Asbestos in Schools Environmental Health and Safety. Webinar Series 04 SEPT 2012 Dr. David Peterson. Presentation Overview. Introduction NESHAP AHERA OSHA Common Asbestos Acronyms & Terms and Definitions What is Asbestos? Why is Asbestos a Hazard? When is Asbestos a Hazard?
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Environmental Health and Safety
04 SEPT 2012
Dr. David Peterson
There are a number of laws that govern how asbestos materials are to be handled in schools, public and commercial buildings, including buildings that are to be demolished or undergoing major renovations. The laws that govern asbestos management and removal under the Environmental Protection Agency include: the Asbestos Hazard Emergency Response Act (AHERA), the Asbestos School Hazard Abatement Reauthorization Act (ASHARA) and the National Emission Standards for Hazardous Air Pollutants for Asbestos (NESHAP). The Occupational Safety and Health Administration (OSHA) regulates exposure to asbestos in the workplace.
SAN FRANCISCO -- The U.S. Environmental Protection Agency recently fined three Arizona charter school operators a combined total of $27,480 for alleged Asbestos Hazard Emergency Response Act (AHERA) violations
Abatement: any operation that is designed to permanently remove asbestos-containing materials.
Asbestos Hazard Emergency Response Act (AHERA): this act became law in 1987 and specified a plan by which K-12 schools would manage asbestos.
Asbestos-Containing Material (ACM): any material that contains more than 1% of asbestos.
Asbestos related work: any work that involves ACM and may result in the release of any quantity of asbestos fibers into the air.
Disturbance: contact with any material that contains ACM or PACM that causes release of fibers.
Fiber: a particulate form of asbestos, 5 micrometers or longer, with a length-to-diameter ratio of at least 3-to-1.
Intact: ACM that has not crumbled, been pulverized, or otherwise deteriorated.
Presumed Asbestos-Containing Material (PACM): materials that may contain asbestos but have not yet been tested.
Removal: all operations where ACM and/or PACM is taken out or stripped from structures or substrates, including demolition operations.
Renovation: any operations that involves altering a facility or one or more facility components in any way.
Asbestos is the name given to a group of naturally occurring
minerals used in certain products, such as building materials and vehicle brakes, to resist heat and corrosion.
- tremolite asbestos
- anthophyllite asbestos,
- actinolite asbestos
- and any of these materials that have been
chemically treated and/or altered.
Asbestos is made up of microscopic bundles of fibers that may become airborne when disturbed. These fibers get into the air and may become inhaled into the lungs, where they may cause significant health problems. Researchers still have not determined a “safe level” of exposure but the greater and the longer the exposure, the greater the risk of contracting
an asbestos related disease.
Some of these health problems include:
- Lung Cancer
Asbestos is a problem when it is disturbed and fibers are released into the air.
Asbestosis: a lung disease first found in naval shipyard workers. As asbestos fibers are inhaled, they become trapped in the lung tissue. The body tries to dissolve the fibers by producing an acid. This acid, due to the chemical resistance of the fiber, does little to damage the fiber, but may scar the surrounding tissue. Eventually, this scarring may become so severe that the lungs cannot function. The latency period is often 25 - 40 years.
Mesothelioma: a cancer of the pleura ( the outer lining of the lung and chest cavity) and/ or the peritoneum ( the lining of the abdominal wall). This form of cancer is peculiar because the only known cause is from asbestos exposure. The latency period for mesothelioma is often 15-30 years.
* Latency period - the time it takes for the disease to develop
Lung Cancer: Asbestos is a contributing factor of lung cancer. The effects of lung cancer are greatly increased by cigarette smoking (by about 50%). Cancer of the gastrointestinal tract can also be caused by asbestos. The latency period for cancer is often 15-30 years.
* Latency period - the time it takes for the disease to develop
Asbestos is not always an immediate hazard. In fact, if asbestos can be maintained in good condition, it is recommended that it be left alone and periodic surveillance performed to monitor its condition. It is only when asbestos containing materials (ACM) are disturbed or the materials become damaged that it becomes a hazard. When the materials become damaged, the fibers separate and may then become airborne. In the asbestos industry, the term ‘friable’is used to describe asbestos that can be reduced to dust by hand pressure. ‘Non-friable’means asbestos that is too hard to be reduced to dust by hand. Non-friable materials, such as transit siding and floor tiles are not regulated provided it does not become friable. Machine grinding, sanding and dry-buffing are ways of causing non-friable materials to become friable.
The purpose of the Asbestos National Emission Standard for Hazardous Air Pollutants (NESHAP) Program is to protect public health from exposure to regulated asbestos-containing material (RACM) during NESHAP facility renovation/demolition activities, asbestos removal, transport and disposal, closely monitoring those activities for proper notification and asbestos emissions control.
Asbestos is known to cause cancer and other respiratorydiseases in humans.
Under Section 112 of the Clean Air Act (CAA), Congress gave the U.S. Environmental Protection Agency (EPA) the responsibility for enforcing regulations relating to asbestos renovations and demolitions activities. The CAA allows the U.S. EPA to delegate this authority to state and local agencies. Even after the U.S. EPA delegates responsibility to a state or local agency, the U.S. EPA retains authority to oversee agency performance and to enforce the Asbestos NESHAP regulations as necessary.
The Asbestos NESHAP program in Arizona is enforced by federal, state, and county Asbestos NESHAP agencies.
National Emission Standards for Hazardous Air Pollutants (NESHAP)
The Asbestos Hazard Emergency Response Act (AHERA), a provision of the Toxic Substances Control Act, became law in 1986.
AHERA requires local education agencies to inspect their schools for asbestos-containing building material and prepare management plans to prevent or reduce asbestos hazards.
Public school districts and non-profit private schools (collectively called local education agencies) are subject to AHERA's requirements. This includes charter schools and schools affiliated with religious institutions.
Asbestos Hazard Emergency Response Act (AHERA) effective 1987.
The rules implementing AHERA are published in the Code of Federal Regulations, Chapter 40, Part 763, Subpart E. The AHERA rules require local education agencies to take actions to:
Only considered by EPA definition ACBM if greater than 1% asbestos
There are three main types:
Thermal System Insulation (TSI)
Structural steel & deck coating
The AHERA schools rule rarely requires the removal of asbestos materials.
Proper asbestos management begins with a comprehensive inspection by qualified, trained and experienced inspectors, accredited through an EPA or state-approved training course.
Inspecting the condition of asbestos materials – initially with AHERA-accredited inspectors and at least semi-annually with trained custodial or maintenance staff – is extremely important so that changes in the material’s condition - damage or deterioration, can be detected and corrected before the condition worsens.
Only an AHERA-accredited management planner – an asbestos professional with proper training, qualifications, and experience – is authorized to advise school officials on which response action is appropriate for a particular situation.
Under the AHERA schools rule, each local education agency (LEA, which means a school district or private school) must take the following asbestos-related actions:
1 Designate and train a person to oversee asbestos-related activities in the school system.
2 Inspect every school building for “friable” and “nonfriable” asbestos-containing building materials.
3 Prepare a management plan for managing asbestos and controlling exposure in each school.
4 Consult with accredited inspection and management professionals to identify and carry out whatever asbestos actions are necessary and appropriate to protect health and the environment. These actions or methods must be documented in the management plan.
5 Notify the public about the asbestos inspection and the availability of the asbestos management plan for review.
6 Use only properly accredited persons to conduct inspections, to develop the asbestos management plan, and to carry out the appropriate response actions.
7 Keep records of all asbestos related activities in the plan and make them available for public review.
Designated Person Do?
This designated person must meet certain training requirements, and serves as the single point of contact for public information about asbestos-related activities in the LEA. He or she is responsible for:
• Ensuring that initial asbestos inspections, re-inspections every three years, and semi-annual surveillance activities are conducted properly by qualified personnel.
• Including results of the inspection in the management plan. The plan must identify all asbestos-containing building materials found in schools and recommend actions for dealing with asbestos hazards.
• Preparing a management plan (for schools built after October 12, 1988) for submission to the appropriate state Agency prior to the school being used as a school building. The management plan should be maintained and updated with records of response actions, periodic surveillance of asbestos containing materials (ACM) and all re-inspections.
Designated Person Do?
• Making sure that custodial and maintenance workers receive required safety training and information about the location of asbestos-containing materials in their school. Warning labels must be posted in all routine maintenance areas, such as boiler rooms, where asbestos-containing building materials are found.
• Ensuring that response actions specified in the management plan are carried out according to the plan’s timetables. The regulations require that all LEAs were to begin to carry out their management plans no later than July 9, 1989.
• Seeing that all asbestos records required by the regulations are accurately maintained.
• Informing all teacher, parent and employee organizations at least once a year about the asbestos activities in each school and about the availability of the management plan for their review.
EPA conducts compliance inspections of a sample of schools each year to make sure they are obeying the law. The Agency is responsible for insuring that schools comply with AHERA and it will investigate reported violations.
EPA Region 9
75 Hawthorne StreetSan Francisco, CA 94105Phone: (415) 947-8000(Arizona, California, Hawaii,Nevada, American Samoa,and Guam)
Step One: Awareness
Your first step is to make sure your school has prepared an asbestos management plan as required by AHERA.
Step Two: Minimize Disturbance
Find out which materials in your school contain asbestos (AHERA MANAGEMENT PLAN FOR MY SCHOOL ). Once you know where asbestos is, use special care to insure that any day-to-day activities, such as repair or maintenance work, do not disturb the material.
A NESHAP Notification shall be postmarked or delivered to the NESHAP Coordinator at least ten (10) working days before asbestos strip-ping or removal work or any activity begins, such as site preparation that would break up, dislodge or similarly disturb asbestos materials, or if the operation is a demolition of a NESHAP facility, demolition of more than one residence by the same owner, same project, even when no asbestos is present. Working day means Monday through Friday and includes holidays that fall on Monday through Friday.
Per Rule 280, Section 313 of the Maricopa County Air Pollution Control Regulations, there is a nonrefundable notification and plan review filing fee based on a sliding fee schedule. A separate fee is required for renovation and for demolition. Make all checks payable to the Maricopa County Air Quality Department.
313.1 Renovation: Any person filing notification of a project to renovate regulated asbestos-containing materials (RACM) shall pay a nonrefundable notification and plan review filing fee based on the amount of regulated asbestos-containing materials removed as shown in the table below:
313.2 Demolition: Any person filing notification of a project to demolish a facility (as defined in 40 CFR 61, Subpart M) shall pay a nonrefundable notification and plan review filing fee of $600.00.
EXAMPLE: A 2000 sq. ft. commercial building having 650 sq. ft. of asbestos abated and then being demolished will require a fee for abatement AND a fee for demolition.
$1,770 (abatement fee - Rule 280, § 313.1)
+ $600 (demolition fee - Rule 280, § 313.2)
You have the right to a safe workplace. The Occupational Safety and Health Act of 1970 (OSH Act) was passed to prevent workers from being killed or seriously harmed at work. The law requires employers to provide their employees with working conditions that are free of known dangers. The Act created the Occupational Safety and Health Administration (OSHA), which sets and enforces protective workplace safety and health standards. OSHA also provides information, training and assistance to workers and employers. Workers may file a complaint to have OSHA inspect their workplace if they believe that their employer is not following OSHA standards or that there are serious hazards.
Workers are entitled to working conditions that do not pose a risk of serious harm. To help assure a safe and healthful workplace, OSHA also provides workers with the right to:
Ask OSHA to inspect their workplace;
Use their rights under the law without retaliation and discrimination;
Receive information and training about hazards, methods to prevent harm, and the OSHA standards that apply to their workplace. The training must be in a language you can understand;
Get copies of test results done to find hazards in the workplace;
Review records of work-related injuries and illnesses;
Get copies of their medical records;
Employers MUST provide their employees with a workplace that does not have serious hazards and follow all relevant OSHA safety and health standards.
Employers MUST also:
Inform employees about hazards through training, labels, alarms, color-coded systems, chemical information sheets and other methods.
Keep accurate records of work-related injuries and illnesses.
Perform tests in the workplace, such as air sampling required by some OSHA standards.
Provide hearing exams or other medical tests required by OSHA standards.
Post OSHA citations, injury and illness data, and the OSHA poster in the workplace where workers will see them.
Notify OSHA within 8 hours of a workplace incident in which there is a death or when three or more workers go to a hospital.
Not discriminate or retaliate against a worker for using their rights under the law.
Response actions – encapsulation, enclosure, and removal – and sometimes the second method – repair – must be done by accredited asbestos professionals.
1. Oversee development and implementation of the District Asbestos Management Plan.
2. Review and evaluate the impact of records and regulatory changes on the District Facilities.
3. Oversee and maintain records of asbestos awareness training given to employees.
4. Participate in determining the need for baseline air monitoring in occupied buildings.
5. Maintain a central location for asbestos management documentation.
The Asbestos Coordinator will see that the PACM will be tested or removed and disposed in compliance with applicable governing regulatory agency regulations/guidelines pertaining to ACM. A Third-Party Consultant used for monitoring and Final Air Clearance and access to the site.
The Asbestos Coordinator will use trained asbestos contractors with the proper license and permits to remove, store and dispose of ACM. Disposal is to an Approved Landfill. District will own that portion in the Landfill. The approved Consultant will hire the proper testing lab as required for clearance.
**Remember – May need an RFQ **
Certified Asbestos Consultants:
- A certified asbestos consultant will be called upon by the Asbestos Coordinator when required. The certified consultant will supervise the asbestos contractor when required by forming a scope of work, supervising containment set up, testing and daily sight visits. All results and reports will be sent to the Asbestos Coordinator.
**Remember – May need an RFQ **
Asbestos Abatement Contractor:
- Any contractor and their employees used for asbestos related work shall be licensed and trained in the proper and safe removal of asbestos and will show their license to the Asbestos Coordinator before starting the project.
- Asbestos contractor will inform the Asbestos Coordinator before beginning a project so that the proper parties can be notified of the project and at the conclusion of project to make a final inspection of the area.
- All labs used for asbestos work must be licensed for asbestos related testing.
No employee of the Physical Plant shall engage in any of the following activities involving PACM.
1. Sweeping up of any PACM
2. Removing of any PACM
3. Taking of samples of PACM
4. Grinding of any PACM
5. Power wire brushing of any PACM
6. Disturbing any PACM
When suspected asbestos-containing material (PACM) is found and must be disturbed to effect needed repairs:
- Employee will request that his manager/supervisor have the material tested. Employee will provide the following information to his supervisor:
Amount that needs to be addressed
Type of ACM it is (pipe, floor tile, plaster, sprayed)
Relative urgency of access
- Unit manager/supervisor will fill out Asbestos Removal/Insulation request sheet.
The Asbestos Coordinator will send out the request for quotes and the Requisition for PO#.
- Once the project date has arrived the Unit Manager/Supervisor will
Coordinate the shutting off of all affected utilities for the contractor to do his job safely. (proper Lock Out/Tag Out)
Notification of effected parties (Asbestos Coordinator will assist with this).
- After contractor has received final clearance to release the area, all systems will be returned to normal
The following procedures must be followed if asbestos is accidentally released:
Immediately isolate the area by closing doors and/or erecting temporary barriers to restrict air movement as well as access to the site.
Notify your supervisor and Asbestos Coordinator.
If asbestos fibers are suspected to have entered the Heating, Ventilation and Air Conditioning (HVAC) system (or may do so), the HVAC system must be shut down and sealed off.
… Through an asbestos contractor, employ thorough cleanup procedures to properly control the ACM, by using wet methods, HEPA vacuums, respiratory protection, etc.
Asbestos Coordinator will inspect the area before clearance is given.
The following procedures must be followed if PACM is accidentally contacted:
(i.e. brushing up against PACM with small amount of fiber sticking to clothes)
DO NOT brush off or blow off PACM.
Remove PACM with wet rag or wet paper towel.
Wrap wet rag or wet paper towel containing PACM in another layer of wet rag or wet paper towel.
Dispose of rags and/or paper towels in sealed plastic bag
Take measures to terminate contact with PACM.
Notify supervisor and Asbestos Coordinator and O&M
Initiate testing procedure for PACM material contacted.
Change clothes and shower
Clothing may be bagged and remain sealed until testing procedure determines if ACM is present.
Arizona Department of Environmental Quality http://www.azdeq.gov/environ/air/asbestos/index.html
Maricopa County Air Quality http://www.maricopa.gov/aq/divisions/compliance/air/asbestos_neshap/Default.aspx
Environmental Protection Agency - Region IX http://www.epa.gov/region9/toxic
The Asbestos Institute (Phoenix)