Weaving Your Way Through the Asbestos Regulation Maze

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1 Weaving Your Way Through the Asbestos Regulation Maze Presented at the Tennessee Environmental Conference 2014 Slideshow, Slide texts & Illustrations

2 The Maze of Asbestos Management Reporters Health Department Insurance Companies Lawyers Property owner Bankers Tenants, Employees, Parents, neighbors, etc. EPA Region State EPA-Air State EPA- Solid Waste OSHA DOT Construction Materials Vendor Asbestos Free!!

3 Inside the Maze EPA NESHAP (Air Pollution) Tennessee Department of Environment and Conservation: Air Pollution Control Shelby, Davidson, Knox and Hamilton Counties-check with your local air program EPA ASHARA with additions Tennessee Department of Environment and Conservation: Division of Solid and Hazardous Waste Management EPA AHERA: EPA Region 4 Tennessee program in waiting

4 Inside the Maze OSHA Construction Standard for Asbestos OSHA General Industry Standard for Asbestos OSHA Shipyard Standard for Asbestos (almost exactly similar to the Construction Standard) Tennessee Department of Labor and Workforce Development Tennessee Occupational Safety and Health

5 Inside the Maze DOT Waste Package Labeling Highway Patrol? Health Departments State Licensing and Work Practice Rules

6 Trip Hazards-NESHAP Overview-applies to facilities and < 160 sf, 260 lf, 35 cf friable projects Notification Basic work practices and packaging Waste Disposal Hazards Failure to Notify, especially maintenance, demos and emergencies Friability mis-interpretation Contractor failures may implicate owner Dry removal Visible emissions Waste diverted Criminal Provisions

7 Trip Hazards-ASHARA Overview: requires training (and state licensing) for asbestos related tasks, especially friable Worker, supervisor Inspector, project designer Management Planners for Schools Trip Hazards Unaccredited/licensed inspecting Unaccredited/licensed project designing

8 Trip Hazards-AHERA Overview: Requires School Asbestos Management Programs Trip Hazards It s so 1988 Private Schools OSHA Compliance Budget Shortcuts

9 Trip Hazards-OSHA Construction Standard 29 CFR Overview: Exposure Monitoring, Personal Protection, Work Practice Requirements, Records for smallest to largest friable and non. Hazards: Failure to identify suspect materials < or =1%, and non-friable Non-regulated minerals Owner inter-employer notification and recordkeeping Adjacent Employer monitoring responsibilities Protect from exposure to airborne asbestos Installation

10 Trip Hazards-OSHA Construction Standard 29 CFR Maintenance Program Hazards Medical monitoring Exposure monitoring Training Equipment maintenance and availability Records Employee Competence Management Commitment Emergencies

11 Trip Hazards-DOT Overview: Requires Waste Package Labeling Hazards: Failure to over 1 pound

12 Trip Hazards-Departments of Health Overview: There are no public health standards for asbestos. Some states (not Tennessee) have implemented standards with the goal of protecting public health. Hazards: No protection for Emergency Volunteers No requirements for homeowners doing their own work Limited requirements for asbestos related work in residential structures

13 Trip Hazards: Construction Material (and other material) Vendors Overview: Asbestos Material Bans are limited to spray-applied friable material, thermal insulation block and insulating cement, (all 1970s) certain asbestos paper products, and new uses (1989). Hazards: Many products still for sale - over 50 at our last count) Misleading and false labels Poor performance of non-asbestos substitutes

14 Trip Hazards: Tort Liabilities Exposure as a cause for action Supreme Court Ruling 1990s Property Damage (Manufacturers) Liability has migrated from Manufacturers and installers to end users > 0.1%

15 Trip Hazards: Health Estimated 10,000 deaths annually Mesothelioma Lung Cancer Asbestosis Gastro-intestinal cancers For cancers, guilt by association. The mechanism is not understood and there is no threshold for exposure f/cc increases lifetime risk 1:1,000,000

16 Trip Hazards: Regulatory Culture Call your own fouls! Who s on first? OSHA? NESHAP Health? Local, State, Federal And can they cooperate? Regulators who major on minors

17 How to Get on the 6 O'clock News Overreaction Disaster Wedge Issue

18 Asbestos Characteristics Naturally occurring Fibrous breaks down to smaller fibers Particulate filters required Aerodynamic small fibers can remain airborne hours or days Chemically stable Fire resistant Does not conduct electricity or heat High Tensile Strength

19 Friable Crush, reduce to powder with hand pressure Non-friable materials can become friable by deterioration Forces acting on them during construction activities ANY non-friable material can become friable Regulated Asbestos Containing Material (RACM) A NESHAP term Friable Non-friable which will become friable

20 Asbestos Characteristics Asbestos is a crystalline structure composed of benign elements The structure is dangerous, not the chemicals The chemical structure varies between the different kinds of asbestos Asbestos differs from fiberglass Retains fibrous structure as it breaks down Breaks down into smaller fibers, with more in the respirable size range

21 Regulated Types of Asbestos Serpentine Chrysotile-White-95% Chrysotile can be wet with water Amphiboles Amosite-Brown Crocidolite-Blue Tremolite Actinolite Anthophyllite

22 Suspect Material: A material that historically may have contained asbestos AND is listed by EPA as a material that must be addressed. Assumed Asbestos Containing Material: A suspect material that will (for the present) not be sampled and thus must be treated as ACM by building management until proven otherwise.

23 Friable ACM Regulated Asbestos Containing Material (RACM) A NESHAP term Friable Category 1 or Category 2 Non-friable which will become friable

24 OSHA PACM Presumed Asbestos Containing Material Thermal System Insulation and Surfacing installed 1980 or before Per Standard Interpretation, Surfacing is limited to friable surfacing Rebuttal of Presumption requires AHERA protocol inspection Only an accredited inspector or CIH may inspect for rebuttal

25 Typical Friable Materials Spray applied Fireproofing Acoustical plaster Popcorn ceiling material Thermal system block insulation Insulating cement Air cell 2x4 Ceiling tiles Flooring felt Asbestos paper Friable Materials are 2014 Thomas considered B Mayhew, PE more dangerous

26 Identifying Asbestos Polarized Light Microscopy (PLM) is the standard method Asbestos cannot be identified by: taste or smell visual examination EPA regulates Asbestos Containing Material (ACM) > 1% asbestos Missouri, Illinois > 1% by weight Texas > 1.0% California, Japan > 0.1% OSHA regulates ACM and asbestos (any percentage)

27 Analyzing for Asbestos Polarized Light Microscopy (PLM) is the standard method EPA recommends TEM follow-up for floor tile that is negative by PLM OSHA requires a recognized method for flooring NESHAP allows point counting if visual estimates of asbestos per cent are less than 10% to try to prove material not ACM (> 1%) 400 point 0.25% 1000 point 0.1% Per EPA < 1.5 % not ACM

28 Asbestos and Health Inhalation Hazard Not skin contact Most diseases affect lungs and breathing ability Long latency period between first exposure and disease More than 20 years Mesothelioma is the disease unique to asbestos exposure Gastro-intestinal cancer risk increases Asbestosis: scarring of the lung

29 Asbestos and Health Dose is related to total lifetime exposure Any reduction in exposure reduces lifetime risk According to OSHA, for expected exposures under current regulations, if dose is doubled, risk is doubled No acute reaction to asbestos exposure You will never need an ambulance on the day of exposure for asbestos!

30 Asbestos and Smoking Smoking cigarettes multiplies risk of LUNG CANCER for asbestos workers For historic exposures 50x to 90x OSHA does not allow smoking where there is an occupational exposure to asbestos

31 AHERA Response Actions: ERERO Encapsulation: Coating Repair: return to undamaged condition Use Non-ACM materials Enclosure: entombment No live building systems Removal The only final solution Operations and Maintenance Program Maintain friable ACM in good condition using management practices All options but O & M require accredited workers, supervisors and project designers All options require asbestos work practices

32 Encapsulation: 3 meanings 1. Response Action for friable materials Bridging AND/OR Penetrating Best application: TSI or non-friable surfacing Not recommended for friable surfacing Weight may cause delamination Still vulnerable to impact Increases future abatement costs As expensive as abatement 2. Lock-down on surfaces after removal Preceded by visual confirmation of removal completion Tinted State required in KS, NE 3. Removal Encapsulant: a chemical that is not water based used to wet amphiboles

33 An AHERA Worker, Supervisor, & Project Designer are Uniquely Qualified for Response Actions Friable ACM Maintenance > SSSD Friable ACM Removal Responding to a Major Fiber Release Episode > 3 sf or 3 lf Any additional projects requiring a license at the state level ASHARA applies to interior space, but OSHA impacts all places an employee works

34 AHERA & ASHARA Interior underside of walkways and porticos HVAC systems Under a roof NOT the exterior decorative transite not under a roof, but includes it under the portico & walkway INCLUDES the transite and gaskets on this rooftop cooling tower

35 Federal Air Monitoring Requirements AHERA: Clearance in regulated schools for Response Actions < 160 sf or 260 lf: PCM analysis allowed > 160 sf or 260 lf: TEM analysis required NESHAP: None (Visible Emissions) OSHA Personal Exposure, 8 hour TWA and 30 Minute Excursion Barrier Samples if Required Critical Barriers not in place

36 Air Sampling OSHA (c) Exposure Limits Permissible Exposure Limit (PEL) 0.1 f/cc 8 hour TWA Excursion Limits (EL) 1.0 f/cc - 30 minute sample

37 Worker Wearing Personal Air Sampling Device Air Sample Cassette

38 OSHA Personal Exposure Monitoring Required Daily for Class I & Class II Not required with an NEA Not required when using Supplied Air combined with standard work practices Required periodically for Class III and unclassified Sufficient to verify the validity of the exposure prediction Results part of the basis for respirator selection and work practices Results of more than one sample may be combined: (TxC+TxC+ +TxC)/8 for T in hours

39 OSHA/ WPR Negative Exposure Assessment Objective Data RFCI-flooring NRCA-roofing Historic Data: Similar, < 12 months old, perhaps higher standard of care Project Data: NEA vs. Records Representative of 8 hour PEL and 30 minute Excursion

40 Respirator Protection Consider all potential airborne hazards Particulate Asbestos Fiberglass Bird and bat droppings Mold Gases and Vapors Spray glue Lock down Mastic solvents Oxygen deficiency Most common cause of death in confined spaces Respirators approved by NIOSH All parts and replacement parts must be from the approved package

41 Air Delivery Modes Continuous Flow Constant Flow Rate Variable Pressure in facepiece Similar to a PAPR Pressure Demand Variable flow rate Constant Pressure Maintains positive pressure in facepiece Most practical for an SCBA in contrast to demand (SCUBA)

42 Respirator Protection Respirators always required when there is no NEA And on Class I projects TSI and surfacing always require at least a half mask Non-intact Class II requires at least a half mask Dry methods for Class II and Class III require at least a half mask Class II, III, unclassified with unknown exposure can start in half mask Class I with NEA can use a half mask Class I with no NEA requires at least a tight-fitting PAPR Class I over 1 f/cc requires FF SA PD with SCBA egress

43 Assigned Protection Factors A Protection Factor of 10 Half mask NPR: 10 Hood PAPR, SA: 25 Half mask PAPR, SA: 50 FF SCBA: 10,000

44 Fit Factor & Protection Factor Arithmetic is the same! Concentration Outside Concentration Inside A Fit Factor of 100 Fit Factor must equal 10x Protection Factor in a QNFT Protection Factor is Assigned to each type of respirator by OSHA

45 Respirator Filters for Asbestos Purple or Magenta HEPA P100, R100, N100 Effective on Particulates (mold, fiberglass, bird and bat droppings, nuisance dust, etc.) No Dust Masks!! (Filtering Facepieces)

46 Respirator Filters for Asbestos Will work on all particulates Will not work on gases Will not work on vapors Will not supply Oxygen! Not approved for IDLH Particulate filters may be combined with other filter elements

47

48 Fit Testing Respirators Fit test tight fitting facepieces annually OR With facial or dental changes obvious weight change New type of respirator Test may be QLFT or QNFT QNFT allows a APF of 50 for FF NPR QLFT for FF NPR? APF=10

49 Using Respirators Inspect before each use Perform a POSITIVE AND NEGATIVE USER SEAL CHECK each time a tight fitting facepiece is donned Glasses? Either contacts or a fitting kit for a full face OK No temple bars through seal User can repair/maintain negative pressure respirators Supplied Air Systems repaired only by factory qualified technicians

50 Using Respirators Clean as often as needed Wear into the shower and clean If there is breathing resistance, change filters Store respirators to protect from Heat and Cold Sunlight Contaminants Physical Damage

51 Respirator Fit Testing Required Annually Required for all Tight-fitting respirators face pieces Negative Pressure PAPR Supplied Air SCBA QLFT or QNFT QLFT options Irritant smoke Banana oil Saccharin or Bitrex QNFT only an advantage for Full Face NPR

52 Responsibilities of Employee wearing a respirator No Eating, Drinking, Smoking, or Chewing or applying cosmetics while wearing the Respirator Shave daily to insure no facial hair interfering with facepiece to skin seal - NO EXCEPTIONS!! Inspect a respirator each time before donning Don a tight fitting facepiece with a user seal check EVERY TIME

53 Respirator Responsibilities of Employer Provide Equipment Insure Use Provide a tight-fitting PAPR in lieu of a negative pressure respirator if it provides sufficient protection Have an up to date Respiratory Protection Program Have a Respirator Program administrator with adequate training to run the program

54 OSHA Medical Screening for Asbestos Annual Signed by a Doctor (not PLHCP) Screening to assure safe use of respirator allowed if asbestos work is 1 to 29 days annually Full Asbestos Physical required within 10 days of 30 th day of asbestos work (Class 1, 2, or 3, or unclassified > PEL) PFT General Physical Asbestos Questionnaire

55 Protective Clothing for Asbestos Required components Whole body covering Head covering Foot covering (non-slip) Gloves No street clothes Provided by the employer Disposable or non-disposable Employer must launder non-disposable clothing Primarily an aid to decontamination

56

57 Decontamination 3 chamber required for personnel on Class I > 10 sf, 25 lf HEPA vacuum on a drop cloth or in a change room for other projects above the PEL Waste packages may be decontaminated and passed out through a waste load-out All tools must be decontaminated Dirty side of Exhaust units and Vacuums sealed Poly & disposable clothing, filters, etc. considered to be asbestos waste

58 3 Chamber Decontamination Required for Class I > 10 sf, 25 lf 3 rooms in series: Clean Room, Shower, Equipment Room (Dirty Room) Field constructed or Prefab decon trailer OK 3 rooms separated by control curtains 3 flap in NE, IL 3 foot Airlocks for IL schools, MN, KY Ventilation curtain OK in KS Shower must have soap, towels, hot and cold mix at tap or warm water Filtering shower water for asbestos recommended

59 3 Chamber Decontamination entry and Exit to containment requires decon procedures Make-up air flows through decon All personnel entry through decon Enter clean room, then shower, then equipment room Don protective clothing and respirators in clean room No street clothes past shower

60 3 Chamber Decontamination All personnel exit through decon Remove gross debris in work area Remove protective clothing in equipment room Fold outside in to contain fibers Place in sealed labeled container Wear respirator into shower Remove after washing around it Wash hair and body with soap Dry and don street clothes in clean room

61 Building Systems during Abatement LEAVE in place as long as possible Fire suppression HVAC Electrical

62 OSHA Warning Signs Required for all Regulated Areas Understandable language Post at containment entrances If no containment, post at approaches to work area to warn bystanders in time to avoid exposure Respirators Required language may not be necessary

63 OSHA Regulated Areas Access limited to authorized persons States may require a daily log of entry & exit Using restroom not prohibited People outside regulated area protected from exposure to airborne asbestos

64

65 Work Area Preparation Preclean using HEPA vacuum and wet wiping Precleaning required before AHERA Response Actions Confirmed by visual inspection Critical barriers when required 2 layers 6 mil for HVAC Electrical outlets, windows & doors, and other openings Remove movable objects Cover objects that cannot be moved with poly

66 Containments Floors typically 2 layers 6 mil poly 10 mil roofing Plywood, cardboard Chalk lines to detect leaks Walls 4 mil or 6 mil poly, 1 or 2 layers Usually 12 inch overlap at seams Floor poly runs up the wall 12 inches Attach with duct tape and spray glue staples, nailed furring strips Self adhesive poly Spray poly

67 Ventilation Ventilation must be considered whenever the PEL is exceeded General area ventilation Local exhaust ventilation (LEV) If air outside may be contaminated, filter make-up air AHERA allows comparison of inside and outside for clearance 4 Air changes per hour 15 times CFM capacity of units Consider actual capacity HEPA vacuums may be used for mini-enclosure and small enclosure 2014 ventilation Thomas B Mayhew, PE

68 Ventilation Ventilation required for Class I over the PEL LEV required on Class III if feasible Make-up air passes through decon Air directed away from the breathing zone of workers Area Ventilation runs 24/7 until project is complete Even runs if crew not present Air movement throughout enclosure required Tested daily with a smoke tube HEPA exhaust inlet placed as far as possible from the decon

69 Negative Air A special system of ventilation requiring a tight enclosure Used for large enclosures & min-enclosures Negative Pressure Enclosure Option Required for mechanical chipping of floor tile Minimum 4 air changes per hour Pressure differential inches water Manometer measures negative pressure Hand held for periodic (minimum daily) measures Continuous recording manometer required by states or specifications

70 Asbestos Waste Wet, Sealed, labeled OSHA Danger label on container NESHAP generator label for NESHAP DOT label for transport container NESHAP allows wet bulk handling and disposal without packaging when removal is unsafe Sanitary landfill Waste disposal records retained 2 years

71 Final Clean HEPA vacuum and wet methods Check behind criticals NE requires Aggressive Cleaning Leaf Blower and fans plus ventilation KS protocol Cleanliness confirmed by visual inspection

72 Final Clearance Monitoring Required for schools by AHERA for Response Actions Public & private, primary & Secondary non-profit schools PCM < 160 sf, 260 lf friable 5 samples < 0.01 f/cc TEM > 160 sf, 260 lf friable 5 samples average < 70 structures Aggressive methods 3 rd party only type of sample collected using aggressive methods Some states may require 2014 Thomas clearance: B Mayhew, PE NE, AR, TX, KS, IL

73 Final Clearance Monitoring Preceded by visual inspection Preceded by lockdown of abated surfaces 3 rd party (AHERA, MO, TX) Collected using high volume pumps (usually electric) TEM flowrate < 10 lpm (AHERA) PCM flowrate maximum 16 lpm (NIOSH 7400) Cassette isolated from pump vibration 45 degree angle down Critical barriers removed after clearance verification

74 Glovebags One standard bag for maintenance is OSHA Class III and EPA SSSD Multiple bags or removal is OSHA Class I and AHERA Response Action

75 Required Protocols Glovebags Regulated Area; NPE optional Exposure Assessment and Monitoring Respiratory Protection Smoke testing seal of each bag Single use Standard bag good only to 150 degrees F. 2 person crew Vacate bag with HEPA Vacuum Negative pressure 2014 Thomas glovebag B Mayhew, is PE optional

76 Mini-enclosures Two workers maximum per OSHA 6 mil plastic HEPA filtered negative pressure Smoke-tested single prefabricated mini-enclosure is under ASHARA in a

77 Major Fiber Release Episode Accidental release of > 3 sf or 3 lf friable ACM Accreditation required for Workers Supervisors Project Designers Clearance sampling required for schools under AHERA AHERA requires written record States may require notification depending on size of the event

78 Examples of Accidental Exposures Prepping next to friable surfacing Working above a drop ceiling with a potential for contamination ACM tile Fireproofing or TSI above Mis-use of high pressure sprayers during abatement Floor tile care without a sufficient finish Maintenance activities disturbing material due to lack of knowledge of ACBM location

79 Class III, SSSD, & Minor Fiber Release Episode OSHA Class III: no larger than material that can be contained in one glovebag or wastebag 60 inches by 60 inches EPA Small Scale/Short Duration A maintenance or emergency purpose is required Several examples of small amounts but no more than one glovebag or prefabricated mini-enclosure Accreditation not required Minor Fiber Release Episode Less than 3 square or linear feet of friable material accidentally released in interior space

80 OSHA Class III Overview 16 hours training for worker 16 hours training for competent person Regulated area required Exposure Assessment required Personal Air Monitoring frequency: sufficient to determine validity of exposure prediction (every 12 months minimum for NEA) Inter-employer communications required

81 OSHA Class III Overview Work Practices Respirators usually required Protective Clothing HEPA Vacuum/dropcloth or change room decon protocol required Wet Methods required Local Exhaust Ventilation required if feasible Containment or isolation required for surfacing or TSI Containment, glovebag, or mini-enclosure required

82 Work Practice Prohibitions of OSHA High Speed Abrasive disc saws WITHOUT HEPA filtered Local Exhaust Ventilation

83 Work Practice Prohibitions of OSHA Compressed Air for Removal Dry Sweeping or Dusting Employee Rotation Vacuums HEPA filters

84 Asbestos Rules EPA TSCA AHERA ASHARA EPA Clean Air Act NESHAP OSHA State or federal enforced States and localities

85 EPA TSCA applicability AHERA Public & private, primary & secondary non-profit schools Interior space US, territories, foreign military bases ASHARA Public & Commercial buildings Not residential structures less than 10 units Interior space

86 RACM EPA NESHAP applicability ACM friable or becoming friable Facility (not residential < 5 units) Tank Bridge Building Installation more than 1 building Work Practices apply if > 160 sf, 260 lf, 35 cf

87 EPA NESHAP notifications Demolitions (removing a load supporting member) All must be notified Renovations Renovations disturbing more than threshold amounts (160/260/35) of RACM must be notified Standard 10 working day Amendments per state rules Annual for renovations expected to add up to more than threshold amounts in a year in a single facility 10 working days before January 1

88 NESHAP Nonfriable removal is not regulated by NESHAP Lower Carefully Leak Tight Labeled Packaging Special Protocols for dry removal glovebags enclosures with filtration GOAL: No Visible Emissions

89 EPA NESHAP Asbestos Bans Spray applied fireproofing passed in 1972 and enacted in 1973 Thermal System Insulation NESHAP 1975 Spray Applied Decorative - Friable ACM: NESHAP 1978

90 Safety and the Competent Person Competent person responsible for asbestos PPE Work practices and engineering controls Personal Air Sampling Competent person responsible for general construction safety Pre-project safety survey & planning FIRE ELECTRICAL EMERGENCY ESCAPE Safety during the project

91 Heat Stress Aggravated by shut down of HVAC and protective clothing that doesn t breathe DO Acclimatize Take breaks as necessary Hydrate (drink fluids) Use engineering controls Use personal cooling devices DON T Take salt tablets Hydrate with caffeine and alcohol Heat Stroke is a medical emergency!

92 Electrical Safety Shut down and lock out electrical system Check individual circuits anyway! Use GFCIs Use grounded equipment Elevate electric cords with nonconductive hangers such as duct tape Use fiberglass ladders and nonmetallic tools Don t touch someone to pull them away from when they are in contact with power

93 Fire Safety Poly and disposable suits melt at 150 degrees F. Have enough ABC fire extinguishers on site Know how to use them Fire Triangle: Fuel-Ignition-Oxygen Negative air machine provides Oxygen Poly, spray glue, provides fuel Manage ignition sources Cutting torches Heat sources Open flames such as boilers and water heaters Smoke inhalation can be as dangerous as burns

94 Extension Ladders o Length cannot exceed 60 o Tied off and extend at least 3 above working surface o o o o 4:1 angle (4 working length:1 horizontal, ladder base to vertical) Overlap at least 3 in middle Face ladder, one person at a time Use as a ladder, not a horizontal platform

95 Scaffold Safety Proper design and inspection by a competent person Use as designed Railings required over 10 feet high Boards can t overlap end of scaffold more than 1 foot Mobile scaffold Don t ride while moving Wheels and wheel locks in good repair No more than 4 times higher than minimum base dimension

96 Working Surfaces Standard worksite preparation and control methods include polyethylene on the floor and the use of amended water This is essentially soapy water on a plastic floor not a good combination! Wear appropriately sized nonslip footware In addition, abatement work often has all manner of objects that can present a trip hazard Airlines & Electrical cords Bags of waste material Debris & tools

97 Other Safety Hazards Biohazards Confined space Power tools

98 Specifications Define delineates specific protocols delineates goals and leave means and methods to the contractor Specifications take precedence over drawings unless otherwise indicated Proprietary Specifications require a specific product

99 Contracts Written contracts signed by both parties Changes must be agreed to by both sides in writing (Change Order) Changes during the bidding process are Addenda

100 Asbestos Recordkeeping OSHA Personal Air Sampling & Medical Employees and former employees have right to records Must be informed of rights annually Free 1 st copy, reasonable charge for 2 nd Employees must be allowed to see exposures at new place of assignment Inspections Inter-employer notifications Fit test Training NESHAP Waste manifest AHERA Inspections All work activities Training States may add project record requirements

101 Asbestos Insurance 1. General Liability: protects in the event of a suit from a third party (i.e., a party who is not a signatory to the contract). Generally has a pollution exclusion, so it will not protect insured for asbestos related lawsuits. General liability may be written in an occurrence or claims made form 2. Workman s compensation: benefits if a worker is injured Minimum levels 2014 required Thomas B Mayhew, by PE law.

102 Insurance May be obtained from: Commercial companies Risk Retention Groups Self-Insurance Generally no fixed limits on the amount of insurance which may be purchased Claims Made forms more common

103 Asbestos Insurance Occurrence and Claims Made Insurance forms For both types the occurrence of the event resulting in a loss must be during the policy period. Additionally, for claims made, the claim must also be made during the policy period. For occurrence forms, the claim may be made at any time.

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