slide1 n.
Skip this Video
Loading SlideShow in 5 Seconds..
Asbestos NESHAP Inspection and Safety Procedures Course PowerPoint Presentation
Download Presentation
Asbestos NESHAP Inspection and Safety Procedures Course

Loading in 2 Seconds...

play fullscreen
1 / 110

Asbestos NESHAP Inspection and Safety Procedures Course - PowerPoint PPT Presentation

  • Uploaded on

Asbestos NESHAP Inspection and Safety Procedures Course. Chapter 4 Asbestos NESHAP Regulation. Version 2012.1. Topics. Introduction History Asbestos NESHAP 40 CFR Part 61, Subpart M Appendix A – Roof Removal Operations. A note before we begin….

I am the owner, or an agent authorized to act on behalf of the owner, of the copyrighted work described.
Download Presentation

PowerPoint Slideshow about 'Asbestos NESHAP Inspection and Safety Procedures Course' - ann

An Image/Link below is provided (as is) to download presentation

Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author.While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server.

- - - - - - - - - - - - - - - - - - - - - - - - - - E N D - - - - - - - - - - - - - - - - - - - - - - - - - -
Presentation Transcript

Asbestos NESHAP Inspection and Safety Procedures Course

Chapter 4

Asbestos NESHAP Regulation

Version 2012.1

  • Introduction
  • History
  • Asbestos NESHAP
    • 40 CFR Part 61, Subpart M
    • Appendix A – Roof Removal Operations
a note before we begin
A note before we begin…
  • This section is an overview of the asbestos NESHAP requirements.
  • For a full understanding and more detail of the NESHAP read:
    • Chapter 4 in the course manual and
    • the asbestos NESHAP regulation
epa legal authority asbestos
EPA Legal Authority - Asbestos
  • Statute: Clean Air Act – Section 112

National Emission Standards for

Hazardous Air Pollutants (NESHAP)

  • Regulation: 40 CFR Part 61, Subpart M

Asbestos NESHAP

asbestos neshap overview
Asbestos NESHAP Overview
  • Examples of substances regulated by EPA’s NESHAP program:
    • Asbestos
    • Benzene
    • Chlordane
    • Formaldehyde
  • Future references to the “NESHAP” in this course mean the asbestos NESHAP
brief asbestos neshap overview
Brief Asbestos NESHAP Overview
  • Applies to all facilities except single residential buildings having 4 units or less
  • Requires a thorough inspection before disturbance
  • Requires controlled removal of Regulated Asbestos Containing Materials (RACM) to avoid disturbance during demolition or renovation
brief asbestos neshap overview cont
Brief Asbestos NESHAP Overview(cont.)
  • Usually requires prior notification to EPA or the designated local/state NESHAP program
  • Requires proper management during disturbance of RACM and disposal to avoid release of fibers
neshap information
NESHAP Information
  • Asbestos NESHAP policy information:
    • Applicability Determination Index (ADI)
  • Stationary source compliance/guidance
    • Technology Transfer Network (TTN)
asbestos neshap history
Asbestos NESHAP History
  • 1973 – Addressed demolitions and banned spray-applied asbestos such as fireproofing
  • 1975 – Addressed renovations and banned wet-applied such as pipe/boiler insulation and pre-molded insulation
  • 1978 – Addressed work practices and banned application of decorative uses such as textured ceilings
asbestos neshap history cont
Asbestos NESHAP History(cont.)
  • 1984 – Repromulgation to address work practices
  • 1990 – Repromulgation to address notification and waste/disposal
  • 1994 – Addition of Appendix A to address roof removal
asbestos neshap sections
Asbestos NESHAP Sections
  • § 61.140 - Applicability
  • § 61.141 - Definitions
  • § 61.145 – Standard for Demo/Renovations
  • § 61.150 – Waste disposal
  • § 61.151 – Inactive waste disposal sites
  • § 61.153 – Source reporting requirements
  • § 61.154 – Active waste disposal sites
  • § 61.157 – Delegation of authority
61 140 applicability
Asbestos mill operations

Roadway surfacing

Product manufacturing

Demolition/renovation operations

Spraying of ACM

Fabricating operations

Use of insulating materials

§ 61.140 - Applicability
61 140 applicability cont
Waste disposal for asbestos mills

Waste disposal for other ACWM

Inactive waste disposal site closure and maintenance

Air-cleaning device operation

Information reporting

Active waste site disposal operation

Conversion operations

§ 61.140 – Applicability(cont.)
40 cfr 61 141 definitions
40 CFR § 61.141 Definitions
  • Adequately wet
  • Asbestos
  • Asbestos-containing waste materials
  • Category I nonfriable ACM
  • Category II nonfriable ACM
  • Demolition
  • Emergency renovation
  • Facility
  • Friable asbestos material
  • Glove bag
  • Inactive waste disposal site
  • In poor condition
  • Installation
  • Leak-tight
  • Natural barrier
  • Outside air
  • Owner or operator
  • Regulated asbestos-containing material
  • Renovation
  • Visible emissions
  • Waste shipment record
  • Working day

Selected definitions to be highlighted in the course.

adequately wet
Adequately wet

To sufficiently mix or penetrate with liquid to prevent the release of particulates

EPA 340/1-90-019

  • Serpentine (chrysotile)
  • Amphiboles
    • Riebeckite (crocidolite)
    • Cummingtonite-grunerite (amosite)
    • Anthophyllite
    • Actinolite-tremolite
asbestos containing waste materials
Asbestos-Containing Waste Materials

ACWM – waste containing commercial asbestos generated by a source regulated by the NESHAP

  • Friable asbestos waste material
  • Control device filters
  • Contaminated bags/packaging
  • Contaminated materials; e.g., disposable equipment and clothing
category i nonfriable acm
… asbestos-containing packings, gaskets, resilient floor covering, and asphaltic roofing products containing >1% asbestos …Category I Nonfriable ACM
  • The wrecking or taking out of any load-supporting structural member of a facility together with any related handling operations
  • The intentional burning of any facility
emergency renovation operation
An unplanned, sudden, unexpected event that could, if not immediately attended to:

present a safety or public health hazard

damage equipment

impose an unreasonable financial burden

Emergency Renovation Operation
Any institutional, commercial, public, industrial, or residential structure, installation or building

Excludes residential buildings with ≤ 4 dwelling units

Ships - common interpretation – commercial vessels, not pleasure craft

Active or inactive waste disposal sites

Previously regulated structures regardless of current use

friable asbestos material
Sec. 10Friable Asbestos Material
  • > 1% asbestos
  • When dry, can be crumbled, pulverized, or reduced to powder by hand pressure
  • If <10%, verify with point counting using polarized light microscopy (PLM)
glove bag
Sealed compartment

Attached inner gloves

Allows handling of ACM inside work area enclosures

Glove Bag
Any building or structure or any group of buildings or structures at a single demolition/renovation site that are under the control of the same owner or operator (or owner or operator under common control)Installation
natural barrier
Natural object that precludes or deters access

Lakes or other large bodies of water

Deep/wide ravines and cliffs


The remote nature of a site DOES NOT constitute a natural barrier

Natural Barrier
nonfriable acm
A material with >1% asbestos that, when dry, cannot be crumbled, pulverized or reduced to powder with hand-pressureNonfriable ACM
outside air
Air outside buildings and structures

This includes air under bridges at open-air ferry docks

Outside Air
owner or operator
Owner or Operator

A person who owns leases, operates, controls or supervises:

  • a facility being demolished or renovated and/or
  • a demolition or renovation operation

Regulated Asbestos Containing Material

  • Friable ACM
  • Category I nonfriable ACM which has become friable
  • Category I nonfriable ACM which has been/will be sanded, ground, cut or abraded
  • Category II nonfriable ACM which has a high probability to become or has become friable

Note: Some local/state programs define RACM more stringently; e.g., wallboard joint compound can be regulated as RACM.

Altering a facility or one or more facility components in any way

Includes stripping or removal of RACM from a facility component

visible emissions
Emissions coming from RACM or ACWM that are visually detectable without the aid of instruments

Excludes condensed uncombined water vapor

Visible Emissions
waste shipment record
Must originate with, and be signed by, the waste generator

Tracks and substantiates disposition of ACWM

See Figure 4-4 in the student manual.

Waste Shipment Record
working day
Weekdays – Monday through Friday

Includes holidays falling on weekdays

Working Day
40 cfr 61 145 standard for demolition and renovation
40 CFR § 61.145Standard for Demolition and Renovation
  • § 61.145(a) - Applicability
  • § 61.145(b) – Notification requirements
  • § 61.145(c) – Emission control
61 145 a applicability
§ 61.145(a) Applicability
  • Depends on presence, amounts and condition of asbestos in the facility
  • Determined by a THOROUGH INSPECTION of the affected facility or part of the facility for the presence of asbestos including Category I & II nonfriable ACM
demolitions renovations
  • 260 linear feet on pipes
  • 160 square feet on other facility components
  • 35 cubic feet of facility off facility components where the length or area cannot be measured

Note: Some local/state programs may have more stringent thresholds than those found in the NESHAP

  • Don’t just count the pieces!
  • 2 halves = 1 length
  • Improper measurements and calculations can result in inaccurate determinations of compliance status
61 145 b notification requirements
§ 61.145(b) Notification Requirements
  • Notification responsibility
  • Notifications timing
  • Notification content
demolition thresholds
Demolition Thresholds

Amount or TypeRequirements

260/160/35 Notification, emission

control procedures

<260/160/25 Notification

(or no asbestos)

Ordered Notification, emission

control procedures

demolition notifications
Demolition Notifications
  • Notifications are required for ALL demolitions, whether asbestos is present or not including demolishing a building, taking out load-bearing structure, or burning.
  • Regulatory agencies should be consulted about handling ACM from burned or partially burned buildings.
  • Requirements can vary significantly from one jurisdiction to the next.
renovation thresholds
Renovation Thresholds

Amount or TypeRequirements

>260/160/35 Notification, emission

control procedures

<260/160/35 None

Planned … individual Notification, emission non-scheduled control procedures

Emergency Notification, emission

control procedures

renovation notifications
Renovation Notifications
  • Renovation notification required if the following quantities are exceeded:
    • 260 linear feet (LF) for pipes (TSI etc.)
    • 160 square feet (SF) on other facility components (fireproofing, etc.)
    • 35 cubic feet (CF) taken from facility components where the length or area cannot be measured.
  • Some local/state programs have more stringent notification thresholds than those found in the NESHAP.
notification responsibility
The owner or operator must:

provide written notification

update notification if scope of work changes; e.g., > 20% % change in amount of ACM

properly deliver notice

U.S. Postal Service postmark

Commercial delivery service

Hand delivery

provide required information

Notification Responsibility
notification timing demo reno
Notification Timing – Demo/Reno
  • All demolitions with or without asbestos
    • 10 working days
  • Renovations
    • < 260/160/35 – notification not required
    • > 260/160/35
      • Normal - 10 working days
      • Planned and involving individual nonscheduled operations –

10 working days before end of the year (annual notifications)

  • Ordered demolitions and emergency renovations
    • As early as possible before, but not later than, the following working day
notification timing updates
Notification Timing - Updates
  • Later starting date
    • Notify via telephone ASAP
    • Notify in writing no later than the original starting date
  • Earlier starting date
    • Notify in writing
    • At least 10 working days before stripping, demolition, or removal begins
notification content general
Notification Content - General
  • Whether an initial or revised notification
  • Information on responsible parties
  • Whether a demolition or renovation
  • Description of facility or affected part
  • Detection/analytical procedures
  • Amount of RACM to be removed
  • Amount of nonfriable ACM to remain (demolitions)
notification content general cont
Notification Content - General (cont.)
  • Facility address/worksite location
  • Starting/completion dates (removals, demolitions, renovations)
  • Planned demolition/renovation work
  • Work practices/engineering controls
  • Waste disposal site information
  • Supervisor certification statement
  • Procedures for dealing with unexpected RACM
notification content updates
Notification Content – Updates
  • Name of contractor (operator)
  • Start date and finish dates
  • Amounts of RACM, Category I or Category II
  • Any other substantive changes

Note: Some local/state programs have more detailed notification requirements.

Note: Some agencies are now developing on-line capabilities for notifications and change notices.

notification content ordered demolitions
Notification ContentOrdered Demolitions
  • Name, title, authority of government representative
  • Date order issued
  • Date demolition will begin
  • Copy of order
notification content emergency renovations
Notification ContentEmergency Renovations
  • Date and hour emergency occurred
  • Description of emergency event
  • Description of circumstances
    • Unsafe condition
    • Equipment damage
    • Unreasonable financial burden

Note: Poor planning IS NOT an emergency!!

notifications miscellaneous
Notifications - Miscellaneous
  • Some local/state programs may have more detailed notification requirements.
  • Some agencies are now developing on-line capabilities for notifications and change notices.
  • Adherence to minimum requirements of the original NESHAP is still required with any modern systems that are deployed.
61 145 c emission control
Removal of ACM

Removal of units/sections

Stripping from in-place component

Treatment of removed units/sections

Treatment of large facility components

Handling of RACM

Below freezing temperatures

Training requirements

Special demolitions

§ 61.145(c) – Emission Control
removal of acm
All RACM must be removed from a facility being demolished or renovated before any activity begins that would break up, dislodge, or similarly disturb the material or preclude access to the material for subsequent removal.Removal of ACM
exceptions to removal requirement
Ordered demolition – structurally unsound, danger of imminent collapse, etc.

Cat I NF – not in poor condition, not friable

Cat II NF – low probability of becoming RACM

Encased in concrete

Not accessible for testing

Found at demolition

Note: All asbestos-contaminated wastes from the bottom two bullets are treated as ACWM.

Exceptions to Removal Requirement
encased in concrete
Encased in Concrete
  • Insulation may be applied to structural members before the floor is poured
  • Asbestos is inaccessible
double wall
Double Wall
  • Pipes may be hidden by walls
  • Asbestos in such cases IS NOT inaccessible!
unit or section removal
Adequately wet all RACM exposed during cutting/disjoining operations

Carefully lower unit/section to floor and to ground level

Unit or Section Removal
wetting techniques
Pump-up-type garden sprayer (small projects)

Garden hose

Hydrant source

Airless paint sprayer

Amended water/surfactant

Wetting Techniques
wetting illustrations
Wetting Illustrations

Not Adequately Wet

Adequately Wet

wetting exceptions
Equipment damage or safety hazard

Request written approval

Use of emission control methods

local exhaust ventilation

glove bag

leak-tight wrapping

Wrapped RACM

Below freezing temperatures

Unit/section removal to maximum extent

Record temperatures

Retain records for two years

Wetting Exceptions
evaluation of wetting procedures
Evaluation of Wetting Procedures

To determine if RACM is being adequately wetted, evaluate the following as applicable:

  • Is an amended water supply on site/in use?
  • Is water being applied to the material?
  • Is condensation visible in the waste bag?
  • Is water visible in the waste bag?
  • Does the waste bag feel heavy?
  • Does the bag feel cool?
  • Does the material look wet?
  • Does the material feel wet?
treatment of removed units sections
Treatment of Removed Units/Sections
  • Strip
    • Adequately wet during stripping or
    • Use LEVC system
  • Contain in leak-tight wrapping
wrapped acm
Wrapped ACM

Wrapping has become a standard practice for large scale

removal of pipes with ACM insulation

exemptions from stripping large facility components
Exemptions from Stripping(Large Facility Components)
  • Remove, transport, store, dispose of, or reuse without disturbing or damaging RACM


  • Encase component in leak-tight, properly labeled wrapping during loading, unloading, and storage
handling of racm
Adequately wet

Carefully lower to the ground/floor

Use leak-tight chutes or containers if >50’

Handling of RACM
training requirements
Training Requirements
    • At least one on-site individual trained in the provisions of NESHAP is required if RACM is to be stripped, removed, handled, or disturbed
    • Refresher training every 2 years
    • Evidence of training posted at job site
  • OSHA and states may be more stringent
  • Fraudulent training programs are a national problem!
  • A trained on-site person is recommended regardless of confirmed presence of asbestos
special demolitions
Special Demolitions
  • Ordered Demolitions
    • Keep affected portions of facility containing RACM adequately wet during demolition
  • Intentional Burning
    • Remove all RACM including Categories I and II nonfriable ACM before burning
      • Common deficiency during fire department training
      • Fire personnel are often not trained in pre-burn NESHAP requirements
      • Building owners may not want to remove ACM
61 150 waste disposal
§ 61.150 – Waste Disposal
  • § 61.150(a) – Visible Emissions
  • § 61.150(b) – Deposition of ACWM
  • § 61.150(c) – Vehicle Marking
  • § 61.150(d) – Offsite Transport
acwm waste disposal
Friable asbestos waste material

RACM waste material

Contaminated packaging or bags

Materials contaminated with asbestos

Control device filters

ACWM Waste Disposal
visible emissions control
Discharge no visible emissions to the outside air during collection, processing, packaging or transporting of ACWM


Use one of the following control methods

Adequately wet ACWM

Process ACWM into nonfriable forms

Use an approved emission control alternative

Visible Emissions Control
wetting procedures for acwm
Mix control device waste to form a slurry

Adequately wet other ACWM

Ensure no visible emissions discharged to outside air

Seal wetted ACWM into leak-tight containers or wrapping

Label packaged waste with OSHA warning label

For offsite waste disposal, attach generator label (name of generator, location of waste generation)

RACM not removed before demolition

adequately wet ACWM at all times after demolition

keep wet during handling and loading for transport

leak-tight containers/wrapping not required

Wetting Procedures for ACWM
waste containerization
Waste Containerization

Leak-tight: Means that solids or liquids cannot escape or spill out. It also means dust-tight.


3 labels on each bundle/bag:

1. OSHA Danger

2. DOT (NA 2212)

3. EPA Waste Generator Label

For bundles; adhesive labels

Lack of Generator labels is an often cited violation!

Typical waste bag seen on

asbestos control projects

disposal of acwm
Disposal of ACWM is required as soon as practical

Asbestos is not regulated like hazardous waste; i.e., no holding time limits, etc.

ACWM must be deposited at an appropriate waste disposal site or conversion site

Most states have landfills that are approved for asbestos – many are municipal solid waste (MSW) landfills

Conversion technology exists but is rarely used due to cost

Disposal of ACWM
vehicle marking
Required only during loading and unloading

Visible signage may include:

OSHA danger signs

Red barrier tape

Vehicle Marking

Is this legal?

vehicle marking1
Vehicle Marking

Required sign

Is this legal?

off site transport
Generator must maintain waste shipment records (WSRs) at least two years

Transporter must provide WSR to disposal site upon arrival

If WSRs are not returned within 35 days, generator must make inquiries to the transporter or disposal facility.

If WSRs are not returned after 45 days, generator must notify the asbestos NESHAP enforcement agency responsible for waste generators and advise of missing records.

Off-site Transport
61 153 source reporting requirements
§ 61.153 Source Reporting Requirements

§ 61.153(a)

New and existing sources

§ 61.153(b)

Active waste disposal sites (WDSs)

source reporting requirements
§61.153(a) New and Existing Sources

Report within 90 days of startup


description of control equipment for each process.

filter specifications

other information as applicable

Note: These requirements do not apply to demolition/renovation sources.

Source Reporting Requirements
source reporting requirements1
§61.153(b) Active Waste Disposal Sites

Owner/operator name and address

Source location

Hazardous pollutants emitted

Method of operation of stationary source

Average weight of asbestos processed per month for past 12 months

Source Reporting Requirements
61 154 active waste disposal sites
§ 61.154 – Active Waste Disposal Sites
  • § 61.154(a-d) Site operation
  • § 61.154(e) Site operation recordkeeping and

reporting (R&R)

  • § 61.154(f-h) Site closure R&R
  • § 61.154(i) Record availability
  • § 61.154(j) Excavation notification

Waste Disposal Site Operation

Warning signs and fencing


No visible emissions



Natural barrier that deters

public access


Six inch cover of compacted

non-asbestos-containing material

within 24-hr period



Warning signs and fencing

Cover with a resinous petroleum-

based dust suppression agent within 24-hr period




Natural barrier that deters

public access


Warning signs and fencing

Alternate control method receiving

prior approval




Natural barrier that deters

public access

active waste disposal sites
Site Operation Recordkeeping and Reporting

Maintain waste shipment records

Notify regarding any improperly enclosed or uncovered waste

ASAP, but not later than 30 days after receipt of waste, send WSR to generator

Resolve discrepancies within 15 days

Retain records and reports at least 2 years

Active Waste Disposal Sites
active waste disposal sites1
Site Closure Recordkeeping and Reporting

Maintain records of location, depth/area, quantity of ACWM

Comply w/closure provisions

Submit records to Administrator

Active Waste Disposal Sites
active waste disposal sites2
Record Availability

Furnish records upon request

Make available during normal business hours

Active Waste Disposal Sites
active waste disposal sites3
Active Waste Disposal Sites

Requirements for notification of disturbance

of interred ACWM

  • Notify 45 days before disturbance
  • Provide projected start and completion dates
  • Provide reasons for the disturbance
  • Provide emission control methods to be used
  • Provide locations of temporary and final disposal site(s)

Note: Administrator can require changes in emission controls

61 151 inactive waste disposal sites
§ 61.151 Inactive Waste Disposal Sites
  • § 61.151(a) – Site operation
  • § 61.151(b) – Site demarcation
  • § 61.151(c) – Control alternatives
  • § 61.151(d) – Excavation notification
  • § 61.151(e) – Deed notation
inactive waste disposal sites
Inactive Site Operation Options

Discharge no visible emissions to the outside air OR

Cover ACWM with:

6” of compacted non-ACM and maintain vegetative cover or

2 feet of compacted non-ACM and provide continuing maintenance OR

Use resinous or petroleum-based suppressant or other approved agent

Inactive Waste Disposal Sites
inactive waste disposal sites1
Deed notation

File within 60 days of site inactivation

Describe land used for ACWM disposal

Provide survey plot, record of location and quantity of ACWM disposed

Note that site is subject to asbestos NESHAP

Inactive Waste Disposal Sites
inactive waste disposal sites2
Excavation notification

Notify 45 days before disturbance

Advise of starting and completion dates

Provide explanation of purpose of excavation

Describe emission control methods used/in use

Identify locations of temporary and/or final disposal sites

Inactive Waste Disposal Sites
61 157 delegation of authority
§ 61.157 Delegation of Authority

Authorities retained by the EPA Administrator and not delegated to states

interpretive rule governing roof removal operations appendix a to subpart m
Interpretive Rule Governing Roof Removal Operations(Appendix A to Subpart M)
  • Applicability
  • Notification
  • Emission Control


  • Waste Disposal
category i nonfriable asbestos containing roofing material
Use of a rotating blade (RB) roof cutter to remove at least 5,580 SF of roofing subjects activity to NESHAP

Smaller removals and those using equipment that does not create RACM are not subject to the NESHAP

Category I Nonfriable Asbestos-Containing Roofing Material

Photo provided by Panther East

Contractor Tools & Equipment

roof removal issues
Asbestos-cement (A/C) shingles and other Cat II nonfriable ACM

SUBJECT if removal method will crumble, pulverize or reduce to powder or contaminate with RACM an area of at least 160 SF

NOT SUBJECT if methods are used that do not create RACM and materials are properly handled

Roof Removal Issues
roof removal issues summary
Roof Removal Issues- Summary
  • Roof blade cutters –


  • Methods that do not create RACM –


  • Power removers and tear-off machines –


roof removal notifications
Roof Removal Notifications

Are notifications required?

  • Demolitions – YES
    • Demolitions always trigger notification requirements
    • Many removals (including most roof removals) are renovations rather than demolitions
  • Renovations - Depends
    • If manual methods or slicing of Category I – NO
    • If Category II (RACM not anticipated) – NO
    • If a RB cutter is used and meets applicability and threshold amounts (5,580 SF) – YES
roof removal issues1
Emission control requirements and exemptions for regulated roof removal operations

Adequately wet, no visible emissions

An RB cutter equipped with a blade guard AND functioning spray mechanism meets these requirements

Wetting exemptions

Building structure damage, building equipment damage and safety hazards require written approval

Freezing temperature – requires recordkeeping

Alternative control methods are required

Roof Removal Issues
roof removal issues2
Waste collection and handling

No RACM generated - NOT SUBJECT

RACM generated - SUBJECT

Determination of whether RACM is generated is key decision

Roof Removal Issues
roof removal issues waste disposal and recordkeeping
Roof Removal IssuesWaste Disposal and Recordkeeping
  • Collected dust/debris from cutting and any contaminated roofing squares must be taken to a compliant landfill or EPA-approved conversion site. § 61.150(b)
  • Waste Shipment Record requirements previously reviewed apply. § 61.150(d)
roof removal training
Roof Removal Training
  • Onsite supervisor required for regulated roof removal operations
  • Supervisor MUST have:
    • NESHAP training
    • Roof specific training or other courses covering areas specified in the regulation; e.g., AHERA courses
  • Worker training
    • NESHAP – Not required
    • OSHA – Required
    • Local/state agencies – Sometimes required
the asbestos neshap
The Asbestos NESHAP
  • The NESHAP regulation is lengthy and there are many interpretations - EPA, states, local agencies
  • It takes time and work experience to understand it all!!
  • Read Chapter 4 of the manual.
  • Read the NESHAP regulation.
  • Ask questions!
further help
Further Help
  • A Guide to Normal Demolition Practices Under the Asbestos NESHAP
    • EPA-340/1-92-013 September 1992
  • Applicability of the Asbestos NESHAP to Asbestos Roofing Removal Projects
    • EPA-340-B-94-001 August 1994
  • Guideline for Asbestos NESHAP Demolition and Renovation Inspection Procedures
    • EPA-340/1-90-007 Rev. November 1990