ABAA CABS cheat sheet

Inhalation is the primary exposure route; ingested fibers are largely excreted, though some may migrate to the GI tract.

Asbestosis is a diffuse interstitial fibrosis caused by cumulative high-dose exposure; latency typically 10–20+ years.

Lung cancer risk increases with cumulative exposure and is multiplied in smokers (synergistic effect).

Mesothelioma is a rare cancer of the pleura or peritoneum; latency 20–50 years, with some risk at low exposures.

Fiber dimensions influence pathogenicity: fibers >5 µm long, <3 µm wide, aspect ratio ≥3:1 are counted by PCM.

Amphibole fibers (amosite, crocidolite) are more biopersistent and generally more carcinogenic than chrysotile.

Asbestos exposure also associated with laryngeal and ovarian cancers, and possibly GI cancers.

OSHA PEL is 0.1 f/cc 8-hr TWA; STEL is 1.0 f/cc over 30 min; excursion limit 1.0 f/cc over 30 min.

NIOSH REL is 0.1 f/cc 8-hr TWA; IDLH is not determined but NIOSH considers 10 f/cc immediately dangerous.

NESHAP (40 CFR 61 Subpart M) regulates asbestos during demolition/renovation; applies to facilities and regulated asbestos-containing material (RACM).

RACM includes friable ACM and nonfriable ACM that will be crumbled, pulverized, or reduced to powder during handling.

AHERA (40 CFR 763 Subpart E) requires accredited inspectors for school inspections and management plans.

OSHA Construction Standard (29 CFR 1926.1101) covers construction, renovation, abatement; General Industry (29 CFR 1910.1001) covers manufacturing.

OSHA Class I work = removal of TSI or surfacing ACM/PACM; Class II = removal of other ACM; Class III = repair/maintenance; Class IV = cleanup.

OSHA requires a regulated area, negative-pressure enclosure for Class I work, and exposure monitoring.

AHERA defines friable ACM as material that can be crumbled, pulverized, or reduced to powder by hand pressure.

NESHAP requires notification to EPA or delegated state at least 10 working days before demolition/renovation.

AHERA accreditation requires training and exam; refresher every year for inspectors/management planners, every 3 years for workers/contractors/supervisors.

ACM is defined by regulation as material containing >1% asbestos by weight (OSHA, EPA, AHERA).

Friable ACM can be crumbled by hand; nonfriable ACM cannot (e.g., vinyl floor tile, asbestos-cement sheet).

Category I nonfriable: asphalt roofing, gaskets, resilient floor coverings; Category II: all other nonfriable (e.g., asbestos-cement).

Surfacing material is sprayed or troweled on (fireproofing, acoustical); TSI is thermal system insulation; miscellaneous includes floor tile, ceiling tile, mastic.

PACM is presumed ACM unless sampled and shown <1%; applies to surfacing and TSI in schools.

Homogeneous area (HA) is material uniform in color and texture; samples from one HA represent the entire area.

AHERA sampling: at least 3 samples per HA; if all 3 are positive, HA is ACM; if all negative, HA is non-ACM; if mixed, sample more (up to 7).

OSHA does not require a specific number of samples but requires representative sampling; often 3–5 per HA.

Nonfriable ACM that may become friable during renovation must be treated as RACM under NESHAP.

Review building drawings, prior inspection reports, permits, and renovation records before site walk.

Determine building construction date; asbestos use peaked 1940s–1970s, but materials may be present in newer buildings.

Identify client needs: purpose (pre-renovation, AHERA management plan, real estate), scope, and report format.

Conduct a walk-through to identify homogeneous areas and suspect materials; document with photographs and notes.

Develop a sampling plan: number of samples per HA based on regulatory requirement (AHERA 3, OSHA representative).

Confirm accreditation and licensing requirements for the jurisdiction; notify client of any limitations.

Arrange access, safety orientation, and PPE; coordinate with building occupants to minimize disruption.

Provide client with a written scope and fee estimate before inspection; document any exclusions.

Use wet methods and a HEPA vacuum to minimize fiber release; wear appropriate PPE (respirator, gloves, coveralls).

Sample each homogeneous area separately; collect a minimum of 3 samples for AHERA, representative samples for OSHA.

Take samples from different locations within the HA; avoid sampling at damaged edges only.

Use a clean sampling tool for each sample; place sample in a sealed container (e.g., zip-lock bag, vial).

Label each sample with unique ID, location, HA, date, and sampler name.

Complete chain-of-custody form: sample ID, date/time, released by, received by; maintain a copy.

Ship samples to an accredited laboratory (NVLAP or state-accredited) using appropriate packaging.

Do not composite samples unless specifically allowed; compositing can dilute asbestos content and cause false negatives.

Document sampling locations on a floor plan or sketch; note material condition and accessibility.

PLM (polarized light microscopy) is the standard method for bulk samples; NIOSH 9002 and EPA 600/R-93/116.

PLM can detect asbestos at ~1% by weight; it cannot reliably quantify below 1%.

Gravimetric/point counting with PLM estimates percentage; multiple analysts may be needed for low concentrations.

TEM is used for air samples (AHERA clearance) and can identify fibers <0.25 µm; bulk TEM may be used for verification.

PCM (phase contrast microscopy) is used for OSHA air monitoring; counts fibers >5 µm, but cannot distinguish asbestos from other fibers.

XRD and SEM/EDS are alternative methods for bulk analysis, often used for confirmation.

A result of "none detected" means no asbestos observed at the detection limit; it does not guarantee zero asbestos.

If PLM result is <1% but asbestos is present, the material is not ACM by regulatory definition, but may still pose a hazard if disturbed.

Laboratory must be accredited (NVLAP or state) and participate in quality assurance programs.

HVAC systems often contain asbestos in duct insulation, gaskets, and vibration isolators.

Thermal system insulation (TSI) on pipes, boilers, and ducts is a common ACM; includes corrugated paper, block, and cement.

Homogeneous areas should be defined by material type, color, texture, and application; not by location alone.

Assess accessibility: materials in occupied spaces or air plenums are higher priority.

Air plenums may contain surfacing ACM; fibers can be distributed through the building if damaged.

Consider building system interactions: water damage, vibration, and maintenance can degrade ACM.

Document quantities (linear feet, square feet) for each HA to support abatement planning.

Evaluate condition: good, damaged, or significantly damaged; friability and potential for disturbance.

Use building plans and system diagrams to ensure all suspect materials are identified.

Inspection report must include: building description, inspection date, inspector name and accreditation, sampling locations, laboratory results, and conclusions.

Include a floor plan or sketch showing sample locations and HA boundaries.

Document material condition, friability, accessibility, and quantity.

AHERA management plans must include: inspection results, response actions, and periodic surveillance plan.

Maintain chain-of-custody and laboratory reports for at least the retention period required by regulation (e.g., AHERA: life of building).

OSHA requires exposure records be kept for 30 years; medical records for duration of employment plus 30 years.

Reports should be clear, concise, and free of jargon; provide recommendations based on findings.

Record any limitations or assumptions (e.g., inaccessible areas, non-suspect materials).

Provide client with a copy of the report and maintain a secure record for future reference.

Inspectors must avoid conflicts of interest; do not recommend abatement by a company you have a financial interest in.

Maintain confidentiality of client information; do not disclose without permission.

Follow safety protocols: wear PPE, use wet methods, avoid disturbing ACM, and decontaminate equipment.

Use accredited laboratories and follow quality assurance/quality control (QA/QC) procedures.

Document all findings accurately; do not alter or falsify data.

Stay current with regulations and best practices through continuing education.

Report any unsafe conditions or regulatory violations to the client and appropriate authorities if necessary.

Ensure sampling equipment is clean and calibrated; avoid cross-contamination.

Adhere to a professional code of ethics (e.g., AIHA, AHERA accreditation requirements).

Abatement oversight includes verifying contractor compliance with work practices, regulations, and specifications.

Pre-abatement: review contractor submittals, verify containment setup, and check worker certifications.

During abatement: monitor work practices, air monitoring, and waste handling; ensure negative pressure and decontamination units.

Post-abatement: conduct visual inspection to confirm no visible debris; then air clearance sampling.

AHERA clearance: PCM analysis of air samples; fibers must be <0.01 f/cc (or TEM <70 s/cc).

OSHA does not specify clearance criteria but requires exposure monitoring; often 0.01 f/cc or less is used.

Clearance air sampling: use aggressive sampling (fans) for AHERA; ensure containment is intact.

Waste must be containerized, labeled, and disposed of in an approved landfill per NESHAP.

Final report should include daily logs, air monitoring results, waste manifests, and clearance documentation.

If clearance fails, re-clean and re-sample; do not release the area until clearance is achieved.