Regulated Building Materials in Property Management. July 30, 2013

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1 Regulated Building Materials in Property Management July 30, 2013

2 Nicole Gladu Property Redevelopment Business Line Manager URS Corporation Century Square th Avenue, Suite 1400 Seattle, Washington nicole.gladu@urs.com Tel: Cell: Introduction

3 Goals Why we assess Regulated Building Materials? What are Regulated Building Materials? How and when is an Assessment performed? What about newer construction? What is unique to hospitals? When is an Assessment performed? How long does an Assessment take and when is it scheduled? What happens after the assessment? What are some trends that may impact Assessments?

4 What are regulated building materials?

5 What are Regulated Building Materials? Asbestos Lead (paint, flashing, specialty applications) PCB-containing light ballasts and transformers PCB caulking Mercury-containing light tubes and thermostats Refrigerants Other heavy metals (cadmium, chrome) Radon Mold (sort of)

6 Urban Myth - The Asbestos Ban Common elements of the myth After 1979, asbestos was banned New construction won t have any asbestos Truths Fifth Circuit overturned the ban in 1989 and only a few materials are still banned Asbestos can be found in materials on the shelf today (roof mastics and gaskets as examples)

7 Urban Myth The Asbestos Ban

8 An Asbestos Geek s Vacation

9 Quick Reminder - What is Asbestos? Naturally occurring mineral which is mined and has been added to thousands of different types of building materials Asbestos Ban really only banned a few materials and asbestos is still coming into our building materials today Regardless of age, building materials need to be assessed for asbestos content If you don t know if a material contains asbestos, you have to assume it does

10 Non-Asbestos-Containing Materials Determining a suspect ACM is non-asbestos requires laboratory analysis which can take time.

11 Building Owner s Responsibility for Assessments (Surveys) OSHA Communicate the presence, location, and quantity of ACM and PACM Inform building occupants and Owner s employees of asbestos projects EPA Thorough survey prior to renovation or demolition Emergency and Disaster Responsibilities depend on the extent of situation

12 Why do we assess regulated building materials?

13 Why do we assess Regulated Building Materials? Protect public health and safety Regulatory Requirements Schedules Budgeting Decision making on projects Documentation Litigation Contractors ask for the documentation

14 ACM Products Over 3,000 Products Pipe and System Insulation Fireproofing Acoustical/Decorative Plasters Drywall, Spackle, and Seam Tape Cement Products Vinyl Asbestos Floor Tile Mastics and Adhesives Ceiling Tiles Theater Curtains Brake Shoes and Pads Fire Blankets

15 Floor Tiles

16 Roofing Materials

17 Window Putty

18 Gaskets

19 Duct Tape and Insulation

20 Spray-on Ceiling Material

21 Ceramic Tile Mastic

22 Pipe Insulation

23 How is an assessment performed? Documentation and proposed project review Walk-through of areas Bulk sampling Destructive sampling Condition assessment Laboratory Analysis Report

24 Asbestos Assessment Presence, Location, and Quantity of ACM and PACM (good faith inspection) Accredited AHERA Building Inspectors (some States have other requirements like NY, PA, IL, TX, CA, FL, MA, OH). WA is just EPA. Accredited Laboratories

25 Lead Assessment Identify Lead-Containing Paint (LCP) or Lead-Based Paint (LBP) EPA s Repair, Renovate, and Paint (RRP) Bulk paint chip sampling Condition assessment Waste Characterization Communication of results

26 PCB Inventory Inspect ballasts for labeling Quantify non-labeled ballasts Transformers Sampling of Bulk Materials (new trend)

27 Universal Wastes Inventory Mercury light tubes, thermostats, and switches HID lights Refrigerants Other chemicals

28 Visual assessments Verification sampling Air sampling Mold and Moisture

29 When is an assessment performed?

30 When is an Assessment performed? Prior to Property acquisition To support Property management Prior to renovation Prior to demolition

31 Building Owners Due diligence to identify asbestos, lead, PCB s, etc. Develop Operation and Maintenance Programs Communicate the results of the survey to tenants, employees, and contractors Design Level Survey when demolition, renovation, or tenant improvement is planned

32 Employers Inform employees of the presence, location, and quantity of ACM/PACM Train employees Design Level Survey when demolition, renovation, or tenant improvement planned

33 How long does an Assessment take and when is it scheduled? Survey (typically 1-3 days) Analysis (typically 5-10 days) Report (typically 5-10 days) Schedule well-ahead of planned projects. Ideally at least, 6 months for major projects (need to consider public bid requirements) 45 days for other projects Develop project schedule Prior to acquisition

34 What is a good procedure for newer construction?

35 What's New Construction? Let s group into the following: 1980 s 1990 s 2000 s and later

36 What About Renovation? We can still group into the three eras but I do not trust renovation in pre s buildings When a building owner says a building was completely remodeled in 1995, it doesn t really mean that all the asbestos was removed

37 Assessment Strategies Separate buildings prior to late 1980s from 1990 and newer Develop an assessment plan Conduct assessment and prepare a report

38 Assessment Strategies Review of contract documents Review MSDS and identify possible "suspect materials" Sample prior to installation Site inspections to confirm building material installation Letters from contractors and architects

39 Assessments in New construction Materials are more uniform so less sampling is needed As-built drawings are more readily available so fieldwork goes better More record reviews to target areas of renovation Less areas of remodel Still need to visually inspect all areas but probably take less samples

40 Materials Being Sampled in Newer Construction Floor Tiles and Mastic Cove Base and Mastic (mastic only if cove base is rubber) Wall systems Ceramic tile mastic, grout, and mortar Ceiling tiles Sink undercoatings Fire doors Roofing Caulking and glazing compound Spray applied fireproofing Popcorn ceilings Fire stops Basically - everything we sample in older construction

41 Joint compound Flooring Roofing 1980s Construction What do we find with asbestos Sink undercoatings Fire doors Other construction mastics and caulkings HVAC sealants All the usual except pipe insulation and spray-on

42 1990s and Newer Construction Roofing (especially sealants, mastics, and silver coating) Sink undercoatings Caulkings Other applications where asbestos is a natural contaminant (e.g., pipe dope) Vermiculite

43 2000 s and Current Construction Sink undercoatings Caulkings and some mastics (mainly roofing mastics) Recycling and reclamation efforts may allow asbestos to reenter our building materials. New materials being imported with asbestos Discussion of wallboard compositing and efforts to recycle gypsum

44 Gaskets Source sampling from 23 glass factory machine shops 75% of the 150 or so gaskets from the shelves contained asbestos (including sheet gaskets) ntry/products_indiaasbestos-gaskets.html

45 Gaskets

46 Floor Tiles and Mastic If asbestos is found in newer floor tiles, it is in very low percentages (<1%) or the asbestos structures do not meet the definition of a fiber TEM is the best way to identify small fibers in vinyl tiles

47 Finding asbestos in some undercoatings in newer construction but not very frequently Sink Undercoating

48 Finding asbestos in some sealants in newer construction but not very frequently HVAC Sealants

49 Fire Doors

50 Vibration Isolators

51 Vermiculite Within CMU walls through the 1990 s Late 1990 construction plastic column with vermiculite inside (0.50% verified by PLM point count) recommend further analysis by TEM

52 Mastic Beneath Computer Floor Stands Example of a mastic application where asbestos is being found in newer construction (again infrequently)

53 Pipe Insulation Not finding asbestos in pipe insulation in newer construction (wouldn t expect to because of the ban) Still need to assess pipe insulation (even if fiberglass) because some of the foil and paper wraps have a mastic layer

54 Fireproofing Not finding asbestos in fireproofing in newer construction (wouldn t expect to because of the ban) One PSCAA inspector reported finding sprayapplied fireproofing with greater than 1% asbestos in a post 1985 building

55 What happens after the assessment?

56 What ideally happens after the assessment? Abatement Design Notification Execution Paperwork

57 Depends on Jurisdiction Who gets Notified? Washington State Department of Labor and Industries, Division of Occupational Safety and Health (DOSH) Puget Sound Clean Air Agency

58 Asbestos Communication Flow Chart Building Owner Employees in the Building Employers in the Building Contractors bidding on work Employees Employees

59 Communication Regarding Asbestos Labels Required on ACM/PACM Where feasible Clearly visible Someone should periodically check to make sure labels are still in place

60 Communication Regarding Asbestos Warning Signs Mechanical Rooms/areas with ACM/PACM Must identify the material, location, and work practices to follow to prevent disturbance

61

62

63 Communication Regarding Asbestos Projects OSHA requires warning signs be placed at the entrances to asbestos work areas:

64 Next Steps Removal by Properly Licensed Contractors Project Monitoring and Management by Licensed Consultants Disposal at proper landfills with paperwork Communication to employees of any material remaining (usually with renovations) Development and implementation of an Operations and Maintenance Program C

65 What are some of the trends that may impact Regulated Building Materials?

66 Asbestos Handling <1% asbestos materials TEM and Point count analyses for asbestos samples Oversea production of materials Asbestos Lead Other

67 PCBs in Building Materials Sampling of Bulk Materials for PCB per EPA Pilot studies being performed by some larger area building owners If greater than 50 ppm PCBs in materials, EPA requires notification and requires an abatement plan Not sure what the standard of care will be in our region Trying to decide what materials, age of buildings, and sampling procedures

68 Lead-Containing Paint Any detectable amount of lead Lead in Construction Training Written Plans Medical Surveillance Air Monitoring Engineering Control the DUST Hygiene Stations

69 Lead-Based Paint and RRP Rule Pre 1978 residential >5,000 ppm (1 micro gram / cm2) Target Housing Child Occupied Special Licensing in WA and most other states Specific assessment and abatement requirements per HUD guidelines

70 Recap and Questions

71 Conclusion Performing Regulated Building Materials Assessments and proper handling procedures can: Protect people and the environment Meet regulatory requirements Add value to a property Assist in project decision making to minimize impact, save money/schedule, improve site conditions, and reduce future liabilities

72 Questions? 78

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