IN Asbestos Abatement cheat sheet

Asbestos is a set of six naturally occurring fibrous silicate minerals: chrysotile, amosite, crocidolite, anthophyllite, tremolite, and actinolite.

Chrysotile (serpentine group) accounts for about 95% of asbestos used in commercial products in the U.S.; its fibers are curly and flexible.

Amphibole asbestos (amosite, crocidolite, anthophyllite, tremolite, actinolite) fibers are straight, needle-like, and more chemically resistant than chrysotile.

Asbestos-containing material (ACM) is any material containing more than 1% asbestos by weight (40 CFR 763.83).

Regulated asbestos-containing material (RACM) is ACM that is friable, or nonfriable ACM that will be or has been crumbled, pulverized, or reduced to powder during demolition or renovation (40 CFR 61.141).

Category I nonfriable ACM includes asphalt roofing products, packings, and gaskets; Category II nonfriable ACM includes all other nonfriable ACM such as transit panels and some siding.

Friability is the ability of a material to be crumbled, pulverized, or reduced to powder by hand pressure when dry.

Common ACM locations: sprayed-on fireproofing, pipe and boiler insulation, floor tile and mastic, ceiling tiles, joint compound, textured paints, and roofing felts.

A material must be assumed ACM unless a bulk sample is analyzed by a qualified laboratory using PLM (polarized light microscopy) or TEM.

Asbestos exposure is associated with asbestosis, lung cancer, mesothelioma, and cancers of the larynx and ovary.

Asbestosis is a nonmalignant fibrotic lung disease; risk increases with cumulative exposure and typically appears 10–20 years after exposure.

Mesothelioma is a cancer of the mesothelial lining of the chest or abdomen; it can occur at low exposure levels and has a long latency (often 20–50 years).

Smoking acts synergistically with asbestos exposure to greatly increase lung cancer risk; asbestos exposure alone also increases risk.

The OSHA permissible exposure limit (PEL) for asbestos is 0.1 fiber per cubic centimeter (f/cc) as an 8-hour time-weighted average; the excursion limit is 1.0 f/cc over 30 minutes (29 CFR 1926.1101 / 1910.1001).

The NIOSH recommended exposure limit (REL) is 0.1 f/cc; NIOSH considers all asbestos fiber types carcinogenic.

Fibers less than 5 micrometers in length are generally not counted for regulatory exposure limits; fibers greater than 5 micrometers are the primary concern.

Environmental impacts: airborne fibers can travel long distances, contaminate soil and water, and persist because asbestos is chemically stable and nonbiodegradable.

Improper disposal can release fibers into ambient air and water; wetting and sealed packaging reduce release during handling and transport.

IDEM (Indiana Department of Environmental Management) administers the federal NESHAP asbestos program in Indiana under 326 IAC 14-10, which incorporates 40 CFR Part 61, Subpart M.

IDEM regulates demolition and renovation activities at facilities, including notification, work practice standards, and waste handling for RACM.

A facility is any institutional, commercial, public, industrial, or residential structure, installation, or building (including mobile homes and ships).

Exempt from NESHAP notification: single-family residential buildings with four or fewer dwelling units and certain residential buildings that are not used for commercial purposes.

Also exempt: demolition or renovation of a facility that is not a regulated facility, and activities involving only nonfriable ACM that will remain nonfriable.

Ordinary household waste from a single-family residence is not regulated as asbestos waste under NESHAP, but local rules may still apply.

IDEM does not regulate asbestos in schools under AHERA (that is EPA), nor worker safety (that is IOSHA/OSHA); IDEM focuses on air emissions and waste.

A renovation is exempt from NESHAP if the amount of RACM to be removed or stripped is less than 80 linear meters (260 linear feet) on pipes or less than 15 square meters (160 square feet) on other components, and less than 1 cubic meter (35 cubic feet) of facility components.

Even when exempt from notification, RACM must still be handled and disposed of properly; the exemption only removes the notification requirement.

NESHAP (National Emission Standards for Hazardous Air Pollutants) for asbestos is 40 CFR Part 61, Subpart M; it sets work practice standards for demolition and renovation.

Indiana adopts NESHAP by reference at 326 IAC 14-10-1 and adds state-specific requirements.

AHERA (Asbestos Hazard Emergency Response Act) is 40 CFR Part 763, Subpart E; it requires inspections, management plans, and response actions in schools.

ASHARA (Asbestos School Hazard Abatement Reauthorization Act) extended AHERA training requirements to public and commercial building inspectors, management planners, project designers, and abatement workers.

OSHA asbestos standards: 29 CFR 1926.1101 for construction and 29 CFR 1910.1001 for general industry; they cover exposure limits, monitoring, PPE, and training.

The Clean Air Act Section 112 authorizes NESHAP; violations can result in civil penalties and criminal enforcement.

The Asbestos Worker Protection Rule (40 CFR Part 763, Subpart G) extends OSHA worker protections to state and local government employees not covered by OSHA.

Indiana requires asbestos abatement contractors to be licensed by the Indiana Department of Health (IDOH) and workers/supervisors to be trained and certified.

The Toxic Substances Control Act (TSCA) Title II governs asbestos in schools and some reporting; EPA administers it.

A thorough inspection must be conducted by a trained and accredited inspector before demolition or renovation to identify and quantify RACM.

Inspection includes a walk-through, identification of suspect materials, bulk sampling, and documentation of quantities and condition.

Bulk samples must be collected in a manner that prevents fiber release and cross-contamination; each sample must be individually bagged and labeled.

Samples are analyzed by PLM (polarized light microscopy) per EPA Method 600/R-93/116 or TEM; PLM can detect asbestos at 1% by weight.

A minimum of one sample per homogeneous area is generally required, but multiple samples (often 3–7) are recommended to increase confidence.

Homogeneous areas are materials that are uniform in color, texture, and date of application; sampling must represent each homogeneous area.

The inspector must prepare a written report including sample locations, laboratory results, quantities, and recommendations.

For AHERA school inspections, inspectors must be accredited and follow 40 CFR 763.85; reinspection is required every 3 years.

Inspection records must be retained and made available to the owner and regulators; IDEM may request them during notification review.

The facility owner or operator must notify IDEM before commencing demolition or renovation that involves RACM.

Notification must be submitted on the IDEM Asbestos Demolition/Renovation Notification form and postmarked or delivered at least 10 working days before the start date.

The 10-working-day waiting period can be waived in emergencies (e.g., unsafe conditions) with approval from IDEM.

Notification must include: facility name and address, owner/operator, contractor, start and completion dates, estimated quantities of RACM, and description of work practices.

A revised notification must be submitted if the start date changes or if the scope of work changes significantly; updates must be sent as soon as possible.

For demolitions, notification is required even if no asbestos is present, unless the facility is exempt (e.g., single-family residence with four or fewer units).

For renovations, notification is required if the amount of RACM to be removed meets or exceeds the threshold (260 linear feet, 160 square feet, or 35 cubic feet).

The notification must be accompanied by the appropriate fee if required by IDEM; fees are based on the amount of RACM.

A copy of the notification must be available at the work site during the project.

RACM must be removed using wet methods (wetting with amended water) to control fiber release, except where wetting is infeasible or unsafe.

Amended water contains a surfactant (e.g., soap) to improve penetration and reduce surface tension.

Friable RACM must be handled and disposed of in leak-tight containers while wet; containers must be labeled as asbestos waste.

Negative air pressure enclosures with HEPA filtration are required for large abatement projects to prevent fiber migration.

Critical barriers (plastic sheeting) must seal all openings, windows, doors, and HVAC systems in the work area.

Workers must wear appropriate PPE, including respirators and disposable coveralls; decontamination units (shower, clean room, equipment room) are required.

Air monitoring must be conducted during abatement and clearance to ensure fiber levels are below clearance criteria (e.g., 0.01 f/cc by TEM or 0.01 f/cc by PCM for some standards).

Waste must be transported in sealed, leak-tight containers with proper labeling; vehicles must be cleaned after transport.

The work area must be visually inspected and air-cleared before dismantling the containment; clearance is required before reoccupancy.

Asbestos waste must be disposed of at a permitted landfill that is authorized to accept asbestos-containing waste.

Waste must be packaged in leak-tight containers (e.g., double 6-mil plastic bags or sealed drums) and labeled with the required warning: 'DANGER: CONTAINS ASBESTOS FIBERS' and 'AVOID CREATING DUST'.

Containers must be marked with the generator's name, address, and the waste shipment date.

Waste must be transported by a licensed hauler and accompanied by a waste manifest or shipping paper.

The landfill must cover asbestos waste with soil or other material at the end of each operating day to prevent fiber release.

Liquid waste containing asbestos must be filtered or treated before disposal; discharge to sanitary sewers may require pretreatment approval.

Disposal records (manifests, landfill receipts) must be retained for at least 2 years, and some states require longer.

Open dumping, burning, or disposing of asbestos waste in regular trash is prohibited and subject to enforcement.

Indiana requires asbestos waste to be disposed of in accordance with 329 IAC 10 (solid waste) and 326 IAC 14-10.

Indiana requires asbestos abatement contractors to be licensed by the Indiana Department of Health (IDOH).

Asbestos workers and supervisors must complete an accredited training course and pass an exam; worker course is 4 days, supervisor course is 5 days.

Refresher training is required annually for workers and supervisors (1 day for worker, 1 day for supervisor).

Inspectors, management planners, and project designers must be accredited under AHERA/ASHARA; refresher training is required annually.

Training providers must be accredited by EPA or an authorized state; IDOH approves courses in Indiana.

Workers must carry their certification card on the job site; supervisors must be present at all times during abatement.

OSHA requires asbestos awareness training for employees who may be exposed to asbestos, and specific training for those performing Class I–IV work.

Contractors must maintain training records and make them available to IDOH and OSHA upon request.

Licensing fees and renewal cycles are set by IDOH; failure to maintain licensing can result in fines and stop-work orders.