REGULATORY OVERVIEW. FEDERAL ASBESTOS REGULATIONS. OSHA. OSHA 29 CFR 1926.1101. OSHA 29 CFR 1926.1101 OSHA 29 CFR 1910.1001 RESPIRATORY PROTECTION 29 CFR 1910.134. EPA. NESHAP 40 CFR 61, Subpart M. NESHAP 40 CFR 61, Subpart M AHERA 40 CFR 763, Subpart E
OSHA 29 CFR 1926.1101
NESHAP 40 CFR 61, Subpart M
AHERA 40 CFR 763, Subpart E
OSHA: Work Site Procedures For Worker Protection
NESHAP: Waste Generation and Management
AHERA: Identification and Management in Buildings
MAP: Certification of Persons
OSHA DOES NOT REQUIRE THE WORK TO BE DONE, BUT REGULATES THE WORK PROCEDURES IF AN EMPLOYEE DISTURBS OR CONTACTS ASBESTOS. OSHA GIVES US WORK PRACTICES!
CLASSES OF WORKDEFINITIONS
Class I Work The removal of TSI, fireproofing or popcorn
Class II Work The removal of anything else
Class III Work The small scale, short duration disturbanceof ACM
Class IV WorkContact, but no disturbance, or cleanup of previously generated debris
CLASSES OF WORKAPPLICATION
Class I WorkRequires NPE, shower decon,full PPE, certified people, air monitoring, NEA
Class II WorkNo initial NPE, NEA exemptions for shower decon, PPE, certified workers, air monitoring. One day training.
Class III WorkRequires PPE for TSI & Surfacing, NEA exemptions for all other ACM. Two day training. SS, SD only.
Class IV WorkRequires NEA, all exemptions allowed, 2 hour training required.
Applies to all facilities except single residential buildings having 4 living units or less.
REQUIRES A THOROUGH INSPECTION BEFORE DISTURBANCE
NESHAP REQUIRES CONTROLLED REMOVAL OF ASBESTOS, BY REGULATING THE GENERATION, MANAGEMENT AND DISPOSAL OF THE WASTE. NESHAP IS ASBESTOS WASTE MANAGEMENT!
61.145 Standard for Demolition and Renovation
(a) Applicability. To determine which requirements of paragraphs (a), (b) and (c) of this section apply to the owner or operator of a demolition or renovation activity and prior to the commencement of the demolition or renovation, thoroughly inspect the affected facility or part of the facility where the demolition or renovation operation will occur for the presence of asbestos, including Category I and Category II nonfriable ACM.
Regulated Asbestos Containing Material (RACM)
e) EPA says that the material is RACM
Nonfriable ACM Categories
Category I nonfriable ACM:asbestos-containing packings, gaskets, resilient floor covering and asphalt roofing products containing more than 1% asbestos. IN GOOD CONDITION.
Category II nonfriable ACM: any material, excluding Category I nonfriable ACM, containing more than 1% asbestos that when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure. IN GOOD CONDITION.
Rule of Thumb: a material would not be Category I or II non-friable
ACM if it cannot be removed without significant breakage
(i.e. rendered friable). The material would be RACM.
AHERA TELLS US WHAT IS ASBESTOS AND WHAT IS NOT, AND REQUIRES THAT ACBM BE MANAGED SAFELY IN OCCUPIED SCHOOL BUILDINGS. AHERA DOES NOT REQUIRE REMOVAL !
The Model Accreditation Plan is an EPA regulation that came out of AHERA, and as such, it applies to Response Actions (friable abatement), inside buildings.