Asbestos Flooring Information and Issues

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1 UNIVERSITY OF WISCONSIN MILWAUKEE Physical Plant Services-Asbestos Management Program USB 222 P.O. Box 413, Milwaukee, WI (414) Developed By: Robert Grieshaber, CIH Date/Revision: December 7, 2011 Asbestos Flooring Information and Issues Background Information: Flooring material that contains asbestos was used extensively from the 1930s until the early 1980s. Based on the age of our buildings, a significant amount of existing floor tile at UWM is asbestos containing material (ACM). Most of the floor tile at UWM is referred to as vinyl asbestos tile (VAT) because of the manufactured components. VAT may include both nine-inch or twelve-inch tile; mastics, sheet flooring and felt-backing may also be ACM. Our older black mastic is almost always ACM. Laboratory analysis is necessary to determine whether the material is ACM or not. There is no prevailing regulation that prohibits the manufacture or importation of asbestos flooring materials (Source: U.S. EPA Asbestos, Manufacture, Importation, Processing and Distribution Prohibitions, 40 CFR 763, Fed Reg 58:58967, Nov. 5, 1993). One would presume that new flooring manufactured in the United States should not contain asbestos; however, all new imported flooring should be analyzed using standard analytical methods (i.e., with few exceptions, asbestos products are not banned; moreover, asbestos is still used/manufactured in many other countries). At the time of this web page posting, the Wisconsin Department of Natural Resources (WDNR) through statute only recognizes polarized light microscopy (PLM) for bulk sample analysis. However, EPA now recommends the use of transmission electron microscopy (TEM) for flooring and other materials with low concentrations of asbestos or with thin fibers below the resolution of PLM, similar to those found in floor tile (Source: Analysis of Floor Tile Samples, Illinois Dept. of Public Health, October 24, 2001, based on EPA guidance document). At the present time, we use PLM analysis. The WDNR refers to ACM floor tile as "Category I non-friable ACM". According to the DNR, Category I ACM must be removed before building demolition if the ACM has or will become friable. Asbestos containing products maintained in good shape are not a hazard. No regulatory authority prohibits asbestos in existing building materials; however, building materials must be maintained so that asbestos is not released. At UWM, care is taken to minimize abnormal wear, breakage or crumbling of floor tile. Flintkote brand vinyl asbestos 12 floor tile, from our attic stock.

2 Carpet and Asbestos Flooring: Departments planning on removing or installing carpeting must have Physical Plant Services determine whether the existing base floor is ACM. UWM Purchasing will not authorize carpet removal or new carpeting or flooring installation without determination of the composition and condition of the existing floor (see policy on carpet squares below). In many cases, removal of existing carpeting will result in damage to the base floor, particularly if the carpet is glued directly to the tile. If the base floor contains ACM, floor tile abatement procedures will be necessary. Besides costs associated with new flooring, departments must also budget for necessary abatement costs and they must schedule all work allowing sufficient time to conduct abatement. Standard Procedures for Removing Carpet Over Floor Tile: Departments must contact Physical Plant Services for determination whether the floor/mastic is asbestos or asbestos-free. Please allow at least two weeks for PPS and the analytical laboratory to make this determination. In most cases, we ll simply check the WALMS room-by-room database. Physical Plant Services will determine whether the carpet is glued or secured with tack strips and will conduct a carpet test-pull to determine the likelihood of the floor tile remaining intact or being disturbed during the actual removal. If during the test-pull it appears that the carpet will come up easily without pulling up floor tiles, permission will be granted to proceed with carpet removal. The department must notify the carpet vendor if the underlying floor is asbestos and that precautions are necessary to prevent tile disturbance. If during actual carpet removal floor tiles are being pulled up with the carpet, please contact Physical Plant Services for advice on how to proceed. Please keep in mind that tile disturbance can immediately turn into a regulated abatement activity. For small areas, authorized PPS staff can pull up the remaining carpet at cost to the department; for larger areas an outside licensed abatement company may have to be used also at cost to the department. If during the test-pull it appears that the carpet will likely cause disturbance of floor tiles, the department requesting carpet removal can either keep the existing carpet (i.e., no further action) or remove the existing carpet and pay for asbestos abatement costs. Please remember that DNR/DHFS may require a 10-working day notice for large projects; in addition the department must coordinate and schedule the movers, abatement contractor and carpet/flooring contractor. Physical Plant Services may require clearance air monitoring immediately following the abatement work at cost to the department; this will require an additional day or two before reoccupancy and new flooring installation may begin. Finally, notation will be made in the WALMS inventory whether the asbestos tile/mastic has been removed or left in place. Policy on Carpet Tile Over Asbestos Flooring: Since 2009, we have authorized the application of carpet tile (a.k.a., carpet squares), over asbestos flooring providing: (1) The existing asbestos flooring must be in satisfactory condition to permit this application; (2) we need to make notation in the WALMS inventory; (3) we need to remain cognizant this will only postpone the inevitable abatement of the asbestos flooring, therefore we typically only permit carpet tile in buildings scheduled for near-term renovation or where circumstances prevent asbestos abatement.

3 Care of Asbestos Flooring- Regulatory Requirements: OSHA/DCOM and other regulatory agencies do not advocate removal of asbestos flooring simply for the sake of removing asbestos. However, OSHA/DCOM has specific requirements for asbestos floor care and maintenance: Sanding or grinding of asbestos-containing flooring material, including mastics, is prohibited (OSHA 29 CFR (k)(7)(i)). Stripping of finishes shall be conducted using low abrasion pads at speeds lower than 300 rpm and wet methods (OSHA 29 CFR.1001(k)(7)(ii)). Burnishing or dry buffing may be performed only on asbestoscontaining flooring which has sufficient finish so that the pad cannot contact the asbestos-containing material (OSHA 29 CFR (k)(7)(iii)). Work operations involving floor tile abatement is generally considered OSHA Class II or Class III abatement; routine custodial care of asbestos floor tile is a Class IV work operation. Routine custodial floor care at UWM often involves asbestos flooring. Chair Casters and Abnormal Floor Wear: Chair casters must be appropriate for the type of flooring. There are both hard casters, for carpet, and soft casters, appropriate for either carpet or hard flooring such as floor tile. Using hard casters on floor tile will result in abnormal floor deterioration and will drastically reduce the life of the floor. Departments must be sure to specify the appropriate type caster when purchasing new office equipment. If you have the wrong type casters, your department must order new, appropriate casters, or install a rubber or plastic mat to protect the floor. Please see the following photos for caster examples: This soft, rubber wheel caster is appropriate for hard flooring at UWM including VAT and VCT. This hard, plastic caster may prematurely deteriorate this floor; not recommended for VAT or VCT.

4 This thin, hard plastic caster will prematurely deteriorate this floor; this caster is appropriate for carpet. UWM Position Statement on Removal of Mastics/Adhesives: At UWM, the abatement of asbestos containing mastics and adhesives during building and flooring renovations is determined on a case-by-case basis. Recent WDNR compliance initiatives make mastic removal a necessity particularly if the base floor will ever by recycled. The campus preference is to use soy-based mastic remover in order to minimize building air quality complaints. The following issues shall be taken into consideration for mastic removal determination: Advantages of Mastic Removal: not a legacy issue (i.e., the asbestos is gone) may result in better adhesion for the new floor, particularly if there is no residual mastic or solvent left on the floor after treatment and the floor is washed with a detergent may be far more expensive and difficult to remove at a later date, particularly if new mastics are applied over the old (i.e., makes sense to remove the mastic now) mastic-free material will allow the base floor to be recycled rather than land-filled at the time of building demolition. Disadvantages of Mastic Removal: increased abatement cost project will take slightly longer to complete mastic may be difficult to remove, especially if covered by other adhesives may result in poor adhesion of new floor, particularly if the old mastic was in poor condition (e.g., loss of adhesiveness to base floor or dried out, friable, etc.) potential indoor air quality complaints from evaporation of the solvent; we typically prefer the low-odor soy based solvents. potential damage to other building components due to the mess, or solvent leakage through cracks and floor penetrations Removal of asbestos containing mastic (adhesive) in the UWM Physics Building (January 2011), using soy-based mastic remover.

5 Other Resources and References: OSHA Standard Interpretation Letter, May 7, 2003: Aggressive vs non-aggressive removal of asbestos containing flooring material; negative exposure assessment methods for direct and indirect employee exposures. Asbestos Program-Carpet Removal Procedures: Environmental Health & Safety at Stony Brook University,