Document DM93pJLd9Be4pvKEBgKZjONyo

.' , i>x Pt<XIMT*ENGlNEEHlNG FACILITIES ENVIRONMENTS SAFETY QA QT J yj U j yj Q ^ / >Gri e:1t 1Ready for the New Asbestos Standard WILLIAM A. ONDERICK, RFM, Inc., West Chester. PA n October 1, OSHA's re vised asbestos rules became law, and with them are many changes from the pre-------------- vious 1986 standard. The presumed asbestos-containing material (PACM) rule is one of the big ger changes in the revised standard. OSHA has declared that owners must presume that there are certain highrisk asbestos-containing materials (ACM) in facilities built prior to 1981, unless bulk sample results prove them to be nonasbestos. The impact of this provision forces companies to think carefully before presuming where asbestos is or where it is not. Companies must also heed the EPA Asbestos National Emission Standards for Hazardous Air Pollu- Bulk samples should bo collactad using a cora sampling tool to vanfy if thermal system insulation materials do or do not contain as bestos. dust taking a portion of materials from the surface may Four options are available for complying with the presumed asbestos-containing material rule, which is one of the major changes in the revised regulations tarns (NESHAP), which require in spections and bulk sampling to identi fy materials prior to renovation or demolition. Compliance Options Short and long term needs should be examined when analyzing how to comply with the PACM provision. There are four options available. Option 1. Ignore the standard and face potential enforcement fines. Some owners practice crisis man agement, and only act when pressured by the situation. Companies thinking this is a realistic option are opening themselves up to potential liability. The likelihood that a company can escape from complying with the PACM provision is more doubtful than ever. Option 2. Presume all materials in pre-1981 build ings contain asbestos and simply post additional warning signs. Another change in the standard requires owners to increase the number of signs indicating where asbestos is located in a given area (pip ing, surfacing materials, etc.), and a contact to call prior to doing work in the area. This requirement is a major change from the 1986 ruling. OSHA recently clarified its posi tion. saying additional warning signs must be posted at strategic locations where people might be expose^ (entrances to mechanical rooms, lab hoods, etc.). One sign posted at the entrance gate of the plant or in a lobby won't cut it. On the other hand, OSHA does not expect companies to post signs in every room where there is floor tile. Companies must use common sense in warning people about PACM. Just posting warning signs in pre-1981 buildings does not guarantee a quality asbestos management program. It only means you are in compliance with the PACM rule. There are pros and cons to just putting up more warning signs. While it makes employees more aware, it also has the potential to scare people and cause concern about working in an area where there is asbestos. Simply posting signs is not a cureall and owners should be aware of its limitations. Option 3. Survey or resurvey the facilities to be in compliance with the PACM ruling. Almost every building owner has done some survey work in the past. Conducting mini-surveys to verify asbestos locations is a more accurate step owners should consider. The goal of this approach is to locate the pre dominant material in a given area, ver 104 October 9, 1995 Plant Engineering FILE 5001/7550/7040 sus as lev inf exi inft I vey tior ful cou nea r pat, vey ma natc 1 thu eno ten tal i I rest qua ligh link mer be \ T due FILE I G 9-5 309 rease ^here (pipind a >rk in xiajor posisigns itions iosed s, lab at the lobby 3SHA ) post ere is i sense 1 Just -1981 quality It only ith the to just While . it also jle and ; in an a curee of its vey the vith the ner has le past, i verify iccurate lie goal the prerea. ver- S50/7040 Naw OSHA Asbestos Standard Highlights A competent person must oversee all asbestos control procedures. Training for this individual must meet EPA's Model Accreditation Plan criteria. Owners must identify or presume suspect materials con tain asbestos. OSHA's PACM provision requires owners to presume that thermal system insulation, surfacing mate rials, and certain miscellaneous materials installed priorto 1981 contain asbestos, unless bulk sampling survey infor mation or other objective data proves it to be nonas bestos. Tougher rules for warning signs and notification of employees and other building occupants of the presence of ACM/PACM to ensure the material will not be dis turbed. OSHA dropped its large and small-scale work defini tions and created more specific work practices and proce dures. Now all asbestos work is grouped into four classifi cations. Class I: Removal of high-risk ACM/PACM, mainly ther mal system insulation (TSI) and surfacing materials (friable materials). Class II: Removal of ACM/PACM other than TSI or sur facing materials, such as floor tile, transite, and gaskets (nonfriable materials). (Although OSHA has eliminated the terms friable and nonfriable, they are used here for clarity. These terms are still used by EPA.) Class III: Repair/maintenance of ACM/PACM generating no more than one waste bag. Class IV: Clean up debris containing ACM/PACM or cus todial activities near damaged or friable asbestos caused by a Class I, II or III activity. Lower permissible exposure limits (PEL) took effect on Oct. 11, 1994: PEL O.lf/cc - 8-hr TWA (reduced from 0.2f/cc) 30-min excursion limit: If/cc Conduct assessments before each asbestos job to deter mine exposure levels, requirements, and work practices. Increase in training requirements: Class I and II -- 32-hr worker training . Class III -- 16-hr worker training Class IV -- 2-hr awareness training. \ I | sus presuming asbestos is everywhere as in Option 2. Mini-surveys provide a comfort level about the accuracy of past survey information. Inaccurate data often exist in old surveys, especially if the information is not kept current. In the early days of conducting sur veys. inspectors routinely took por tions of insulation materials instead of full core samples. This technique could result in an asbestos layer under neath being missed. Also, older facilities have a lot of patchwork insulation. Many past sur veys overlooked this fact, and there may be asbestos in nonasbestos desig nated areas or vice versa. Undersampling was the rule of thumb in past surveys. Not taking enough samples to accurately charac terize an area could result in acciden tal exposure. In addition, inaccurate bulk sample results were common in the past Poor quality from labs performing polarized light microscopy may be the weakest link in a successful asbestos manage ment program. Past lab results should be verified during mini-surveys. The time period a survey was con ducted might be a clue to accuracy. Prior to 1980, if a bulk sample con tained 5% or less asbestos, it was clas sified as nonasbestos. Today, a materi al is considered asbestos if it is 1% or greater. In fact, some states say 0.1 % is an asbestos material. If conducting a PACM Verification Study or mini-survey, four major action steps should be considered. Step 1: Define homogeneous areas in pre-1981 buildings. This step is nothing more than dividing the facility into smaller and like areas so survey dam can be managed more efficiently. Sup 2: Conduct a walkthrough to verify where asbestos or nonasbestos is located in homogeneous areas. This step is more of a visual walk through. but may also require additional sample taking. Step 3: Verify labeling needs while verifying where PACM exists. Step 4: Verify condition of materials and damage. This step is not required as part of the PACM rule, but it is a smart approach to take while verifying other information. If work is performed in an area designated as PACM without really knowing for sure, you could end up spending money for no : reason. Presuming a material is i i asbestos can be costly. You might be j , removing nonasbestos material using ; expensive control practices, putting ! workers in personal protective equip- ' ment which can trigger expensive i ; medical surveillance, or deposit non- : , asbestos waste in more costly landfills. , j' Older facilities might have a patch- work of pipe insulation. There i could be aabaatoa in nonasbastos i daajgnated areas, or vies versa. Pasurveying an area verifies aabaatoa iocationa. FILE 5001/7550/7040 October 9, 1995 Plant Engineering 105 PLANT ENGINEERING -I 5 090400 Thorough surveying of the plant determines if and where an asbestos-related concern exists The survey determines the facts as they exist today. Owners should consider putting sur ges information in a computer data base to keep it current. Option 4: Conduct more compre hensive surveys. Taking this step re quires considering how long you plan to stay in the building, degree of reno\ation work expected over the next several years, and how accurate cur rent survey information is. Unless the company has embarked on a total removal campaign, it has probably conducted a full-site survey or done partial survey work due to ren ovation or to be in compliance with the , EPA Asbestos NESHAP. Regardless of i i the situation, now might be the best , I time to rethink the company's asbestos \ \ management philosophy and to upi 1 grade current survey data records to be in compliance with this PACM rule. Some companies have decided to beat the regulation instead of just meeting it. With EPA recently issuing a testing consent order on refractory ceramic fibers (RCFs), and the onagain/off-again OSHA Reform Bill in Congress proposing new permissible exposure limits for RCFs. mineral wool, and fibrous glass, it may not be too long until these respirable fibers are regulated as well. Including other fibers in surveys should be considered. Combination Approach The four basic options can be com bined in various forms. For example, an owner might only conduct compre hensive surveys when an area or indi vidual building is undergoing exten sive renovation or a shutdown is scheduled. Perhaps the company might only conduct a verification study in pre-1981 buildings that have a high concentration of employees or traffic. In areas where there are few or no employees, an owner may decide to just post signs. Owners should carefully evaluate their options in order to comply with the new PACM provision, and be smart about where to spend money. Howev er. regardless of budget limitations, nothing is more important than pro tecting the health and safety of em ployees and visitors. -- Edited by Ron Holzhauer, Managing Editor, 708-390-2668 For more information... 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