND PRIVATE
•NOT FOR PROFIT
AHERA CONCEPTS USED
UNIVERSALLY
•ACCREDITATION
•ASBESTOS INSPECTION PROTOCOL
•NVLAP CERTIFIED LABORATORIES
•RESPONSE ACTIONS
•O & M PROGRAMS
•FORMAL PROJECT DESIGN
•FINAL CLEARANCE.
SCOPE & APPLICABILITY OF
MAP
•Applies in all buildings except residential housing through
10 units
•Requires certification of inspectors
•Requires certification of persons who design or
conduct response actions:
Project Designers
Contractor/Supervisors
Workers
•Requires certified specifications
The Model Accreditation Plan is an EPA regulation that
came out of AHERA, and as such, it applies to Response
Actions (friable abatement), inside buildings.
SCOPE of the MAP
•Requires accreditation of training
curriculums.
•Requires certification of people who
design and conduct response
actions.
•Requires certification of asbestos
inspectors.
DEFINITIONS
• RESPONSE ACTION: A response to
•Friable ACM
•Inside the building
•Bigger than SS/SD
Application of the MAP
When addressing a Response Action, the
following is required:
•Formal specs done by a certified Project
Designer
•Contractor/Supervisor certification of the
competent person
•Worker certification of all workers