"Second wind/! brings contaminant back into public eye By Jeffery C. Camplin

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1 II SIGMA 1300 West Canal Street, Milwaukee, Wi (414) "Second wind/! brings contaminant back into public eye By Jeffery C. Camplin PROFESSIONAlS MAY BE OPERATING fale sens of secuty on asbestos issues. every SH&E professional feared, a topic Jeffery C. campi in. esp. CPEA, is president of Camplin Environmental Services Inc., a safety and environmental consulting firm located in Rosemont IL He provides asbestos consulting services, including teaching EPA-accredited asbestos courses at several training centers in the Chicago area. Camplin has a degree in safety from Northern iiinios University and has been an i/inois licensed asbestos professional since He is a professional member of ASSE's Northeastern iiinois Chapter; and is currently serving a second term as the asbestos has bee pushed to the back burer in reent years by emergig issues such as mold, terrorim and emergency preparedness. What many SH&E professionals do not realie is that asbestos has been qtnetly remergig as a front-burer issue. Asbestos can sti be a concern even if building inpections state tht none is present. These inpections are tyicaly plagued by a series of flwsrangig from improper inpection scope, lack of inpector and lab qualcations, new reguatory requiements and plai old errors. Ten of these flaws are dised in th artcle. Asbestos can alo reappear if all asbestos has reportedly been removed from a buiding. Even new buidings can have asbestos since asbestos products are sti being produced, imported and sold thoughout the u.s. The U.S. Geological Surey estiated that more than 13,000 metric tons of asbestos were imported into the U.S. in 2001 (Buckigham and Yates). Common products such as flooring materials, roofig materials, frction materials (such as vehicle brake pads) and cement product sti contain asbestos. At th tie, all buildings are subject to contamnation: Asbestos is natually occurrig and has contamted communties and products durig. its mig. Damaged and distubed asbestos in buildings has also caused contamation. Improper buiding demolitions and unoreseen building collapses (such as the World Trade Center) have also released large amounts of asbestos into the environment. Yet, testig for contamiation remains controversial. Asistant Administrator of ASSE's Environmental Practice Specialty 32 PROFESSIONAL SAFET AUGUST 2003 ww.asse.org SH&E professionals must be aware of these controversies so sound decisions can be made regarding potential asbestos contamination in buidings and products. Asbestos Issues: What Every SH&E Professional Should Know Asbestos became a reguatory issue in the early 1970s when exposure to it was lined to adverse worker health effects. Massive num- bers of individual and class-acton lawsuits followed in the 1980s, cratig a legal cris. In response, Senator Or Hatch (R-UT) proposed the Faiess in Asbestos Injur Resolution in the U.S. Senate in May Intended to streamline asbestos lawsuits and relieve the court systems, the bil would create a $108 billon trst n.ind to effciently compensate those with asbestos diseaes while capping the liabilty of businesses and cubing the number of banptcies. Ahuge industr was created in the mid 1980s to inpect, test, analyze and abate asbestos found in buidings. By the early 1990s, the lawsuits and the asbestos industry began a steady declie as new issues garered attention. Recent developments indicate a reemergence of asbestos-related legal actions, including many clais without any demonstrable disease (Geeral Cologne Re 2). The largest single factor in the rise of tort costs in 2001 was a $6 bilon increase in liabilities tied to asbestos claim over 2000 levels (Tilghast & Towers Perrin 1). The Fairess in Asbestos Injur Resolution was designed to address th rise in clai. Furthermore, reguatory updates and revisions can suddenly change materials previously tested as non-asbestos-eontaing into regulated asbestos upon retesting. Finally, asbestos contamation caused by releases and in buildig and consumer products is a growing fear. Failur to address these evolving issues could :t asbestos right back in the spotlight. Issue #1: Asbestos in New Construction Materials Asbestos Use in Many Product Banned in U.S. Asbestos is predomiantly an aiborne hazard that has been lied to lung cancer, mesothelioma and asbestosis. EPA responded to health hazard concern by bang the production of the most hazardous forms of asbestos in the early 1970s though the early 1990s under authority of the Clean Air Act. The hazardous or friable (crbles or reduces to powder by hand pressure when dry) materials that were baned are thermal systems inulation including wet-applied and pre-formed asbestos pipe coverig (1975); pre-formed asbestos block inulation on boilers and hot water tan (1975); spray-applied fireproofig/inulation (1973); and spray-applied materials for decorative pwposes (1978). In late 1990, spray-applied materials containing more than one percent asbestos were prolubited from use

2 II SIGMA 1300 West Canal Street, Milwaukee, Wi (414) iless they were encapsulated with a bituinous or reinous binder. In 1989, under the authority of the Toxic Substace Control Act (TCA), EPA bared most reg asbetos material. Materials sti subjec to tht ban include corrgated paper, roll board, comiercial paper, specalty paper, floorig felt and new uses of asbetos (EPA "EPA Asbestos Material Ban" 1-4). These product were no longer being produced in the U.S. at the tie of the ban. So, if all of these uses were bared over the last 30 years, where is the asbestos comig frm? Current U.s. Production & Importation of Asbestos Product In 1991, the U.S. Court of Appeal for the Fif Circut vacated the 1989 EPA ban (EPA "EPA Asbestos Material Ban" 3). Thus, materials contaiing asbestos tht were being produced in the U.S. at the tie of the ban are sti legal to produce, import and use; thes include corrgated and flat cement sheetig, clothg, pipelie wrap, roofig felt, viyl floor tie, cement shigle, rnboard, cement pipe, automatic tranmision components, clutch facigs, frction materials, di brake pads, dn brake liings, brake blocks, gaskets, nonroofig coatigs and roof coatigs. (Te sidebar on pg. 38 lits suspected asbestos-eontag material.) Senator Patt Muray (D-WA) recently propose The Ban Asbestos in America Act of 2003, which closely resembles EPA's 1989 ban. EPA sponsored a "blue-ribon panel" focs group organized through the Global Envionmenta Tecology Foundation (GET to develop asbestos policies. EPA released the GETF report in May 2003; it recommended several aspects of the Murray bil, and caled on Congress to pass legilation. Seeking Additional Information EPA doe not track the maufactue, processing or distrbution in commerce of asbestos-containing products. The most promient uses of asbestos in 2001 included roofig, floorig, gaskets and friction products (Buckgham and Yates 4). Since EPA has no exitig ban on many product, the agency recommends tht a prudent consumer inqui about the presence of asbestos in a particular product. According to the agency, possible inormation sources include inquies to dealers/suppliers/manufacters, MSDS or tests by a qualied laboratory (EPA "EPAAsbestos Material Ban" 4). In the author's experience, the fist two reommendations tyicaly lead to uneliable inormtion, whie testig supect material prior to intalation often wi produce documentation that the material does not contain asbetos. Therefore, inpection, testig and analytical methods must be caefuy selected to determe whether a materil try does not contain asbestos. Issue #2: Evaluation of Inspections & Non-Asbestos-Containing Materials The term "asbestos-contaig material" is a regulatory term usualy defied as a material that con- tai more th one percent asbestos. The scope of an asbestos building inection should address those regulations tht afec the facity or the project in question. A quick review of federal reguations is necessar to determe how comprehenive the asbetos inpecton should be. In 1986, President Reagan signed the Asbestos Hazard Emergency Response Act (AHRA) into law. Th reguation requies the use of accredited inpecors to conduct inpections and madates that accrdited response action contractors conduct frable asbestos abatement actvities in public and private schools (grades K-12). EPA also enforces the National Emissions Stadards for Hazardous Ai Pollutats (NSHA), which is commonly called the demolition and renovation reguation. Th regulation reuires buiding owners to inpect at least those portions of a strctue tht are to be renovated or demolihed for reguated asbestos and to have it removed prior to begig the demolition or renovation process. Regulated material are all friable materials and any non-frable materials that could release viible emisions due to these activities. In addition, OSHA regulates worker exposure to airborne asbestos. Its constrcton and general industry asbestos standards requie employers to determie whether their employees are comig into contact and are ditubing asbestos durg work activities. If so, the employer must determie the employees' exposure. Identication of the presence, quantity and location of asbestos is a mai responsibilty of buildig owners and employers tmder OSHA. Don't Rely on Previous Asbestos Inspections & Testing Many building owners have conducted asbestos studies of their buidings in order to manage any materials that are in place and to determe what removal is required before demolition and renovation actvities. However, the buyerbeware priciple applies. Asbestos inpections can be inerently flawed due to lited scope, inpecor error, improper saplig, lab error, hidden materials and new/revised reguations. ww.asse.org AUGUST 2003 PROFESSIONAL SAFET 33

3 II SIGMA 1300 West Canal Street, Milwaukee, Wi (414) State-of-the-Art School Building Asbestos Inspection Procedures Limited K-12 public and private schools ar the only group of buildings that must comply with AHRA. 'l1'is regulation ffâldates what to I.11spect for, where to inpect, how to sample and anlyze, and how to docent suspected.asbestos-eontaig materials. Accredited personnel must perform inpections, develop management plan and perform abatement actvities. Most states use th accrdited traing as a prerequisite for issuing asbestos licenss. In 1992, the accreditation requiments were extended to public and commercial buidigs, includig residential strctes featug 10 or more unts (TCA, Setion 206 Revisions ASHA). Th first flw in a tyical inspection is the lack of properly accredited (and in most states licend) asbestos building inspectors. The AHRA scool reguations addrs frable asbestos and non-frable materials that if ditubed could release aiborne asbestos which could subsequently be inaled by buiding occpants. EPA estimates that more than 3,000 commercial products conta asbestos (EPA" Asbestos Buidig Inpeon" 2). Fnable form fall into two categories: 1) thermal systems inulation used to inbit heat tranfer or for condensation contrl on heatig, ventilatig and air conditionig systems (H AC); and 2) surfacig matenal sprayed or troweled on for acoustical, decorative and fieproofig puroses. As noted, these materials are hazardous and have bee baned. However, other materials that do not fall into these categories-sch as ceilg ties, flooring materials, cement boards (tranite) and dral systems-may also contain asbestos. These frable and non-frable matenals fal into a thd category: "micellaneous materials." AHRA reguations require identication of these thee categories of suspected asbestos materials found on the inide of a scool buidig; however, th protocol does not require identication of most materials found on the outside 34 PROFESSIONAL SAFET AUGUST 2003 ww.ase.org of a building. It also requirs that a numum numer of samples be taken for al suspect material and analyzed by an accredited laboratory using a polaried light microscope (PLM. Th requent applies to non-scool buidings as well 1lder OSHA standards (which are descbed later). Th second and third flws of most asbestos inspections is that the scape is limited to interior spacs and the failure to use accredited laboratories for sample anaysis. Non-School Buildings Also Regulated NESHAP is trggered when demolition or renovation actvities occu in commercial and public buidigs, including residential buidings with more than four unts. The reguation does not specif who must conduct the inpection, what material reqture testig or how many samples m).lst be taken. It does, however, require identification of all asbestos-containg building materials inide and outside a buiding. NESHAP also has a special analytical protocol that applies to frable material. It requies that saples intially found to have asbestos detected in quantities up to 10 percent be subjected to a more exact quantication method. EPA believes th meaurement is necessary to conf whether the material is more than one percent asbestos and, therefore, reguated. Previously tested materials found to be a nonasbestos-containg matenal must be subjected to th additional analytical method before demolition and renovation actvities commence as well. Caled point-eountig (see sidebar pg. 35), th procedure requis requantication of the percent of asbestos found in material intialy quantied at one percent or less (non-asbestos-eontaing). To a buiding owner, ths mean that a prior asbestos inpection could identify a matenal as non-regulated because it was analyzed and found to be one percent asbestos or less and, therefore, is docuented in the inpection report as a non-asbestos-eontaig material; however, when the material is distubed durg renovation or demolition, it must treated as a reguated asbestos-containg material unti point-eountig conf that it contai one percent or less asbestos. The fourth flw in an asbestos inspection is failure to perform point-counting on "trace" amounts of asbestos detected in friable materials. Another analytical requiement under NESHA deals with multiayered material such as plasters and stuccos (EPA" Asbestos Bulk Saplig Buleti" 3). If plaster and stucco wal or ceilg systems are layered, and the layers can be ditiguished, then each layer must be analyzed separately. Again, th affects buiding owners who have had these elements analyzed as a composite and identied as non-asbestos-eontaing material. Once these layers are analyzed separately, one or more layer may exceed the one percent asbestos cntena, makig the material reguated durg demolition and renovation activities. The fifth flaw in an asbestos inspection is

4 the failure to considr and reanalyz prevously tested platers and stucco materls that ma contain multiple layers. Building Owner., Employer. Must Communicate the Presence of Asbestos OSHAs general industr asbestos stadards (29 CPR ) and constrcton industr standard (29 CFR ) requi buiding owners and employers to identi the presence of asbestos and communcate th informtion to employees, tents and outside contractors who occupy their buidings or jobsites. OSHA would accept an AHERA inpecon as long as it also addreses potentil asbestos exosures on the outside of a buiding. However, OSHA does not requie inpections. If a buidig owner does not have an asbestos inpecon performed, then certin material must be presumed to contai asbestos. It's Asbestos Until Proven Otherwise OSHAs priar concern is employees ditubing and breathg asbestos. Fnable asbetos material alow asbestos fibers to become easily aiborne. As noted, the largest groups of these material are thermal system insulations and surfacing materi, which are baned. To protect employees from airborne exposure to these matenal, OSHA requies buiding owners to prese that all thermal system and surfacing materials intalled no later than 1980 contain asbetos and treat them as such unti testig is performed. OSHA has alo identied resilent floorig materi including floor ties, related adhesives and mastics, and sheet goods as suspect and requies them to be treated as asbestos-eontaing material unti testig proves otherw. OSHA has adopted the AHERA school reguation testig protocol (use of accrdited inpectors, mimum numbers of samples taken for each material, use of recognd analytical protocol and accredited laboratories) to rebut the presumption that a material contài asbetos. Without proper testig, the owner must contiue to treat these materials as if they contain asbestos and must comply with al relevant OSHA requiments. Th sixth flw in asbestos building inspection is failure to presume that materials in non-school buildings are asbestos or to apply the AHERA sampling protocol to suspect materls to rebut this presumption. OSHA specically addresses two of the thee categories of asbetos materials. For the "micellaneous matenal" such as tranite, cement boards, roofig matenals, ceilg ties, dral and myriad other suseced asbestos-eontaing commercial products identied by EPA, OSHA ha a thee-pronged attack to protect workers from asbestos exposure. 1) As noted, building owners must presume certai materials contain asbestos. 2) Building owners must address those materials known to contain asbestos. If testig or manufacturer labelig indicates the presence of asbestos, then the buiding owner must treat it as such. 3) The thd requiement is a catchal. Buildig owners must identi those material that should have bee found though the exercie of due digence. Although OSHA does not defie due dilgence, a buidig owner can be found in violation if a worker is unowingly exposed to asbestos. If a worker is exposed to asbestos, then OSHA can challenge the due dilgence component of the inpecton. Th seventh flaw of an asbestos building inspection is the failure to perorm a thorough due diligence inspection. (( Scrutinize Resílent Flooring Materials The fial OSHA-specifc issue relates to analytical methods. The agency allows the us of the AHRA scool inection testig and analytical protocol to prove tht a presumed material doe not contain asbestos-with the exception of resilent floorig materials. For these materials, OSHA requires buiding owners to consult an industral hygient in order to deteitne an appropriate analytical method. Ths is based on a 1994 EPA buleti which stated tht the AHRA analytical method was not adequate for identiing material that contai small, th asbestos fibers (EPA" Asbestos Bul Samplig Bulleti" 2). EPA found that fibers such as those found in floor ties were too smal and th to be identied at the resolution of a PLM, so it recommended that floor tiles folind to be non-asbestoscontaing be retested using a tranmision electron microscope (TM). TEM analysis has found that l! - AUGUST 2003 PROFESSIONAL SAFET 35 o on"" c0 "" CD,- :! Ċ0 C0 N C0 t. 5: CD :J cr 1i êi ãi c cr ü t5 CD S oc0

5 (q l!- 36 oo(\.q c0.q il,- :: Ċ0 C0 (\ C0 l! 5: as J2 :: 1 1i ù5 ëõ c c o t5 o oc0 many presumed non-asbestos floorig product actaly contain more than 20 percent asbestos. However, since th method is not requid, many buidig owner choo not to have it perormed. The OSHA statement iner the us of the TE method on floorig. Th eighth flw in an asbestos builing insection is not coniderng whehe floo tiles contain sma, thin fibers and, theefore, not reanayzing the materls with a rem. Issue #3: Errors By Inspectors & Labs The AHRA'scool inecon foriat is considered to be the state-f-the-ar method for determing the preence of asbestos. However, in addition to the litations alrady described, errors made by inpectors and laboratories ar a concern. Al K-12 schools had to conduct AHRA inpections in the late 1980s. EPA later eväluated these inpections for thoroughess, accuacy andcompliance, and found signcant problem, includig mised suspected asbestos-eontaing materials, underestiated material quantities and inaccurate docentation of location of materials identied. EPA alo reviewed the qualty control testig results performed on accredited laboratories and agai found errors. Labs were found to have miidentied asbestos-eontaing materials ard inaccurately quantiied the asbestos percentages in material (Harey, et äl2). What Materials Are Suspec & Where Are They Found? According to EPA, thousands of products contai asbestos, yet most asbestos inpecors are only aware of a smal fracton of these materi (EPA" Asbestos Buidig Inpecon"). In 1991, EPA evaluated the thoroughess of AHRA scool asbestos inpecons and found tht 38 percent were deficient or seriously deficient (EPA "Asbestos in Scools" 2). Priar deficiencies included faiur to identi al suspected asbestos materials; faiure to clearly reord their location; and faiure to quanti them with acceptable stadards of accuracy As noted, OSHA requies buiding owners to communcate the presece, location and quantity of asbestos; inccuate inpectons wil not provide a strng due digence defen. According to EPA, 82 percent of the AHRA scool asbestos inpections had at least one undentied material. The material. mised most frquently were fire doors, sheet floorig, drywal and vibration-dampeng cloth in air ducts. Oter tyica inector errors include misidentiing additional materials, such as the presence of floor ties under caretig or other layers of tie; origiäl ceilgs above dropped ceilgs; roof and santa drai; tranite panels; and material in concealed areas such as attc spaces and pipe tuels. Remember, als, that these inpections exclude most materials on abuilding's exterior-such as siding, fascia board, wal panels, eaves and roofig. Despite these fidigs, the inpections are sti considered by many building owners, consultants and regulatory agencies to be state-of-the-art. Th ninth flw in an PROFESSIONAL SAFET AUGUST 2003 ww.asse.org asbestos building inspection is failure of inspectors to identif, locate and quantif all suspected asbestos required by the scope of work. Asbestos Lab Work Is Not an Exact Science The most common analytcäl method used by accrted laboratories to identi the presence of asbetos in materi is PLM using the dipersion stag tecque. Th method has litations in tht it caot identi sma, tl1i fibers (0(0.3 microns in diaeter) such as those in floorig product. Another limitation is its inbilty to identify asbestos in material tht have heavy binders (such as those found in cement products and roofig material without specal treatment). Once asbestos is identied, its quantication is lited in tht the method can accuately estiate the percent of asbestos to a lower lit of only thee percent. The viual estiates of asbestos quantities at or below one percent have been found to be signicantly overestiated by laboratories (Perki, et al5). In fact, overestiation can be as high as 1,000 percent by the PLM method, which can result in non-asbestos contag material being identied as over one percent and, therefore, subject to reguation. Th tenth flw of an asbestos building inspection is failure of accredited laborators to accurately identif and quantif the o.sbestos in materials. Issue #4: Asbestos-Contaminated Products & Building Materials What Isn't Contaminated With Asbestos? The fact that asbestos is present in the environment as a natualy occug mieral, in consumer products and building materials creates many potential contamation issues. For example, many automobile brake pads sti conta asbestos and can release contaation each tie a driver applies the brakes. The state of Caliorna has issued guidelies and regulations to reduce aiborne levels of natually occug asbestos used to surface unpaved roads, parkig lots, playgrounds and other open areas. Asbestos contamation has alo occurred in communties and in material durg the mig of other mierals such as venncute. Contamation also exits in areas where friable asbestos or damaged asbestos materials have released fibers over tie, resultig in asbestos in settled dust. Ceilig ties and fiters on ventiation systems have become contaminated by distubance and air movement near spray-on fieproofig applied to strctal steel in buildings. Improper demolition and the unplared collapse of building strctes can also contamate large areas. The identiication, quantification and response to these potential asbestos contamitions are conh'oversial. What Is Contamination? Asbestos contamation can exit for many reasons. The most common contamation issue occurs durig abatement activities. Asbestos must be distubed durg removal, resultig in containation of the work area. Specal negative-pressure contain-

6 ments are often designed to prevent the spread of contamtion. Speal cleang and work practces reove visible and microscopic contamtion. Once work is complete, a cleaance air test can be penormed to docent a clean ar prior to releasing the asbetos contrctor from the jobsite. Under federa regutions, scools must have cleace ai testig penormed, but no federa requiements mandate such tests in non-scool buidigs. Clearance ai testig doe not requre an asbetos-fr work area. Milons of astos fis can remai in the air and on surfaces of work aras while sti achevig clearance. If contation can exit after an asbestos abatement projec, how should buidig owners and employers addrs other form of contation? Surface Dust Testing Is Controversial No federal reguation requies surface dust to be tested for asbetos. More importatly, no federal clearance or safe levels have been determed for asbetos in surface dust. Yet, many buildig owners routiely test surfaces to determine whether asbetos contamtion exits-without chengig how samples are taken or what the results mean. ASlM ha developed several method for general testig for asbestos on buidig suaces such as ceig ties, shelvig, electrcal components and ductork. Even ASlM ackowledges tht these methods ar controversial (ASlM Interntional STP 134). The methods defie how to obtai and anyze a sample, yet provide no guidance on where or how often to test. The method discu how to expre measurd results, but provide no clearance or clean sunce measurments agait which reults can be compared. Each AS method states tht it doe not desbe proædur or tecques requied for the evaluation of the saety or habitabilty of buidigs with asbestos-eontag materils, or compliance with federal, state or loc regulations or statutes. ASlM fuer state tht it is the usr's reonsibilty to mae thes determations (ASlM D ). Therefore, before conductig any dust samplig for asbestos contaation, buidig owners and employers should carefuy review how the evaluation wil be performed, and must scrtie testig methods, the ntunber of sample sites, anlytical measrements, and inpector and laboratory credentials. Furthermore, measurement levels that requi a response should be agreed upon before testig commences. Asbestos-Contaminated Product Consumer Product Safety Commssion (CPS) ha investigated and identied several consumer prouct and buildig material tht have been indvertently contamated with asbestos. These product include play sand, talc, gravel and vermculte proucts. Zonolite, a venncute inultion usd in attcs and wall cavities in residential homes, was contamted with Tremolite asbestos durg its ming. (Se sidebar on pg. 39.) It was used in 15 to 35 miion homes, causing concern to mions of homeowners (EPA" Asbestos in Vermicute" 1). NIOSH and EPA have not provided specific inormation on asbestos-contaminated vermiculite due to challenges from TIie Vermiculite Assn. (TVA) (Chatfield). TVA cites errors in the analytical methods employed by EPA on vermiculite-contaminated gardening products in a 2000 study (EPA "Sampling and Analysis"). Its review found that the asbestos identified may not have been fibrous or even an asbestos mineral (Chatfield 21). c( AUCUST 2003 PROFESSIONAL SAFET 37 00(\ -a c0 -a CD ;; :s Ċ' (\ l! ai ei - l! :: CI ã5 êi (i cci Ü t5 ei S 0

7 S 0 00C\ "" c0 "" CO :s ci i Ċ' C\ L( cd (J - L! :: ci ã5 êi ëi c 0 ci tí (J Nevertheless, building owners are callig asbestos professionals and laboratories for testig. Again, however, inspectors can bias sample results. Contamation on vermculite attic inulation is generally heavier than on the lightweight expanded vermiculite. The contamination may have settled in an attc or wall cavity over several decades; if the inpector takes the sample from the top of l1ie pile, the contamination may appear lower than is actually present. Analytical methods employed to determine asbestos contamination in surface dust contiue to be controversial. Therefore, before considerig surface dust tests, building owners and employers should note that EPA uses ai samplig to determine conta1nation in residences and businesses affected by the collapse of the World Trade Center (EPA WTC 1). Before testig for asbestos contamation, one should ask "What isn't contamnated?" 38 PROFESSIONAL SAFET AUGUST Conclusion Asbestos lawsuits are agai on the rie. The SH&E commurty can no longer asume asbestos is on the back burer. Whe many recogne that asbestos is present in their faciities and address issues as they arie, others operate under a fale sense of sety by relying on previous asbestos inpections fr.at may not pass t.he inpection flaw test. Newer buildigs may also contai asbestos without anyone's knowledge. Due dilgence requirements to identi asbestos can certaiy raie the bar for most SH&E professionals-with or without exitig asbestos inspectons. Asbestos is naturally occurrg and can be found in background levels throughout the world. Contamination can occur naturally or by ditubance of asbestos-eontilnig materials. SH&E professionals should proceed cautiously when asbestos contamination becomes a concern. Many of the cuent analyti-

8 cal methods are indequate and controversial, parcuarly those involvig prouct and surace dust asbestos contation. Fortately, EPA has develope exællent gudance for testig, cleang and clearig asbetosontated buidigs. Those who believe asbetos is no longer being produced. are ignorig the fact. Some 13,100 metrc tons of asbetos were' imported into the US. in 2001, and worldwide mig of asbestos was estiated at 2,050,00 metric tons in 2001(Buckigha and Yates 3). Asbestos is not just hangig around; it's gettg a seond wid.. References ASTM International. Standar Test Method for Microvacuum Saplig and Indict Anysis of Dut by Tranmision Elecon Microscopy for Asbestos Strcte Num Concentrations. D Annual Book of ASTM Standrds. Secton 11: Water and Envinmenta Tecolog (2002): ASTM International. Standar Test Method for Micrvacuum Saplig and Indi Anysis of Dut by Tranmiion Elecon Microsopy for Asbetos Ma Concentrations. D Annual Bok of ASTM Standrds. Secton 11: Water and Envinmental Tecology (2002): ASTM International. ST 134 Advancements in Envinmental Meaurment Method for Asbestos. Advertement. ASTM Intertionl New. Order Form Buckgham, D. and R. Yates. "Asbetos Statistics" Wasgton IX: U.S. Gelogica Surey, Aug. 26, tt: llmieral.usgs.gov II mier /pubs / of(l-ü/ asbeos.xi;.. California Environmenta Protecton Agency (CEPA). "Fact Sheet #3: Ways to Control Natualy Occug Asbetos Dut." Sacramento, CA; CEA, Jan tt://arb.m.gov / toxics / asbestos /3control.htr. Chatfeld. E. "Review of Samplig and Analysis of Consumer Garen Prouct tht Contai Veraite: EPA 744R-û10, Aug. 200." Prentation at Vermaite Conerence LicoIn, UK: The. Veraite As., Nov. 15, Conser Pruct Safety Commsion (CPO. "Caer.. Ha! CPS War About Asbeto in Consum Pruct: Saet Aler" CP Doent #580. Wasgton, IX cp EPA. Asbestos: Manufact, Importation, Proessing and Ditnbution in Commerce Prolubitions. Fin Rule. Federal Regiter July 12, 1989: EPA. "Asbestos Buidig Inpection: Model Curcuum for Trai Buidig Inpector Cour." Waslugton: EPA, Jan (revied). EPA. "Asbestos Bul Samplig Buleti" Waslugton, DC: EPA, Sept. 30, EPA. "Asbestos in Schools: Evaluation of the Asbestos Hazard Emergency Response Act (AHERA): A Fact Sheet." Waslugton, IX: EPA, July EPA. "Asbestos in Vermcute Inultion." Washigton, DC: EPA, Jan 15, tt://ww.epa.gov/asbetos/intion.ht:. EPA. Clean Ai Act. Nationa Emsions Standards for Hazdous Ai Pollutants (NHA). 40 CPR Washigton, IX: EPA. EPA. "EPA Asbestos Matenal Ban: Clarcation." Washigton, DC: May 18, EPA. "Method for th Determtion of Asbetos in Bulk Buiding Matenals." EPA 60R Waslugton IX: EPA, EPA. "Sampli and Anysis of Consumer Garen Prouct 'Tt Conta Vermculte." EPA 744R-00-QI0. Washigton, IX: Aug EPA. Teccal Amendment in Respons to Court Deásion on Asbestos: Manufactu, Importation, Prossing and Ditrution in Commerce Prhiitions. Fin Rule. Fedeal Register. June 28, 1994: EPA. Toxic Substace Control Act (fa). Asbestos Hazard Emergency Response Act (AHERA). 40 CFR 763 Subpart E. Washington, IX: EPA. EPA. TSA. Seon 206 Reviions: Asbestos School Hazd Abatement Reauthorition Act (ASH). Washigton, IX: EPA. Nov. 28, EPA. "WTC Residential Dust Cleanup Program: Cleang & Testig Fact Sheet." Waslugton, IX: EPA, Jan. 7, tt://ww.epa.gov /wtc/factheets/ c1eantest.htj. General Cologne Re. "The Reemergence of Asbestos: More Claims, More Defendants, More Dollars." Hazardous Times. Nov. 2001: 1-7. Harey, B., et al. "A Blid Surey of Bulk Asbestos Laboratories Participatig in the Nationa Voluntar Laboratory Accrditation Program." Waslugton, DC: EPA, Methods Research and Development Div., OSHA. Asbestos Standard for General Industr. 29 CFR Waslugton, DC: U.S. Dept. of Labor, OSHA. OSHA. Asbestos Stadard for the Constrction Industr. 29 CP Waslugton, DC: U.s. Dept. of Labor, OSHA. Perkins. R., et al. "The One Percent Diemma." Environmental Infomui/iii Assn. Jounuil. Sumer 1994 (reprit). TIllinghast & Towers Perr. "U.S. Tort Costs Cled to $205 Bilion in 2001." Press releas. New York:, Tilght, Feb (( l!- oṉ - ch -- CD., :s Ċ' N L( 5: ai :: il ã5 (! êi ei c il Ü t5 o ww.asse.org AUGUST 2003 PROFESSIONAL SAFET 39

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