HI Asbestos Abatement cheat sheet

Hawaii asbestos rules are administered by the state Department of Health (HDOH) under Hawaii Administrative Rules Title 11, Chapter 501, which adopts and amends the federal NESHAP program for the state.

Federal NESHAP (40 CFR Part 61, Subpart M) defines regulated asbestos-containing material (RACM) as material with >1% asbestos that is friable, or will be crumbled/dry by handling, or has been subjected to sanding, grinding, cutting, or abrading.

Category I nonfriable ACM: packing, gaskets, resilient floor coverings, and asphalt roofing products containing >1% asbestos that are not friable and not likely to become friable when dry.

Category II nonfriable ACM: any material other than Category I that is nonfriable and contains >1% asbestos; if it may be crumbled, pulverized, or reduced to powder by the work practices used, it becomes RACM.

OSHA construction standard (29 CFR 1926.1101) sets a permissible exposure limit of 0.1 f/cc as an 8-hour TWA and an excursion limit of 1.0 f/cc averaged over 30 minutes.

Asbestos exposure causes asbestosis, lung cancer, mesothelioma, and other cancers; the latency period is typically 10-40 years, and smoking multiplies lung cancer risk synergistically.

Class I work is removal of thermal system insulation (TSI) or surfacing ACM; Class II is removal of ACM other than TSI/surfacing; Class III is repair/maintenance; Class IV is cleanup of dust/debris from Class I-III work.

Friable ACM means material that can be crumbled, pulverized, or reduced to powder by hand pressure when dry; nonfriable ACM does not meet that test.

A material is presumed ACM until bulk sampling and laboratory analysis (PLM, or TEM for verification) demonstrate asbestos content of 1% or less; the OSHA/NESHAP action threshold is >1%.

Bulk samples must be collected by a trained person using wet methods and proper containment, sealed in labeled containers, and shipped with chain-of-custody documentation.

Polarized light microscopy (PLM) with dispersion staining is the standard method (EPA Method 600/R-93/116); gravimetric reduction and TEM may be needed for fine fibers or when PLM is inconclusive.

A homogeneous area is material of uniform color and texture applied at the same time; sampling scheme requires at least 3 samples per homogeneous area for surfacing and TSI, and 3-7 for other materials depending on size.

An asbestos survey must document material location, quantity (square or linear feet), friability, accessibility, condition, and whether the material is RACM.

Presumed ACM categories in buildings include sprayed-on or troweled-on surfacing, TSI (pipe/boiler insulation), and miscellaneous materials such as floor tile, mastic, ceiling tile, joint compound, and roofing.

A material that is nonfriable but will be sanded, ground, cut, or abraded during renovation must be treated as RACM regardless of its original condition.

Renovation or demolition of a facility requires a thorough inspection for asbestos before work begins; NESHAP requires notification to the state at least 10 working days before demolition or a renovation that will disturb regulated asbestos.

Respiratory protection levels: half-mask APR with HEPA filters for exposures up to 10x PEL; full-face APR up to 50x PEL; PAPR up to 100x PEL; Type C supplied-air respirator with escape bottle for high exposures or when the PEL is unknown.

A tight-fitting respirator requires a fit test before use (annual, plus after facial changes), a medical evaluation, and a user seal check each time it is worn.

Protective clothing: disposable full-body coveralls, head covering, and boot covers; avoid street clothing; remove and dispose of contaminated clothing as asbestos waste.

Gloves, eye protection, and hard hats are worn as needed; PPE must be inspected before each use and damaged items discarded.

Employees must be trained at no cost: Class I and II work require 32-hour initial training and 8-hour annual refresher; Class III and IV require 16-hour initial training and 8-hour annual refresher.

The employer must provide a medical surveillance program for employees exposed above the PEL for 30 or more days per year, including chest X-ray, spirometry, and medical history.

A written respiratory protection program is required and must cover selection, fit testing, maintenance, and training, and recordkeeping of fit tests and medical clearances.

Decontamination must precede removal of respirators; workers should not eat, drink, smoke, or chew in regulated areas.

Before abatement, isolate the work area, shut off HVAC, seal openings, post warning signs, and establish the regulated area boundary.

Wet methods: keep ACM wet with amended water (surfactant) to suppress fiber release; use low-pressure spray and avoid high-velocity sprays that aerosolize fibers.

Removal sequence: remove ACM in sections, starting from the top and working downward; wrap TSI in plastic and cut in manageable sections; do not drop or throw debris.

For surfacing ACM, use manual scraping after wetting; power tools may be used only with HEPA-equipped shrouds and should be avoided where possible.

Floor tile removal: use a wet scraping method, or heat/chemical softening; do not dry-cut or dry-chip tile or mastic.

Remove and bag debris as it is generated; seal each bag, and keep the work area clean throughout the project, not only at the end.

Negative air machines with HEPA filters must maintain the containment under negative pressure relative to adjacent spaces; monitor and record pressure differentials.

Final cleaning: wet wipe and HEPA vacuum all surfaces; then conduct visual inspection and clearance air monitoring before dismantling containment.

Containment types: glove bag for small pipe work; mini-enclosure for localized area; full containment (critical barrier) with plastic sheeting for larger areas.

Critical barriers seal all openings (windows, doors, vents, penetrations) with two layers of 6-mil plastic; floors are covered and seams are taped.

Decontamination unit has three stages: clean room, shower, and dirty room, arranged so workers pass clean-to-dirty on entry and dirty-to-clean on exit.

Negative air machines should provide at least 4 air changes per hour in the containment; verify with a pressure differential monitor and a smoke test.

HEPA filtration removes 99.97% of particles 0.3 microns and larger; all vacuums and negative air units used in abatement must be HEPA-equipped.

Workers must shower and change clothes before leaving the decontamination unit; contaminated clothing and PPE are left in the dirty room.

Containment must be inspected daily for tears, and any breach repaired immediately; a log of inspections and repairs is kept.

Engineering controls include local exhaust ventilation, wet suppression, and enclosure; these reduce but do not eliminate the need for respirators.

Asbestos-containing waste must be wetted, placed in sealed, leak-tight containers, and labeled as asbestos waste; bags are doubled and sealed.

Waste containers must be labeled with the OSHA caution sign or the required asbestos warning, and with the generator's name and location.

Transport off-site requires a hazardous waste manifest or the state-required shipping document; the waste must go to a permitted landfill that accepts asbestos.

NESHAP requires that RACM be kept wet and handled so as not to generate dust; no visible emissions are allowed during handling, transport, or disposal.

Waste should be stored in a secure area and not left uncovered; do not compact or break ACM waste containers.

The generator retains copies of waste shipment records; keep records for at least the period required by the state and federal rules (commonly 3 years).

Disposal site operators must cover asbestos waste with soil or other cover at the end of each operating day; the location is recorded in the site's operating record.

Reusable equipment must be decontaminated before leaving the site; disposable items are bagged as waste.

Personal air samples are collected in the breathing zone using a calibrated pump and a filter cassette; results are compared to the PEL (0.1 f/cc 8-hour TWA) and excursion limit (1.0 f/cc over 30 minutes).

Phase contrast microscopy (PCM) is the standard method for counting fibers (NIOSH 7400); it does not distinguish asbestos from other fibers, so TEM is used for confirmation.

Clearance air monitoring is performed after final cleaning and before containment removal; the work area must be visually clean first.

Clearance criteria commonly require that airborne fiber concentrations be below 0.01 f/cc (or a level specified by the project/state rule), measured by PCM or TEM as required.

Air samples must be collected with calibrated pumps, and calibration records, sample logs, and chain-of-custody forms are retained.

Aggressive sampling (fans to disturb air) may be required for clearance to ensure fibers are dislodged and detected.

Air monitoring records should include sample location, date, time, flow rate, duration, and results; these are part of the project record.

If clearance fails, re-clean and re-test; do not remove containment until clearance is achieved.

The supervisor ensures the written respiratory protection program, training records, medical clearances, and fit test records are current for all workers.

The supervisor verifies containment integrity, negative pressure, and decontamination procedures daily and documents inspections.

The supervisor maintains the project log: daily activities, worker names, hours, air monitoring results, waste shipments, and any incidents.

Training records must include the employee's name, training dates, and the type of training; retain per OSHA and state requirements (commonly 1-3 years, check Hawaii rules).

The supervisor must ensure the NESHAP notification is filed at least 10 working days before the project and that any changes are reported.

Incident reporting: any uncontrolled fiber release, injury, or containment breach must be documented and reported as required.

The supervisor confirms that waste manifests are completed and copies retained, and that the landfill accepts the waste.

The supervisor ensures final clearance documentation and the project closeout report are completed and retained.