MI Asbestos Abatement cheat sheet

NESHAP (40 CFR Part 61, Subpart M) governs asbestos emissions from demolition, renovation, spraying, manufacturing, fabricating, and waste disposal; it is a work-practice standard, not a worker-exposure standard.

NESHAP trigger: renovation or demolition of a facility where the combined regulated asbestos-containing material (RACM) is at least 160 square feet on pipes or other facility components, 260 linear feet on pipes, or 35 cubic feet off facility components where length cannot be measured.

RACM categories: friable asbestos material, Category I nonfriable that will be or has become friable, Category II nonfriable that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder.

Category I nonfriable: asphalt roofing products, packings, gaskets, resilient floor covering, and asphalt-containing mastics. Category II nonfriable: all other nonfriable ACM, e.g., asbestos-cement sheet and shingles.

OSHA construction asbestos standard is 29 CFR 1926.1101; general industry is 29 CFR 1910.1001. The construction standard applies to repair, renovation, demolition, and removal of ACM.

Class I work: removal of thermal system insulation (TSI) and surfacing ACM/PACM. Class II: removal of ACM other than TSI and surfacing. Class III: repair and maintenance where ACM is likely to be disturbed. Class IV: maintenance and repair where ACM is not likely to be disturbed but employees contact ACM.

Permissible exposure limit: 0.1 fiber per cubic centimeter (f/cc) as an 8-hour time-weighted average; excursion limit is 1.0 f/cc averaged over a 30-minute sampling period.

A competent person is required on all asbestos work and must be capable of identifying hazards, has authority to take corrective action, and performs site inspections at least once per shift for Class I and Class II work.

State and local programs may be more stringent than federal rules; the Asbestos NESHAP delegation often sits with the state air agency, and many states operate their own abatement licensing and notification systems.

Inhalation is the primary occupational route of concern; fibers below roughly 5 micrometers in length and 3:1 aspect ratio are counted by phase contrast microscopy, and fibers in the 5-20 micrometer range deposit in the airways.

Asbestosis is diffuse interstitial fibrosis caused by cumulative dose; latency is typically 15-30 years, and it is a non-malignant pneumoconiosis.

Lung cancer risk is synergistic with cigarette smoking (multiplicative rather than merely additive), and latency is typically 15-30 years from first exposure.

Mesothelioma is a malignancy of the pleura or peritoneum with latency commonly 20-50 years; risk is associated with amphibole fibers (amosite, crocidolite) more strongly than with chrysotile.

Medical surveillance under 29 CFR 1926.1101 is required for employees exposed at or above the PEL or excursion limit for 30 or more days per year; examinations are provided within 10 working days of assignment and annually thereafter.

Required surveillance elements: medical and work history with emphasis on asbestos exposure, standardized questionnaire, physical examination, and pulmonary function tests (FVC and FEV1).

OSHA requires the employer to offer the employee the opportunity for a chest roentgenogram (posterior-anterior 14 by 17 inch film or digital equivalent) in accordance with NIOSH guidelines; the employer must inform the employee of results and provide a copy.

Smoking cessation is the single most effective risk-reduction intervention for an asbestos-exposed smoker; the employer must provide information on smoking cessation programs.

Medical removal protection: an employee showing signs of asbestos-related disease must be examined by a specialist; if the physician recommends removal, transfer with rate retention applies.

Six regulated asbestos minerals: chrysotile (serpentine), and the amphiboles amosite, crocidolite, anthophyllite, tremolite, and actinolite.

Chrysotile is a curly, sheet-silicate fiber that is more soluble and cleared faster than amphiboles; amphiboles are straight, needle-like, and more biopersistent.

Friable material can be crumbled, pulverized, or reduced to powder by hand pressure when dry; nonfriable material cannot.

Thermal system insulation includes pipe wrap, block insulation, cement, and mudded fittings; pre-1980 TSI is presumed ACM until sampled.

Surfacing material is sprayed-on or troweled-on acoustical or fireproofing material on decks, ceilings, walls, and structural members.

Common nonfriable ACM: vinyl asbestos floor tile (typically 9x9 inch and 12x12 inch), asbestos-cement transite panels and pipe, roofing felt and shingles, gaskets, and mastics.

Miscellaneous ACM includes ceiling tile, joint compound, textured paint, caulk, and laboratory bench tops; these are not part of the three NESHAP categories but still require assessment.

Presumed ACM under OSHA: TSI and surfacing material in buildings constructed before 1981 are presumed to contain asbestos unless sampled and shown otherwise.

PACM (presumed asbestos-containing material) labeling and communication is required for TSI and surfacing material until it is proven not to contain asbestos.

A thorough inspection identifies all ACM and PACM, including materials in concealed spaces, above ceilings, behind walls, and in mechanical chases; destructive sampling is required where access is limited.

Bulk sampling: collect a minimum number of samples per homogeneous area (commonly 3 for TSI and surfacing and 3 for other materials, with more for large areas) using a wetting agent, a HEPA vacuum, and a sealed container to avoid cross-contamination.

Homogeneous areas are materials that are uniform in color, texture, and date of application; each area must be sampled separately.

Polarized light microscopy (PLM) is the standard bulk method under EPA guidelines; point counting or gravimetric/matrix reduction is used for verification, and TEM may be used for air or special bulk analysis.

The abatement project design should specify the scope, containment type, engineering controls, work practices, decontamination, waste handling, and clearance criteria before work begins.

A written respiratory protection program, exposure assessment, and site-specific work plan must be in place; the plan should include emergency procedures and evacuation routes.

Notification to the EPA or delegated state agency under NESHAP must be postmarked or delivered at least 10 working days before the start of work, with a revised notification if the start date changes.

Pre-abatement planning includes utility lockout/tagout, isolation of HVAC systems, protection of building occupants, and a plan for monitoring airborne fiber levels.

Contract documents should specify the abatement contractor's licensing, insurance, and the clearance standard, since the abatement contractor is generally responsible for achieving clearance.

Negative pressure enclosure: HEPA-filtered negative air machines maintain a pressure differential of at least 0.02 inches of water column (5 Pa) relative to adjacent areas, with a minimum of 4 air changes per hour in the work area.

Critical barriers seal openings, HVAC vents, and penetrations; the containment must be constructed of fire-retardant plastic sheeting with a minimum 6-mil thickness for floors and 4-mil for walls.

Wet methods: saturate ACM with amended water (water plus a surfactant) before and during removal to suppress fiber release; amended water reduces surface tension and improves penetration.

Removal sequence: work from top to bottom, remove TSI in sections, wrap in plastic, and lower to the floor; do not drop or throw debris.

Decontamination unit: a three-stage system of clean room, shower, and equipment/waste room, with HEPA vacuuming before entering the shower and clean-room clothing procedures.

Air locks and flaps maintain the pressure differential; workers must not pass through the clean room while wearing contaminated PPE.

Final cleaning uses HEPA vacuums and wet wiping of all surfaces, followed by a visual inspection before clearance air sampling.

Personal decontamination: HEPA vacuum the suit, remove disposable clothing, shower, and do not transport contaminated clothing or equipment out of the containment.

The competent person inspects the enclosure at least once per shift for Class I and II work and must verify the integrity of critical barriers and the negative pressure system.

Respiratory protection is required for Class I work, for any work with a negative exposure assessment not demonstrating the PEL is met, and for Class II, III, and IV work when exposures are expected to exceed the PEL.

Required minimum respirators: a half-mask air-purifying respirator with HEPA filters for exposures up to 10 times the PEL; a full-facepiece air-purifying respirator up to 50 times the PEL; and supplied-air or powered air-purifying respirators for higher levels.

Tight-fitting respirators require a medical evaluation (OSHA 29 CFR 1910.134), annual fit testing, and user seal checks before each use.

HEPA filters (P100) are the only air-purifying filters permitted for asbestos; dust/mist respirators are not adequate.

Disposable protective clothing: full-body coveralls with hood and booties, plus gloves and eye protection; duct tape seals wrists and ankles.

The employer must provide training on the use, limitations, and care of respirators, and must keep records of fit testing and medical evaluations.

Respirator use in a negative pressure enclosure must account for the additional breathing resistance; supplied-air respirators are required for high-exposure tasks such as removal of TSI without wet methods.

Employees must be permitted to leave the work area to wash, change, and shower; PPE must not be worn outside the containment.

Personal air monitoring is performed with a calibrated sampling pump and an open-face cassette with a 0.8 micrometer mixed cellulose ester (MCE) filter; the pump is calibrated before and after sampling.

Phase contrast microscopy (PCM) counts fibers longer than 5 micrometers with a length-to-width ratio of at least 3:1; PCM cannot distinguish asbestos from other fibers.

Transmission electron microscopy (TEM) is used for clearance in many jurisdictions; NIOSH Method 7402 and the AHERA method are the standard TEM methods.

Clearance criteria vary by jurisdiction; a common standard is a maximum of 70 structures per square millimeter (s/mm2) on TEM or a PCM result of 0.01 f/cc or less, but the project's contract and the local regulator control.

Clearance air sampling is conducted after final cleaning and visual inspection, and the containment must remain under negative pressure during sampling.

The number and location of clearance samples should be determined by the project design; a common approach is at least one sample per 1,000-5,000 square feet of work area, with samples in each room and at the decontamination exit.

Aggressive sampling methods (fan or air movement to disturb settled fibers) may be specified to provide a conservative clearance result.

Exposure monitoring results must be kept and made available to employees; the employer must provide written notification of monitoring results within 15 working days of receipt.

RACM must be wetted, bagged, and sealed in leak-tight containers before it leaves the contained area; containers must be labeled as asbestos waste.

Waste must be transported in covered, leak-tight vehicles; the NESHAP requires the waste to be handled with no visible emissions and to be deposited at an approved landfill.

Landfills accepting asbestos waste must be permitted for that purpose and must cover the waste with at least 6 inches of non-asbestos material or otherwise comply with the permit.

The generator must maintain a chain of custody from the work area to the disposal site, including the hauler's name, the landfill, and the weight or volume of the waste.

Waste shipment records (manifests or landfill receipts) should be retained; they are part of the project file and may be requested by the regulator.

Category I and II nonfriable waste may be handled as non-RACM if it remains nonfriable; if it becomes friable, it is RACM and must be handled accordingly.

Decontaminate the exterior of waste containers before they leave the containment, and do not store waste outside the enclosure for extended periods.

Asbestos waste is not a hazardous waste under RCRA Subtitle C unless it is mixed with a hazardous waste; it is regulated under NESHAP and state solid waste rules.

NESHAP notification: submit to the EPA or delegated state agency at least 10 working days before work begins; the notice includes the owner, operator, contractor, facility description, amount of RACM, and start and completion dates.

A revised notification is required if the start date changes or if the amount of RACM changes by more than 20 percent or the work practices change.

OSHA records: exposure monitoring results, medical surveillance records, fit test records, and training records must be retained; exposure records are typically kept for 30 years and medical records for the duration of employment plus 30 years.

Training records must document the employee's name, the training date, and the instructor; refresher training is required annually for asbestos workers.

The abatement contractor must maintain a project file with the work plan, daily logs, air monitoring results, waste manifests, and clearance reports.

The building owner should retain the inspection report, abatement records, and any remaining ACM locations for future renovation and demolition planning.

Report releases or exceedances to the appropriate agency as required by the permit or regulation, and document corrective actions in the project log.

Employee notification of monitoring results must be provided in writing within 15 working days of receipt, either individually or by posting in a conspicuous location.