EPA MODEL ASBESTOS SUPERVISOR TRAINING MANUAL (Revised by State Employees Asbestos Program) 1
This manual is not intended as an interpretation of EPA or OSHA regulations. The Maryland Department of the Environment has modified this publication to meet the needs of the State Employees Asbestos Program. 2
CONTENTS Chapter Page How to Use This Manual...6 Introduction...10 Chapter 1: Identifying Asbestos...11 Materials that Contain Asbestos Friable and Non-Friable Materials Bulk Sampling TypesofAsbestosFibers Chapter 2: Asbestos Diseases and Medical Exams...25 Chapter 3: Laws...84 Chapter 4: Respirators...47 Types of Respirators Fitting and Maintaining Respirators Other Safety Equipment Chapter 5: Control Methods...107 Chapter 6: Pre Work Activities and Considerations...115 Chapter 7: Setup...133 Keeping Asbestos Out of the Air Negative Air Machines Setting-Up the Work Area Chapter 8: Record Keeping...165 Chapter 9: Removal...171 Removing Asbestos Waste Disposal during Removal Decontamination Chapter 10: Cleanup and Disposal...182 Cleaning the Work Area Removing Plastic Waste Disposal during Cleanup Lockdown/Sprayback Air Sampling Chapter 11: Maintenance-Related Removal...191 Mini-enclosures Glove Bags Chapter 12: Other Health and Safety Problems...202 Chapter 13: Contract Specifications...220 Chapter 14: Legal and Insurance Considerations...237 Chapter 15: Supervisory Techniques...251 Glossary...256 3
HOW TO USE THIS MANUAL This manual is yours to keep. Use a highlighter during the class and put notes on the sides of the pages to help you remember important information. This will help you when you study for the test at the end of the class. After the class is over, you can use this manual for information about your rights and responsibilities as a worker, the rights and responsibilities of your employer and the legal requirements for safe work. On the first day of class you will learn about: How asbestos is identified (Chapter 1: Identification). How asbestos can harm your health (Chapter 2: Asbestos Diseases). How doctors can help you with medical exams (Chapter 2: Asbestos Diseases). How the laws about asbestos work (Chapter 3: Laws). How to protect yourself from asbestos (Chapter 4: Respirators). On the second day of class you will learn about: How a building owner can control asbestos (Chapter 5: Control Methods). What to consider before work begins (Chapter 6: Pre-work Considerations) How to keep asbestos out of the air (Chapter 7: Setup). How to set up a job (Chapter 7: Setup). Record keeping requirements (Chapter 8: Recordkeeping) On the third day of class you will learn about: How to take off asbestos (Chapter 9: Removal). How to clean up after a job (Chapter 10: Cleanup). On the fourth day of class you will learn about: How to do small jobs (Chapter 11: Maintenance). On the fifth day of class you will learn about: Safety on the job (Chapter 12: Safety). Contract specifications (Chapters 13: Contract Specifications) Legal and insurance considerations (Chapter 14: Legal & Insurance Considerations) Supervisory techniques (Chapter 15: Supervisory Techniques) Each day of class will also give you the opportunity to practice using the skill that learn in this class. You will practice on non-asbestos materials. You will: Be fitted with a respirator and practice maintaining it Build a work area and remove non-asbestos insulation Use a glove bag to remove non-asbestos pipe insulation Build an enclosure around non-asbestos support beam. Build and use a mini enclosure to remove ceiling tiles.
Determine how many, operate and maintain HEPA vacuums and negative air machines. Build and use a decontamination area. Learn methods to remove floor tiles safely. Practice supervisory skills Practice preparing contract specs Write up things to consider before work begins Many chapters end with a box called "Key Facts." For example, the Key Facts for Chapter 1 are on page 17. This tells you the most important ideas and words that are covered in the chapter. There is a glossary at the end of the manual to help you find the information you need. The glossary on page 254 has definitions of the most important terms used in the manual. When you see these words in the manual: have to, must, required, shall, this is something that the law says you must do: When you see these words in the manual, can, may, might, suggested, this is something that is a good idea, but the law does not say you have to do it: 5
ABBREVIATIONS USED IN THE MANUAL ACM ACBM AHERA CO EL EPA F/CC GFCI HEPA HVAC IH MSDS MUL NESHAP NIOSH O&M OSHA PAPR Asbestos-Containing Material Asbestos-Containing Building Material Asbestos Hazard Emergency Response Act Carbon monoxide Excursion Limit Environmental Protection Agency Fibers per Cubic Centimeter Ground Fault Circuit Interrupter High Efficiency Particulate Air Heating, Ventilating and Air Conditioning Industrial Hygienist Material Safety Data Sheet Maximum Use Level National Emission Standards for Hazardous Air Pollutants National Institute for Occupational Safety and Health Operations and Maintenance Occupational Safety and Health Administration Powered Air-Purifying Respirator 6
PCM PEL PF PLM PSI SCBA TEM VAT Phase-Contrast Microscope Permissible Exposure Limit Protection Factor Polarized Light Microscope Pounds per Square Inch Self-Contained Breathing Apparatus Transmission Electron Microscope Vinyl-Asbestos Tile 7
INTRODUCTION Asbestos can cause disease or kill you unless you protect yourself Up until the mid nineteen seventies, workers weren't told that asbestos is dangerous. They did not protect themselves when they were working. Various sources have estimated that upwards of 12,000 workers will die of asbestos-related diseases every year. Most of these workers died ten to forty years after they started working with asbestos. Asbestos can kill you or your family unless you protect yourself from it. Fortunately, there are ways to protect yourself and to work with asbestos safely. In this class, you will learn how to protect yourself and others. You will learn how to make your work with asbestos as safe as possible. This means safe for you, safe for your workers, safe for your family, and safe for the environment. If you learn the rules for working with asbestos, you will greatly lower your chances of getting sick years from now. You must work carefully and follow the laws. If you do this, you will also help protect your workers, family and neighbors from asbestos diseases and other ailments related to asbestos exposure. You will learn how to keep asbestos out of the air. You will learn how to keep asbestos out of your lungs after it gets in the air. You will learn how to keep asbestos from spreading outside of the work area. This manual also has important information about how asbestos may affect your health. It tells you about the special medical exams that are required. It tells you where to go for more information. Asbestos is found naturally in the air at low levels almost everywhere. Everyone breathes some asbestos just from breathing the air. But asbestos workers handle large amounts of asbestos. Your employer has to give you the right equipment. You have to use the equipment in the right ways to protect yourself. The more you know about asbestos removal, the better you can protect yourself and others. 8
CHAPTER 1 IDENTIFYING ASBESTOS In this chapter you will learn: What asbestos is. That asbestos can be dangerous. When asbestos is dangerous. How asbestos gets in the air. Where you may find asbestos. How asbestos is identified. About the different kinds of asbestos fibers. WHAT IS ASBESTOS? Asbestos is a mineral. It is a natural rock mined from the ground. There are several places like Canada, and South Africa where it is mined commercially. Asbestos is not a man-made fiber. (Fiberglass is a man-made fiber.) Asbestos has been used since Greek and Roman times. More recently, it has been used in building and other materials. When asbestos is crushed, it does not make ordinary dust, like other rocks. Asbestos breaks into tiny, sharp fibers that are too small to see. You cannot see, feel, or taste asbestos fibers that get into your lungs. WHEN IS ASBESTOS DANGEROUS? Asbestos is dangerous when you breathe it. Asbestos is dangerous when you breathe it. Asbestos fibers are so small they can easily get into your lungs. Asbestos can make you very sick many years after you breathe it. Asbestos will not make you cough or sneeze or itch while you breathe it. But if enough asbestos gets into your lungs, it can kill you many years later. When asbestos gets in the air, you can breathe it. Sometimes plaster has asbestos in it. If the plaster stays on the wall, the asbestos will not hurt you. If you tear down the wall, the asbestos may get in the air. When asbestos is in the air, it is dangerous. 9
It is easy to get asbestos in the air. If you handle asbestos at all, it can get in the air. If you Saw Sand Drill Nail Cut Bump Tear Abrade Grind Strike Hit Rip Break or Chip asbestos, it can get in the air. Once asbestos is in the air, it can get in your lungs and make you sick. Asbestos fibers are very small. Many are so small that you can t see them. Asbestos fibers are also very light; they go wherever the air goes. If asbestos is in the air in a boiler room, it can travel through the building. It can go through air ducts, under doors, and down halls and stairs. Asbestos is so light it can hang in the air for days. If you step in asbestos dust on the floor, you may cause it to go back into the air. HOW MUCH ASBESTOS IS IN THE AIR? There are ways to measure how much asbestos is in the air. Air pumps pull the air through a small filter. The asbestos fibers stick to this filter. The fibers are counted with the use of a microscope. The amount of air that passes through the pump is also measured. The amount of air is measured in cubic centimeters. A cubic centimeter is about the size of a sugar cube. Asbestos is measured in fibers per cubic centimeter (f/cc) of air. This is called air sampling. You will learn more about air sampling in Chapter 10. Even though you cannot see asbestos in the air, it can be measured. Remember that asbestos is dangerous when it is in the air. IF ASBESTOS IS SO DANGEROUS, WHY IS THERE SO MUCH OF IT? Asbestos is a very good fire, heat and sound insulator. It is also very strong. Pound for pound, asbestos is stronger than steel. For example, asbestos is in brake shoes, which need to be strong and resist heat. Asbestos has also been used for many building and construction materials. 10
Asbestos is most common in: Sprayed-on and troweled on ceiling insulation; Pipe, duct and boiler insulation; Floor and ceiling tiles Asbestos is in more than 3,000 different products. It is in many building materials. Building materials that are most likely to have asbestos in them are: fire proof insulation condensate insulation heat insulation sound insulation A lot of asbestos is in old buildings. New buildings built after 1980 don' t have as much asbestos in them as older buildings do. You are likely to find asbestos in: 1. Sprayed-on ceiling insulation 2. Pipe and boiler insulation 3. Duct insulation 4. Floor and ceiling tiles 5. Fire doors 1. Sprayed-on asbestos insulation is usually fluffy material sprayed onto ceilings or beams. Sometimes you can see the insulation from the floor. Sometimes it is covered by ceiling tiles. 2. Asbestos pipe and boiler insulation may be covered with paper, cloth or metal. The insulation may be cardboard-like pipe wrap or cement on pipe elbows. It may also be troweled-on insulation on boilers or boiler wrap. 11
3. Asbestos duct insulation is usually a thin layer of insulation. It is usually painted to match the room. It may be covered with paper, cloth or metal. 4. Asbestos floor and ceiling tile look exactly like non-asbestos tile. Asbestos floor tile is usually vinyl asbestos tile (VAT). Asbestos floor tile can be found in either 9 inch or 12 inch squares. Asbestos ceiling tile is used for sound insulation or for dropped ceilings. SOME EXAMPLES OF ASBESTOS-CONTAINING MATERIALS (ACM) acoustical (sound) plaster fireproofing on beams acoustical (sound) tiles flue pipes boiler insulation mastic brake shoes pipe gaskets ceiling insulation pipe insulation chemical tanks roofing felts decorative plaster roofing asphalt dropped ceiling tiles siding duct insulation spackling electrical insulation Transite (cement) sheets fire blankets Transite (cement) pipes fire curtains valves fire doors vinyl-asbestos floor tiles Asbestos is common in boiler rooms, on ceilings or above ceilings, and wherever pipes are found. CATEGORIES OF ASBESTOS-CONTAINING MATERIALS For the purposes of assessment, asbestos-containing materials (or ACM) are placed into one of three different categories. Products such as sprayed-on fireproofing or acoustical plaster are in the surfacing category. Pipe wrap, boiler, and duct covering are in the thermal system insulation category. Fire doors, floor tiles, ceiling tiles, siding, etc. are in the miscellaneous category. 12
The first two categories are the most dangerous and often the most frequently removed because they are considered normally friable. (Miscellaneous materials may also become friable but it is more difficult to make them so.) FRIABLE (CRUMBLY) ASBESTOS Asbestos that can be crumbled to a powder in your hand when it is dry is called "friable: (FRY-able) asbestos. A friable (crumbly) piece of asbestos is more dangerous than a non-friable piece of asbestos. The fibers are more likely to be released and get into the air. An example of friable asbestos is sprayed-on ceiling insulation. The insulation may fall off the ceiling and get in the air without even being touched. When someone touches the ceiling, asbestos may get in the air. When air blows across it, asbestos may get in the air. An example of non-friable asbestos is vinyl-asbestos floor tile (VAT) in good condition. If you leave it alone, the asbestos fibers will probably stay in the tiles. But if you saw, drill, or sand the tile, asbestos may get into the air. IDENTIFYING ASBESTOS You can't tell if a product contains asbestos just by looking at it. Since you may be supervising employees who remove asbestos, you need to tell them where the asbestos is on the job. They may not know where all the asbestos is in their building. If you do not know if a material contains asbestos, always assume that it is asbestos. Then check building records or have a sample taken by an accredited asbestos building inspector to find out for sure. You can then check by looking at the lab report(s). Remember: treat all materials as asbestos containing unless they are proven to be non- asbestos containing by laboratory tests. 13
Because you work in a State facility you can look at your facility' s Management Plan. The sampling results are kept with it; they show you whether or not the material is asbestos. Many things look the same as asbestos, whether they have asbestos in them or not. Ceiling tiles made by different companies are made to look the same so they can be replaced. A ceiling tile with no asbestos may look exactly the same as a ceiling tile with 30% asbestos. Sometimes asbestos looks white and fluffy. Sometimes it is colored and looks like brown mud. Sometimes it is covered with a paper jacket. The jacket may be painted any color. Unless the material has been checked in a laboratory, there is no way to tell if the material contains asbestos. Some people say they can tell if something is asbestos just by looking at it. This is not true. No one can tell for sure if something is asbestos by looking, feeling, or smelling. The only way to tell for sure is to send a piece of material to a lab. This is the only way allowed by law. At the lab, a trained analyst looks at the sample under a microscope. A report will be sent back to tell you if asbestos is present or not. A few building materials have a standard look. Some contain asbestos, some don' t. Corrugated, papery pipe covering, called "air cell", almost always has asbestos in it. Fiberglass, black polyurethane foam, and cork almost never have asbestos in them. As you can see, asbestos can be in many (but not all) building materials. You need to work carefully around insulation and other building materials that might be asbestos. Remember that not everything has asbestos in it. Glass, gypsum board, fiberglass, polyurethane foam, cork, and ceramic tiles usually do not have asbestos in them. Always treat any material as asbestos unless you know for certain that it is not asbestos. WHAT IS SENT TO A LAB? To tell whether something is asbestos, an asbestos building inspector trained and accredited under the Model Accreditation program (COMAR 26.11.23) takes a piece of the material. This is called a bulk sample. The inspector repairs the area where the sample was taken. The inspector sends the piece of material to a lab. Samples taken from schools or other public or commercial buildings must go to an National Voluntary Accreditation Program (NVLAP) approved lab. 14
The lab grinds up the bulk sample and stains it with dye. The lab then looks at it under a special microscope. It is called a Polarized Light Microscope PLM). ARE THERE DIFFERENT KINDS OF ASBESTOS? There are six kinds of asbestos fibers. They are all dangerous. The three most common kinds of asbestos fibers are: CHRYSOTILE (CRY-so-tile) AMOSITE (AM-o-site) CROCIDOLITE (crow-sid-o-lite) CHRYSOTILE asbestos is 80% of all asbestos in buildings. It is known as white asbestos. It is the only member of the serpentine family of asbestos rock. It wets easily. AMOSITE is less than 15% of all asbestos in buildings. It is known as brown asbestos. It is a member of the amphibole family of asbestos rock. AMOSITE doesn' t soak up water. All asbestos must be wet before you handle it. Wetting asbestos helps to keep the fibers out of the air. A surfactant added to water helps to wet amosite. CROCIDOLITE is less than 5% of all asbestos. It is known as blue asbestos. It is also a member of the amphibole family. There are three other kinds of asbestos fibers. Anthophyllite (an THAW-fo-lite) Tremolite (TREH-mo-lite) Actinolite (ack-tin-o-lite) All asbestos fibers are dangerous.. ASBESTOS ASSESSMENT CONSIDERATIONS In addition to obtaining bulk samples, an accredited asbestos building inspector must also decide on what condition the asbestos-containing material is in and its potential for future disturbance. Some of the factors that go into this decision include: - The location and the amount of the material, both in total quantity and as a percentage of the functional space - The condition of the material such as type of damage (flaking, blistering, water damage, etc.), severity of damage (major flaking, severely torn jackets, etc.), and the extent or spread of damage - The accessibility of the material - The material' s potential for disturbance 15
- Known or suspected causes of damage (air erosion, vandalism, vibration, water, impact, etc.) AND - Preventive measures which might eliminate the reasonable likelihood of undamaged asbestos-containing material from becoming damaged PROTECTING YOURSELF Asbestos is dangerous, but you can protect yourself and those around you. Asbestos is dangerous if you breathe it. To work safely with asbestos, you have to keep it out of the air. There are lots of good ways to do this. You will learn about them in this class. You have to take asbestos out of the air with special filters. Most important, you have to filter the air that you breathe with a respirator--a device that filters the air. You can also wear a respirator that pumps in clean air from outside the work area. You must wear a disposable suit when you work. You must not take asbestos home with you on your clothes. The air that leaves the work area also has to be specially filtered before it leaves the work area. This protects people outside of the work area You cannot tell when asbestos is in the air or is hurting your lungs. But you can use your knowledge to work more safely and protect yourself. See SEC 4 for more information on protecting yourself. 16
IDENTIFYING ASBESTOS Key Facts Asbestos is a mineral that breaks down into fibers. Asbestos is dangerous when it is in the air and you breathe it. It is very easy to get asbestos in the air. Wherever air goes, airborne asbestos can go. Asbestos can kill you, but you can protect yourself and others. To work safely with asbestos, you have to keep it out of the air. When asbestos gets in the air, you have to filter the air with special filters. You must also protect yourself with respirators and special clothing. Asbestos is in more than 3,000 different products. In buildings, you will probably find asbestos in: Sprayed-on ceiling insulation Pipe and boiler insulation Duct insulation Floor and ceiling tiles Friable (crumbly) asbestos is more dangerous than non-friable (hard) asbestos. You can' t tell if something contains asbestos just by looking at it. A lab can test a piece of material, called a bulk sample. The lab looks at the bulk sample under a Polarized Light Microscope (PLM). If you do not know whether something is asbestos, assume that it is asbestos until a bulk sample proves it is not. There are three common kinds of asbestos fibers: CHRYSOTILE (CRY-so-tile) (80% of asbestos in buildings) AMOSITE (AM-o-site) (hard to wet) CROCIDOLITE (crow-sid-o-lite) 17
Discussion questions 1. Is asbestos dangerous if gets on your clothes? 2. Sometimes air ducts are insulated with asbestos. Why is this so bad? 3. Is asbestos floor tile friable? Is this always true? 4. You can' t tell whether a product contains asbestos by just looking at it. Why does this make asbestos more dangerous than other workplace problems? 5. Why is it harder to work safely with AMOSITE asbestos than with other kinds of asbestos? For more information *List of asbestos-containing materials, Appendix A to EPA, "Guidance For Controlling Asbestos-Containing Materials in Buildings," (the "Purple Book") EPA Publication No. EPA 560/5-85-024. *OSHA Asbestos Standard, 29 CFR 1926.1101, Appendix H, "Substance Technical Information for Asbestos." * "Bulk Sampling," chapter in the "Model EPA Curriculum for Training Building Inspectors," *The State of Maryland s Asbestos Safety and Health Program s Policies and Procedures Manual. *Your instructor has copies of this information for you to look at. 18
T RAINING FACT SHEET There are a lot of facts that you need to know about asbestos. This fact sheet has been made to help you. It has information you must know. All of the information will be covered in the class. Read this fact sheet over every day. The facts may not make sense when you first start reading them. If you read this every day, it will help you during the class and it will help you pass the test. I. Federal Government Agencies Involved With Asbestos: There are three federal government agencies that deal with asbestos. You will hear about these agencies throughout this training. Here is a list of the agencies and a brief description of each. 1. EPA. The Environmental Protection Agency. A federal government agency that protects against pollution. The EPA makes and enforces regulations to protect the community and the environment from pollution. (See SEC 3 for more information about the EPA.) AHERA. Asbestos Hazard Emergency Response Act The EPA' s "asbestos in schools" law. (See SEC 3 for more information about AHERA.) NESHAP. National Emission Standards for Hazardous Air Pollutants The EPA law that covers asbestos as an air pollution problem. (See SEC 3 for more information about NESHAP.) ASHARA. Asbestos School Hazard Abatement & Reauthorization Act. 2. NIOSH National Institute of Occupational Safety & Health A federal government agency that researches worker safety and health, and reports its findings to OSHA. NIOSH also certifies respirators. 3. OSHA The Occupational Safety and Health Administration A federal government agency that covers worker safety and health. OSHA makes and enforces regulations (standards) to protect workers. OSHA has regulations about: asbestos, chemical safety, electrical safety, ladders, respirators, scaffolds and many other workplace hazards. (See SEC 3 for more information about OSHA.) 19
II. State Governmental Agencies Involved With Asbestos: There are two state government agencies that deal with asbestos. You will hear about these agencies throughout this training. Here is a list of the agencies and a brief description of each. 1. MDE. Maryland Department of the Environment A state government agency that protects against pollution. MDE enforces regulations to protect the community and the environment from pollution. (See SEC 3 for more information about MDE.) COMAR 26.11.21. Control of Asbestos. The MDE law that covers the licensing, notifications, and work practices of entities who remove asbestos (See SEC 3 for more information about COMAR 26.11.21) COMAR 26.11.23 Accreditation of Individuals and Approval of Training Courses The MDE law that covers asbestos training provider and individual accreditation. (See SEC 3 for more information about COMAR 26.11 23.) 2. MOSH. Maryland Occupational Safety & Health A state government agency that protects workers against occupational safety & health hazards. MOSH enforces both its own and OSHA regulations to protect workers from occupational hazards. (See SEC 3 for more information about MOSH.) III. Measurement of Asbestos Asbestos is measured in fibers per cubic centimeter (f/cc) of air. A cubic centimeter is about the size of a sugar cube. The air is checked for asbestos fibers through air sampling methods. (See the Air Sampling handout for more information about air sampling.) OSHA sets limits on the amount of asbestos fibers you can be exposed to in your work. There are two (2) limits that you will need to know. They are the Permissible Exposure Limit (PEL), and the Excursion Limit (EL). Permissible Exposure Limit (PEL) - 0.1 f/cc The Permissible Exposure Limit is 0.1 f/cc. It is the average number of fibers in the air over an 8-hour period of time that equal 0.1f/cc. 20
The PEL is the highest number of fibers in the air (allowed by Law) or a worker to be exposed to. The Permissible Exposure Limit is like a red light. It means stop work. Excursion Limit (EL) - 1 f/cc The Excursion Limit is 1 f/cc. It is the average number of fibers in the air over a 30- minute period of time that equal 1f/cc. The Excursion Limit is the highest number of fibers a worker can be exposed to in any thirty minute time period. It is like a red light. It means stop work. The Excursion Limit protects you from large amounts of asbestos exposure in a short time period. Neither the Permissible Exposure Limit (PEL) nor the Excursion Limit (EL) represent a safe level of exposure. Any exposure has some risk. Thus, exposure to airborne asbestos must be kept as low as possible. IV. Respirators Respirators are used to protect your from breathing asbestos fibers. There are three terms that you need to know to use the information about respirators. It is important to learn these terms so that you know whether you have the right respirator for your asbestos work. These terms are: 1. Maximum Use Level (MUL) - the largest amount of airborne asbestos (in fibers/cc) a respirator can handle 2. Protection Factor (PF) - the degree of protection of a respirator 3. Permissible Exposure Limit (PEL) = 0.1 fibers/cubic centimeter of air These three terms combine to give you a formula that you can use. Formula: Maximum Use Level = Protection Factor x Permissible Exposure Limit MUL = PF x PEL (0.1 f/cc) 21
How to Use The Formula: An Example: A powered air-purifying respirator (PAPR) has a protection factor of 100 with the motor on. For every 100 fibers outside, 1 fiber leaks in. When can you use this respirator? MUL = PF (100) x (0.1 f/cc) PEL so 10 f/cc = 100 x 0.1 f/cc The Maximum Use Level for a PAPR is 10 fiber/cc, so 1. Below 10 fibers/cc in the air, a powered, air-purifying respirator is legal. (however at 10f/cc asbestos fibers are visible and this is not a good situation) 2. Above 10 fibers/cc the respirator is not allowed. You need at least a Type C Pressure Demand Airline Respirator. (The State Employees Asbestos Program requires at least a Powered Air Purifying Respirator for Level II building maintenance workers) 22
CHAPTER 2 ASBESTOS DISEASES - PART 1 In this chapter you will learn: About the diseases caused by asbestos. How asbestos gets into your body. When asbestos is dangerous. How much asbestos can make you sick. How long it takes to get sick from asbestos. How your respiratory (breathing) system works. The connections between asbestos, smoking, and disease. ASBESTOS DISEASES Asbestos can kill you. When you work with asbestos, you must work carefully. You are in this class to learn how to protect yourself and others from asbestos exposure. Asbestos exposure means breathing or swallowing asbestos fibers. If you are in an area where asbestos is in the air and you are not protected, then you are exposed. This is called asbestos exposure. Asbestos exposure causes: Asbestosis: "white lung" a disease that causes scars on the lungs. Lung cancer: a cancer of the lungs. Mesothelioma: a cancer of the lining of the chest or the lining of the abdomen. Other cancers: cancers of the digestive system. How do we know that asbestos can make you sick? We know that asbestos causes asbestosis, mesothelioma, lung cancer, and other cancers because of many scientific studies. One of the most important studies looked at death certificates of union insulation workers who worked with asbestos. All of the men had worked with dangerous amounts of asbestos for at least 20 years. (This was before the OSHA standards). These workers did not know how dangerous their work with asbestos was. No one told them that they needed to keep asbestos out of the air. No one told them that they had to protect themselves with respirators and disposable suits. There were no laws to protect them. Many of these workers died from asbestos disease. 23
Working with asbestos is a big responsibility You are in this asbestos supervisor class for 5 days. You will learn that asbestos is dangerous. Asbestos can cause diseases that kill. You will learn when asbestos is most dangerous and how to keep the danger levels as low as possible. You will learn how to protect yourself and others as you work with asbestos. You will learn how to supervise others to protect themselves and the environment. Use the information from this class when you work. Ask for and use the right equipment and protective gear. This will help to reduce the risk of getting an asbestos-related disease. When is asbestos dangerous? You cannot tell when you are breathing asbestos! Asbestos is dangerous when it is in the air. When asbestos is in the air, you cannot see it, but you breathe it. Asbestos is dangerous when it gets into your body. Asbestos gets into your body when you breathe or swallow it. Asbestos enters your body through your nose and mouth. Remember that asbestos fibers are so small you can' t see them. You cannot see, feel, or taste asbestos. Asbestos will not make you cough or sneeze. It will not make your throat or skin itch. Other materials mixed with the asbestos may cause these reactions. Asbestos has no warning properties. It does not let you know it is there. How much asbestos is dangerous? There is no amount of asbestos that has proven to be safe! The more asbestos you are exposed to, the more likely you are to get an asbestos-related disease. All of the asbestos diseases except one are dose-related. Dose-related means the more asbestos you breathe, the more likely you are to get an asbestos-related disease. You may not get sick until many years after you breathe the asbestos. The more asbestos you breathe, the more likely you are to get asbestosis. The more asbestos you breathe, the more likely you are to get lung cancer. The more asbestos you breathe, the more likely you are to get a digestive system cancer. Asbestosis, lung cancer, and digestive system cancers are dose-related. The asbestos-related disease that is different is mesothelioma. Small amounts of asbestos can give you Mesothelioma. Asbestos worker s families have gotten Mesothelioma from the dust the workers brought home on their clothes. Like other things that cause cancer, there is no amount of asbestos that has been proven to be safe. 24
How long does it take to get sick from asbestos? Asbestos can make you sick 10 to 40 years after you breathe it. All of the asbestos diseases have a latency period. Thelatency period is the gap between the time you breathe asbestos and the time you start to feel sick. The latency period for asbestos diseases is approximately ten to forty years long. Even if you only worked with asbestos for a year and then stopped, you still might get sick ten to forty years later, depending on the amount of asbestos you were exposed to. If you breathe tear gas, it will make you feel ill right away. It will make your eyes water and throat hurt as soon as you are exposed to it. If you breathe asbestos, you probably won't even know you are breathing it. Asbestos does not irritate you while you are being exposed to it. It gives no warning. You will not feel sick during the latency period of ten to forty years. If you get an asbestos-related disease, you will begin to feel sick after the latency period. Not everyone who is exposed to asbestos gets an asbestos-related disease. But anyone who is exposed to asbestos has a higher risk of getting an asbestos disease. Most of the asbestos diseases are difficult to treat and cure. The only cure for most asbestos diseases is to prevent them. Except for colon cancer, asbestos diseases (asbestosis, lung cancer, mesothelioma) are very difficult to treat. The only cure for most asbestos diseases is to prevent them. When you breathe in asbestos, a few fibers are caught in your throat before they get to your lungs. But many fibers lodge in your lungs, and stay there for the rest of your life. It is important to stop these fibers from entering your lungs. You can keep many of these fibers out of your lungs with the safe work practices and personal protection you will learn about in this course. 25
How your lungs work. To understand how asbestos makes you sick, you need to know how your respiratory (breathing) system works. Your respiratory system brings oxygen (a gas in the air) into your body. You cannot live without oxygen for more than a couple of minutes. When you breathe in air, oxygen goes into your lungs. Your lungs are like a giant sponge with a huge surface area for taking in oxygen. Your lungs take oxygen out of the air into your blood and get rid of carbon dioxide (a waste gas in your blood). Then your heart pumps the oxygen rich blood through your body. Every cell in your body needs the oxygen that comes through your lungs. Take a deep breath. When you breathe in, air goes through your nose and mouth into your windpipe. The windpipe divides into smaller and smaller tubes and finally ends in tiny sacs called alveoli (al-ve-o-lie). In the alveoli, oxygen from the air goes into your blood and carbon dioxide from your blood goes through your lungs and out of your body when you breathe out. The alveoli are like the leaves on a tree. In the alveoli, oxygen passes into the blood and carbon dioxide waste goes out. The walls of your alveoli have to be very thin so that oxygen and carbon dioxide can move through them. When you breathe, your chest moves in and out. It widens or expands when you breathe in, so that more air can come into your lungs. When you breathe out, your chest narrows or contracts, as your lungs push out the carbon dioxide. There is a two-layered lining called the pleura. It lines your lungs and rib cage. This lining lubricates your chest. It reduces the friction caused by breathing. All of the parts of your respiratory system work together so that you can breathe and live. 26
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Your body's defenses against asbestos. Your breathing system has some good defenses against breathing in dusts that can hurt you. But the small asbestos fibers can overcome your body's natural defenses and make you sick years later. Here are some of your body's defenses against asbestos: Nose Hairs - dust and fibers get stuck in the hairs of your nose. You sneeze to get rid of it. You can blow out the large asbestos fibers. The smaller fibers travel on to your throat. Muco-ciliary Escalator - the cells in your windpipe are covered with tiny hairs called cilia (Silly - uh). These tiny hairs beat in an upward motion. There are other cells in your windpipe that make mucus, a sticky gum - like substance. Some of the asbestos fibers stick to the mucus. The cilia wave upward, slowly pushing the fibers up to the back of your throat. Then you will either cough them out or swallow them. Cigarette smoke paralyzes the tiny hairs. It destroys one of your body' s important defenses against asbestos. You also swallow about a quart of mucus a day. If the mucus has asbestos fibers in it, then the fibers can lodge in your digestive system. Some of the smaller asbestos fibers travel into the branches of your breathing system. They then lodge in your lungs or the lining of your lungs. They may even enter your bloodstream. White Blood Cells (Phagocytes) and Scar Formation - this part of your immune system tries to eat up asbestos, just like it would eat up a germ. But the asbestos fibers either kill or outlive the white blood cells. The dead cells wrap around the asbestos fibers and your body forms scar tissue. This scar tissue on your alveoli (air sacs) is called fibrosis. The scarring thickens the walls of the alveoli and makes it difficult for oxygen to reach the blood. This scarring can become asbestosis. 28
Diseases Caused by Asbestos Disease Signs & Symptoms Treatment of Symptoms Asbestosis 10-20 yrs. to develop Lung Cancer 20-30 yrs. to develop Mesothelioma 30-50 yrs. to develop Digestive System Cancers 20-30 yrs. to develop Severely Short of Breath Dry Cough Feeling Very Tired Clubbed Fingers Short of Breath Constant Cough Feeling Tired and Weak Deep Chest Pain Cough up Blood Weight Loss Chest (pleural): lodges in the lining of the chest. Short of breath. Dull chest pain under the ribs. Swelling in chest. Belly (peritoneal): lodges in the lining of the abdomen. Swollen stomach Belly pain Weight loss Change in bowel patterns Blood in bowel movement Feeling Tired Weight Loss Treatment, but no cure. Stop working with asbestos. Stop smoking Get flu shots Treat all chest colds quickly. Treatments: surgery, radiation, and chemotherapy. 9% to 13% live for 5 years or more. Poor cure rate. Smoking multiplies your risk of getting lung cancer. STOP SMOKING! No treatment, some medical procedures for pain reduction. Will kill you in 6 months to 2 years after it is discovered. A few people have lived up to 5 years. Treatment: Surgery, Radiation, and Chemotherapy. Chances of living good if colon cancer found early. 80% to 90% live for 5 years or more. 29
Asbestosis (as-bes-to-sis) - a scarring of the lungs that can weaken and destroy your lungs ("white lung"). Asbestosis is not a cancer. It is a progressive disease. This means that scars keep forming in your lungs even after you stop asbestos exposure. When you breathe in asbestos fibers, they go deep into your lungs. Asbestos fibers are skinny, sharp, and jagged. They lodge in your lungs like tiny needles. Your body forms scars around them. The scarred lungs cannot get oxygen into your blood any more. The scarred areas of your lungs become useless. You have to breathe more often to get the oxygen you need. You become short of breath. (See the chart on the previous page for other symptoms) When you have asbestosis, your heart (your body' s pump) has to work much harder to get blood with enough oxygen to all the cells of your body. Many people with asbestosis die from heart attacks or heart failure because their hearts are overworked. Other people with asbestosis die of pneumonia, other infections, and respiratory failure, because asbestosis weakens them. Asbestosis is dose - related. The more asbestos you breathe, the more likely you are to get asbestosis. The more asbestos you breathe, the more severe the asbestosis will be. What is cancer? Many cancers are linked to asbestos exposure. Cancer is a name for a large group of diseases, which affect many different parts of the body. All cancers are made up of cells, which are not normal. These abnormal cancer cells grow rapidly out of control. They either remain in one area of the body and form a tumor or they spread to other areas of the body where they cause harm. Mesothelioma (mes-o-the-lee-o-ma) - a rare but deadly cancer - It is the different asbestos disease. Low levels of asbestos exposure can cause mesothelioma. It is estimated that less than 2% of asbestos worker deaths are caused by mesothelioma. Mesothelioma is a difficult disease to identify or diagnose. It is often not identified or is misdiagnosed. It is difficult to know how rare this disease really is. There are two kinds of mesothelioma: (1) Pleural Mesothelioma is a cancer that attacks the 2-layered pleural lining of the chest. 30
(2) Peritoneal Mesothelioma is a cancer that attacks the lining of the abdomen (belly). Most of the time Mesothelioma is caused by exposure to asbestos. Because of this, it is called a "marker" disease. This means that if someone has Mesothelioma, you can be pretty sure that they have been exposed to asbestos. Mesothelioma has been directly linked to asbestos exposure in at least 96% of the documented cases. There is no cure or effective treatment for Mesothelioma. It kills most people 6 months to 2 years after it is detected. Some people have lived as long as 5 years after their Mesothelioma was discovered. Mesothelioma has the longest latency period of all the asbestos diseases. The latency period for Mesothelioma is between 30 and 50 years. Children are the exception to the long latency period rule. A child' s body grows at a rapid rate. The latency period for a child is much shorter than for an adult. It may only take a very small amount of asbestos to give you Mesothelioma. Mesothelioma has killed asbestos worker' s wives, children, and even pet dogs. This is why you must not take asbestos home with you on your clothes. We say that Mesothelioma is NOT dose-related because low levels of asbestos exposure can cause this disease. There is no amount of asbestos that has been proven to be safe. Lung cancer Smoking multiplies your chances of getting lung cancer. Asbestos is a strong cancer - causing substance. Lung cancer is the biggest killer of all the asbestos diseases. Between 20% and 25% of asbestos worker deaths are caused by lung cancer. Lung cancer is cancer that lodges in the lung. It is dose related. Asbestos and smoking together are a deadly mix. The risk of getting lung cancer is not just the risk from smoking plus the risk from asbestos. It is the risk from smoking times the risk from asbestos! Prevent lung cancer: quit smoking and avoid exposure! What does all this mean? Lung cancer has the highest death rate of all the asbestos diseases. An asbestos worker who does not smoke is about 5 times more likely to get lung cancer than someone who does not work with asbestos. 31
A smoker who does not work with asbestos is about 10 to 22 times more likely than a nonsmoker to get lung cancer. So if all you did was smoke and never worked with asbestos, your risk of lung cancer would be 4 times more than an asbestos worker who never smoked. But, when you combine smoking and asbestos exposure, the combination is deadly. Asbestos workers who smoke are about 50 to 90 times more likely to get lung cancer. Lung cancer is a horrible disease. Your probability of a cure is only 11%. It is a disease that drains you and your loved ones emotionally and financially for a long time. The best thing you can do is to prevent this disease. Quit smoking and avoid asbestos exposure. If you are a smoker, get help to quit. Nicotine addiction and the pleasure of smoking make smoking a very difficult habit to break. How difficult a habit (or addiction) is to break can be measured. It is measured by the percent of relapse. Relapse means that you tried to stop smoking, but started again. Let' s say you stopped smoking for 30 days. Then onday 31, you picked up a cigarette and by day 40 you were smoking a pack a day again. You just had a relapse. About 70% of smokers who quit, relapse in the first three months. The rate of relapse is about the same for those who are addicted to heroin and those who are alcoholics. There is hope. Surveys show that most people who keep trying to quit finally succeed. There are many programs that can help you stop smoking. Please get help. Your local chapter of the American Lung Association can give you a list of where you can go to get help. 32
Other cancers Many other cancers are more often found in asbestos workers then in people who don' t work with asbestos. These cancers include cancers of the digestive system, i.e. cancer in the mouth, the esophagus (the tube from your mouth to your stomach), the stomach, and the lower intestine (colon and rectum). A doctor may be able to successfully treat colon and rectum cancer if the doctor finds it early. Digestive system cancers are dose -related. Other Signs of Asbestos Exposure Pleural Plaques are found in asbestos workers. They are lesions that grow slowly. They are made of fibrous tissue that can harden. They are found in the lining of the lungs. You may not even know you have pleural plaques until you get a chest X-ray. You may never have a problem with them. Always alert your doctor about them. If you have these plaques, your risk of lung cancer doubles. You may also develop asbestosis, which is a scarring of the lining of the lungs. Smoking does not cause Pleural plaques. Pleural Effusion is fluid between the chest wall and the lungs. Pleural Thickening is a thickening of the lining of the chest or lung cavity. Asbestos Bodies are asbestos fibers that have been encapsulated by your body. They are found when a doctor takes a sample of lung tissue, stains it, and looks at it under a microscope. Asbestos Warts are skin lesions caused by asbestos irritation. Asbestos is not known to enter the body through the skin If you protect yourself and keep asbestos out of the air, you lower your odds of getting sick! 33
ASBESTOS DISEASES Key Facts Asbestos can kill you unless you protect yourself Asbestos is silent and deadly. You do not know it is there. You cannot see, hear, feel, taste, smell or sense the small asbestos fibers that enter your body. When asbestos is in the air, it gets into your body when you breathe and when you swallow. Diseases Asbestos causes four types of disease: 1. Asbestosis, "white lung" - a scarring of the lungs which makes it hard to breathe. 2. Mesothelioma, the "marker disease" - a cancer of the lining of the lungs or the lining of the belly. It is rare but it always kills. It is not dose-related. 3. Lung Cancer (also caused by smoking) is the biggest killer of all the asbestos diseases. Asbestos workers who smoke are 50 to 90 times more likely to get lung cancer then the general public. 4. Other Cancers - cancers of the belly or gut. Dose-related The more asbestos fibers you breathe or swallow, the more likely you are to get sick. This is called a dose relationship. The higher the amount of asbestos, the greater your chances of getting an asbestos disease. Mesothelioma is the exception. Latency period All of the asbestos diseases have a latency period. The latency period is the time gap between when you take the asbestos into your body and when you become sick. For asbestos diseases the latency period is between 10 and 40 years long. 34
Discussion questions 1. Why is it important to know about the health hazards of asbestos? 2. When is asbestos dangerous? 3. Is there a safe level of asbestos exposure? 4. How do we know that asbestos causes diseases that can kill? For more information *OSHA Asbestos Standard, 29 CFR 1926.1101. American Lung Association White Lung Association Sourcebook on Asbestos Diseases, George A. Peters and Barbara J. Peters, Garland STPM Press, 1980. Asbestos Disease Update, George A. Peters and Barbara J. Peters, Garland Publishing, 1989. NIOSH - OSHA Asbestos Work Group, "Workplace Exposure to Asbestos," DHHS (NIOSH) Publication No. 81-103. Asbestiform Fibers: Nonoccupational Health Risks, National Research Council, National Academy Press, 1984. *Your instructor has a copy of this publication for you to look at. 35
Asbestos diseases exercise This is not a test. It is an exercise. Use it to see for yourself how well you understand the material in the chapter? 1. How do asbestos fibers enter your body? 2. What is a latency period? 3. What does dose-related mean? 4. What are the diseases that asbestos causes? 5. How do asbestos exposure and smoking cigarettes mix? 36
ASBESTOS DISEASES -Part 2: Medical Exams In this chapter you will learn: What happens during a medical exam. Why you need a medical exam. When to have a medical exam. About the medical records your employer has to keep. MEDICAL EXAMS A doctor can help you find medical problems early. If you work with asbestos, you must have a special kind of medical exam called medical surveillance (medical monitoring). You have to have a medical exam before you start work and once a year thereafter. The doctor who gives you medical surveillance is a doctor whose specialty is occupational diseases. Your occupation or job causes occupational diseases. Asbestos causes occupational disease. Medical exams are required by the State Employees Asbestos Program and OSHA law under certain conditions. You must have a baseline (pre-placement) exam before you start to work. The baseline exam documents your health and your fitness for duty (including your ability to wear a respirator). It is the first medical exam that you get with the job. It is a long and complete exam that usually takes 2-3 hours. Each year after that you have a shorter medical exam. The doctor looks for any changes in your health since your first exam. With the yearly exam, a disease can be found early. The earlier an asbestos disease is found the better your chances for treatment. Be sure that you and your workers get these exams. They can save lives. Your Agency pays for these exams. Initial asbestos medical exams will have at least these four parts: 1. A work/medical history, to see if you' ve ever worked with materials that might have damaged your lungs. These include coal dust, cotton fibers, silica or asbestos. This is a long questionnaire. It asks you about what kind of work you' ve done in the past. It asks you about your smoking habits. It asks you about any lung diseases you have had. In addition, there will be questions about respirator and protective equipment usage. 37
There are certain questions on the questionnaire that OSHA requires. These questions must be asked. They can be found in Appendix D of the OSHA Standards 29 CFR 1926.1101. The employer must include these questions on the questionnaire. He or she cannot substitute his/her own. The questionnaire is about 20 pages long. 2. A general physical exam that concentrates on your lungs, heart, and stomach. This is to see if your lungs, heart, and stomach are normal and in good shape. In your baseline exam, the doctor will document your health and state how healthy you are before you work with asbestos. It is also to make sure that you don' t have any medical problems that asbestos would make worse. After checking your lungs and heart, the doctor will tell if you can wear a respirator (a mask that protects you from asbestos,) and if you can work with asbestos. In the yearly exam, the doctor looks for any signs (symptoms) of asbestosis, lung cancer, or other asbestos diseases. For example, the doctor will listen for "rales" or crackling sounds in your lungs, which may be a sign that you are getting asbestosis. 3. A breathing test, called a Pulmonary Function Test (PFT). A breathing test makes sure that your lungs are not damaged before you begin work. It is used as a comparison for later tests. You blow out through a tube using your mouth. Your nose is held shut so that you do not breathe through it. All the air that your lungs push out is measured. A meter reads how much air you can blow out in one second. The breathing test is a very simple, safe test. This test often gives the first clue that your lungs are being hurt by asbestos. Remember, it is important to find asbestos diseases early. Smoking, a heavy meal, or a bad cold may also result in poor pulmonary function test results. 38
4. A chest x-ray to make sure that your lungs are not damaged before you begin to work. It is compared to future x-rays to find any changes that take place in your lungs as you work with asbestos over the years. The need for a chest x-ray is based on your doctor' s decision. It is usually part of the baseline examination. The x-ray must be checked by a doctor with experience in reading x- rays of work-related lung diseases. Doctors who are trained and certified to read x-rays for asbestos workers are called "B readers". Additional tests may be ordered at the Dr. s discretion. When must workers have medical exams? You and your workers must have a medical exam before you start Level II work and then: The State Employees Asbestos Program will provide exams annually thereafter as well as give you one when you leave State service. The State Employees Asbestos Program requires medical exams whenever there is any potential for asbestos exposure For Non-Level II workers in the State of Maryland, COMAR law says you must have medical exams before you do any asbestos work. For Non-Level II employees the OSHA law says that your employer must provide medical exams when: 1. Medical exams are required whenever you are engaged in Class I, II, or III asbestos work more than 30 days per year. You will learn about these classes of work in later sections of this manual. 39
2. Medical exams are required whenever you are exposed to asbestos above the permissible exposure or excursion limits. The permissible exposure limit is 0.1 fibers per cubic centimeter. At the Permissible Exposure Level, the average number of fibers sampled over an eight-hour period is 0.1 f/cc. The excursion Limit is 1 fiber per cubic centimeter (f/cc). The Excursion Limit of 1 f/cc is the average number of fibers sampled over a 30-minute period. 3. Medical exams are required whenever you must wear a negative pressure respirator. You will learn about negative pressure respirators in the next section. A doctor must medically clear you before you can wear a respirator. This is to make sure that your heart and lungs can handle the strain of wearing a respirator. Why are medical exams required? Yearly medical exams are the quickest way to tell if asbestos is making you sick. The exams are for finding asbestos diseases early and to make sure that you can safely wear a respirator. Remember that most asbestos related diseases get worse, the more asbestos you breathe. It' s important to find these diseases as early as possible so that treatment will be more effective. Medical exams are used as evidence for Workers' Compensation. Workers' Compensation is a no-fault insurance system. You must prove that you got your disease or injury on the job. Medical exams also help doctors do research on asbestos diseases, so we can prevent them in the future. The first exam shows a baseline - how healthy you were when you started work. Yearly exams can catch a problem when it first starts. The yearly exam is a little shorter than the first one. It also includes 3 to 4 parts: 1. A questionnaire every year. This is also an official OSHA (Occupational Safety & Health Administration) questionnaire. It asks about your work experience, smoking habits, and lung diseases over the past year. 2. A general physical exam each year, just like the first year. 3. Pulmonary Function Test (PFT' s) each year, just like the first year. 4. A chest X-ray every 5 years (more often if you' re older and /or have worked with asbestos for more than 10 years, less often if the doctor says so). You do not need to have a chest X-ray every year. The table below is a recommended (not required) schedule. The physician will also use his/her professional judgment when deciding the need for a chest x-ray. 40
RECOMMENDED SCHEDULE FOR CHEST X-RAYS Years Since First Worked With Asbestos Age Now 18-35 Age Now 36-45 Age Now Over 45 0 to 10 Years Every 5 Years Every 5 Years Every 5 Years More Than 10 Years Every 5 years Every 2 Years Once A Year Many people' s lives have been saved by these test s. Employers are required by OSHA law to provide these tests for their workers. The tests are not to punish you for getting sick on the job. They are to keep you from getting sicker if asbestos begins to make you sick. It is important to note that medical surveillance is not preventative. Once an asbestos- related disease is found, the person has the disease. The earlier most asbestos diseases are found the better your chances for treatment. Medical exams are also very important if you ever have to file for workers' compensation or disability. The best way to prevent asbestos related diseases is to reduce exposure by following safe work practices and wearing protective equipment. After your medical exam, the doctor writes a report and gives a copy to you. The written report is confidential between the doctor and the patient (worker/supervisor). The doctor only tells your employer whether you are able to wear a respirator or not and if there are any limitations on your work. You may also receive a report on the status of your employees, but again, it will only say whether the employees can wear a respirator and if there are any limitations on their work Your employer pays for the doctor. The law requires the employer to inform the doctor of the required and recommended tests for the medical exam. The employer must also inform the doctor not to report any findings that are not related to your ability to wear a respirator or work with asbestos. You are the doctor' s patient. By law, the doctor must not tell your employer anything about your health unless it will prevent you from doing asbestos work. You must be given a copy of the doctor' s report within 30 days after getting the exam. RECORDS Your employer must keep your medical records for 30 years after you leave the job. You have the right to get copies of your medical records from the doctor. You may want the information from your medical records 20-30 years from now. YOU MAY WISH TO GET A COPY OF YOUR ENTIRE MEDICAL RECORD AND KEEP IT IN A SAFE 41
PLACE. A safe deposit box is a good place to keep them. Thirty years from now, you may need these records, and they need to be in a place where you can find them. OSHA Standard 29CFR 1910.1020 covers the employee s right of access to medical and exposure monitoring records. They must be informed of these rights and how to access their records on an annual basis. If you wish to obtain a copy of your medical records for yourself or a designated representative, you should call the State Employees Asbestos Program office to obtain a medical release form to be presented to the clinic. Beyond medical exams There are some things you can do to lower your risk of getting cancer from working with asbestos: 1. Always remember how dangerous asbestos can be. The law requires your employer to give you the right equipment and protective gear but you need to do a good job using the equipment and protective gear. Following the safe work practices that you learn in this course protects you and everyone else around you. Keep asbestos out of the air. Use the right equipment. Work safely. Protect yourself with the right respirator and disposable suit. 2. Quit smoking. There are many places you can go for help to quit smoking. Encourage others to quit smoking. 3. Inform any doctor you visit that you have worked with asbestos. Tell the doctor the year when you started working with asbestos. Tell the doctor how long you worked with it. Asbestos diseases have a latency period of ten to forty years. Tell the doctor about all the diseases that asbestos causes and ask the doctor to look for those diseases. 4. Even after you stop working with asbestos, you should have a yearly exam. (At this time the State Employees Asbestos Program will provide these for you if you request them). This is even more important if you worked with asbestos over 10 years ago. 5. You have the right to know what you are working with. Work with your agency, co-workers, and union, to ensure that you get the information that you need. 42
MEDICAL EXAMS Key Facts Asbestos workers have to have medical surveillance, a special kind of doctor' s check-up: 1. before they start work, 2. once a year Medical exams are the quickest way to tell if asbestos is making you sick. A medical exam includes: First Exam Long questionnaire General physical (lung, heart, stomach) Lung test [Pulmonary Function Test (PFT)] ChestX-ray Every Year Short questionnaire General physical Lung test (PFT) Chest X-ray at the discretion of the physician. Your employer must ensure that you get a copy of the results of your medical exam within 30 days after the exam. Your employer must keep your medical records for over 30 years. 43
Discussion questions 1. What good is medical surveillance? 2. Why is it important to find asbestos diseases early? 5. Why is it important to have an asbestos medical exam before doing any asbestos work? 4. When are medical exams required? 5. List the required parts of an asbestos medical exam. 6. What is the baseline exam? 7. How long must the employer keep the medical records? 8. Why keep copies of your medical records? 9. What do I do when I am no longer working with asbestos and do not get yearly medical surveillance? For more information *OSHA Asbestos Standard, 29 CFR 1926.1101. Stop smoking Information: Call your local chapter of the American Lung Association Call your local chapter of the American Cancer Society Look under the yellow pages under "Smoking". *Your instructor has a copy of this publication for you to look at. 44
CHAPTER 3 LAWS In this chapter you will learn about: LAWS Regulations and how they are enforced. The differences between State and Federal asbestos laws. The government offices that cover asbestos removal. The laws that protect you on the job. The laws that protect the environment on the job. The law is one tool for a safer and healthier job. However, the protection furnished by occupational and environmental safety laws depends extensively on how well people comply with these provisions. When it comes to asbestos and other hazardous materials, substantial compliance is not enough. Everyone must do his or her part. For example, if just one individual fails to comply with the requirements, he/she could create conditions that endanger the entire work crew or could contaminate the environment. Thus, it is extremely important for everyone working with asbestos to know the safety and health requirements. Each person must follow them to the letter and should insist that fellow workers also follow the requirements. Asbestos project supervisors have an ethical and legal responsibility to ensure that work proceeds in a safe manner. The minimum standards for safe asbestos work are prescribed in regulations set forth by OSHA (the Occupational Safety and Health Administration) and EPA (the Environmental Protection Agency). These regulations were promulgated on statutes enacted by Congress, and carry enforcement penalties for non-compliance. There are also State of Maryland Regulations based on laws enacted by the Maryland General Assembly, which both complement and supplement Federal Regulations. As stated before, these regulations set the minimum requirements to protect workers and the environment from asbestos hazards. They also serve as a competency standard for supervisors. For example, OSHA s asbestos regulations specifically requir e supervisors to be a Competent Person. By definition, a Competent Person is a knowledgeable person able to identify asbestos and associated safety hazards, prescribe control measures to protect workers and the environment. In addition, to be a competent person, the individual must also have the authority to take prompt corrective actions to eliminate hazards that may arise during the project. It is important to note that the supervisor, as a competent person, may be judged by how well he/she protected workers and the environment, not necessarily on the question did 45
he/she just follows the regulations. These competency issues are likely to be decided by a jury during a tort liability trial sometime in the future, with the consequences much more severe than any penalty levied by regulatory enforcement officials. It is also important for supervisors to realize that there are several serious safety hazards at the worksite besides asbestos. These could include heat stress, electrical hazards, fall hazards, confined spaces, lifting and material handling hazards, among others. As a supervisor, you need to be competent in addressing these other safety concerns. Before any work commences on an asbestos project, you should assess all the potential safety hazards on the job site, and be sure that appropriate control measures are implemented according to established safety practices in the industry. It is recommended that a copy of the OSHA regulation 29 CFR1926 be checked as part of the project planning process. 46
ASBESTOS STANDARDS and REGULATIONS Occupational Safety and Health (OSHA) Construction Standards 29 CFR 1926.1101 ASBESTOS Replaced 1926.58 on August 10, 1994; MOSH adoption Jan. 30, 1995. Applies to: [(a)] (1) removal or encapsulation of materials containing asbestos; (2) construction, alteration, repair, maintenance, or renovation of structures, substrates, or portions thereof, that contain asbestos; (3) asbestos spill/emergency cleanup; (4) transportation, disposal, storage, containment of, and housekeeping activities involving asbestos or products containing asbestos on the site or location at which construction activities are performed. New Definitions: [(b)] * Building/facility owner: legal entity, including lessee, which exercises control over management and record keeping functions related to the building or facility. * Disturbance: a Class III operation where contact with ACM or PACM (either accidental or intentional) is or could be released but amount is no more than what will fill a standard size glove bag or waste bag (60 united inches). {NOTE: If amount above is exceeded, the operation becomes a Class I or II job, depending on the type of asbestos disturbed (TSI/Surfacing or Misc.)}. * PACM: Presumed Asbestos Containing Material. * Competent person training: If Class I or II work: Supervisor training (5 day); If Class III or IV must have O & M course training (2 day). (Class IV work is not allowed in MD as OSHA defines it) 47
Permissible Exposure Limits (PELs) of: [(c)] * 0.1 f/cc, for an 8-hour Time-Weighted Average (TWA); and 1.0 f/cc over a 30-minute sampling period called Excursion Limit (EL). No more action limit (AL). Regulated Area: [(e)] * an area established and demarcated by the employer where Class I, II, III work is being conducted and any adjourning areas where debris and waste accumulate, * where airborne concentrations are or may exceed the PELs, * only authorized persons allowed, * must wear an appropriate respirator, * have appropriate sign and demarcation tape, * no eating, drinking, smoking, chewing tobacco or gum, or applying of cosmetics. NOTE: standard does not address Class IV operations as regulated areas but would be if above PELs. Competent Person: [(o)] * Employer must designate such a person and must have the qualifications and authority to ensure worker safety and health under 1926.20 (b)(2) through 1926.32, which includes: - accident prevention program, which includes frequent and regular on-site inspections; - education and training program in the recognition and avoidance of unsafe conditions and the regulations applicable to the work environment; safe handling, personal hygiene, and personal protective practices; - confined space entry procedures; - housekeeping; - illumination; - fire protection and prevention; - first aid procedures; and * fromthe ASBESTOS standard: - inspect Class I site at least once per shift or at employee' s request, - inspect Class II, III, and IV at sufficient enough intervals to assess whether conditions have changed and at an employee' s request, - set up regulated area, enclosure, or other containment, - supervise employee exposure monitoring and ensure it is conducted correctly, 48
- ensure employees in containment or using glove bags are wearing respirators and protective clothing, - ensure through on-site inspections that engineering controls are working properly and employees are using proper work practices, - ensure that employees are using the hygiene facilities and decontamination procedures, and - ensure notification requirements are met. Need for Initial Exposure Assessment (IEA) (personal sampling): Must be conducted by a "competent person" immediately before or at the initiation of the operation. [(f)(2)] [(b)] *Exception- Class I jobs must assume > TWA or EL until exposure monitoring conducted and shows < TWA/EL. Negative Exposure Assessment (NEA) [(f)(2)(iii)] For any one specific job, the employer may demonstrate exposures below PELs from data, which is... A. Objective data demonstrating that product/material or activity cannot release fibers exceeding PELs; or B. Previous monitoring (below PELs) within last 12 months and the data obtained closely resembles the process, type of material, control methods, work practices, environmental conditions, and training and experience of employees. From this data, there must be a high degree of certainty that exposures will be under the TWA and EL; or C. Results of initial breathing zone monitoring of current job are under the PELs and are representative of entire job. CLASSES OF WORK: Class I: activities involving removal of Thermal System Insulation and surfacing ACM or PACM (Presumed Asbestos Containing Material); [(g)(4)] *** respirator must be provided and required to be used *** [(h)]...if no negative exposure assessment must provide a full face, supplied-air respirator operated in the pressure demand mode and equipped with an auxiliary, positive-pressure, self-contained breathing apparatus; 49
***but if exposures are under 1.0 f/cc for an 8-hour TWA, a tight-fitting, full-face piece, powered-air purifying respirator (PAPR) may be used. DECON unit: > 10 ft 2 or 25 linear feet of TSI or surfacing is being removed, a 3-stage unit (connected equipment, shower, & clean rooms) is required; When < 10/25, or where exposures > PEL or no negative exposure assessment shall establish an equipment room or area adjacent to regulated area. Protective coveralls and gloves if over TWA/EL or over 10 SF or 25 LF. NOTE: If the removal is a glove bag operation, there must be two employees present to perform this activity. Class II: activities involving removal of ACM other than TSI or surfacing material if not done in an intact state. [(g)(7)] Examples- removal of wallboard, floor tile and sheeting, roofing, siding shingles, mastics, cutting into fire doors or privy doors. -respirator must be provided and required usage if asbestos is not removed in a substantially intact state, or not using wet methods, or no negative exposure assessment. [(h)(1)] Vinyl and asphalt flooring - no sanding, must use HEPA vac, resilient sheeting cutting with wetting at the snip point and wetting during delamination. Rip-ups prohibited. Scraping of adhesive residue and/or backing using wet methods. Removal of intact tiles only unless can show not possible. If can be removed intact by heating, wet method can be omitted. [(g)(8)(i)] Care of asbestos-containing flooring material: (1910 - General Industry) Stripping conducted using low abrasive pad, < 300-rpm buffer, and wet methods. Burnishing or dry buffing performed only when enough finish so pad does not contact flooring material. 08/26/04 50
Siding shingles or panels - no breaking, cutting, or abrading unless can demonstrate other methods can not be used. Wetting with amended water. Immediately wrapped or bagged. Disposed at end of each workday. [(g)(8)(iii)] Gaskets - Removed within glovebag if visibly deteriorated or unlikely to be removed intact. Thoroughly wetted with amended water including residue. Immediately placed in disposal container. [(g)(8)(iv)] Class III: repair and maintenance operations where ACM including TSI or surfacing is likely to be disturbed (either accidentally or intentionally) and contact can releases fibers. [(g)(9)] -disturbance is an amount that does not exceed amount contained in one standard-sized glove bag or waste bag (1/3 to 1/2 full) and in no event shall exceed 60 inches in length and width. -required to use wet methods and to extent feasible, local exhaust ventilation. -if no sampling data or over PEL' s or no negative exposure assessment, must use impermeable drop cloths and plastic barriers or equivalent and isolate by using mini-enclosures or Glovebags. Class IV: Housekeeping (not cleanup) that takes place in an area after a Class I, II, or III job has been completed. Does not include picking up and bagging of asbestos debris/dust during Class I, II, or III operations. [ (g)(10)] NOTE: Class IV work is not allowed in MD as OSHA defines it! "Competent person" must evaluate work before being done to assure the work is not another class of work. -mandated to use wet methods, HEPA vacuums, and promptly clean up debris containing ACM or PACM. -if TSI or surfacing is accessible during housekeeping operations, other waste and debris is to be considered asbestos containing (contaminated). Requirements when exposures over the PEL or EL or without a Negative Exposure Assessment: -regulated area with appropriate sign and demarcation. -respiratory protection with specific Class and emergency use requirements. 08/26/04 51
-protective clothing with immediate repairs to rips and tears and competent person to examine once per work shift. -training, medical surveillance, record keeping. -competent person: designated by employer with qualifications and authority to ensure worker safety and health and perform inspections of the site. NOTE: If specific control measures not given, then must use... A. Use of HEPA vacuums, B. Wet methods unless infeasible due to hazards of electricity or slips or equipment malfunction, C. Prompt clean-up and disposal of debris in leak-tight containers, D. Local exhaust systems with HEPA filtration, E. Enclosure or isolation. Labels: affixed to all products containing asbestos and to containers containing asbestos. If feasible, installed asbestos products shall contain a visible label unless has been modified by a bonding agent, coating, binder, or other material and manufacturer can demonstrate that through use, handling, storage, processing, or disposal no release at PEL or EL will occur or < 1%. [(k)(7)] Previously installed PACM/ACM shall be clearly labeled or signs to notify employees of what materials containing PACM/ACM there are in their building and to entrances of mechanical rooms containing ACM/PACM. Signs may be used in lieu of labels if contain required label information. Training: Variable amounts according to Class of work. (k)(9)] Class I & II training equivalent to EPA' s 4-day asbestos abatement worker or 5-day for asbestos supervisor and both include 16 hours of "hands-on". Class III training equivalent to 16-hour Operations and Maintenance course for EPA. Class IV training equivalent to 2-hour awareness training course for EPA. NOTE: Every employee who works with a category of ACM material (roofing, flooring, siding, or Transite) containing asbestos shall receive additional training. 08/26/04 52
Housekeeping: [(l)] If using a vacuum, must be HEPA filtered. NO compressed air blow downs of area or tools. Medical Surveillance: [(m)] Program for employees for 30 or more days per year engaged in Class I, II, III work (Does NOT apply to Level II workers) or exposed at or above TWA or EL and wear negative-pressure respirators. NOTE: this does not apply in Maryland. There is no 30 day stipulation Initial examination conducted prior to assignment and at least annually thereafter. Building and Facility Owners must before work subject to this standard is begun: [(k)] * identify presence, location, and quantity of ACM or PACM at site. * notify in writing or personal communication: (A) prospective employers, (B) employees of employers, (C) tenants who occupy areas containing such materials. * post signs on mechanical room doors which identify type, location, and appropriate work practices to ensure will not disturb ACM/PACM. * affix labels or signs to notify employees of what materials contain ACM/PACM. 08/26/04 53
29 CFR 1910.134 RESPIRATORY PROTECTION Employer' s primary obligation is to control atmospheric contamination by feasible and accepted engineering control methods (for example, enclosure or confinement of the operation, general and local ventilation, or substitution of less toxic contaminants). When not feasible or while engineering controls are being implemented, appropriate respirators shall be used under the following requirements: 1) when necessary to protect the health of the employee, 2) applicable and suitable for the purpose intended, and 3) responsible for the establishment and maintenance of a respiratory protection program. Requirements for a minimal acceptable program: 1) written SOPs governing the selection and use..., 2) selected on the basis of the hazards to which worker is exposed, 3) instructed and trained in the proper use and limitations, including having it fitted properly, test its face-to-facepiece seal, and wear in a test atmosphere, 4) where practicable, should be assigned to individuals for exclusive use, 5) regularly cleaned and disinfected after each use, 6) stored in a convenient, clean, and sanitary location, 7) routinely inspected during cleaning, worn and deteriorated parts shall be replaced, according to the manufacturer s instructions 8) appropriate surveillance of work area conditions and degree of employee exposure or stress shall be implemented and maintained on an on-going basis, 9) regular inspections and evaluation to determine the continued effectiveness of the program shall be conducted, 10) must be medically evaluated to determine if physically able to work and wear respirator(s), considering the conditions in the environment in which the respirator will be worn, 11) only approved respirators shall be used and provide adequate protection from the hazard for which it was designed. 12) respirators must provide adequate protection from the hazard(s) for which they were designed. 08/26/04 54
13) the employer shall designate a program administrator who is qualified by appropriate training or experience that is commensurate with the complexity of the respiratory program to oversee the program and conduct the required evaluations of program effectiveness. 29 CFR 1910.1020 ACCESS TO EMPLOYEE EXPOSURE AND MEDICAL RECORDS - Provides employees and their designated representatives a right to relevant exposure and medical records. - Applies to general industry, maritime, and construction employers who make, maintain, contract for, or have access to employee exposure or medical records, or analyses thereof, pertaining to employees exposed to toxic substances or harmful physical agents. - "Access," means the right and opportunity to examine and copy. - "Designated representative" means any individual or organization to which an employee gives written authorization to exercise a right of access. - Employer has 15 days to respond to a request. - No charge for the first copy and only reasonable administrative cost for copies of the same record thereafter. - Upon an employee' s first entering into employment, and at least annually thereafter, each employer shall inform employees exposed to toxic substances or harmful physical agents of the following: (i) the existence, location, and availability of any records covered by this section; (ii) The person responsible for maintaining and providing access to records; and (iii) Each employee' s rights of access to these records. 55
29 CFR 1910.1200 HAZARD COMMUNICATION - Requires employers to develop, implement, and maintain a written Hazard Communication Program, which describes how the employer will inform employees of this law, its elements, and their rights. - Includes a list of chemicals which Maryland mandates being called CIL as noted above. Elements: Labels and other forms of warning: Every container, tank, or vessel must have a label identifying the hazardous ingredients and appropriate hazard warnings and manufacturer' s name, address, & phone. NOTE: THERE ARE EXCEPTIONS NOT COVERED HERE Material Safety Data Sheets: Must have an appropriate MSDS for every hazardous or toxic chemical on the site and available for employee access. Employee information and training: Must be informed of this law and its requirements, what operations where hazardous chemicals are present, and location of CIL, MSDSs, and written hazard communication program. Must be trained on: * methods and observations that may be used to detect the presence or release of hazardous chemicals (monitoring methods, visual and odor detection), * physical and health hazards, * procedures and practices to protect themselves from exposures. 56
Environmental Protection Agency (EPA) NATIONAL EMISSIONS STANDARD FOR HAZARDOUS AIR POLLUTANTS NESHAP (CAA) (40 CFR 61 Part M) (1990) (Revised from 1984) - Banned asbestos spray-applied insulation, pre-molded insulation (if friable), spray-applied decorative material. - No visible emissions to the outside. - Required notification 10 days prior to any removals, demolition, and renovations when asbestos amounts larger than 160 square feet or 260 linear feet or 35 cubic feet. - Removal and stripping of asbestos made adequately wet and no dropping, throwing, sliding, or otherwise disturbing. - Use of local exhaust and collection systems (negative air machines). - Only approved variances for nonwetted renovations and removals when there are safety and equipment damage concerns. - Defined Category I and II nonfriable RACM (regulated asbestos-containing material) in relation to demolition and renovation operations. Category I nonfriable ACM includes asbestos-containing packings, gaskets, resilient floor covering and asphalt roofing products. Category II nonfriable ACM includes any asbestos-containing material, not included in Category I nonfriable ACM, that when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure but mechanical forces during the course of demolition or renovation make them friable. Examples are cement siding shingles and Transite products. - Established standards for waste disposal for manufacturing, fabricating, demolition, renovation, and spraying operations. - Training requirements for onsite representatives. 57
ASBESTOS HAZARD EMERGENCY RESPONSE ACT AHERA (40 CFR Part 763, TSCA-- published October 30, 1987; effective December 14, 1987; implementation of MP- May 1989) - Applicable to private and public non profit schools through 12 th grade (including non-profit nurseries and pre-schools) required inspecting buildings for asbestos presence and condition. - Local Education Agency (LEA)- Designates a person to ensure implementation of the management plan for the school. - Must develop and implement updated asbestos management plans. - Operations/Maintenance Plan and implementation. - Abatement project planning/supervision. Abatement work done by certified persons who have attended 3-5 day training courses with EPA approval. - Annual notification to parents and occupants. - Specific training requirements for accredited persons. - Required periodic surveillance (every 6 months) and re-inspection (every 3 years) to monitor ACM left in schools. - EPA was to recommend to Congress to extend this regulation to public buildings. ASBESTOS MANUFACTURING, PROCESSING, IMPORTATION AND DISTRIBUTION PROHIBITIONS (TSCA) November 5, 1993 40 CFR Part 763 EPA issued a final rule under section 6 of the Toxic Substances Control Act (TSCA) prohibiting, at staged intervals, the future manufacture, importation, processing, and distribution in commerce of almost all asbestos-containing products, and required labeling of such products in the interim. On October 18, 1991, the United States Court of Appeals vacated and remanded most of the rule but left intact the portion that regulates products that were not being manufactured, produced, or imported when the rule was published on July 12, 1989. The six asbestos-containing product categories that are still subject to the prohibition are corrugated paper, rollboard, commercial paper, specialty paper, flooring felt, and new uses of asbestos. 58
The asbestos-containing product categories that are no longer subject to the rule are: asbestos-cement corrugated sheet, asbestos-cement flat sheet, asbestos clothing, pipeline wrap, roofing felt, vinyl-asbestos floor tile, asbestos-cement shingle, millboard, asbestoscement pipe, automatic transmission components, clutch facings, friction materials, disc brake pads, drum brake linings, brake blocks, gaskets, non-roofing coatings, and roof coatings. (Thus, it is possible that these products could contain asbestos, even today. Work involving these materials should proceed with caution. The supervisor should either have samples taken by an accredited asbestos building inspector or obtain reliable information on the content of these materials before performing work activities.) ASBESTOS SCHOOL HAZARD ABATEMENT REAUTHORIZATION ACT ASHARA Passed by Congress as an interim final rule and amended AHERA' s Model Accreditation Plan (Effective 10-3-94) - Clarifies the types of persons who must be accredited to work with asbestos in schools and expanded coverage to public and commercial buildings, i.e., individuals working in public and commercial buildings, must have AHERA accredited training as either a worker, supervisor, project designer, or building inspector, as applicable. - Increased the minimum number of hours of training, including additional hours of hands-on health & safety training for abatement workers and contractor/supervisors. - Congress expanded accreditation for inspectors, project designers, workers, contractors/supervisors working in schools, public and private building but did not enact accreditation requirements to management planners working in public and commercial buildings. - Exempted residential properties and dwellings with <10 units. - Defined "small-scale, short-duration activities," where less than 3 square or linear feet did not have to use accredited workers and over 3 square or linear feet would have to use accredited workers. - Certificates for accreditation required issuing provider' s name, address, and telephone number. - Civil penalty of $5000 per day per violation provisions. 59
State of Maryland EXECUTIVE ORDER 01.01.1987.22 - ASBESTOS OVERSIGHT COMMITTEE (AOC) (Rescinded Executive Order 01.01.1983.09) established the AOC and its responsibilities. Re-affirmed the State Asbestos Safety and Health Program and addressed each agency' s/facility' s requirements for identifying LEVEL I & II State employees 1 and maintaining programs of medical monitoring and training for these employees. AOC: assigned to "define the status of the asbestos situation in the State with respect to its employees and facilities and to develop and implement an asbestos management plan (AMP) and appropriate policies to effectively address and resolve any asbestos related issues." Established members from several Departments with at least quarterly meetings. Asbestos Management Plan (AMP): develop and update annually and consist of a safety, health, and equipment program, a training and medical monitoring program, and a statewide operations and maintenance program. Asbestos Abatement Plan: develop a prioritized schedule of abatement activities. Safety and Health Program: State employees required to work with asbestos only when incidental to their work and less than 160 square feet or 260 linear feet or 35 cubic feet of ACM per building per year. Exceeding shall be contracted out. Each department/agency shall implement and shall appoint a S&H Coordinator who appoints a S&H Committee. Each facility shall have a S&H Specialist be responsible for their program. Level II State employees can volunteer to remove Level I employees are those workers employed in positions with the potential for asbestos exposure because of work-related activities or location, but who are not required to break, cut into, tear out or otherwise disturb asbestos or asbestos-containing materials. Level II employees are those workers employed in positions whose job activities may cause them to break, cut into, tear out, or otherwise disturb asbestos-containing materials, or who must work in areas where this activity takes place. 60
ACM if requirements of training, medical monitoring, and PPE usage is in order but only if it is under the 160/260/35 limits for the building. Incentive pay for working with asbestos. Equipment: provide employees with appropriate respiratory protection [(1/2 face for automotive workers) (PAPR, or Type C, pressure-demand, supplied-air for other designations)] and protective clothing while performing Level II-type activities. Medical Monitoring and Training: Employees agreeing to work in positions which involve incidental exposure to asbestos shall participate in this monitoring program after successfully completing a formal asbestos training program. Operations and Maintenance Program: (within the AMP) contains a procedure to locate and identify asbestos in State buildings, and to assess its condition and type; a statewide project schedule for abatement projects; a procedure for performing recurrent surveys and inspections to update existing conditions, and guidelines for preparation and prioritization of contract removals with outside contractors. COMAR 26.11.21 CONTROL OF ASBESTOS Updated in (1998) - Applies to all business entities and local governments. - State agencies/facilities are exempt from its requirements as per Executive Order however; asbestos work practices performed by State Facilities must be equal to or better than the State regulations. - Defines "Operations and maintenance" as removal, encapsulation or disturbance of friable ACM of less than 10 ft 2 or 20 linear feet and associated with small repairs or maintenance. - Licensed remover must notify MDE Air & Radiation Management Admin. (ARMA) in writing for project > O & M. - Requires licensing for entity engaging in an asbestos project. - Workers within preceding year must be medically examined to determine ability to wear a respirator. - Specific sign requirements for > NESHAP with posting for 3 days prior to starting and placement outside of all entrances and exits. Must display startup and anticipated completion dates, posting date, and complaint information and phone number to ARMA. 61
- Specific air monitoring requirements of 1 per room and 1 per room size/volume. After cleaning and with barriers still up; send final written results to ARMA within 24 hours after receiving. - Use of negative-pressure systems with at least 4 air changes per hour. - Bag labeling to show license number, date of sealing, & where generated. - Copy of disposal receipt or record of disposal to MDE within 10 days showing appropriate facility and date. - Maintain records concerning each project for 6 years. - Licensing application, fee, and revocation/suspension requirements. - Safety & Health training course requirements. COMAR 26.11.23 SCHOOL ASBESTOS ACCREDITATION OF INDIVIDUALS AND APPROVAL OF TRAINING COURSES (Updated in 1998) - Applies to individuals performing asbestos projects in Maryland schools and public and commercial buildings and to persons applying for approval of training for asbestos occupations. - Establishes training requirements for accreditation of specific types of disciplines for individuals working-with-asbestos. - Establishes fees for training providers' appl ication. - Requires MD photo ID card to work in Md. - Establishes means to suspend or revoke a training course; and to decertify accredited persons. LABOR AND EMPLOYMENT ARTICLE TITLE 5. OCCUPATIONAL SAFETY AND HEALTH COMAR 09.12.31 ACCESS TO INFORMATION ABOUT HAZARDOUS AND TOXIC SUBSTANCES Employer is required to generate and maintain a Chemical Information List (CIL) that lists the hazardous and toxic substances that an employee is exposed or potentially exposed. Lists the chemicals alphabetically by common name, includes their chemicals name(s), and where it is found on the worksite. Update every 2 years. Copy sent to MDE initially and upon each updating. Each employee has a right of access to the CIL within 1 day for viewing and 5 days for a copy. 62
Applies only to construction work Defines a confined space as a space: COMAR 09.12.35 CONFINED SPACES (1) Having limited means of entry or egress; (2) So enclosed that adequate dilution ventilation is not obtained by: a. Natural air movement, or b. Mechanically induced movement; and (3) Subject to: a. The accumulation of toxic or combustible agents, or b. An oxygen deficiency If determined to be a confined space: (1) a blind or other device capable of ensuring complete closure must block lines entering the CS that contains a harmful agent. (2) there must be Lock out/tag out (LOTO) on electrical service equipment. (3) you must test the internal atmosphere for oxygen deficiency first, thentest for the combustible gases and any other potential air contaminants. (4) you must provide safe lighting, rescue equipment, employees trained in rescue procedures and CPR, and maintain constant communication with employees inside the CS, and have written emergency rescue procedures. NOTE: There is a Federal OSHA Permit-Required Confined Spaces standard (29 CFR 1910.146) for General Industry operations. In an attempt to ascertain what standard applies, the COMAR regulation would apply if the work being done was a construction operation. Asbestos being removed from within a confined space would fall under the COMAR regulation. If an employee entered a utility/steam tunnel to turn off a valve, the permit-required standard would apply if it met that standard' s confined space criteria requirements. To be a permit-required confined space it must have one or more of the following characteristics: (1) contains or has the potential to contain a hazardous atmosphere, (2) contains a material that has the potential for engulfing an entrant, (3) has an internal configuration that might cause an entrant to be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section, and/or (4) contains any other recognized serious safety or health hazards. 63
OSHA EXERCISE (To be used with a copy of the OSHA Asbestos Standard 29CFR1926.1101) 1. What is the 8 Hour Time Weighted Average Permissible Exposure Limit for asbestos? 2. What is the Excursion Limit for asbestos? 3. When are regulated areas required? 4. List five things that must be done every time a regulated work area is set up. 5. What does a competent person do on an asbestos job? 6. What is a negative exposure assessment? 7. How is the negative exposure assessment determined? 64
8. List four things you must always do to keep asbestos out of the air. 9. According to the OSHA standard, when do you have to wear a respirator? 10. When does an airline respirator have to be used? 11. What happens if you can t wear a respirator? 12. What are the three rooms in a decon? 13. Name two duties of the Building or Facility owner. 14. Where do warning signs and labels need to be posted? 65
15. Name three unacceptable methods to remove resilient sheeting or floor tiles. 16. How long does your employer have to keep your records? 17. How many people are required to perform a glovebag job for Class I work? 18. How must Class III work be performed? 66
DISCUSSION QUESTIONS 1. WHY DO THE FEDERAL GOVERNMENT AND STATES BOTH HAVE LAWS ABOUT ASBESTOS? 2. IS THE LEGAL LIMIT FOR ASBESTOS TOTALLY SAFE? 3. WHY DO YOU HAVE TO KEEP ASBESTOS OUT OF THE AIR WHEN YOU ALREADY HAVE TO WEAR A RESPIRATOR AND A SUIT? 4. WHAT ARE SOME OF THE RIGHTS THAT AN EMPLOYEE HAS UNDER THE SATE EMPLOYEES ASBESTOS PROGRAM? 67
CHAPTER 4 RESPIRATORS - Part 1: Types In this chapter you will learn: What respirators are. You must wear a respirator when you work with asbestos. How respirators work. Respirators are not perfect. Respirators have to fit. Not everyone can wear a respirator. What kinds of respirators are allowed on an asbestos job. What kinds of respirators are not allowed on an asbestos job. How to figure out whether you have the right respirator for the job. What is a respirator? Respirators are your last line of defense against asbestos. You need to keep asbestos out of your lungs when you work with it. One way to do this is to keep asbestos out of the air. But no matter what you do, some asbestos will still be in the air. This is why you have to wear a respirator. A respirator is a device that a person wears that filters the air in the work area or supplies clean air from outside the work area. The purpose of a respirator is to provide clean, breathable, air to the user. Paper dust masks will not protect anyone from asbestos. They are illegal on asbestos jobs. USE ONLY NIOSH APPROVED RESPIRATORS FOR ASBESTOS! 68
THE LAST LINE OF DEFENSE Respirators are your last line of defense. They are absolutely necessary to protect your lungs from asbestos disease. Workers don' t like respirators. Respirators are uncomfortable, hot,and heavy. They block your sight, and they make it harder to breathe. It is important to remind your workers why they have to wear these uncomfortable pieces of equipment. Remember you are protecting them and yourself from asbestos diseases by wearing them. Respirators are also not a quick fix, though many people think they are. The State Employees Asbestos Program says that before they can wear a respirator, workers have to have a doctor' s permission, a fitting session (called a fit test), and training. Respirators must be maintained and kept in good condition all the time. Employers must also have a written respiratory protection program. They must do regular inspections to be sure that respirators actually protect workers and that the written program is meeting its stated objectives. A respirator is only as good as its fit If you wear a respirator that doesn t fit, air and asbestos will leak in around the sides of the facepiece. Instead of being caught by the filters, asbestos will go into your lungs. This is why the law says you must have a fit test. The test tells whether the respirator seals around your face. A respirator that does not fit looks the same as one that does. There is no way to tell if a respirator protects you or not just by looking at it. NOT EVERYONE CAN WEAR A RESPIRATOR Some people cannot find a respirator to fit their face. If you have a beard, even a "5 o' clock shadow", you cannot wear any of the respirators approved for this program. If you have any hair on your face where the respirator seals, the respirator will not protect you. Even a large mustache can break the seal of your respirator. If you have a broken nose you may not be able to wear a respirator. If you have missing teeth, large scars, a very narrow or broad face, or any face with an unusual shape you may not be able to wear a respirator. If you feel very anxious, a little faint and shaky when you first try 69
a respirator on, you may not be able to wear a respirator. You may have claustrophobia, a fear of closed in spaces. Respirators also make it harder for you to breathe. You have to have a medical checkup to be sure that your lungs and heart are strong enough to take the strain of working with a respirator. You must have permission from a doctor before you can wear a respirator on the job. When do you wear a respirator? You must wear a respirator whenever you work with asbestos. Asbestos is measured in fibers per cubic centimeter (f/cc) of air. A cubic centimeter is about the size of a sugar cube. One thousand cubic centimeters equal one liter, which is about the size of a quart. You breathe about one thousand liters of air every hour when you are working. The State Employees Asbestos Program says that you have to wear a respirator under the following circumstances: 1. Whenever you cut, break, or otherwise disturb asbestos. 2. When there is the possibility you might disturb asbestos during your work. 3. When you must work in an area where asbestos is being disturbed. 4. When you must enter a restricted area. NO RESPIRATOR IS PERFECT Every kind of respirator has its good and bad points. Every respirator leaks. Some respirators protect you more than others. Each respirator described below has a protection factor (PF). This number tells you how much the respirator protects you. The more asbestos in the air, the more you will need a respirator with greater protection. 70
There are two kinds of respirators allowed on Level II asbestos jobs. Which respirator you wear depends on the amount of asbestos in the air and the working conditions. Your employer must monitor a worker' s breathing air and working conditions. Then he or she decides what kind of respirator is needed, based on how much asbestos is in air and what the working conditions are. Respirators fall into two categories: Air purifying respirators use a filter to clean (purify) the air that' s in the workplace. Air supplied respirators supply clean air to you from a compressor or air tanks Of the two kinds of respirators that you can use, one is an air purifying and the other is an air supplied. 71
RESPIRATORS APPROVED FOR USE BY STATE EMPLOYEES: #1 POWERED AIR PURIFYING RESPIRATOR This respirator is legal up to 100x the permissible exposure limit (PEL) of 0.1f/cc of asbestos. This means that the air can contain up to 10 f/cc of asbestos and it is still OK for you to use this respirator (provided the motor is running). This respirator has a facepiece that covers the entire face. It is attached to a motor. It has filters. The motor and filters can be worn either at your waist or face depending on the brand of respirator you have. The batteries are worn at the waist. The motor pulls air through the filters. If the motor is not attached to the facepiece, the air gets to the facepiece through a hose. This respirator only filters the air that is already in the room. It cannot be used in an atmosphere that is IDLH (Immediately Dangerous to Life or Health). It is an air-purifying respirator. Because it has a motor, this respirator is called a powered air purifying respirator or PAPR. The air coming to the facepiece pushes air and asbestos away from the sides of the facepiece if leakage occurs. The motor makes a positive pressure inside the facepiece. One good thing about this type of respirator is that if it leaks, it leaks out. Another good thing about a powered air-purifying respirator (PAPR) is that your lungs do not have to work as hard to pull air through the filters. The motor does some of the work for you. If the batteries are low or the motor isn t on, however, then this respirator is no better than a full faced non-powered air purifying respirator. Another problem with a PAPR is that it only filters the dirty air in the room. It is just like any other air-purifying respirator. If the batteries in the motor are run down, air and asbestos can leak in around the sides of the mask and cause exposure. This can also happen if the filters are clogged with dust or you breathe very hard. To reduce the risk of this happening, there are two things you must do. First of all make sure that you flow test the PAPR before each use. Flow testing lets you know if the filters are getting clogged or if the blower is blowing air at the proper flow rate (usually 4-6 cfm/min.) Secondly make sure that the batteries are fully charged before every use. Also, run the batteries all the way down about once a month so they do not develop a "memory". (This means that an 8 hour battery may only run for 2 hours even when it is fully charged because it has only been used for periods of less than 8 hours over many months so it will no longer hold for more than this.) Newer nickel metal hydride batteries have overcome this problem and will not develop a memory. 72
Another concern is that of the HEPA filters on the respirator becoming overloaded and reducing the airflow to less than the minimum airflow requirement for the respirator (4cfm or the manufacturer s requirement). Also, when filters beco me overloaded this can lead to possibly tripping a circuit breaker on the battery pack. To avoid this problem change the HEPA as soon as a resistance in breathing is felt or when they become wet. The motor on a PAPR blows air into the facepiece at the same rate, no matter how hard you breathe. The facepiece has to fit perfectly on your face. If you breathe very hard, it makes a suction or negative pressure inside the facepiece. If it does not form an airtight seal, air and asbestos will leak in around the edges of the facepiece. This is called over breathing the respirator. 73
#1 POWERED AIR-PURIFYING RESPIRATOR (PAPR) Protection Factor = 100 means: for every 100 fibers of asbestos outside the mask, only 1 fiber will leak in. 74
#2 PRESSURE-DEMAND AIR-SUPPLIED RESPIRATOR This respirator can be used in air that contains up to one thousand times the PEL. This means the air can contain 100f/cc of asbestos and it is still OK for you to use this respirator. Fresh air comes in through a hose from another air source. It is a Type C respirator. It is also a positive pressure respirator. One good thing about a positive pressure respirator is that if it leaks, it leaks out. This respirator has a tiny valve, which gives you more air when you breathe harder. It is called a pressure demand respirator. When you breathe harder, more air comes through the hose into the face piece. A pressure demand respirator is one of the most protective of the respirators that you can use. One problem with this type of respirator is that you can trip on the hose, or it can get caught on a scaffold. The length of hose that you can have from the source of air to the regulator is also limited. The law says that the length of hose may not exceed 300 feet. Therefore this type of respirator has a limited range. You must also be careful when working around hot pipes and machinery as the hose can melt. The respirator also needs an extra filter or, in the case of an area where the air contaminants may become immediately dangerous to life or health, a tank of air (reserve air) in case the air supply is cut off. Immediately Dangerous to Life or Health (IDLH) means that the air contaminants will injure or even kill you very quickly. 75
#2 TYPE C PRESSURE-DEMAND AIR-SUPPLIED RESPIRATOR protection factor = 1,000 legal up to 100 f/cc Protection Factor = 1000 means: for every 1000 asbestos fibers outside the mask, only 1 fiber will leak in. 76
MORE ABOUT TYPE C RESPIRATORS Type C respirators are more complicated than other types of respirators. Air tanks or a compressor must supply fresh air. It is then supplied to the face piece through a hose. The air has to be clean, cool, and at low pressure so that it' s comfortable to breathe. The air you breathe in a Type C respirator must be "Grade D Air" or breathable air. (You do not breathe pure oxygen in a Type C respirator). Grade D air is air that has chemicals filtered out. It has enough oxygen for you to breathe - Between 19.5 and 23.5 percent. (Normal air has about 21% oxygen). Grade D air has 10ppm or less of carbon monoxide and 1000ppm or less of carbon dioxide. There is no noticeable odor. The supervisor must ensure that Grade D air is used. Carbon monoxide is a dangerous gas, which you can' t smell. Your employer may use a special rig, which filters the air to Grade D quality. A compressor supplies the air. He may also buy bottled air which the manufacturer or distributor certifies to be Grade D or "breathable". If your employer chooses to use a compressor, it must not be a regular shop compressor. A regular compressor will pump dirty air into your mask. A compressor that is used to supply Grade D air must have these features: 1. A filter to take out odors, dust and some chemicals. 2. A carbon monoxide (CO) alarm or a high temperature alarm. CO can come from compressors, which work at high temperatures, or from space heaters, forklifts, gas water heaters and the outsideairbecauseofcarsortrucks. A carbon monoxide alarm is better than a high temperature alarm. 3. A trap to catch water condensate or oil mists*(if using an oil lubricated compressor) in the air. * Oil-less compressors are strongly recommended The filters on the air purification panel must be cleaned and maintained in accordance with the manufacturer s requirements. If the carbon monoxide alarm goes off, stop work immediately. Leave the area immediately. Supervisors must make sure all workers are out. They must make sure that all personnel using the respirators are accounted for. 77
TYPE OF SYSTEM PRESSURE RANGE RESERVE AIR Low-pressure 100-200 psi* has standby reserve air tanks High-pressure 2000-4000 psi has in-line, high-pressure tanks *psi = pounds per square inch You may have up to 300 feet of hose for a Type C respirator. more than 300 feet of hose with a Type C respirator. It is illegal to have IMPORTANT CONSIDERATIONS WITH TYPE C RESPIRATOR SYSTEMS Training Special training must be given to each worker who is using a Type C respirator. The training should be specific to the exact type of respirator that is issued. Supplied air respirators do not necessarily have emergency escape provisions. A HEPA filter or a small auxiliary escape tank of air attached & connected to the respirator can give you this safe escape mechanism. In cases where the atmosphere in the work area may become immediately dangerous to life or health, only the auxiliary tank of air can be used for escape. The air tank must allow for 5 to 15 min. of air for escape from the area. If the atmosphere is already immediately dangerous to life or health you can' t use this respirator. You must know how to use your escape gear. Remember, if the air you breathe is supplied, anything can happen to that air supply. When the source of your air is gone you will panic. It is very important to practice how to use your escape gear. If you practice, you are more likely to remember how to use your escape air when you need it. A supervisor must watch the system Type C respirator systems protect workers the most. They are also the most complicated respirator systems. There are individual respirators, many long hoses, manifolds, compressors, air tanks, pumps, and alarms. Each person using the Type C respirator should be aware of all the parts of the system and know how they operate. As the supervisor or foreman, you are responsible for checking to make sure that the entire Type C system is operating correctly. You must know the Type C system that is being used. You must consistently monitor the system, and be alert to the alarms. This monitoring can save lives by making sure that workers are being supplied breathable air. If you are given a Type C respirator, make sure that you really know how the system works as instructed by the manufacturer. An untrained person must never be responsible for monitoring the system. Non - breathable air can kill workers much faster then asbestos can 78
Protection factor How much asbestos can a respirator handle? Some respirators are better than others at keeping asbestos out of your lungs. A respirator' s Protection Factor (PF) is a measure of how well it should protect you from asbestos. Protection Factors go from 10 to 1,000. Protection Factors are based on how respirators that fit under laboratory conditions. These can be different from protection factors under actual usage conditions due to perspiration, movement, facial features, etc. while working A PAPR respirator has a Protection Factor of 100. (For every 100 fibers of asbestos in the air, 1 fiber leaks into the mask.) A pressure demand air supplied respirator has a Protection Factor of 1,000. (For every 1,000 fibers of asbestos, 1 fiber leaks in). The higher the Protection Factor, the more a respirator protects you. A respirator will not protect you unless it is the right one for the job, it fits and has the right filters and parts. A large protection factor is better than a small one. How do you know it' s the right respirator? When you see your air sampling results, how can you tell which respirator will protect you enough? You need to know the respirator' s limit or Maximum Use Level (MUL). This is how much asbestos the respirator can protect you from. 79
A half-mask, air-purifying respirator is legal up to 1 f/cc. The Maximum Use Level is 1 f/cc. A full-face, air-purifying respirator is legal up to 5 f/cc. The Maximum Use Level is 5 f/cc. A powered air - purifying respirator (PAPR) is legal up to 10 f/cc The Maximum Use Level is 10 f/cc. A continuous-flow Type C respirator is legal up to 10 f/cc. The Maximum Use Level is 10 f/cc. A pressure - demand Type C respirator is legal up to 100f/cc The Maximum Use Level is 100f/cc. To figure out the Maximum Use Level for a respirator, take the legal limit (the PEL=0.1) and multiply it by the Protection Factor. The Protection Factor (PF) tells you how many fibers leak in, compared to the number of fibers outside. You need to keep the number of fibers inside below 0.1f/cc (the legal limit) 0.1f/cc (legal limit) x Protection Factor = Maximum Use Level 0.1f/cc x PF = MUL A Powered Air Purifying Respirator has a Protection Factor of 100. 0.1f/cc x 100 = 10f/cc The Maximum Use Level is 10f/cc A Pressure - Demand Air Supplied Respirator has a Protection Factor of 1,000. 0.1f/cc x 1,000 = 100f/cc The Maximum Use Level is 100f/cc 80
Math review for your own information Number line The numbers get bigger as you go down. 0 0.1 = 1/10 0.2 = 2/10 = 1/5 0.3 = 3/10 0.4 = 4/10 0.5 = 5/10 = 2/5 0.6 = 6/10 0.7 = 7/10 0.8 = 8/10 0.9 = 9/10 1.0 = 10/10 = 1 1.1 = 1 1/10 1.2 = 1 2/10 Decimals 1.0 is more than.5 ("point five") 0.5(point five") is more than.2 ("point two") 0.2 ("point two") is more than.1 ("point one") 0.1 ("point one") is more than.01 ("point oh one") Decimals and fractions 0.1 ("point one") = 1/10 ("one tenth") 0.2 ("point two") = 2/10 ("two tenths") = 1/5 0.01 ("point oh one") - 1/100 ("one one-hundredth") 81
RESPIRATORS Key Facts You must wear a respirator when you work with asbestos. You must have a doctor' s permission before you can wear a respirator on the job. Not everyone can wear a respirator. Respirators don' t work unless they fit properly and are the correct one for the job. Paper dust masks are illegal for asbestos work. Positive pressure (air flows into the mask and the resulting positive pressure keeps fibers from leaking into the mask) is better than Negative pressure (your lungs do all the work to move the air). A Full face mask is better than a Half face mask Powered - Air Purifying (PAPR) (a motor does some of the work) is better than non-powered Air - Purifying (your lungs do all the work) Tight-fitting(an air tight seal) is better than Loose - fitting (no seal) Air supplied (pumps in clean air from an outside source) is better than Airpurifying (filters the air in the room) Pressure - demand (the regulator supplies more air when you breathe harder) is better than Continuous flow (a regulator always supplies air at the same rate) Your employer chooses your respirators based on air sampling results and working conditions. Air supplied respirators use Grade D air. 82
This respirator is a powered air-purifying (PAPR) positive pressure, full - face respirator which has a protection factor of 100. It is legal up to 10 f/cc. This respirator is an air-supplied (Type C) positive pressure full face pressure - demand respirator which has a protection factor of 1,000. It is legal up to 100f/cc. For more information * OSHA Construction Industry Asbestos Standard, 29 CFR 1926.1101 American Lung Association, "What You Should Know About On - The - Job Respiratory Protection," ALA Item No. 0683. * "Establishing a Type C Supplied -Air System," in "Model Curriculum for Training Asbestos Abatement Contractors and Supervisors." *EPA/NIOSH, "A Guide to Respiratory Protection for the Asbestos Abatement Industry," Publication No. EPA-560-OPTS-86-001.3. *NIOSH, "Respiratory Protection, A Guide for the Employee," DHHS (NIOSH) Publication No. 78-193B. NIOSH "Guide to Industrial Respiratory Protection," DHHS (NIOSH) Publication No. 87-116. *Your instructor has a copy of these publications for you to look at. 83
RESPIRATORS - PART 2: CARING FOR YOUR RESPIRATOR In this chapter you will learn: What your employer has to do before giving you a respirator. How to make sure your respirator fits. How to take care of your respirator. How to: clean, inspect, maintain; and store your respirator. About a written respirator program A respirator can' t protect you unless it fits When OSHA inspects a job for health problems, more than one-third of the problems are in the company' srespirator program. The law says your employer has to have a very strong, effective respirator program. RESPIRATOR PROGRAM What the employer has to do Before your employer hands you a respirator, he or she has to do a lot of things. The employer has to find out if you can wear a respirator. Who will pick the respirators? Who will maintain them? These things have to be written down in a respirator program. 1. Your employer must provide respirators when necessary to protect your health. 2. Your employer must develop and implement a written respiratory protection program that is administered by a suitably trained person. Find out who the person in charge is and get a copy of the program from them. In State facilities this is usually the Agency Safety & health Specialist s responsibility. 84
3. Your employer must evaluate the respiratory hazards in the workplace and identify user and workplace factors and base the respirator selection on them. A gas filter won' t protect you from a dust. A dust filter won' t protect you from a gas. A filter respirator won' t protect you if there isn' t enough oxygen in the air. Your employer must determine what and how much of a contaminant you are exposed to and base the selection on that. Under the State Employees Asbestos Program, your employer is limited to selecting either a PAPR or a Type C Pressure Demand Airline respirator for Level II building maintenance staff. 4. Your employer must offer medical exams to everyone who wears a respirator to determine their fitness to wear a respirator. No one is allowed to wear a respirator without permission from a doctor. As the supervisor you must ensure that each of your employees has had medical monitoring before allowing them to use a respirator. 5. Your employer must have you trained about respirators. Before you put on a respirator, you have to be trained. You need training on each respirator you work with. You have to learn about all the parts of your respirator. You have to learn how your respirator works. You need to know what a respirator can do for you. You need to know what a respirator can' t do for you. You have to be trained on how to clean, inspect, and store your respirator. You have to have this training every year. As the supervisor you must ensure that each of your employees has had this training and it is documented before allowing them to use a respirator. 6. Your employer must use approved respirators Respirators have to be approved by the National Institute for Occupational Safety & Health (NIOSH) under 42CFR Part 84. All labels must comply with NIOSH and be readable. Make sure they do! 7. Your employer must ensure that all employees receive and pass a fit test. Employees must have a fit test every year! 85
When you first get a respirator and every year after that, the fit must be tested. You must also be fit tested when you get a new or different respirator. Remember that a respirator is only as good as its fit. The fit tests are called qualitative or quantitative. The tests take from ½ to 1 hour. As the supervisor you must ensure that each of your employees has had a documented fit test on the respirator that they will be using before allowing them to do asbestos work. NOTE: If you don t work with asbestos within a 1 year period, then you do not have to be fit tested every year. You will have to be fit tested before you do the next asbestos job and the respirator must fit you properly. If the size you have does not fit you, then you must get a new size or brand of respirator. In a qualitative fit test, you stand in a well ventilated room and the tester pumps irritating smoke around the edges of the respirator. If the material leaks into the mask, it will cause you to cough. This means that the mask does not fit well enough to keep asbestos out of your lungs. In a quantitative fit test, you will don a special respirator mask that has a probe in it. You will be tested on the same size mask that you will use for work. The probe is connected to a machine like a Port - A - Count that measures the concentration of particulate inside your mask and outside your mask. The machine will then calculate how much leakage there is. You and your employees will have one of these fit tests during the initial training class. You must have a fit test on every respirator that you will use in your work. You must have a fit test every year and at other times between the annual fit test whenever any of the following occur: if you lose or gain more than 10 pounds break your nose lose teeth or get new dentures have facial surgery get glasses for the first time 86
8. Your employer must establish and implement procedures for the proper use of respirators. As a supervisor you are an important part of the implementation process so know what the written respiratory protection program says! 9. Your employer must provide for the cleaning, disinfecting, storage, inspection, and repair of respirators. If there is anything wrong with your respirator, your employer has to fix it before you can wear it or provide you with a suitable replacement. Your employer has to check the respirators to make sure they are in good shape. Your employer has to have trained people to fix your respirator. Your employer must give you a clean, dry place to keep your respirator. As the supervisor you must ensure that each of your employees follows the proper procedures for cleaning, disinfecting, storing and inspecting their respirators. 10. Your employer must provide grade D or better breathing quality air when you use a supplied air respirator. 11. Your employer must evaluate the workplace to ensure that the program is working (meeting its stated objectives) and that employees are using respirators properly. As a supervisor, your employer may delegate this task to you. 12. Your employer must establish and retain written information regarding medical exams, fit tests, and the respirator program. Make sure you know where the written information is and how to access it. Included below is a checklist to help you determine if the requirements of the respiratory protection program are being met. 87
RESPIRATOR PROGRAM CHECKLIST In general, the respirator program should be evaluated at least annually with program adjustments, as appropriate, made to reflect the evaluation results Program function can be separated into administration and operation. A. Program Administration 1. Is there a written policy that acknowledges employer responsibility for providing a safe and healthful workplace, and assigns program responsibility, accountability, and authority? 2. Is program responsibility vested in one individual who is knowledgeable and who can coordinate all aspects of the program at the job site? 3. Can feasible engineering controls or work practices eliminate the need for respirators? 4. Are there written procedures/statements covering the various aspects of the respirator program, including: designation of an administrator; respirator selection; purchase of approved equipment; medical aspects of respirator usage; issuance of equipment; fitting; training; maintenance, storage, and repair; inspection; use under special conditions; and 88
B. Program Operation work area under surveillance? 1. Respiratory protective equipment selection and assignment Are work area conditions and employee exposures properly surveyed? Are respirators selected on the basis of hazards to which the employee is exposed? Are selections made by individuals knowledgeable of proper selection procedures? Are only approved respirators purchased and used; do they provide adequate protection for the specific hazard and concentration of the contaminant? Has a medical evaluation of the prospective user been made to determine physical and psychological ability to wear the selected respiratory protective equipment? Where practical, have respirators been issued to the users for their exclusive use, and are there records covering issuance? 2. Respiratory protective equipment fitting Are the users given the opportunity to try on several respirators to determine whether the respirator they will subsequently be wearing is the best fitting one? Is the fit tested at appropriate intervals? Are those users who require corrective lenses properly fitted? Are users prohibited from wearing contact lenses when using respirators? Is the face piece-to-face seal tested in a test atmosphere? 89
Are workers prohibited from entering contaminated work areas when they have facial hair or other characteristics that prohibit the use of tight fitting face pieces? 3. Respirator use Are respirators being worn correctly (i.e., head covering over respirator straps)? Are workers keeping respirators on all the time when necessary? 4. Maintenance of respiratory protective equipment a. Cleaning and Disinfecting Are respirators cleaned and disinfected after each use? Are proper methods of cleaning and disinfecting utilized? b. Storage Are respirators stored in a manner so as to protect them from dust, sunlight, heat, excessive cold or moisture, or damaging chemicals? Are respirators stored properly in a storage facility so as to prevent them from deforming? Is storage in lockers and toolboxes permitted only if the respirator is in a carrying case or carton? c. Inspection Are respirators inspected before and after each use and during cleaning? Are qualified individuals/users instructed in inspection techniques? Is respiratory protective equipment designated as "emergency use" inspected at least monthly (in addition to after each use)? Is a record kept of the inspection of "emergency use" respiratory protective equipment? 90
d. Repair Are replacement parts used in repair, those of the manufacturer of the respirator? 5. Special use conditions Is a procedure developed for respiratory protective equipment usage in atmospheres immediately dangerous to life or health? Is a procedure developed for equipment usage for entry into confined spaces? 6. Training Are users trained in proper respirator use, cleaning and inspection? Are users trained in the basis for selection of respirators? Are users evaluated, using competency-based evaluation, before and after training? 91
What employees have to do After your employer gives you the respirator, you have to use it safely. Do you have the right one? Did you get a fit test on your respirator? Does the respirator work? Is it clean? You are the one who cares the most about whether your respirator works. If it is not in good shape, you could breathe asbestos. Learn how to use your respirator and take care of it. 1. Do you have the right respirator? Does your respirator fit you? You must get a fit test for your respirator. Do you have an approved respirator? Look for the NIOSH seal on your respirator box and on the filters. You need to have the right respirator for the job. Figure out which respirator you need. Is your respirator good enough? Your employer must choose the right respirator for the job. Even if you have an approved respirator, it might not protect you enough from the amount of asbestos in the air. Respirator Protection Factors come from tests in labs. The respirator maker tests an average size person. The tests are done in a clean, cool lab. Only a new respirator is used. But you don' t work in a lab. You may not have an average face. You sweat when you work. The respirator may slide on your face. Maybe your respirator isn' t as perfect as when it was new. There are many reasons why the respirator may not work as well for you as it did in the lab. Respirators may not protect you as well as they are supposed to. If you can, get a more protective respirator than the law requires. 2. Know how to use your respirator If you don' t know how to use your respirator, it will not protect you. Learn how your respirator works. If you don' t have a clean- face, the respirator will not protect you. If you don' t maintain it, the respirator will not protect you. Get to know your respirator. Get training on the respirator you use. Inspect your respirator. Are all the parts where they belong? Always inspect your respirator before you put it on. 92
3. Inspect your respirator every time you use it A respirator can' t help you unlessit' s in good shape.you need to inspect your respirator before you put it on. Make sure all the parts are there. Make sure all the parts are in good shape. Make sure all the parts are in the right place. If you find anything wrong with your respirator, do not wear it until it has been fixed. THE PARTS OF A RESPIRATOR All respirators have the following parts: Inhalation Valves - This is where you breathe in. There are one or two small rubber flaps. They are about the size of a quarter. Exhalation Valves - This is where you breathe out. It may be one or two small rubber flap(s) about the size of a quarter. It is underneath a cover. Face piece - These are made of silicon, rubber, and other materials. Straps - These hold the respirator onto your head. There are many kinds of straps. There are two straps that connect at the sides of your neck. There are two straps that connect at your temples. There is on strap that connects at your forehead. In addition to the above parts the PAPR has: Hose - if the motor is on your belt, this carries air up to your face. Cord - if the motor is on your face, this connects the motor to the battery. Battery - Every PAPR has a rechargeable battery to run the motor Motor - Every PAPR has a motor either worn on a belt at your waist or on the facepiece. Filters - These are rectangular or round in shape. They filter the asbestos out of the air. Flow Tester This device, separate from the respirator itself, helps to measure the airflow of the motor to the facepiece. It can help tell you if the filters need changing, the battery needs charging, or if it is not supplying you with the minimum required airflow needed to protect you. It can be either wall mounted or hand held. 93
In addition to the parts common to all respirators, The Type C respirator also has: Air Regulator - This valve controls how much air comes into the mask. Escape Air Bottle - If air stops coming through the hose, you can breathe air from the bottle while you leave the area. (This is for escape from an IDLH atmosphere). Face Piece Hose - This carries the air from the regulator to your face. Airline Hose - This carries air from the pump, tanks, or compressor to the regulator. Low Air Alarm - This device signals that air in the tanks is getting low (there is < 15 min. of air left.) Manifold - A device that splits the regulator' s single air outlet into 1-4 outlets to supply air to 1-4 workers. INSPECTING YOUR RESPIRATOR The following are common to all respirators and should be inspected: Inhalation Valves - Check the valves. Are they there? Are they ripped or bent? Are they dirty? Exhalation Valves - Take off the cover (You can' t do this with a Type C airline respirator). Is the valve there? Is it ripped or bent? Is it dirty? Is the cover piece in place? Face piece - Is it ripped or worn? Is the face piece bent? Is it clean? Straps - Are they still elastic? Are they worn? Do the buckles and snaps work? For a PAPR respirator you must check all of the above plus the following: Hose - Is it bent or cut? Are there cracks in it? Battery - Is it fully charged? Are back up batteries charged and ready? Flow - Use a flow-tester each time the PAPR is used to see how much air the fan is blowing Filters - Do you have the right filter for the job? When you work with asbestos, you need purple (magenta) filters. Change the filters when it becomes harder to breathe. This can be 94
cause by the filters being overloaded with asbestos or by being wet. You may have to decontaminate them before you change them. For a Type C respirator, you need to check the parts common to all respirators as well as the following: Escape Air Tank - Is it full? Is it connected? Face Piece Hose - Is it bent or cracked? Are there cracks in it? Airline Hose - Is it bent or cut? Are there cracks in it? Regulator - Can only be checked by a factory- trained person. No one else should attempt to disassemble or repair a regulator. Low Air Alarm - Must be checked by a trained person. Air Tanks - Are they full? Manifold - Note that all manifold connections should be capped when not in use to avoid being contaminated with grease, oil, or lubricating fluids which may cause fires or explosions in contact with gases under high pressure. Repairs Respirator parts have to come from the same manufacturer that made the respirator. In other words, you may not use MSA brand filters on a Cesco brand respirator. You may not use 3M brand valves on an AO brand respirator. No one should fix your respirator unless he or she knows how to fix it. It is important for the supervisor to ensure that parts aren t mixed or that respirators are not repaired by untrained, unauthorized personnel. 4. Putting on a respirator When you put on your full-face piece respirator, put your chin in the chin cup first. Next fit the mask to your face. Smile, frown, and move you face around. Be sure the edges of the mask fit your face. Next pull the straps over your head. Fasten the temple straps first, then the neck straps, and finally the top strap. The straps need to be tight enough to hold the respirator on your face and give you a good seal. DO NOT make them too tight. The mask will dig into your face and will be very uncomfortable to wear. Always refer to the manufacturer s instructions before putting on any respirator. 95
5. Do user seal checks every time you put on a respirator In addition to annual fit tests which must be done every year to make sure you have the right size respirator, you also have to check the fit yourself every time you put on a respirator. The seal checks s you do yourself are called a negative pressure user seal check and a positive pressure user seal check. You must do both of these fit checks every time you put on your PAPR respirator. (You can' t do a positive pressure fit heck on a Type C respirator.) You must ensure that your employees perform these checks. The negative pressure user seal check. Cover the place where the hose connects to the facepiece with your hand and suck in gently. Hold for a count of ten seconds. You will feel the respirator pull against your face. You can feel the area of the seal tightening to your face. If there is a leak, air will rush in through the leak instead of pulling the facepiece against your face. You will feel air move against your cheeks. It may feel like a feather brushing across your face. The air will move toward your mouth. You may hear the airflow. If someone is watching you, they should see the respirator suck in a little at your nose if you have a good fit. The positive pressure user seal check. Take the cover off the exhalation valve(s) on your chin or on the sides of the face piece. Cover the rubber flap(s) with your hand(s) and blow out gently. You should feel the force of your breath puff the respirator out a little bit. This is like the feeling when you first blow up a balloon. If there is a leak in the facepiece, air will rush out of the leak instead of making the mask puff out. If there is a leak, you will feel air rush out against your cheeks. You will not feel the seal tightening to your face. Don' t blow too hard or you can blow out your inhalation valves and break a good seal. 96
6. Keep your respirator clean It is very easy to clean your respirator, and you must clean it every time you use it. Wash the respirator in warm water (not exceeding 120 degrees) with a mild soap. You must also use an EPA registered disinfectant that is either especially made for respirators or recommended by the manufacturer. Wash the inside and outside of the face piece with a soft bristle brush or a clean rag. Rinse the respirator in clean water, and let it air dry. In addition to washing the face piece you need to wipe down all other parts of the respirator with a clean damp rag. Do not immerse the motor, battery, or filters of the PAPR in water. 7. Dry and store your respirator in a safe place Don' t hang your respirator by its straps to dry. This can stretch out the straps. Do not dry your respirator on a sunny window, radiator or other place that is more than 120 degrees. Too high a temperature will cause your respirator facepiece to lose its shape so that it no longer fits. Keep your respirator in a clean, dry place inside of a clean plastic storage bag. It is easy to damage respirators or have them become contaminated. 97
CARING FOR YOUR RESPIRATOR A respirator will not protect you unless it fits. Key Facts You must have a fit test before you can wear a respirator at work. Qualitative fit testing doesn' t use machines. You use your sense of smell ortaste. Quantitative fit testing uses a machine. It measures how much air leaks around the edges of your respirator. You must be fit tested every year. You must inspect your respirator before you put it on. You must use a flow tester each time you use a PAPR to measure airflow to the facepiece. You must do your own seal checks every time you enter an area with asbestos in it. The negative pressure user seal check: cover the inhalation valve(s) and suck in gently. The positive pressure user seal check: cover the exhalation valve(s) and blow out gently. You must clean your respirator with soap and water and an EPA registered disinfectant every time you use it. Store your respirator in a clean, safe place in a clean plastic bag. With a PAPR use HEPA filters for asbestos. Change the filters when the flow tester no longer measures in the good range. (If this doesn t help, you made need to change the batteries.) 98
Discussion questions 1. The law gives you the right to go through decontamination and wash your face if asbestos or your respirator irritates it. Why do you have this right? 2. When you first pick up your respirator, what are you going to do? 3. How often do you need a fit test? 4. Why is it important to learn how to do the positive and negative pressure fit checks? For more information *OSHA Respirator Standard, 29 CFR 1910.134. American Lung Association, "What You Should Know About On-The-Job Respiratory Protection," ALA Item No. 0683. *NIOSH, "Respiratory Protection, A Guide for the Employee," DHHS (NIOSH) Publication No. 78-193B. *EPA/NIOSH, "A Guide to Respiratory Protection for the Asbestos Abatement Industry," Publication No. EPA-560-OPTS-86-001. *Your instructor has a copy of these publications for you to look at. 99
Respirator exercise This is not a test. It is an exercise. Use it to see for yourself how well you understand the material in the chapter. 1. What is the difference between a negative-pressure respirator and a positive pressure respirator? 2. Which one protects you more? Why? 3. If you are working on an abatement job and air samples show 2.5 f/cc of asbestos in the air, which respirator do you have to wear? 4. Can you request a respirator that will protect you more? 5. What is the difference between a qualitative fit test and a quantitative fit test? 6. Some people have a harder time getting a good fit on a respirator. Who are they? Why do they have a hard time? 100
7. Name the limits of respirators, i.e., reasons why they protect you less than they are supposed to. 8. Name two parts of a good respiratory protection program. 101
RESPIRATORS Part 3: Other Safety Equipment In this chapter you will learn: About disposable suits. About hard hats, boots, and other equipment. Other Safety Equipment A respirator is the most important piece of equipment for protecting you from asbestos. You also have to wear disposable protective clothing to protect your skin. Asbestos workers must always wear single use disposable suits. The suit includes coveralls, booties, and a hood. Sometimes suits are made in one piece, sometimes in two or three. They are usually made of a papery material like Tyvek or Kleen Guard. Suits come in several sizes. Everyone in the work area must wear a disposable suit. You may also need to wear gloves to keep asbestos off your hands. You can make a large suit smaller by putting duct tape around the waist, wrists, and ankles. Disposable suits that are too small or just fit, tear easily. A larger suit can give more freedom of movement. Booties are very slippery, especially on wet plastic in asbestos work areas. You may wear canvas or rubber shoes outside the booties. You may wear boots or steel-toed safety shoes. These keep you from slipping or being hurt by falling objects or electrical shocks. You can' t take these shoes off the job unless they are cleaned. Sometimes you can clean all the asbestos off them. (Leather and fabric shoes can not be cleaned; rubber shoes without seams can be cleaned.) If you can' t clean them, you have to throw them out or tie them up in a bag. Your employer can take them from job to job in a sealed plastic bag with a warning label on it. You should not wear street clothes on an asbestos job. You do not want to take any asbestos home with you on your clothes. If you use any non- disposable equipment (such as work boots or a hard hat) on an asbestos job, you must clean it. Do not take it off the job unless it is clean. Your employer can take it from job to job in a sealed, labeled, plastic bag. 102
Disposable suits are the only ones that you can use in the State of Maryland. If you work in cold weather, you will probably wear long underwear. It should not leave the job. If you take asbestos home on your skin or street clothes, dust can come off in your home. Your family could get asbestosis, mesothelioma, or other asbestos diseases if they breathe or swallow asbestos. It is very important to wear a disposable suit and not take your work clothes home. Asbestos work has many of the same dangers as ordinary demolition work. You need to wear latex, cotton, or leather gloves if you work with sharp metal lath or around hot pipes or if you are working with thermal system insulation or surfacing materials in amounts greater than 10 SQ. FT. or 25 LIN. FT. You need to wear steel - toed safety boots and hard hats if building materials might fall. You should have some training about how to use safety equipment. For example, hard hats are made to protect you if something falls straight down on your head. But they will not protect you if something hits you from the side. Your employer should train you about hard hats. OSHA has rules about protective equipment like hard hats, goggles, and boots. Many of the rules for respirators also apply to other equipment. For example, goggles will not protect you unless they are in good shape. They have to be cleaned, stored, maintained, and inspected for defects. 103
OTHER PROTECTIVE EQUIPMENT Key Facts You must wear disposable protective clothing on an asbestos job. Asbestos work is just as dangerous as other demolition work. You may need to wear a hard hat, goggles, or special boots outside your disposable suit. For more information *OSHA Personal Protective Equipment Standards, 1910.132, 1910.133, 1910.135, 1910.136. *OSHA, "Personal Protective Equipment," Publication No. OSHA 3077. *Your instructor has copies of these publications for you to look at. 104
CHAPTER 5 CONTROL METHODS In this chapter you will learn: How asbestos can be controlled. About the kind of asbestos work you may do. Control Methods When asbestos materials are found in a building, the owner of the building must make a decision about what to do with them. The danger from asbestos materials depends on how likely they are to release fibers into the air. Products, which are in good shape and are unlikely to be damaged by accident, are not a problem. These products can stay in the building and might not be removed until the building is renovated or demolished. Products, which are in bad shape, need to have something done to them to prevent fibers from getting into the building air. There are a number of different ways to do this. These are called control methods. Thecontrol methods, which may be used, are: 1. Operations & Maintenance 2. Repair 3. Encapsulation 4. Enclosure 5. Removal 6. Restriction These Control Methods are sometimes used together on one project. For example, a job may involve the removal of 100 feet of pipe covering and repair of an additional 1000 feet. Or encapsulation of most of the ceiling material in a building, but removal of the material which is in areas where the hallway is low. Usually, asbestos supervisors will not decide which method to use. That decision is made by the building owner or a Project Designer accredited under the Model Accreditation Program. It is then included in the job specifications (specs) for the project. 105
1. Operation and Maintenance An Operations and Maintenance program is a control method used for managing asbestos while it remains in a building. An Operations and Maintenance program should be set up in any building, which has asbestos in it. The program has a number of different parts. They are listed below: 1. A list or inventory of all asbestos materials in the building is made. The inventory includes what kinds of materials, where they are located, how much there is, and what kind of shape they' re in. 2. Materials in the building must be labeled with stickers to alert workers that they contain asbestos. Signs may need to be posted in areas that contain asbestos. 3. The materials are checked at least every six months to see if they are still in good shape. 4. Training is done for maintenance employees so that they can handle small amounts of asbestos that might be disturbed during their work. 5. Work procedures are developed for maintenance work. For example, how to safely remove and dispose of a small amount of pipe insulation so that a leaking pipe valve could be repaired. 6. Proper equipment is provided to maintenance workers so that they can do the work safely. 7. Procedures are developed for dealing with accidental damage to asbestos materials (such as fiber release episodes). The point of the Operations and Maintenance program is to prevent the asbestos materials from releasing fibers into the building. This protects maintenance and service workers, outside contractors (plumbers, electricians, etc.) and other people in the building. All of the parts of the program are important. If some parts are done but others are not, the program won' t be effective. A good Operations and Maintenance program also requires that the building owner have a knowledgeable person on staff to deal with asbestos. The building engineer or someone else should be trained to know about asbestos hazards and how to run the owner' s program. 106
2. Repair Repair is a control method, which can be used if there are small amounts of damage to asbestos materials. For example, asbestos pipe insulation might have a canvas covering that is torn and the tear may expose the asbestos fibers so that they can be released into the air. Wrapping new canvas around the tear and repainting it, is considered a repair. 3. Encapsulation Encapsulation is the spraying or brushing on of a paint-like coating over the material. The coating is put on with either a low-pressure sprayer or a brush. When material is encapsulated, the coating prevents release of fibers into the air. The coating can also prevent some damage to the material from contact. 107
When you work on an encapsulation job, you can still be exposed to asbestos fibers. In fact, when the encapsulant hits the material a small amount of dust is sometimes blown into the air. The material cannot be wetted first, because the encapsulant will not stick. Because of this, an encapsulation job is set up just like a removal job. Workers will also wear respirators and protective clothing while doing encapsulation. Two kinds of encapsulants are used. One kind is called a bridging encapsulant This kind covers the material with a "tough skin" on the outside. The other kind is called a penetrating encapsulant. This kind soaks into the material and binds the material together. The material then becomes hard like a plaster cast. When doing encapsulation, workers usually apply two coats over the material depending on the manufacturer' s instructions. This is done to make sure that the asbestos is completely covered. The encapsulant takes some time to dry. Materials contaminated with dust during the job are disposed of as asbestos waste. This includes plastic barriers, suits, and other items. 4. Enclosure Enclosure means building an airtight barrier around asbestos containing materials. The enclosure is built with non-asbestos building materials. Examples are sheet rock, wood, and spline joints, caulked sheet metal and other materials. 108
If the barrier is not airtight, it is not considered an enclosure. For example, putting in a drop ceiling to control asbestos fireproofing material is not an enclosure. An enclosure job also requires that a containment be built. Building the enclosure often requires disturbing the material. Workers will also have to wear respirators and protective clothing. If drills or nail guns are used to attach the enclosure, asbestos dust can be released. Another type of enclosure is sometimes referred to as encasement. Encasement means spraying a closed cell foam directly on an asbestos material or onto a lattice hung below the material. Another example would be to pour concrete onto a dirt floor in a crawl space. During an enclosure job, disturb the material as little as possible. It is best to use power tools such as drills only if they are attached to a HEPA vacuum. Items from the work area (like plastic sheeting and suits) that get dust on them have to be disposed of as asbestos waste. Other things like power tools must be cleaned before they leave the containment. 5. Removal Removal is the method used most to control fiber release from asbestos materials in buildings. Removal means taking the asbestos off of whatever it is on. Except in rare circumstances, asbestos is always wetted before it is removed. It is then bagged and sealed and taken to landfill that accepts asbestos and is licensed to do so. A removal job must not only remove the material that can be easily seen but also that which is not easily visible to the naked eye. Workers will also be doing lots of cleaning. This is because when asbestos is scraped, pulled, or ripped off surfaces or mechanical systems, many fibers are released. These must be cleaned up as part of the removal job. On a removal job you can be exposed to a lot of asbestos dust. This is why strong rules have been made for these jobs. If removal jobs are not done right, workers can be exposed to asbestos. In addition, a poor removal job can leave more asbestos fibers in the building air than there were before. These two reasons are why it is so important to use the methods and follow the rules, which we will learn about in the rest of the manual. 109
6. Restriction Restriction is a control method, which is often used for areas, which do not require frequent access or in cases where funding is limited. Restriction means that the area can only be accessed by trained and medically monitored Level II personnel. These Level II employees must be wearing a respirator and a disposable suit when working in restricted areas. Areas are restricted which have asbestos that is damaged and cannot be abated right away. 110
CONTROL METHODS KEY FACTS Asbestos in buildings can be controlled in a number of different ways. The different ways are: 1. Encapsulation 2. Enclosure 3. Removal 4. Repair 5. Operations and Maintenance Program 6. Restriction An Operations and Maintenance Program (O&M) is a written program. It is needed when asbestos will remain in a building. The written O&M program includes: 1. Where asbestos is found. 2. Signs & Labeling of asbestos containing materials 3. Worker training requirements. 4. Ways to work with asbestos safely. This includes equipment, worker protection, and medical exams. 5. Permits, which are required before beginning, work. 6. How to check the condition of asbestos materials and record any changes. 7. Record keeping. Repair means fixing small areas of damaged asbestos material Encapsulation means spraying or brushing a paint-like coating over the asbestos material. This binds the material together. Enclosure means building an airtight barrier around the asbestos material. Removal means taking off the asbestos material from whatever it is on, cleaning the material up, and properly disposing of it. Restriction means access to the area is limited to properly trained and equipped Level II personnel. 111
Discussion Questions 1. What kind of material do you think would not be good to encapsulate? 2. Can you see a situation in which more than one control method might be used in an area? For more information *Guidance for Controlling Asbestos Containing Materials in Buildings (The Purple Book), U.S. Environmental Protection Agency, June 1985. *Managing Asbestos in Place, A Building Owner' s Guide to Operations and Maintenance Programs for Asbestos Containing Materials (The Green Book), U.S. Environmental Protection Agency, July 1990. *Your instructor has a copy of these materials for you to look at. 112
CHAPTER 6 PRE - WORK ACTIVITIES AND CONSIDERATIONS In this chapter you will learn: - Information in this section should enable participants to: - Understand what to look for when conducting the pre-job walk-through survey of the job site. - Ask specific questions relating to job site conditions and how they affect job design or specifications. - Become knowledgeable in good techniques for screening and selecting abatement workers. - Understand the type of information that needs to be covered in a training program for abatement workers. - Understand the design and use of a project logbook and its importance during an asbestos abatement job. ASSESSING THE WORK AREA An important "rule of thumb" for any asbestos abatement contractor or supervisor is to never oversee a project, without first viewing and assessing the site. There is much valuable information to be gained during one of these assessments, such as determining the size of the job (number of sq. ft. or lin. ft. of asbestos containing material (ACM)) or examining the configuration of the surface or layout of the pipes from which the asbestos is to be removed. A survey such as this also provides the basis upon which the supervisor can formulate an effective strategy for asbestos removal and/or control. Existing damage or potential problems (expensive rugs, fixtures, etc.) need to be identified and procedures for resolution dealt with before work begins. Some of the important items an asbestos abatement supervisor needs to look for on this walk-through survey of the site are outlined in this section. Check Analytical Results of Bulk Samples The first questions that a supervisor probably should ask during the pre-job walk-through survey are who did the initial survey to identify the asbestos, what type of sampling was conducted, and what forms of analysis were used. The supervisor should review appropriate bulk sampling results as well as any relevant air sampling data. Not only will this help identify where the asbestos is, but also what the background levels of asbestos are in the area. If the abatement work will involve going into previously inaccessible spaces, i.e. behind walls etc., than the supervisor may wish to have additional bulk samples taken of any newly uncovered suspect material. Also, if the material in the area was only assumed to contain 113
asbestos, now might be a good time to find out for sure. This could save both time and money if it turns out not to have asbestos in it. Both bulk and air samples should be analyzed in an accredited laboratory. Any inspections done in schools, public, or commercial buildings must have been completed by an AHERA accredited asbestos building inspector. Bulk sample analysis must be done by laboratories accredited by the National Institute of Standards and Technology (NIST) through its National Voluntary Laboratory Accreditation Program (NVLAP). The supervisor should review the results of the bulk sample analysis to determine the types and percentages of the asbestos present. There are several reasons why this type of information will be of benefit to the supervisor. First, the analytical reports provide documentation that can be used in establishing a project file. The file can then be used as a good source of reference should any questions arise concerning the asbestos containing materials in the building. Information contained in the analytical reports is also important because different types of asbestos will require different handling methods. For example, amosite is difficult to wet and will require more aggressive control methods. Fiber counts tend to be higher with amosite than with other forms of asbestos. Inspect the Nature of the Asbestos-Containing Material The supervisor should determine the hardness or friability and texture of the asbestos containing material to be removed by touching it. He/she should note whether or not it has been covered, painted, or encapsulated. (A disposable suit and a HEPA filtered respirator may be needed to do this). Checking the Accessibility of the Material Note the accessibility of the material to be removed. If it is poorly accessible, an alternate control method such as restriction, encapsulation or enclosure might have to be used. Several factors that enter into this decision include ceiling height, false ceilings, pipes, sprinklers ducts, sloping floors, fixed barriers, etc. The building access may also require innovative methods. Checking for Difficulty of Isolating the Work Area Another important concern is isolating the area in which removal will take place. Is it possible to enclose the area completely by using 6-mil polyethylene? Or, will other measures have to be implemented in certain areas to adequately isolate the abatement site? In some cases it may be easier to simply line the walls and floors with two layers of 6-mil poly since all moveable objects will be taken from the room. However, if some fixed objects, like pews, blackboards, machinery, etc., must remain in the area, then plywood and plastic enclosures 114
may have to be constructed. This is to prevent the materials left in the room from being contaminated with asbestos during abatement activities. Determine if Areas Adjacent to Abatement Activity Will Be Occupied If areas adjacent to the abatement area will remain occupied, several important practices need to be observed. Most importantly the HVAC system will need to be altered or the controls locked out in the off position. The openings of the HVAC system into the work area must be completely sealed off. The supply, return and exhaust system serving a specific work area must be shut down and locked out or disconnected. Sealing off the HVAC system helps ensure that airborne fibers will not be drawn into the air return system and dispersed throughout adjacent areas, or the supply system will not place the work area under positive pressure and cause airborne fibers to escape. A redundancy in the number of negative pressure units is a prudent method to minimize the risk of loss of negative pressure and ensuing fiber release to the occupied areas. To provide documentation that contamination of adjacent areas has not occurred, a qualified person should take background air samples in each of the areas before abatement work begins. These results are then compared to the results of samples taken in these areas during and after the work is completed. By doing this sampling, it can be demonstrated that other areas were not contaminated as a result of the asbestos abatement work. In addition to these requirements, the OSHA standard says that whenever there are other employer' s employees working in an area adjacent to an asbestos abatement job, you must: 1.) Inform those employer' s employees about the nature of your work with asbestos, the existence of and requirements pertaining to regulated areas, and the measures taken to ensure that those employees are not exposed to asbestos. 2.) Abate any hazards at the work site that you created or had control over the source of contamination. For example, if there is a significant breach of an enclosure in which you were doing Class I asbestos work, then you would be responsible for repairing the breach immediately and decontaminating the area. 3.) If there are employees working adjacent to an asbestos project and they become exposed through a breach in the containment, then their employer must remove them from the area or perform an initial exposure assessment on them. 4.) The employer of employees working adjacent to a regulated area shall take steps on a daily basis to ascertain the integrity of the enclosure/ or the effectiveness of the control method to assure that fibers do not migrate to such adjacent areas. 115
Determine Room Volume and Natural Air Movement in the Work Area During this walk - through survey, consideration should be given to the number and placement of negative air units. A calculation of the air volume in the work area is necessary for determining the number of units needed to achieve the desired number of air changes per hour. Also, the way in which air will move through the work area is a consideration in the placement of the negative air units. Experience with negative pressure systems on asbestos abatement projects indicates a required minimum rate of one air change every 15 minutes. The volume (in cubic feet) of the work area is determined by multiplying the length of the room by its width and then by the height of the ceiling. The total volumetric airflow requirement (in cubic feet/minute) for the work area is determined by dividing this volume by the air change rate (i.e. one air change every 15 minutes). Total cubic feet/minute = Volume of work area (in cubic feet) 15 minutes The number of units needed for the application is determined by dividing the total cubic feet/minute by the rated capacity of the exhaust unit. Number of units needed = Total cubic feet/minute Capacity of unit (cubic feet/minute) The exhaust unit(s) should be located so that makeup air enters the work area through the decontamination facility and other makeup sources traverse the work area as much as possible. Check Items Requiring Special Protection During the pre-job walk-through, items requiring special protection should be noted. These items might include wood paneling, trophy cabinets, glass piping, carpets, lab equipment, chemicals, computers, and elevators. In the case of wood paneling, common sense should be used when hanging poly to enclose the work area. Care must be taken when tacking up the poly so that the paneling will not become damaged. The nails should be placed between the panel strips in the natural gaps as near to the ceiling as possible to prevent any small holes from being visible. For trophy/storage cabinets that are stationary and must remain in the work area while removal is taking place, proper measures must be taken to ensure that the cabinet is adequately enclosed with 2 layers of 6-mil poly and duct tape. During this initial survey, the supervisor should note the condition of any of these cabinets, and the exact contents of each to 116
prevent any future conflicts that could result if someone were to claim that something was damaged or missing. Glass piping is another item that the supervisor should note during the pre-job walk-through since special procedures must be followed to ensure that it does not become damaged. These glass/ceramic pipes will often contain hazardous materials (i.e. acids, hazardous waste, etc.). Therefore the pipes should be tagged and/or labeled as to their contents and workers should avoid contacting them if possible. These glass pipes are often found in the vicinity of other pipes, which have asbestos containing lagging on them. Therefore, contingency procedures must be established to prevent and handle hazards, which could develop from working around these pipes. Determine Supervisor' s Responsibility Concerning Moveable Objects During the pre-job walk-through, it must be determined what the supervisor' s responsibilities are concerning any and all moveable objects. Discuss with the facility head what equipment, furnishings, and finishes (i.e. light fixtures) must be cleaned, moved, stored, and reinstalled or discarded and replaced. This one aspect if neglected, can be quite costly. Does contamination already exist requiring cleaning of objects before they are moved? Where are these items to be stored? Will there be space in an area not being abated or will space need to be provided? Is reinstallation also, then the responsibility of the supervisor? Is it more cost effective to discard some items (i.e. carpeting, light fixtures, contaminated furniture, drapes, etc.) and replace? Some items moved and stored will, inevitably, be damaged or broken. Having all these considerations addressed during the pre-job walk-through will help alleviate misunderstandings and increased costs once the job has started. Special note should also be made of where carpeting is located in the facility. In most cases, the carpeting should be removed completely from the area in which the asbestos removal will be taking place. When fibers settle on a carpeted surface, they often penetrate through to the floor and become trapped underneath. Once this occurs, repeated traffic over the area will cause the fibers to be re-dispersed throughout the surrounding air. If carpet is specified for removal, assess the difficulty of removing it. Also, consideration must be given to disposal requirements/procedures. If carpet will remain in the area during the abatement, it must be covered with plywood and 2 to 3 layers of 6 mil poly. Note Any Materials or Equipment Which Will Require Special Handling Additionally, the supervisor should examine lab equipment and/or dangerous chemicals closely during the pre-job walk-through survey. It may be necessary to remove much of the equipment and/or chemicals from the work area before work begins. If the supervisor' s 117
employees will be moving expensive lab equipment or hazardous chemicals; the supervisor should ensure that all items are appropriately handled through training and/or direct supervision. This may be a tedious process requiring extra time to complete. In some cases the facility head will have the staff occupying the area perform these functions before the supervisor and his crew come on the site. Note Stationary Objects That Require Special Attention If the abatement work area will be in a room that contains computers that must remain functional, then this work must be contracted out. Elevators can also be a major problem on an asbestos abatement job. The elevator or the shaft can become contaminated with asbestos containing material or their movement can cause air displacement in contaminated areas. The supervisor will need to take special precautions to properly seal off the doors with 2 layers of 6 mil poly (sometimes even plywood) and to key the elevator not to stop at the floor(s) on which the work area is located. Other Considerations The supervisor should also document all pre-existing damage in the areas in which his/her employees will be working. This documentation should include all surface damage (walls, tables, desks, etc.) vandalism, roof leaks, or other water damage. This consideration is important because often after a project has been completed the staff reoccupying the area will claim that some damage occurred as a result of the work. By using the list that was developed at the beginning of the job, the supervisor can verify whether the damages were pre-existing and not as a result of the work. Other important aspects that should be considered by a supervisor when conducting a pre-job walk-through survey include an estimate of the temperature when the job is scheduled to begin. It may be that the job is at the end of the summer or in the winter. In these cases appropriate climate control strategies will need to be implemented. Also, at this time, it should be decided who will provide security at night or off-hours to assure that no unauthorized entries into the contaminated work area will occur. Additional safety hazards that need to be considered include all electrical circuits and/or receptacles, equipment, etc. Since the work area in an asbestos abatement job will commonly contain large amounts of water, the potential for electrical hazards will be greatly increased. During the pre-job walk-through the supervisor should make note of all these potential hazards. Once the facility head is made aware of these situations, an appropriate plan of action can be implemented. It may be possible and appropriate to shut down all power to the work area while the project is going on. If not, an outside contractor must be called in to do the job. 118
Another area of concern during the walk-through should be the configuration of the areas where tape will be attached. This is important to determine how the poly will have to be hung to adequately enclose the work area. Care must be used when hanging poly so that surfaces will not be damaged and the poly will stay in place. The issue of damage is of greater concern in office and public areas than in boiler rooms. This is an important consideration at this time since the supervisor will have to estimate how much material will be needed to enclose all work areas. Many times the facility head will want the project to be inconspicuous to the general public and other building occupants. Therefore, opaque poly may have to be used to construct from the work area outside to the waste disposal truck. Additionally, depending on the nature of the work area, special tools, equipment, and manlifts or sissorlifts may have to be used during prepping of the work area. The location and type of decontamination units should also be a major consideration. Will it be possible to have one central decontamination unit? Will it be necessary to establish multiple units? Some facilities may have their own units already built. Under no circumstances should the supervisor permit his/her employees to use regular building shower facilities as part of the decontamination sequence. Separate facilities should be constructed using appropriate wastewater filtration equipment. An advantage of building temporary site units is that the chance of residual contamination is reduced since they will be taken down and either disposed of or stored in an airtight container at the end of the job. All locations for decontamination units must be cleared with the Agency Safety & Health Specialist prior to construction. Also, a major area of concern when assessing a facility prior to beginning work is identification of any hot surfaces (pipes) that could present a hazard to abatement workers. First, it should be noted whether pipes would be active or inactive. If they are active, appropriate measures will have to be taken to ensure that workers will not contact these surfaces. If the lines are inactive, work may be carried out, as it would be on any other surface at normal temperature. The supervisor should investigate the types of insulation that will be required on surfaces and pipes after the asbestos has been removed. The original material was there for some specific purpose; thus, a replacement material with similar properties will probably be necessary. If Type C air supplied respirators will be used, the supervisor must determine whether or nor the hoses will reach the work area from the air generating source. Low-pressure air-supply lines cannot exceed 300 feet, according to OSHA regulations. Another important aspect that must be considered by a supervisor before a job, is whether air sampling will be necessary and if so, who will do the air monitoring and whether or not the person conducting the monitoring is qualified. This should be established in the project design. The facility head should always be responsible to ensure that daily air sampling is performed, but the supervisor is often responsible (and required) to conduct personal air 119
sampling on the Level II employees. The State Employees Asbestos Program is available to provide information and assistance on the requirements for air sampling. The supervisor should ensure that enough time has been allotted for the project. If the facility head calls for a hurry-up job, the supervisor should inform the facility head if they do not feel that adequate time is available to complete the project in a safe and satisfactory manner. Attempting to perform the job hastily may only result in sloppy work and may needlessly endanger the health and safety of employees or other building occupants. These are not all of the special considerations that need to be examined when conducting a pre-job walk-through survey of an asbestos containing facility; rather they are some common concerns that should typically be investigated because they could cost a substantial amount of money and time, in addition to possibly endangering the lives of employees or other building occupants. It is imperative that the supervisor and the facility head have a firm understanding as to how exactly each step of the project will be carried out. MEDICAL SURVEILLANCE The State is required as an employer to provide at no cost to the employee (if a Level II or former Level II employee) a physical examination by a qualified physician. There are specific items that these physicals must address (Refer to OSHA 29CFR 1926.1101). EMPLOYEE TRAINING Any workers who will be classified as Level II workers must be trained in how to work safely with asbestos. Under the Asbestos School Hazard Abatement & Reauthorization Act (ASHARA) and OSHA' s ConstructionIndustry Asbestos Standards (29 CFR 1926.1101), there are mandatory training requirements. These requirements dictate both the content and amount of training that employees must receive. Training is provided by the State Employees Asbestos Program at no cost to employees or their agencies at this time. After the facility head submits a list of names of those employees who need training, they are scheduled for the appropriate training course. Classes range from 3 to 5 days in length. Employees are required to pass a written exam for each class. Upon successful completion they will be issued a photo I.D. card. This card is valid for one year. One-day yearly recertification classes are also required in order to renew an employee' s accreditation.supervisors must ensure that these photo ID cards are available for inspection by State and Federal inspectors and compliance agents. 120
DESIGN AND USE OF A PROJECT LOGBOOK Prior to the start of any asbestos abatement project, a logbook should be established. This logbook will serve as a vehicle for maintaining all the records associated with a project. At a minimum, included in the book should be copies of the employee' s respirator status, medical clearance, copies of accidents and injuries, unusual events or occurrences (such as failure of the negative air machine or containment barriers), air sampling results, notes concerning any deviation from standard work procedures, sign in sheets, employee training records, MSDS s, and all other pertinent documents. Copies of these documents may be kept by other sources and you can obtain copies for your logbook. The logbook serves many important functions. First of all, it provides an easy reference for projects that can be presented at any time during a project, or long after its completion. Likewise, the logbook can be an important tool for planning future jobs and estimating costs. When planning a project similar in nature, it can aid in estimating how long the project will take to complete, how many people will be necessary, and how to approach specific problems. Another function of the project logbook is possible protection for a supervisor regarding liability over specific projects. A logbook documents that the supervisor performing the work actually doing the best work possible using state-of-the-art techniques. The sign-in sheets maintain a record of all people entering and exiting the work area, for what purpose, for how long, and what personal protective equipment they need. This information coupled with the air sampling data can quickly be used to estimate how much asbestos exposure the person was exposed to and for how long. Copies of daily inspection reports will also reveal if employees were wearing appropriate protective equipment and whether or not it was adequate in protecting them from the airborne fiber levels documented by the air sampling results. This information would be valuable if needed for litigation in the future. It is important to note that all records must be kept not just a portion of them. The logbook should be well organized, but in a style decided by the supervisor. There are two common methods of organization. First, there is the day by day such as a ship captain' s log. If this method is chosen, a loose leaf or bound notebook with dividers labeled for each day should be maintained for each job. Be sure to make entries on days that no work is done, including how the integrity of the job site was maintained. Another more common method of organizing a logbook is by activity. Using this method, a loose-leaf notebook is divided into each activity and all documentation, notes, and receipts concerning that activity are maintained in the appropriate section. The following outline is a suggested logbook organization format. (NOTE: This is just an outline; depending on the requirements of each project, some sections may not apply, while additional ones may be necessary.) 121
EXHIBIT XII-I LOGBOOK ORGANIZATION SECTION Pre-Work Papers Project Design CONTENTS EPA or State notification forms, or any necessary permits. Job specifications, including all drawings/diagrams, submittals (like MSDS s) would be in this section. Personnel Personnel records including employment application, W-4 withholding forms, medical records, state certification numbers and training certificates (on each worker and supervisor), consent forms, fit test results, and any other records pertaining to each employee. Some firms also have their employees sign certificates stating that they have read and understood the OSHA asbestos standard (29CFR 1926.1101), been trained in asbestos removal techniques, trained and fit tested for respirators etc. Sign-In Contractors Air Monitoring Waste Disposal A separate section containing the daily sign-in sheet indicating when each employee went in or out of the work area, their affiliation, and their purpose for entering the work area. In this section would be a list of all authorized personnel permitted to enter the contaminated area. Also in this section is a record of each employees work hours for payroll purposes. This section would be a record of all subcontractors activities including copies of the contract, names, dates, etc. All air sampling for the job should be included in this section. Area air sampling and personal sampling results should be presented. Also presented in this section should be a copy of the sampling and analytical method used along with information on who did the sampling and analysis. Equipment calibration data would also appear in this section. Records of waste disposal activities including trip tickets should be kept in this section. 122
Daily Other Sections Copies of daily inspection reports should be maintained. These reports, addressed Reports elsewhere, should also indicate who performed the inspection and date and time of the inspection. It is extremely important to include comments on unusual aspects of the project, and to address any problems that arose and how they were handled. Other sections may be added as necessary. Possibly injury/illness reports, receipts for rental equipment, lodging, outside inspections, newspaper clippings, minutes from progress meetings, etc. The responsibility of maintaining the logbook should be assigned to a responsible supervisory person. Normally the job site supervisor or the other person responsible for coordinating activities at the site performs this function. Upon conclusion of the job, this person may write a one-page summary of the project. This summary and the project logbook should be stored in a secure location. 123
DAILY PROJECT LOG DATE: / / PROJECT NAME: SUPERINTENDENT: (PRINT) NOTE: Fill in GENERAL comments on routine progress for the above date. DETAIL major problems and action taken, injuries, equipment breakdown, unusual conditions or situations, inspections, hiring or firing of personnel and any other occurrence which may affect the project. This log may be used as a legal document. Signature: 124
DATE: / / PROJECT: SUPT.: All personnel must sign in or out every time they enter/exit the work area. PLEASE SIGN CLEARLY JOB SIGN-IN/SIGN-OUT AND VISITORS LOG NAME & EMPLOYER TIME IN TIME OUT REASON/PPE ISSUED 125
EXAMPLE INVENTORY CHECKLIST FOR ASBESTOS ABATEMENT PROJECTS PROJECT: PERSONAL PROTECTION EQUIPMENT HAND TOOLS SAFETY BOOTS BENT 3" SCRAPER RUBBER BOOTS STRAIGHT 3" SCRAPER DECK SHOES 12" WIDE KNIVES PROTECTIVE CLOTHING, DISPOSABLE 6" WIDE KNIVES SHOWER CAPS, DISPOSABLE PUTTY KNIVES RUBBER GLOVES HAWK BILL KNIVES CLOTH GLOVES WIRE CUTTERS LEATHER GLOVES VOLTAGE TESTER HARD HATS RAZOR KNIVES PAPER TOWELS RAZOR KNIFE BLADES RESPIRATOR WIPES MEASURING TAPES FIRST AID KIT NYLON BRUSHES WETTING WANDS RESPIRATORY EQUIPMENT SCREWDRIVER, SMALL SCREWDRIVER, MEDIUM PAPR (BRAND "A") SCREWDRIVER, LARGE PAPR (BRAND "B") PHILLIPS SCREWDRIVER HEPA RESPIRATOR CARTRIDGES CABLE CUTTERS (BRAND "A") VICE GRIPS HEPA RESPIRATOR CARTRIDGES PLIERS (BRAND "B") CROWBARS PAPR BATTERIES (BRAND A) TIE WIRE PAPR BATTERIES (BRAND B) HAMMERS BATTERY POUCHES ELECTRIC STAPLE GUN BATTERY CHARGERS STAPLES SUPPLIED AIR MASK SWEEP BROOMS SUPPLIED AIR BELTS DUST PANS, PLASTIC SUPPLIED AIR HOSE MOPS CARBON MONOXIDE (CO) MONITOR MOP PADS AIR BOARD STRING MOPS RESERVE AIR BOTTLES MOP BUCKETS RESERVE AIR MANIFOLD 5/6" AIR LINE, 50' LENGTHS VACUUMS 3/4" AIR LINE SUPPLY MOISTURE TRAPS HEPA VACUUMS CROWFEET CONNECTIONS VACUUM ATTACHMENTS QUICK CONNECT FITTINGS (EXTRA) HOSE EXTENSION AIRLINE MANIFOLDS WET/DRY VACUUM GRADE D AIR SUPPLY COMPRESSOR VACUUM FILTERS/BAGS 126
NEGATIVE PRESSURE EQUIPMENT NEGATIVE PRESSURE EXHAUST UNITS PREFILTERS PLEATED FILTERS GROUND FAULT CIRCUIT INTERRUPTER (GFCI) NEGATIVE PRESSURE EQUIPMENT HEPA FILTERS EXTENSION CORD DUCT HOSE ADAPTER FOR WINDOWS PLASTICIZING MATERIALS DECON MATERIALS 6' LADDER 10' LADDER 12' LADDER 24" EXT. LADDER 40" EXT. LADDER PLYWOOD SHEETS REMOVAL MATERIALS TARPS 6 MIL POLY, 12 X 110, CLEAR BARRICADE TAPE 6 MIL POLY, 20 X 100, CLEAR WARNING SIGNS 6 MIL POLY, 24 X 100, CLEAR WATER TUBS, LARGE 6 MIL POLY, 28 X 100, CLEAR WATER TUBS, SMALL 6 MIL POLY, 32 X 100, CLEAR WATER FILTER HOUSING 4 MIL POLY, 12 X 100, CLEAR WATER FILTER, 100 UM 4 MIL POLY, 24 X 100, CLEAR WATER FILTER, 50 UM 4 MIL POLY, 20 X 200, CLEAR WATER FILTER, 25 UM 10 MIL POLY, 20 X 100, CLEAR WATER FILTER, 5 UM 6 MIL POLY, 20 X 100, BLACK LIGHT BULBS CLEAR TAPE, 3" WIDE CLOCK 2" DUCT TAPE WATER HOSE 3" DUCT TAPE HOSE ATTACHMENTS 3" BLACK TAPE HOSE GASKETS WHITE TAPE CHAINS FOR LOCKUP TAPE GUNS LOCKS WASTE DISPOSAL BAGS, 6 MIL ENCAPSULANT LABELED AIRLESS SPRAY RIG SUMP PUMPS PAPERWORK (SUPERVISOR) TEEL PUMP WETTING AGENT PROJECT LOGBOOK MIXING TANK REGULATORY BOOK GARBAGE CANS SIGN IN AND OUR FORMS FIBERBOARD DRUMS DISPOSAL FORMS BARREL PAPER WORKER RELEASE FORMS BARRELS STEEL ACCIDENT REPORT FORMS POWER SAW RESPIRATORY TRAINING FORMS HAND SAW WORKER TRAINING/CERTIFICATION FILE EXTENSION CORD 4 WAY OUTLET BOX FLASHLIGHT 127
DECON MATERIALS FLOOD LIGHTS SPOT LIGHTS, CLIP ON REGULAR SCAFFOLD PIECES SPONGES SCAFFOLD BRACES WIRE MASHER SCAFFOLD PINS PLYWOOD FORMS SCAFFOLD BOARDS 2' X 4' BOARDS SCAFFOLD JACKS NAIL BLOCKS WALKBOARD 24' SHOWER PANS WALKBOARD 20' MORTAR PAN YELLOW SCAFFOLDS WATER COOLERS CUPS ELECTROLYTE DRINK SOAP LYSOL WIRE NUTS WALL NAIL BLOCK CONCRETE BLOCK NAILS CONDUIT FRAMES STRAIGHT CONDUIT SHOWER HEAD BOARD SPRAY ADHESIVE 8' LADDER 4' LADDER NOTE: THIS IS NOT A COMPLETE CHECK-LIST. ITEMS VARY FROM PROJECT TO PROJECT. YOU ARE ENCOURAGED TO PREPARE YOUR OWN CHECKLIST. 128
PRE-ABATEMENT CONSIDERATIONS WHO WHAT WHEN WHERE -FACILITY -MATERIAL TO BE -PROJECT WINDOW -SITE REPRESENTATIVE. ABATED -WORK HOURS EVALUATION -PHYSICAL PLANT -MATERIAL TO BE -IMPACT OF DELAY LIAISON -WORK NOT INCLUDED PARTIES WHO IN PROJECT NEED -RENOVATION/RESTORATION NOTIFICATION NEEDS WHY -DO WE REALLY HAVE TO? -ARE THERE ALTERNATIVES? HOW -SECURITY -SPECIAL NEEDS SITE EVALUATION AKA SYSTEMS ANALYSIS Containment Problems * Identify open space scenario HVAC systems * onlyinworkarea * multiple services area * how to deactivate? * Holes, cracks & crevices to/be closed * Open Non-functioning pipes/ducts, etc. communicating with adjacent area. MECHANICAL SYSTEM Identify equipment to be taken out of services Identify equipment to left operating * Special ventilation, & other precautions * Identify facility personnel who may have to service/repair equipment. 129
ELECTRICAL SYSTEM Identify circuits - what can be cut off in work area Identify electrical capacity * Enough to handle negative air devices & HEPA vacuum cleaners & MISC equipment? * Where can temporary electric lines be tied into Determine other needs, e.g. need for portable generator, ground fault interrupter circuit, etc. present? PLUMBING SYSTEM Availability of water? Availability for hot water for shower? Where floor drains are located Sump pump wells present? Contamination in well? Toilet facility available? Need for portable toilet? Where can temporary water lines be installed? Vacuum breakers for hoses connections LIGHTING SYSTEMS Adequate natural light? Need for temporary lights? FIRE PROTECTION SYSTEM Presence of sprinklers, smoke alarms, etc? Will those be left activated? If not, what alternative measures are needed? FINISHES What finishes need special protection? 130
CHAPTER 7 SETUP In this chapter you will learn: How to keep asbestos out of the air. About wearing a respirator and disposable suit. What an asbestos job looks like. How to clean the work room. How to set up the work room. KEEP ASBESTOS OUT OF THE AIR Six basic rules for working with asbestos: 1. keep the asbestos wet 2. contain the work area 3. filter the air 4. use negative air pressure 5. practice good housekeeping 6. proper waste disposal No matter how good your respirator is, some asbestos will leak in. So one of the best ways to keep asbestos out of your lungs is to keep it out of the air. There are many ways to keep asbestos out of the air. These are called work practice controls and engineering controls. There are six basic rules for working with asbestos. Follow these rules when you take asbestos out of a whole room or off a single pipe. Follow these rules when you set up a job. Follow these rules when you take down the asbestos and properly dispose of it. Follow these rules when you clean up the work area. 1. Keep the asbestos wet When you work on asbestos, you must keep it wet. Dry, fluffy asbestos can send up a cloud of fibers you can' t even see. The fibers are so light they can float in the air for days. When the asbestos is wet, the fibers stick together. When you spray water into the air, onto the asbestos fibers they trapped by drops of water. The fibers are pulled down to the ground, out of the air. To make the water soak into the asbestos faster, always add a chemical called 131
surfactant which is a soap-like solution. Surfactant makes the water wetter. Water with surfactant in it is called amended water. Get the asbestos wet before you cut it or even touch it. Do this when you are working on a large job or a small one. Do this when you are setting up, removing asbestos, disposing of it, or cleaning up. 2. Contain the work area Cover the surfaces of the work area that will not be abated with plastic. Use polyethylene sheet plastic, which must be 6 mil thick. On the job it is usually called poly (pronounced polly). Putting up poly does four things: 1. It protects surfaces from water and asbestos. 2. It keeps asbestos from spreading outside the work area. 3. It keeps everyone but workers away from the asbestos. 4. It makes clean up easier. The plastic must be airtight. Put up plastic on large jobs and small jobs. When working on a whole room, use a full containment. When working on a small section of pipe, use a mini enclosure or a glove bag. 3. Filter the air Any air that has asbestos in it must be filtered before it is released from the work area. You must use a filter that is so fine it can catch the asbestos in the air. It is called a High Efficiency Particulate Air filter (HEPA-filter). A HEPA filter takes out 99.97% of all particles 0.3 microns or larger. (A micron is very small. More than 25,000 fit in one inch). 132
Respirators, vacuum cleaners, and negative air machines (see above); all must have HEPA filters in them so that the air will be safe to breathe. Never use an ordinary shop vacuum for asbestos work. The vacuum has a paper filter that will not trap asbestos. You will blow asbestos into the air. You must use a vacuum with HEPA filters (a HEPA vac) when you work with asbestos. 4. Use negative air pressure Put one or more heavy-duty fans with HEPA filters at one end of the work area. These are called negative air machines. The fans pull dirty air into the negative air machines. The HEPA filters catch the asbestos. All the air that leaves the room is clean. The negative air machines also pull clean air in from across the work area through the flaps at the entrance to the work area from the decon area. It makes the workroom a little cooler. This system also creates a negative pressure in the work area relative to adjacent areas. Thus, if there is a small leak in the containment, clean air will rush in instead of contaminated air leaving the workroom. If the leak in the containment is substantial however, negative pressure inside the workroom will be lost and asbestos contamination will spread to surrounding areas. Use negative air pressure on both large and small jobs. On a large job use a negative air machine for negative air pressure. On a small job, use a vacuum with HEPA filters (a HEPA vac) for negative air pressure. 133
Negative Pressure Filtration Systems The planning strategy for the use of negative pressure systems in abatement work includes three main goals. - Changing air within the containment area at a minimum of every 15 minutes while filtering the exhausted air through HEPA filters. - Achievement of 0.02 inches of water gauge negative pressure in the work area. - Establishing conditions in which air from all portions of the sealed zone is being pulled toward the negative pressure fans and HEPA filters. Negative pressure systems shall be used on an abatement project to accomplish several positive effects. - Containment of airborne fibers even if the barrier is ripped or punctured (as long as it isn' t a major failure). - Lower concentration of airborne fibers in the work area. - Worker comfort and increased productivity. - Improved efficiency in final clean up. Negative pressure filtration units are known by several names. EPA adopted the concept of air filtration systems as a primary control technique on asbestos abatement projects in 1983. A general discussion on negative air systems is provided in the following pages that are reproduced with some modifications from EPA report number 560/5-85-024, Guidance for Controlling Friable Asbestos-Containing Materials in Buildings, June 1985 ("The Purple Book"). RECOMMENDED SPECIFICATIONS AND OPERATING PROCEDURES FOR THE USE OF NEGATIVE PRESSURE SYSTEMS FOR ASBESTOS ABATEMENT This section provides guidelines for the use of negative pressure systems in abating asbestoscontaining materials in buildings. The manufacturer' s instructions for equipment use should be followed for negative air filtration units, as well as all other equipment discussed in this manual. A negative pressure system is one in which the static air pressure in an enclosed work area is lower than that of the environment outside the containment barriers. 134
The pressure gradient is maintained by exhausting more air from the work area than is coming into the work. Exhaust air is filtered by a series of pre-filters and then a high efficiency particulate air (HEPA) filter to remove asbestos fibers. The use of negative pressure during asbestos abatement helps protect against the large-scale release of fibers to the surrounding area in case of a small breach in the containment barrier. A negative pressure system can also reduce the concentration of airborne asbestos in the work area by increasing the dilution ventilation rate (i.e., diluting contaminated air in the work area with uncontaminated air from outside) and exhausting contaminated air through HEPA filters. The circulation of fresh air through the work area reportedly also improves worker comfort by increasing the cooling effect, which may aid in the abatement process, by increasing job productivity. MATERIALS AND EQUIPMENT The Portable, HEPA-Filtered, Powered Exhaust Unit The exhaust unit establishes lower air pressure inside than outside the enclosed work area during asbestos abatement by moving air from the contaminated work area to the outside. Basically the unit consists of a cabinet with an opening at each end, one for air intake and one for exhaust. A fan and a series of filters are arranged inside the cabinet between the openings. The fan draws contaminated air through the intake and filters and discharges clean air through the exhaust. 135
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Portable exhaust units used for negative pressure systems in asbestos abatement projects should meet the following specifications. STRUCTURAL SPECIFICATIONS The cabinet should be ruggedly constructed and made of durable materials to withstand damage from rough handling and transportation. The width of the cabinet should be less than 30 inches to fit through standard doorways. Appropriate cabinet seals should prevent asbestos-containing dust from being emitted during use, transport, or maintenance. There should be easy access to all air filters from the intake end; the filters must be easy to replace. The unit should be mounted on casters or wheels so it can be easily moved. It should also be accessible for easy cleaning. MECHANICAL SPECIFICATIONS Fans The fan for each unit should be sized to draw a desired air volume through the filters in the unit at a specific static pressure drop (see manufacturer' s literature for this information). The unit should have an air-handling capacity of at least 500 to 2,000 cubic feet per minute (CFM or ft 3 /min) under "clean" filter conditions. The fan should be the centrifugal type. For large-scale abatement projects, where the use of a larger capacity, specially designed exhaust system may be more practical than several smaller units, the fan should be appropriately sized according to the proper load capacity established for the application i.e., (volume of work area in ft 3 )(air changes/hour) Total ft 3 /min = 60 min/hour Smaller capacity units (e.g., 500 ft 3 /min) equipped with appropriately sized fans and filters may be used to ventilate smaller work areas. The desired airflow could be achieved with several units. Filters Prefilters, which protect the final filter by removing the larger particle, are recommended to prolong the operating life of the HEPA filter. Prefilters prevent the premature loading of the HEPA filter. They can also save energy and cost. One (minimum) or two (preferred) stages of prefiltration may be used. The first stage prefilter should be a low efficiency type (e.g., for particles 10 um and larger). The second stage (or intermediate) filter should have a medium efficiency rating (e.g., effective for particles down to 5 um). Various types of filters and filter 137
media for pre-filtration applications are available from many manufacturers. Prefilters and intermediate filters should be installed either on or in the intake grid of the unit and held in place with special housings or clamps. The final filter must be the HEPA type. Each filter should have a standard nominal rating of at least 1,100 ft 3 /min with a maximum pressure drop of 1-inch H 2 O clean resistance. This pressure drop will increase with the filter load and the manufacturer' s literature will indicate a clean filter pressure drop and a recommended maximum allowable pressure drop for dirty filters. The filter media (folded into closely pleated panels) must be completely sealed on all edges with a structurally rigid frame and cross-braced as required to prevent air bypassing the filter. Exact dimensions of the filter housing should correspond with the dimensions of the inside the cabinet or the dimensions of the filter holding frame. The recommended standard size HEPA filter is 24 inches high x 24 inches wide x 11-1 / 2 deep. The overall dimensions and squareness should be within 1 / 8 inch. A continuous rubber gasket must be located between the filter and the filter housing to form a tight seal. The size of the gasket material is dependent upon the manufacturer. (Some manufacturers use gaskets that are approximately 1 / 4 inch thick and 3 / 4 inch wide.) This gasket should be checked periodically for cracks and gaps. Any break in this gasket may permit significant leakage of contaminated air. Leaks in the gasket or filter will be indicated by lower than normal "clean resistance" pressure. Each HEPA filter should be individually tested and certified by the manufacturer to have an efficiency of not less than 99.97 percent when challenged with 0.3 micrometers (um) dioctylphthalate (DOP) aerosol. Each filter should bear a UL586 label to indicate ability to perform under specific conditions. Each filter should be marked with: the name of the manufacturer, serial number, air flow rating, efficiency and resistance and the direction of test air flow. Instrumentation Each unit should be equipped with a Magnehelic gauge or manometer to measure the pressure drop across the filters, which would indicate when filters have become loaded and need to be changed. The static pressure across the filters (resistance) increases, as they become loaded with dust, affecting the ability of the unit to move air at its rated capacity. ELECTRICAL General The electrical system should have a remote fuse disconnect. The fan motor should be totally enclosed, fan cooled, and the non-overloading type. The unit may use a standard 115-V, 138
single phase, 60-cycle service. All electrical components approved by the National Electrical Manufacturers Association (NEMA) and Underwriter' s Laboratories (UL). Fans The motor, fan, fan housing, and cabinet should be grounded. All units should have an electrical (or mechanical) lockout to prevent the fan from operating without a HEPA filter. Instrumentation An automatic shutdown system that would stop the fan motor in the event of a major rupture in the HEPA filter or blocked air discharge is recommended. Optional warning lights are recommended to indicate normal operation, too high of a pressure drop across the filters (i.e., filter overloading), and too low a pressure drop (i.e., major rupture in the HEPA filter or obstructed discharge). Elapsed time meters may also be purchased to show the total accumulated hours of operation of the negative pressure units. SETUP AND USE OF A NEGATIVE PRESSURE SYSTEM Determining Approximate Ventilation Requirements for a Work Area Experience with negative pressure systems on asbestos abatement projects indicates a required minimum rate of one air change every 15 minutes. The volume (ft 3 )oftheworkareais determined by multiplying the floor area by the ceiling area and height. The total volumetric airflow requirement (ft 3 /min) for the work area is determined by dividing this volume by the specified air change rate (i.e., one air change every 15 minutes). * ** Total ft 3 /min = Volume of work area (ft 3 )/15 min * The minimum required air exchange rate. ** This formula is different than the previous one, but both are correct and will yield the same result. The number of units needed for the application is determined by dividing the total ft 3 /min by the rated capacity of the exhaust unit. Total ft 3 /min Number of units needed = Capacity of unit (ft 3 /min) 139
Be sure to add one additional unit for backup. Also keep in mind that the capacity of the machine as rated may not be the same during actual performance. Location of Negative Air Machines The negative air machine(s) shall be located so that makeup air enters the work area through the decontamination facility and other makeup air sources. Makeup air shall traverse the work area as much as possible. This may be accomplished by positioning the negative air machine(s) at a maximum distance from the worker access opening of the decontamination facility or other makeup air sources. Wherever practical, work area negative air machines can be located on the floor in or near unused exterior doorways or windows. The end of the unit or its exhaust duct should be placed through an opening in the plastic barrier or wall covering. The plastic around the unit or duct should then be sealed with tape. Each unit must have temporary electrical power (115V A.C.). If necessary, three wire extension cords can supply power to a unit. The cords must be in continuous lengths (without splice), in good condition, and should be not more than 100 feet long. They must not be fastened with staples, hung from nails, or suspended by wire. Extension cords should be suspended off the floor and out of worker' s way to protect the cords from traffic, sharp objects, and pinching. Negative Air Machines must be vented to the outside of the building. This may involve the use of additional lengths of flexible or rigid duct connected to the air outlet and routed to the nearest outside opening. Keep the amount of flex duct at a practical length to avoid affecting the fan s capacity. Windowpanes may have to be removed temporarily. Additional makeup air may be necessary to avoid creating too high a pressure differential, which could cause the plastic coverings and temporary barriers to detach from the walls and fall. Additional make-up air also may be needed to move air most effectively through the work area. Supplemental makeup air inlets may be made by making openings in the plastic sheeting that allow air from outside the building into the work area. Auxiliary makeup air inlets should be as far as possible from the exhaust unit(s) (e.g., on an opposite wall), off the floor (preferably near the ceiling), and away from barriers that separate the work area from occupied clean areas. Make up air inlets should be constructed in such a fashion (using weighted flaps, etc.) that allows the openings to be sealed in case of accidental pressure differential loss. Because the pressure differential (and ultimately the effectiveness of the system) is affected by the adequacy of makeup air, the number of auxiliary air inlets should be designed and placed in order to maintain adequate pressure differential and to maximize air circulation throughout the work area. Figure 7-1 presents examples of negative pressure systems denoting the location of HEPAfiltered exhaust units and the direction of airflow. Figure 7-2 is a schematic representation of negative air HEPA system in place. 140
Figure 7-1 Examples of negative pressure systems. DF, Decontamination Facility; EU, Exhaust Unit; WA, Worker Access; A, Single -room work area with multiple windows; B, Single-room work area with single window near entrance; C, Single-room work area with exhaust unit placed on the outside of the building; D, Large single-room work area with windows and auxiliary makeup air source (dotted arrow). Arrows denote direction of airflow. Circled numbers indicate progression of removal sequence. 141
Figure 7-2 142
USE OF THE NEGATIVE PRESSURE SYSTEM Testing the System The negative pressure system should be tested before any asbestos containing material is wetted or removed. After the work area has been prepared, the decontamination facility set up, and the exhaust unit(s) installed, the unit(s) should be started (one at a time). Observe the barriers and plastic sheeting. The plastic curtains of the decontamination facility should move slightly in toward the work area. The use of ventilation smoke tubes and an aspirator bulb is another easy and inexpensive way to visually check system performance and direction of airflow through openings in the barrier. For example, smoke emitted on the inside of the work area at a barrier should not leak outward. Smoke emitted in the shower room of the decontamination facility should move inward toward the work area. Smoke tubes can also be used to check that airflow is moving inward at high and low levels of the work area. Another test method for negative pressure is to use a Magnehelic gauge (or other instrument) to measure the static pressure differential across the barrier. The measuring device must be sensitive enough to detect a relatively low-pressure drop. A Magnehelic gauge with a scale of 0 to 0.25 or 0.50 inch of H 2 O and 0.005 or 0.01 inch graduations is generally adequate. The pressure drop across the barrier is measured from the outside by punching a small hole in the plastic barrier and inserting one end of a piece of rubber or Tygon tubing (be sure to seal around the tubing if the tube is left in place). The other end of the tubing is connected to the "low pressure" tap of the instrument. The "high pressure" tap must be open to the atmosphere. The pressure is read directly from the scale. After the test is completed, the hole in the barrier must be patched. Instruments are also available which monitor the pressure drop continuously. These units can be connected to a strip chart recorder to provide continuous documentation of negative pressure. An audible and /or visible alarm may be used to alert the project manager of a severe drop in pressure. Typically, a pressure drop of 0.02 inches of water is maintained throughout the asbestos abatement project (this pressure drop is affected by the air change rate). Use of System During Removal Operations The negative air machines shall be started just before beginning removal (i.e., before any asbestos-containing material is disturbed). After removal has begun, the machines shall run continuously to maintain a constant negative pressure until decontamination of the work area is complete. The machines shall not be turned off at the end of the work shift or when removal operations temporarily stop. 143
Employees should start removing the asbestos-containing material at a location farthest from the negative air machines and work toward them. Employees should try to avoid putting themselves in between the asbestos and the negative air machine. If an electric power failure occurs, removal must stop immediately and should not resume until power is restored and the machines are operating again. However, work activities to ensure that accumulated waste on the floor stays wet should still be conducted. Because airborne asbestos fibers are microscopic in size and tend to remain in suspension for a long time, the negative air machines must keep operating throughout the entire removal, decontamination, and final clearance process. Leaving the negative pressure operating during the final clean-up and clearance process allows the suspended fibers the potential to be "cleaned" from the air. Also, until the results of final clearance air samples are known, the confining and minimizing aspects of negative pressure filtration are needed to ensure leakage of contaminated air outside the enclosure does not occur. To ensure continuous operation (and therefore continuous negative pressure differential), a spare negative air pressure machine shall be readily available at all times. Filter Replacement All filters must be accessible from the work area or "contaminated" side of the barrier. Thus, personnel responsible for changing filters while the negative pressure system is in use should wear approved respirators and other protective equipment. The operating life of a HEPA filter depends on the level of particulate contamination and other conditions (such as high humidity) in the environment in which it is used. During use, filters will become loaded with dust, which increases resistance to airflow and diminishes the air-handling capacity of the unit. The difference in pressure drop across the filters between "clean" and "loaded" conditions is a convenient means of estimating the extent of air-flow resistance and determining when the filters should be replaced. When the pressure drop across the filters (as determined by the Magnehelic gauge or manometer on the machine) exceeds the pressure specified by the manufacturer, the prefilter should be replaced first. The prefilter, which fan suction will generally hold in place on the intake grill, should be removed with the unit running by carefully rolling or folding in its sides. Any dust dislodged from the prefilter during removal will be collected on the intermediate filter. The used prefilter should be placed inside a 6 mil plastic bag, sealed, and labeled and disposed of as asbestos containing waste. A new prefilter is then placed on the intake grill. Filters for prefiltration applications may be purchased as individual precut panels or in a roll of specified width and must be cut to size. 144
If the pressure drop still exceeds the manufacturer' s specified pressure after the prefilter has been replaced, the intermediate filter is replaced. With the machine operating, the prefilter should be removed, the intake grill or filter access opened, and the intermediate filter removed. Any dust dislodged from the intermediate filter during removal will be collected on the HEPA filter. The used intermediate filter should be placed in a sealable 6 mil plastic bag (appropriately labeled) and disposed of as asbestos containing waste. A new replacement filter is then installed and the intake grill or filter access closed. Some brands of negative air machines require removal of the prefilter to gain access to the intermediate filter. This filter should be replaced as the last step of replacing the intermediate filter. The HEPA filter should be replaced if prefilter and/or intermediate filter replacement does not restore the pressure drop across the filters to its original clean resistance reading or if the HEPA filter becomes damaged (HEPA filters will fail if they absorb too much moisture). The negative air machine is shut off and disconnected from the power source to replace the HEPA filter (A backup machine shall be used during filter changing to ensure proper negative pressure is maintained.) Used HEPA filters should be placed in a sealable 6 mil plastic bag (appropriately labeled) and disposed of as asbestos containing waste. The gasket between the filter and the housing should be inspected for any gaps or cracks. Worn gaskets should be replaced as needed. A new HEPA filter (structurally identical to the original filter) should then be installed. The intake grill and intermediate filter should be put back in place, the machine turned on, and the prefilter positioned on the intake grill. Whenever the HEPA filter is replaced, the prefilter and intermediate filter should also be replaced. When several exhaust units are used to ventilate a work area, negative pressure can be maintained during the HEPA filter replacement and the direction of airflow into the work area will be maintained. If only one or two exhaust units are operating on-site, a backup unit shall be available and operating before an original unit is shut down for HEPA filter replacement. An abatement enclosure must have at least one exhaust unit operating at all times! A backup machine is essential because failure of the one unit for any reason would eliminate the negative pressure in the work area. Thus, the risk of asbestos fiber release to the outside environment is controlled with the backup machine. Any filters used in the system may be replaced more frequently than the pressure drop across the filters indicates is necessary. Experience has shown that prefilters, for example, should be replaced two to four times a day or when accumulations of particulate matter become visible. Intermediate filters must be replaced once every day or so, and the HEPA filter may be replaced at the beginning of each new project. (Used filters must be disposed of as asbestos containing waste). Conditions in the work area dictate the frequency of filter changes. In a work area where thorough wetting and good work practices effectively control fiber release, fewer filter changes mayberequiredthaninworkareaswherethe removal process is not well controlled. 145
It should also be noted that the collection efficiency of a filter generally improves as particulate accumulates on it. Thus, filters can be used effectively until resistance (as a result of excessive particulate loading) diminishes the exhaust capacity of the unit. Dismantling the System As gross removal nears completion, filters should be checked for loading and replaced if necessary. If a prefilter is being used on the outside of the negative air machine, it should be removed before final cleanup begins. Filters in the exhaust system should not be replaced after final air clearance sampling is complete in order to avoid any risk of re-contaminating the area. When the negative air system is shut down at the end of the project, the filters should be left in the negative air filtration machine and the openings sealed with polyethylene and duct tape to avoid spreading contamination when the unit is moved from the work site. Tips for Using Negative Air Pressure Systems 1. Check the integrity of the gasket between the HEPA filter and housing each time the filter is changed or after the unit has been transported to a new location 2. Changing out the prefilters as soon as the gauge shows an increase over recommended pressures will prolong the life of the much more expensive HEPA filter. 3. Before removal begins, check the availability of a 20-amp circuit. Most negative air machines require 18 amps for start-up and 15 amps during normal operation. 4. Negative air machines usually pull less volume than the ratings assigned by the manufacturer. For instance, a unit rated at 2,000 CFM will typically pull 1300-1500 CFM. Also, as filters load, the CFM is reduced. Note: The reduced flow volume at the maximum accepted pressure drop (see manufacturer' s literature) should be the criteria used for this calculation. Adjust your calculations accordingly for the number of machines as necessary. 5. Start the negative air machine(s) before beginning work and check to see if it is functioning properly. Make sure there is adequate makeup air, otherwise the polyethylene may pull away from the walls. 6. Ventilation smoke tubes are useful for checking airflow inside the containment. 7. Use heavy-duty extension cords to energize the negative air filtration units as recommended by the National Electric Codes. If a series of cords are connected, take necessary precautions to avoid shock hazards. Make sure the temporary electrical system is properly grounded. 146
8. As a rule of thumb, the containment area should be no larger than 10,000 square feet for efficient use of a negative air filtration system. 9. The negative air system is most effective in reducing fiber concentrations when workers start removal at the farthest point from the negative air units and work toward them. 10. When venting the negative air filtration exhaust outside a window, a good seal can be formed by placing a piece of plywood with a hole cut for the flex duct in the window and sealing it with duct tape. Another seal can be formed by placing a piece of 6 mil polyethylene over the plywood template and cutting a slit in it for the insertion of the exhaust duct. Duct tape is used to seal the space between the opening and the flex duct. 5. Practice good housekeeping To reduce fiber release, good housekeeping is a must. This means that you do not let asbestos pile up on the floor where it can dry out and be reintroduced into the air. Bag the asbestos as you work while it is still wet. In addition, you must never drop or throw asbestos. 6. Dispose of Asbestos Waste Properly All asbestos waste must be disposed of in 6mil specially labeled bags or fiber drums. It must be sent to an EPA approved landfill. It must be transported in an enclosed truck. You cannot take the waste just anywhere. After you follow these six basic rules, there will still be asbestos in the air. You must wear a respirator and you must wear a disposable suit every time you work with asbestos. 147
KEEPING ASBESTOS OUT OF THE AIR Key Facts One of the best ways to keep asbestos out of your lungs is to keep it out of the air. Six basic rules for keeping asbestos out of the air: 1. Keep the asbestos wet. Wet down the asbestos material before you handle it. To make the water soak into the asbestos faster, add a chemical called surfactant. Water with surfactant in it is called amended water. 2. Contain the work area with plastic (poly). The plastic can be as large as a work room or as small as a glove bag. 3. Filter the air with High Efficiency Particulate Air filters (HEPA filters). Use a respirator with HEPA filters. Use a HEPA vacuum. Use a negative air machine to clean the air that leaves the work room. 4. Use negative air pressure. Use a negative air machine to clean the air. 5. Practice Good Housekeeping bag waste while wet, don t drop or throw it. 6. Properly Dispose of all waste must go to an approved landfill You must wear a respirator and a disposable suit every time you work with asbestos. 148
Discussion Questions 1. Why not try to spread asbestos fibers around and lower the concentration in the air? 2. Why won' t fibers leak out if there is a negative air machine set up? For more information *OSHA Asbestos Standard, 29 CFR 1926.1101 Your instructor has a copy of this publication for you to look at. 149
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SET UP - OVERVIEW By now, you know that protecting your lungs with respirators and wearing disposable suits is very important. You also know about some ways to keep asbestos out of the air. One way to do this is to cover the surfaces that will not be abated with 2 layers of 6 mil sheet plastic (Poly.) This keeps the asbestos in the work area. It keeps it out of the rest of the building. Now you will apply the rules you have learned, to a large asbestos removal job (> 10sq. ft. or 25 lin. Ft. but < 160sq. ft. or 260lin. Ft. or 35 cu. Ft.). Keep the asbestos wet, contain the work area, filter the air, use negative air pressure, practice good housekeeping and cleanup and dispose of all asbestos-containing waste properly. When you take asbestos off a whole ceiling, build a full containment. Do this when you take asbestos off a whole run of pipes or air ducts or a whole wall or floor. Cover the surfaces that will not be abated with 2 sheets of 6 mil plastic (poly). Seal off all the exits except one. Build a decontamination unit or decon there. If you are removing more than 10 sq. ft. or 25 lin. ft. of asbestos you will need a decontamination unit that has a clean room, a shower room, and an equipment room all separated from each other, the outside, and the work room by double flap doors made of 6 mil poly. If you are removing less than these amounts then an equipment room or area will be all that is required. Set up a negative air machine at the other end of the room. Most of this manual is based on what OSHA regulation says you have to do as well as the State Employees Asbestos Program requirements. SETUP Setup is at least 40% of an asbestos job. Experienced asbestos supervisors know that a good setup is at least 40% of an asbestos job. Before you even touch the asbestos, you have to cover the room with 6 mil sheet plastic (poly). You have to turn off both the existing ventilation and electrical systems in the work area. You have to clean and protect the room. You have to bring in extension cords for your lights and negative air machines. Good setup makes the rest of your job much easier. It also prevents many safety problems. For jobs over 3 sq. Ft. or 3 lin. Ft., an accredited Project Designer must write up how the job will be done. This should tell you how to setup the work area. An accredited Supervisor must supervise setup. The supervisor is called the "competent person". 151
Before you do any work, find out if you need to put on a disposable suit and respirator. Remember: If there is any possibility of asbestos dust then you will definitely need to wear a disposable suit and respirator during set up. Set up the work room in this order: 1. Notify affected parties and put up warning signs 2. Begin recording activities in a project log 3. Shut off the ventilation system, lock out the controls, and cover and seal vents 4. Shut off the electrical system and lock out the controls. 5. Bring in extension cords. 6. Bring scaffolds and tools into the room. 7. Build the decontamination (decon). 8. Hook up and start the negative air machine. 9. Clean everything in the room. 10 Throw out what you can' t clean. 11. Take out anything you can move. 12. Wrap anything you can' t move in 6 mil poly. 13. Cover all openings (Critical Barriers) in the room with 2 layers of 6 mil. plastic (poly). 14. Put two layers of 6 mil poly on all surfaces that are not being abated. 1. Put up warning signs Notify building occupants and employees of intentions involving asbestos. Put up a barrier outside the work area. This will keep non-workers out. Hang asbestos warning signs on the barrier. The signs must look exactly like this one. The signs should be at eye level. They should be in a language that building users can read. 2. Begin using the project log This is the time to begin using the asbestos project log. See section 6 for more detailed instructions for use. 3. Shut off the ventilation system The ventilation system carries air through the building. It can carry asbestos through the building. Asbestos fibers go where the air goes. The ventilation system for the work area must be shut off. Shut off the system at the electrical box. Lock the box and label it with a tag. Cover and seal the vent openings with 2 layers of 6-mil thick plastic. The ventilation system is often called the HVAC system. HVAC stands for Heating, Ventilation, and Air Conditioning. 152
4. Shut off the electrical system Asbestos jobs are wet. Electrical shocks are one of the worst dangers on an asbestos job. Water can leak into an electrical outlet and kill you. The electrical system must be shut off. Shut off the system at the electrical box. Lock the box and label it with a tag. Turning off wall switches is not enough. Someone who doesn' t know about asbestos work could electrocute you by mistake by throwing a switch that is not locked and tagged out. For more information consult OSHA s Elect rical Safety Work Practices Standards 29 CFR 1910.333. Machines and other mechanical systems also have to be shut off. A machine with moving parts could hurt someone. It has to be turned off and locked out so that people can work safely around it. For more information consult OSHA s Control of Hazardous Energy Standard 29 CFR 1910. 147. Steam pipes have to be shut off too. Let the pipes cool for at least 12 hours before working on them. For more information consult OSHA s Control of Hazardous Energy Standard 29 CFR 1910. 147. 5. Bring in extension cords Negative air machines, safety lights, HEPA vacuums, and tools all need power. Bring in extension cords for all the equipment. Extension cords are sometimes called temporary wiring. Tape the cords onto the walls so that workers won' t trip on them. Do not hang cords with metal wire. This could cause a shock. Cords must be hooked up to sensitive circuit breakers. These are called Ground Fault Circuit Interrupters (GFCI' s). 6. Bring scaffolds, ladders, and tools into the work area Scaffolds may be too big to bring through the decontamination unit (decon). Bring the scaffolds in before the decon is hooked up. Put tape over any open the ends of the scaffolds so that asbestos won' t fall n. i Bring in any large equipment. Be sure that all the tools you need are in the work area before removal begins. 153
7. Build the decontamination unit (decon) You go into and leave the work area through a special series of rooms. This is called the decontamination unit (decon). The decon has a shower. Every time you leave the work area, you must take a shower or wash off. Don' t take asbestos out of the work area on your body with you. The decon has three rooms. They have to be in this order (starting from the work area): Work area - Dirty room - Shower - Clean room 154
The decon is lined with two layers of 6 mil thick poly and duct tape. The rooms have plastic flaps between them. The flaps keep air from moving out, but let air come in. Seal the decon air- tight to the work area. Make sure the base plastic (poly) extends one foot up the side framing. This ensures that any asbestos laden water will not leak out. 155
Some decons have extra empty rooms (airlocks). These keep air from moving out through the decon. Some new decons have solid doors with gaskets (rubber strips around the edge). Air comes in through HEPA filters or flaps built into the walls of the decon or work room. Some contractors build their own decons. They use wood, pipes, poly, spray glue, and tape. Some contractors use hard plastic decons. Others use decon trailers that go outside the building. Sometimes a separate decon is built for waste bags and tools. This is called a waste load out. 8. Hook up and start the negative air machine The clean air from the negative air machine goes out a window to the outside. The seal at the window has to be airtight. Cut holes in a piece of plywood and tape the hose in. If you are working in a large room, there will be more than one machine. Put the negative air machine as far away as possible from the decon. Air should be pulled away from workers across the longest possible distance from the decon. You may have to use hoses if the only window in the room is right next to the decon. If there is more than one machine, they should all be on the side of the room farthest from the decon. When the negative air machine is on, air comes into the room through the decon. The negative air machine should be on 24 hours a day until the project passes final clearance air monitoring. Air should only leak in, not out. Sometimes extra holes are cut in the poly so that enough air will come in. This is called makeup air. These holes must be covered on the inside with plastic flaps or HEPA filters in case the negative air machine shuts down. 9. Clean everything in the room You might do a great job of scraping the asbestos off a ceiling. But what about the asbestos fibers that were on the furnishings and surfaces before you started the job? Asbestos fibers must be cleaned up. If you don' t clean before you take the asbestos off, the room will still be dirty at the end of the job. Clean everything in the room before you put up the poly (plastic). In this situation be sure to wear a respirator and disposable protective clothing. Use damp rags and HEPA vacuums. When you clean, you may get asbestos in the air. Even if you can' t see it, the asbestos may be there. As soon as you start to disturb asbestos, put on a respirator and disposable suit. Your employer should test the air. You must have permission from a doctor before you may wear a respirator. You must pass a fit test before you may wear a respirator. 156
Clean everything in the room: - walls - electrical outlets - floors - paintings - window sills - posters - furniture - books - air vents - office equipment - office supplies - machines - circuit breakers - fuse boxes - lights - non-moveable objects Clean the surface of air vents with damp rags and HEPA vacuums. Wet the filters and dispose of them with the asbestos. After deactivating the power, clean electrical outlets with HEPA vacuums. If needed, clean de-energized circuit breakers and fuse boxes with HEPA Vacuums. Clean the lights inside and out with HEPA vacuums. Clean carefully, starting at the top of the walls and working down. Fold the rags periodically to expose a new clean portion of the rag. Otherwise you will spread asbestos onto places you' ve already cleaned.the rags have to be thrown out with the asbestos. 10. Dispose of what you can' t clean Contaminated rugs and fabric on furniture must be disposed of. Wrap the rug in two layers of poly (plastic). Seal it up with duct tape and put a label on it. The label must look like the OSHA label. Send the rug to an asbestos landfill. 11. Take out anything you can move Move anything you can out of the room: - chairs - office supplies - books - desks - machines - air grates - computers - paintings - lights - cabinets - posters - bookshelves There is no excuse for piling furniture in a corner of the room. Even if you cover it with poly, it will get asbestos or water on it. Lights should always be taken out unless they can' t be moved. If they can t be moved they will need to be protected as outlined in step 12. 157
12. Wrap anything in poly you can' t move Those objects that you can' t movemust be sealed. Wrap them in two layers of 6-mil thick poly and duct tape. Put tape on all of the seams. Tape the poly to the floor. The poly has to be totally sealed so that it is air tight, not just draped over the machine. Sinks and water fountains also have to be sealed in two layers of poly. Shut them off at the valve. Label them with DO NOT DRINK signs. You may not use the sinks or electrical boxes in the room during the job. Seal up electrical boxes, blackboards, thermostats, alarms, and anything else that must stay in the room. In places like boiler rooms you may have to seal off a working machine. This is hard, since poly will melt and can burn at 150 degrees. Machines give off heat and may also need air to work. You may have to build an enclosure around the machine. You have to keep asbestos out of the machine without staring a fire. If machines cannot be shut off or safely enclosed, State employee cannot do that asbestos job. It must be contracted out. 13. Cover all windows and openings to the room In the work area, air should only come through the decontamination unit (decon) Air should only go out through the negative air machine. Seal up any other places where air can go into or out of the room. Cover windows and doors with two layers of 6-mil thick poly and duct tape. Leave part of one window uncovered for the negative air machine. Cover all these places: - windows - air vents - electrical outlets, boxes, & conduit openings - doors - light wells (where lights were taken out) - pipe chases (where pipes go through a wall) - holes in surfaces Cover air vents with two layers of 6 mil poly. Seal them with duct tape. Seal the poly so that no water and no air can get in or out. Cover light wells with two layer of 6 mil poly and duct tape. If you can' t take the lights out, seal them up with poly and tape. The poly over windows and other openings that communicate with other areas is called a "critical barrier". 158
14. Put poly on the floor (or other surface not being abated) The first layer of poly goes on the floor or other surface not being abated. Cut the poly big enough so that it goes up the walls or other areas not being abated at least one foot. Tape all the way around the edges of the poly. The idea is to build a watertight plastic basin inside the room. The poly on the floor should catch all of the asbestos and water. Air and water should not leak out of the basin. Try to cover the whole surface with one piece of poly. If there are seams in the poly, they have to be sealed. Overlap the seams of plastic 12 inches. Use duct tape. It is a good idea to put a line of blue carpenter' s chalk under the seams. If water and asbestos leak through, they will make the chalk dark. Then you can clean them up before they damage the floor. There may be seams in both layers of poly. Put the seams from each layer at least 6 feet apart. Then a leak in the top layer won' t leak through the bottom layer.the poly should overlap other surfaces not being abated by at least 12 inches. 15. Put poly on the walls (or other surface not being abated) Cut the poly big enough so that it comes down at least one foot onto the floor. There should be at least a one-foot overlap between the poly on the floor and on the walls (or other surfaces not being abated). Tape the poly on the top of the walls. 159
Don' t tape it one or two feet down from the ceiling. Remember that the poly has to make an airtight and watertight bubble inside the room. It protects the walls from asbestos and water. If the top of the wall is not covered, it may get asbestos on it. It will probably be damaged. Tape all the way around the edges of the poly at the bottom. Poly is heavy, and duct tape can come loose when it' s wet. Duct tape may not be strong enough to hold the poly on the walls. You may have to nail furring strips (small pieces of wood) to the walls. Staple the poly to the furring strips. Put duct tape over all the staples and the edge of the poly. When you have finished putting the first layer of poly on the floor and walls, or other surfaces not being abated, repeat steps 13 and 14 with a second layer. There must be two layers of poly on all surfaces not being abated. Otherwise, if there is a leak, the asbestos will get on the surfaces of the room. Work areas can be poorly illuminated and confusing, especially in an emergency or in the dark. It is a good idea to make some arrows out of bright luminescent tape on the walls that point the way to the decon. In an emergency, the arrows will show you how to get out of the work area. Testing the negative air machine The negative air machine should pull the plastic doors in the decon toward the machine. You can test the negative air pressure in the room. Puff ventilation smoke from outside the clean room. The air and smoke should be pulled in through the decon. The smoke should be sucked in, not drift out through cracks. Test the seals on primary barriers to make sure they are really airtight. (If you cut a hole to do the smoke test, seal it up). You have now built an airtight and watertight containment, which is under negative air pressure. You are ready to begin removing the asbestos. 160
SETUP Key Facts Good setup makes asbestos work safer and easier! Always wear a suit and a respirator when you work with asbestos 1. Put up warning signs and barriers at eye level. 2. Shut off and isolate the ventilation system. 3. Shut off the electrical system. Lock out the electrical box. Don' t count on a switch to protect you. 4. Tape extension cords up off the floor. 5. Bring scaffolds and tools into the room before you build the decon. 6. The decon has three rooms (starting from the work area): Work area - Dirty room - Shower - Clean room 7. Set up the negative air machine at the other end of the room from the decon. 8. Clean everything in the room before you put up poly. 9. If you can' t clean something, wrap it in poly, label it, and take it to an asbestos landfill. 10. Take out anything you can move. 11. If you can' t take something out of the work area, seal it airtight and water tight with poly and duct tape. 12. Cover all doors and windows with 2 layers of 6 mil poly. Cover air vents, pipe chases, and electrical outlets with 2 layers of 6 mil poly. 13. Tape one layer of 6 mil poly on the surfaces not being abated overlapping other surfaces one foot. 14. Put one layer of 6 mil poly on the other surfaces not being abated overlapping by one foot. Put another layer of 6 mil poly on the surfaces not being abated. 161
Discussion questions 1. Why shouldn' t the electricity be turned off at the wall switches? 2. Why are two layers of poly put on the floor? 3. Some state laws say you have to put plywood on the floor if you leave carpets on the floor when you remove asbestos. Why is this done? 4. You have to protect yourself from asbestos when you set up. What other dangers do you need to think about when you' re setting up? 5. You are about to start a project where the material being removed is on the ceiling of a computer room and the computers cannot be shut down. How could you do the preparation of the work area? For more information *OSHA Asbestos Standard 29 CFR 1926.1101 * "Pre-Work Activities and Considerations" and "Preparing the Work Area and Establishing the Decontamination Unit," in "Model Curriculum for Training Asbestos Abatement Contractors and Supervisors." *EPA, "Guidance For Controlling Asbestos-Containing Materials in Buildings," (The Purple Book) EPA Publication No. EPA560/5-85-024. *National Institute of Building Sciences, "Temporary Enclosures," in Model Asbestos Abatement Guide Specification, Section 01526. *Your instructor has a copy of this publication for you to look at. 162
CHAPTER 8 RECORDKEEPING STATE EMPLOYEES ASBESTOS PROGRAM MAJOR AREAS OF RECORDKEEPING I. Personnel Records A. Medical Monitoring and training - records kept by the Departmental Asbestos Coordinator with notification to the Agency Asbestos Safety & Health Specialist and facilities. B. Retraining - Kept by the Agency Asbestos Safety & Health Specialist with notification to the Departmental Asbestos Coordinator. C. Refusal - Kept by the Departmental Asbestos Coordinator, notification as necessary. D. Consent - Kept by Agency Personnel Department after hiring process. E. Fit Test Results- Kept by Person in Charge of the Respirator Program F. Redesignation/Change of Position Forms Kept by Agency Safety & Health Specialist II. Facility-Wide Asbestos Records A. Asbestos Hazard Report - investigation and reporting by Agency Asbestos Safety and Health Specialists, notification of the Departmental Asbestos Coordinator. B. Special reports from Tracor (baseline) survey. C. Survey reports - from DHMH, Tracor (baseline survey), DGS, etc. D. Asbestos Management Plan. E. Periodic Surveillance Results F. Information to rebut the presence of Asbestos 163
III Level II Asbestos Work A. Level II work log - by the Agency Asbestos Safety & Health Specialists. B. Individual job records. (by Bldg.) C. Exposure Monitoring Results D. Quarterly review - summary of asbestos work performed, hazard investigation and other asbestos problems to the Departmental Asbestos Coordinator - by Agency Asbestos Safety & Health Specialist. IV. Equipment A. Inventories - Kept by Agency Asbestos Safety & Health Specialist. B. Maintenance and Repair - Kept by the Agency Asbestos Safety & Health Specialist. C. Usage logs - Kept by the Agency Asbestos Safety & Health Specialist. D. Written Respiratory Protection Program - Kept by Person in Charge of the Program 164
FIGURE 1 PERMIT APPLICATION FOR PERFORMING MAINTENANCE REPAIR WORK INVOLVING ASBESTOS 1. Address, building, and room number of area involved. 2. Starting Date: Anticipated Completion Date: 3. Description of Work Involved: 4. Approximate amount of asbestos (linear feet of pipe, size of tank, other) 5. Planned asbestos control methods to be used (i.e., glovebag, HEPA vacuum, wet methods) 6. Type of Protective Equipment to be worn 7. Name and telephone number of supervisor Please return this form to: 165
FIGURE 2 ASBESTOS MAINTENANCE/REPAIR PROJECT CLOSURE FORM 1. Address, building, and room number of area involved. 2. Project Start Date: Project Completion Date: 3. Description of Work Involved: 4. Amount of asbestos removed (linear feet, etc.) 5. Asbestos Control Methods Used: 6. Employees Performing Work (please list) 7. Type of Protective Equipment Worn by Employees 8. Were any unprotected employees in work area at any time? (If so, explain). 9. Where was waste disposed of? 166
10. Was Air Sampling Performed? YES NO (If yes, by whom?) The following items should be attached (as applicable): 11. Permit to perform work, with copy of work order 12. Air Sampling Results 13. Landfill receipts 14. Other pertinent information or photographs 15. Any unusual occurrences during the project? YES NO If yes, please explain Supervisor' s Signature: Date: (Return to Asbestos Coordinator at ) Asbestos Coordinator: Date: 167
ASBESTOS MONITORING CHECK SHEET DATE: CONDITION OF ASBESTOS: GOOD NEEDS REPAIR LOCATION: TYPE OF ASBESTOS: DAMAGE DESCRIPTION: CAUSE/CORRECTION: SUGGESTED REPAIR: REPAIR CHECK LIST ATTACHED: YES NO INSPECTOR: SUPERVISOR: 168
CHAPTER 9 REMOVAL In this chapter you will learn: Removal How to go into the work area. How to take asbestos off ceilings, walls, and pipes. How to keep asbestos out of the air. How to bag asbestos waste. How to go out of the work area. How your employer measures asbestos in the air. Six basic rules for working with asbestos: - Keep the asbestos wet - Contain the work area - Filter the air - Use negative pressure - Practice good housekeeping - Properly dispose of asbestos waste material Good setup makes the work of taking asbestos off the substrate much easier. Taking off asbestos safely means using the basic rules we' ve talked about all through this manual. You have to keep the asbestos wet, contain the work area, filter the air, use negative air pressure, practice good housekeeping, and properly cleanup and dispose of all waste. You also have to use respirators that fit right and disposable suits. Entering the work room When you go into the work area, start in the clean room of the decon. In the clean room, take your street clothes off. Put them in a locker. Inspect your respirator. 169
Put it on and do the negative and positive pressure user seal checks. Make sure your respirator fits. Inspect your suit and put it on. Use duct tape to make it fit right so you won' t trip over it. Pull the hood of the suit over the respirator straps. Tighten the hood around your face. Always wear a respirator and a disposable suit when you work with asbestos. Walk through the shower room and into the dirty (equipment) room. Put on any gear stored there. You might put on boots, hard hats, or a belt for your respirator hose. Pick up scrapers, squeegees, and other tools. If you are using a Type C respirator, the hookup is usually in the decon. Some workers may put on pumps. These are called personal air sampling pumps. They are small air pumps that you wear on your belt. A hose goes under your shoulder. A small plastic cylinder with a paper filter clips to your collar. The filter faces down. The pump pulls air through the filter. The pump should be on all the time you are working. Asbestos in the air is caught on the filter. Your employer sends the filter to a lab. The lab tells him how many fibers are in the air when you are working. Never touch the filter when you are working. This will interfere with the air sample. Personal air sampling tells you how much asbestos is in the air. The supervisor is responsible for deciding whether PAPR or Airline respirators will be worn. When there is more asbestos in the air, you have to wear a respirator with a higher Protection Factor. When you go into the work area, the negative air machine must be on. 1. Keep the asbestos wet The first step in taking off the asbestos is getting it wet. Wet the asbestos before you remove it, while you remove it, and after you remove it. Use a low-pressure sprayer or a garden sprayer. Use enough amended water (water with surfactant) to really soak the asbestos. Follow the manufacturer' s instructions when mixing the surfactant. 170
The asbestos may turn a darker color or swell a bit. Sometimes asbestos is in a paper cover. Make a small hole in the paper and spray water inside it. At least one worker should wet the asbestos as the work goes on. He or she should make sure that the asbestos on the ceilings, pipes, etc. is really wet. The worker should mist the air as the work goes on. Drops of water will catch the asbestos in the air and pull it down to the floor. The worker should wet the asbestos on the floor until it is put in bags. Use only enough water to make sure the asbestos stays adequately wet. Too much water could leak through the poly or cause someone to slip and fall. Remember that plain water will not soak into amosite asbestos. Never use water on live electrical lines. You could get a bad shock. All temporary lines should be connected to a GFCI. Never use water on a hot steam line. The water could boil (flash) and burn you. 2. Scraping Once the asbestos is wet, it is usually the texture of cooked oatmeal. You can easily scrape it off with plastic or rubber scrapers. You may have to use ladders, scaffolds, or long handled scrapers to get to the asbestos. It is safer to use a scraper with a long handle than to stand on a scaffold. Take asbestos off pipes with scrapers and utility knives. You may need snips to cut wire or metal bands. Chicken wire can be sharp. Use the tool to cut the metal. You can burn yourself on a hot pipe. Wear gloves to protect your hands. Asbestos may be in wire lath, which is heavy and sharp. You may need a hardhat or steel-toed boots to protect you from falling plaster. As you take asbestos off, don' t throw it. Don' t drop it. Scrape as much as you can directly into a waste bag to avoid cleaning up asbestos on the floor. If you work on a high ceiling, bag the asbestos on the scaffold or lower it to the ground using a scaffunnel (as in the picture). You must never use an air gun to blow asbestos off. Scrape it or cut it off. asbestos into the air. Air samples show that air guns blow a lot of asbestos into the air. Highpressure water or air can force asbestos into cracks or blow it out of the work area. Water guns cannot be used in Maryland. After you scrape off the big pieces, there will still be some asbestos on the substrate. Use a nylon bristle brush to take off all the asbestos. Wire brushes break the asbestos into smaller, more dangerous fibers. Be sure to scrub off all the asbestos. 171
Wipe the surface with a damp lint free rag until you can' t see any asbestos at all. Remember to fold the rag periodically to expose a clean portion of the rag. 3. Bagging Bagging asbestos promptly as it is being removed is one of the best ways to keep it out of the air. The asbestos will dry out if it sits on the floor or piles up. When workers walk through it, a lot of asbestos fibers will get into the air. A few workers will use plastic shovels and squeegees to bag the asbestos as it is taken off. (Metal shovels can rip the poly). Be sure the asbestos is wet when you put it in the bag. Asbestos must be put in sealed containers (bags or drums) with warning labels. Use a HEPA vacuum to pull the air out of the bag. Then twist the top of the bag. Tape around it. Double the top of the bag back on itself. Tape around it again. This is called "goosenecking" the bag. Just tying a knot in the top of the bag will not make a watertight seal. On the job, workers usually put one bag inside another. If the first bag breaks, asbestos won' t leak out. This is calleddouble bagging. Put sharp metal lath in cardboard drums. Wrap large pieces of waste (like carpets) in two layers of poly and tape them up. Put a label on the poly. Private contractors have to put their license # and company name on the bags as well as the date that the bag was sealed. Use only the amount of water necessary to keep the asbestos adequately wet so that workers won' t slip. Use a wet/dry HEPA vacuum to pick up small amounts of asbestos and water. (Water will ruin a dry HEPA vacuum). 4. Tools Use plastic or composite tools, such as scrapers, shovels, and squeegees. Metal tools can rip the poly and can also contribute to electric shocks. Use special power tools on an asbestos job. They have a HEPA vacuum attached. (This is called local ventilation or local exhaust ventilation). Power tools should be double insulated or they should be grounded. This means they are less likely to shock you, even if they are wet. Never use a regular shop vacuum. You should not use a regular drill, saw, or other power tool. All tools should have HEPA vacuums attached to them. 172
Filters in the negative air machine need to be changed many times a day. Be sure they are wet before you put them in a waste bag. Never take off your respirator inside the work area. Always wear your respirator and suit inside the work area. Never take off your respirator inside the work area. If your suit tears, fix it with duct tape. If you have to put on a new suit, you must decontaminate first (See page 174). You may not eat, drink, chew gum, chew tobacco, smoke or apply cosmetics in the work area. To do that, you would have to take your respirator off. Don' t do it! Supervisors are required to ensure that the integrity of worker s suits is not breached and that they follow proper decontamination procedures. 5. Clean up every day Clean all of the asbestos off the floor at the end of every day. Never allow the asbestos to dry out. Use wet rags and HEPA vacuums to clean the poly. It is easy to rip poly. Shovels, scaffolds, equipment, and tools can all rip the poly on the floor. As a supervisor you must check the poly periodically throughout the work and fix any rips or holes right away. 173
6. Decontamination You must go through decontamination every time you leave the work area. When you leave the work area, clean off your suit and respirator. In the decon take off your suit, take a shower, and wash your respirator. Leave the asbestos fibers behind you. Don t take them into the clean room or outside. In the work area, clean off your suit with a damp rag or a HEPA vacuum cleaner. Go into the dirty room (this is sometimes called the equipment room). Take off your hard hat, boots, and any other dirty equipment. As the supervisor, you will take any sampling pumps off of the workers and turn them off. Wipe off your equipment and leave it in the dirty room. Take off your suit carefully and discard it. Fold it inside out as you take it off. Try to keep the asbestos on the suit and off your skin. Leave your respirator on, and get into the shower. Wipe off the motor and the battery of the PAPR. Do Not get them wet! Hold them away from the water. (A face-mounted motor may need to be removed from the face piece before showering). Wash off the facepiece under the showerhead. Rinse your face and the rest of your body. Take the dirty wet filters off your respirator and throw them out with the asbestos contaminated waste. Remember water destroys HEPA filters. If your filters get wet, you must discard them. Take off your respirator and wash it in soap and water. Wash your body and your hair with soap and water. In the clean room, put on street clothes or another disposable suit. It usually takes 3 to 5 minutes to decontaminate. If you do not take this long, you are probably taking asbestos home with you. Don' t take asbestos fibers home, decontaminate every time you leave the work area! 174
The shower must have warm water, towels, and soap. There must be one shower for every ten workers. If men and women both work on the job, they will shower separately. You must decontaminate every time you leave the work area. Every time you take a break, you decontaminate. Every time you go to the bathroom, wash your face, eat, drink, or smoke, you must decontaminate. You must dispose of your suit, wash your respirator, and take a shower. When you go back in, you have to put on another suit. You can' t take short cuts with decontamination. You may decontaminate four or more times each day. At the end of the day, clean the dirty room. Use wet rags and HEPA vacuums. Clean up any asbestos you can see. Seal up the bag with dirty suits and respirator filters. Water from the shower must be filtered before going into the sewer system. 7. Asbestos cleanup jobs Most asbestos jobs are planned ahead of time. But sometimes you may work on a job that wasn' t planned. If there is an accident - a fire, or a flood or a ceiling falls in - you may have to go and clean up the asbestos. The building owner has to shut off the ventilation and electricity as soon as the accident happens. The building owner must also get people out of the area and put up OSHA signs to keep non-asbestos workers out If you clean up such a site, you can' t just walk in and put up poly. You have to make sure the building is safe to work in while you take out the asbestos. (A local government building code inspector must decide this) Is the electricity shut off? Is the fire totally out? Once you are sure the building is structurally safe you can think about the asbestos. After you set up, the job will look like any other removal job. You will have to put up plastic, build a decon, and run a negative air machine. You must wear a respirator and a disposable suit. There may be a lot of asbestos in the air. You should wear a Type C respirator until air sampling shows that asbestos fiber levels are below 10f/cc. When you come in, there will probably be dry asbestos all over the floor. Everyone must wear disposable suits and respirators while setting up. Build the decon before you handle any asbestos. The first step is to get the asbestos wet. Bag some of the asbestos to make room to walk around in. Cover the air vents and set up a negative air machine. You may have to build barriers if the room opens up into a hallway. After that, take out the asbestos, just like any other job. If you are already on the job and a lot of asbestos falls down, get it wet right away. Stop all other work and bag up the asbestos. 175
8. The competent person One of the most important people on an asbestos job is the "competent person". By law, your employer has to have one person on every shift that makes sure that rules are followed. The competent person is usually an accredited Supervisor or Project Designer who has been accredited under the Model Accreditation Plan. This person has 5 to 3 days of training respectively. The competent person must make sure that no one but trained workers are on the job. The competent person must make sure that everyone wears respirators and disposable suits. This person must make sure that there are enough disposable suits, duct tape, respirator filters, and other supplies. The competent person must supervise set up. The competent person must make sure that the negative air machine is working. The competent person must check the work area to make sure the poly stays up. He or she must make sure that everyone goes through decontamination. This person must make sure that rules about eating, drinking, and smoking on the job are followed. The competent person should be well trained, and a good source of information. You as the competent person may be asked questions about how to do the work safely. You should be able to answer them or know where to get the answers. 9. What you can do to work safely There are many things your employer has to do to make the work safer. But there are also a lot of things you have to do to keep yourself safe. Always wear your respirator. Keep it in good shape. Do your fit checks. Wear your disposable suit and a hard hat if you need one. Clean yourself off carefully in the decon. Don' t take asbestos home with you. You are the only one who can do these things. The difference between doing a good job and doing a sloppy job could cost you your health or even your life! 10. Waste Disposal You may only store 20 cubic yards of waste at your facility. Such waste must be in rigid containers (like fiber drums) inside of a secure (locked) area. The containers of waste must be properly labeled. All waste that is disposed of must have a manifest. This manifest must be returned to the facility after the waste is disposed of. 176
REMOVAL Key Facts Good setup makes asbestos work easier and safer! Protection Use good work methods - keep the asbestos wet, contain the work area, use negative air pressure, filter the air with HEPA filters, and practice good housekeeping. Use respirators that fit right and disposable suits. Do negative and positive pressure user seal checks before you go in the work area. Never take your respirator off inside the work area. Removal Wet the asbestos and keep it wet. Do not use vacuum cleaners or power tools unless they have HEPA filters on them. Do not drop or throw asbestos. Bag it as you remove it as close to the removal area as possible Keep asbestos out of the air by wetting the air. Waste disposal Keep asbestos out of the air by bagging it as soon as possible while the material is still wet. Do not let asbestos waste dry out. Use waste bags with warning labels. Pull all the air out of the bag with a HEPA vacuum and seal it airtight. (Gooseneck the bag.) Waste must have a manifest when sent to a landfill. No more than 20 cubic yards of waste can be stored on site. Decontamination Enter and leave through the decon. You must decontaminate yourself (throw out your suit, take a shower with your respirator on, and throw out your respirator filters) every time you leave the work area. 177
Setup and decon exercise This is not a test. It is an exercise. Use it to see for yourself how well you understand the material in the chapter. 1. Why do you contain the work area? 2. How do you do it? 3. In what order do you cover the work area with poly? 4. Where is the equipment room? 5. What happens in the equipment room? 178
Discussion questions 1. Why do you put colored chalk under the seams between sheets of poly on the floor? 2. Why do you put tape or wood over poly on stairs in the work area? 3. There are some jobs where you need to be extra careful. If you know about good work methods, how to wear a respirator, and how to understand air-sampling results, you can figure out what to do on an unusual job. Here are a few examples which you can use for discussion: Amosite asbestos Can' t shut off electricity Working equipment in the room Taking off asbestos above a dropped ceiling Taking off part of the asbestos in a large room (taking off half of the ceiling from a whole warehouse) For more information *OSHA Asbestos Standard 29 CFR 1926.1101 * "Confining and Minimizing Airborne Fibers," in "Model curriculum for Training Asbestos Abatement Contractors and Supervisors." *EPA, "Guidance for Controlling Asbestos-Containing Materials in Buildings," (the "Purple Book"), EPA Publication No. EPA 560/5-85-024. *National Institute of Building Sciences, "Removal of Asbestos-Containing Materials," in Model Asbestos Abatement Guide Specifications, Section 02081. *Your instructor has a copy of these publications for you to look at. 179
CHAPTER 10 CLEANUP AND DISPOSAL In this chapter you will learn: How to clean up the work area. How to take down the poly on the walls and floor. What happens to asbestos after it leaves the job. How your employer tests the air at the end of the job. How to replace the insulation. Cleanup and disposal Clean up all the asbestos you can see... and all the asbestos fibers you can' t see It is very important to clean up the work area after you remove the asbestos. The work is not finished until the job passes a final visual inspection by the competent person (supervisor) and a final clearance air sample test. These are very strict tests. If all of the asbestos has not been cleaned off the beams, poly, waste bags, pipes, and other surfaces, the job will not pass the air sample test. Everything will have to be cleaned again, until the job passes this test. It can be very expensive to clean and take air samples again. If you do a careful job the first time, you will not have to spend time later on cleaning the room again. 1. Clean up the asbestos you can see 180
It takes a long time to clean up an asbestos job. The first step is to clean up all the asbestos you can see. As you take the asbestos down, bag it up. Clean the substrate and other surfaces with nylon bristle brush. Wipe the surface with a damp lint free rag until you can' t see any fibers. As a supervisor, you will do a visual inspection at this time to ensure that no visible asbestos remains on the substrate. Next, remove any bags of asbestos waste from the work area. Make sure you wipe them off first. 2. Waste disposal Everything used on the job must be cleaned or disposed of. Poly, disposable suits, and respirator filters have to be disposed of with the asbestos as asbestos containing waste. All poly has to be sealed in airtight bags with labels just like asbestos. Sometimes there is a waste load out chamber, which is like a decon for waste bags. It has two rooms - a washroom and a holding room. A worker inside the work area puts the bag into the washroom. A worker in the washroom washes off the bag and stores it in the holding room. People don' t walk through the waste-load-out. Only waste bags go through it. Anything with asbestos on it must be taken to a landfill that follows EPA regulations. It must be sealed in leak-proof, labeled bags or containers. The waste truck must have closed sides and a top along with lockable doors. The truck should be lined with poly. It must be cleaned at the end of the job. 3. Take down the first layer of poly After you have locked down the substrate with a lock down encapsulant, you are ready to wet wipe and HEPA vacuum the first layer of poly. Use lint free rags to do the wiping so that they won t leave fib ers behind. Some air clearance methods can t distinguish between rag fibers and asbestos fibers. 181
Also, wipe in one direction only and never go back over an area you just wiped. Fold the rag frequently to expose a clean surface. Start at the top and work down. After the first cleaning, do an inspection. Make sure there is no asbestos that can be seen. After you clean, you' re ready to take down the first layer of poly. Make sure you do this in the reverse order from how you put it up. Cut the sheets into six-foot-wide strips. Cut through one layer of poly only. Gently loosen the duct tape. NO RIPPING, NO TEARING! Roll the poly onto itself, from the top down. Fold it into bundles that you can handle easily, and bag it. 4. Take down the second layer of poly Repeat the actions in step 4 for the second layer of poly. Remember to allow time for a visual inspection before removing the poly. 182
5. Take the poly off non -moveable objects/ clean poly on critical barriers Clean the poly on the non-moveable objects just as you did for the first and second layers of poly. Remove this poly after you make sure it is cleaned. Next, clean the poly on the critical barriers but do not remove it. This poly must remain in place until the job passes final air clearance monitoring. (On most Level II jobs, final clearance air monitoring will not be necessary. In this case you can remove the critical barrier poly after you remove the poly from the non-moveable objects.) 6. Shut off negative air machine(s)/disassemble the Decon After the job passes the air monitoring, you can shut off the negative air machines and disassemble the decon. The negative air machines, tools, and the interior of the decon should have been cleaned prior to this. Take apart the decon in pieces and roll the poly in on itself. Plywood must be disposed of as contaminated waste but PVC pipe can be cleaned and reused. If you are putting back a substitute material, you can leave the critical barrier poly and the decon in place until you have put up the substitute material. 7. Tool Clean up Cleaning tools Everything that leaves the job has to be cleaned. This includes: scrapers respirator scaffolds hoses squeegees hard hats ladders tools water sprayers boots negative air machines HEPA vacuums Scrub everything off and rinse it well. Seal it in clear waste bags with labels, and take to the next job. You must clean everything very well, especially if it will be used on a non-asbestos job. 183
CLEANUP AND DISPOSAL Key Facts 1. Use damp lint free rags and HEPA vacuums to clean up the work area. First clean all the asbestos you can see. Then clean all the asbestos you can' t see. 2. Spray a lockdown encapsulant on the surface and on the poly. 3. Roll up the poly from the top down or inside out and bag it as asbestos waste. Leave the critical barriers in place until the job passes the clearance air sampling. 4. Take asbestos, poly, dirty suits and other waste to an EPA-approved asbestos landfill. 5. Clean all tools with wet rags and HEPA vacuums. 6. The clearance air sampling tells the building owner whether the area is clean enough. Clearance air sampling uses aggressive sampling - stirring up the air with fans and leaf blowers. Clearance air samples are sent to a lab, where the fibers are counted. A Transmission Electron Microscope (TEM) is often used. A job is not clean until air-sampling results show less than.01 f/cc or background. 7. After the job passes the clearance air sampling, put on new insulation (sprayback) and take down critical barriers. 184
Discussion Questions 1. Why is it important to clean up the poly if it will be thrown away? 2. Some people say that lockdown should not be used. They argue that cleanup should be done so well that lockdown is not needed. What do you think? 3. After taking off most of the asbestos, a contractor spray painted the beams instead of cleaning them off. What is the problem with this? 4. Why is the air stirred up before clearance air samples are taken? 5. Why do you wait until after the job passes the air test to put on sprayback? 6. In what order would you conduct the following clean-up activities? Wet wipe/hepa vacuum first layer of plastic. Conduct final visual inspection of the work area. Disassemble the decontamination unit. Wet wipe/hepa vacuum the second layer of plastic. Clean critical barriers. Conduct clearance air monitoring. Take down critical barriers. Spray a lockdown encapsulant on substrate. Remove all bags of ACM debris from the work area. FOR MORE INFORMATION *OSHA Asbestos Standard, 29 CFR 1926.1101 * "Sampling and Analytical Methodology Pertaining to Asbestos Abatement," in "Model Curriculum for Training Asbestos Abatement Contractors and Supervisors." * EPA, "Asbestos Waste Management Guidance: Generation, Transport, Disposal," Publication No. EPA/530-SW-85-007. Your instructor has a copy of these publications for you to look at. 185
Lock down Once a visual inspection by a competent person verifies that there is no visible residue, seal up the asbestos fibers you can t see. Use a low -pressure sprayer to spray a sealant called "lockdown" encapsulant. You can spray or brush on the sealant to pipes. Be sure that the "lockdown" encapsulant you use is compatible with the substrate to which it is applied and the new insulation that will be installed. The "lockdown" encapsulant glues down any fibers you missed so they can' t get in the air. It is hard to pass the clearance air sample test at the end of the job without it. You may not use lockdown spray instead of cleaning. Sprayback or Replace the Asbestos Containing Material with Non-Asbestos Containing Material Many times new insulation to replace the asbestos is needed. This could be fiberglass, mineral wool, or some other non-asbestos insulation. This replacement is called sprayback when it applies to re-insulating ceilings, beams, and columns. Don' t put up sprayback or substitute materials until the job passes the final visual inspection and the final clearance air test. Replacement materials may not be completely safe! Find out how to work safely with them. You should wear a respirator when you put up fiberglass or mineral wool. Just because the material isn' t asbestos, doesn' t mean it' s safe. After you put up the sprayback or other substitute materials, you can take down the critical barriers. You can take the poly off the objects in the room. You can clean the decon and take it down. You can take out the negative air machine. Sprayback or replacement materials must meet the requirements of applicable building codes. Selection of the sprayback or other substitute materials should be done by a licensed, professional engineer or architect. Air Sampling Personal Air Sampling Your employer must take 8-hour air samples from some workers on every shift. (There are a few exceptions). Your employer has to know how much asbestos is in the air under the worst conditions. Usually, 1/4 of the workers wear sampling pumps each day. Personal air samples also tell you whether you' re doing the work right (keeping asbestos out of the air). If air samples show a lot of asbestos in the air, you should verify that the asbestos is really wet, that the negative air machine is working, and that asbestos isn' t piling up on the floor. 186
Building owners sometimes take air samples outside the work area. They want to know if asbestos is leaking out of the work area. These are called area air samples. You may see airsampling pumps outside the clean room. You may also see them outside the negative air machine or outside the building. Even if your employer takes area air samples, the employer also has to sample workers. At the end of the day the filters from the air sampling pumps go to a lab. At the lab, the technician cuts a small piece of the filter. The technician dissolves the filter and counts the asbestos fibers under a microscope. The microscope is called a Phase Contrast Microscope (PCM). The lab sends your employer a report. The report has the number of asbestos fibers per cubic centimeter of air (fibers per cc or f/cc). Your employer must post the air sampling results as soon as he or she gets them from the lab. AirSampleResultsHelpTo: 1. Tell if you are using the right respirator. 2. Tell if your work practices are working. Final Clearance Air Monitoring Prior to testing the air, a final visual inspection is done by the owner s representative and the competent person. All visible residue must be cleaned up before air testing. A job may look clean, but what about the asbestos you can' t see? There is no way to know if the room is clean without testing the air. On some jobs, after the poly is taken down, an industrial hygienist (IH) will take air samples. The air samples tell the building owner whether the room is clean enough. This final air sampling is called clearance air sampling. Clearance air sampling is different from the air samples taken on workers. It is done aggressively by stirring up the air with fans and leaf blowers. A pump pulls air through a filter. The fans stir up any fibers that are on the walls, floors, or corners. More fibers can be caught on the filter. 187
Stirring up the air is called aggressive sampling. The final air sample is sent to a lab, where the fibers on the filters are counted. There are several ways to count the fibers. In many cases, the area is considered clean enough when an air sample is less than.01 (point oh one) fibers per cubic centimeter. Sometimes the area is clean enough when it is at least as clean as the air outside the area. For schools, the lab usually uses a very powerful microscope called a Transmission Electron Microscope (TEM). The TEM clearance level is <70 s/mm 2 Remember that the job isn' t done until the final air clearance test is passed. If the job does not pass the clearance air sampling, the area must be cleaned again. This is why critical barriers are left up until the job passes the test. 188
Chapter 11 MAINTENANCE - RELATED REMOVAL Mini-Enclosures and Glove Bags In this chapter you will learn: About using the same methods on small and large jobs. How to take off asbestos to repair pipes. How to use a mini-enclosure and a glove bag. Mini-enclosures and Glove Bags To take off small amounts of asbestos, follow the same 6 basic rules you do on a large job. When you take asbestos off a whole ceiling, you need to cover the whole room with 6-mil poly. You also need to do this for a whole run of pipes or air ducts, or a whole wall or floor. You need to put up poly, build a decon, andsetupanegative air machine. But there are lots of jobs where you only need to take off a little asbestos. It would be impractical to cover a whole room with plastic just to take asbestos cement off one pipe elbow. But you still need to protect your self and others from the asbestos. You can use a mini-enclosure (a plastic closet) and/or a glove bag (a plastic bag with gloves built in) to do a small job. Small jobs are usually repair jobs. When you do a small job you must keep the asbestos wet, contain the work area, filter the air, use negative pressure, practice good housekeeping, and set up a small decon area and properly dispose of all waste. Protect yourself with respirators that fit right and disposable suits. On a small job, you must apply these work methods in different ways. Mini-enclosures How do you take off a small patch of asbestos to hang a sprinkler pipe? You don' t have to build a full room. You can build a tiny work room - a mini-enclosure--- A Minienclosure is a closet like chamber you build to do asbestos 189
work inside of. The decontamination/equipment area for a minienclosure is either a second enclosed chamber attached to it or can be just a piece of 6mil poly plastic on the floor just outside of the mini-enclosure. The type of decon area you use will depend on the job. A mini-enclosure is also good for: taking off insulation around one electrical box, taking off insulation around one outlet, taking off ceiling insulation to put up lights, working above drop ceilings where asbestos is present, anytime you only need to enclose a small area When you use a mini-enclosure, follow the same six basic rules as on a large job: keep the asbestos wet, contain the work area, filter the air, use negative air pressure, practice good housekeeping and properly dispose of waste. With a mini-enclosure, use a HEPA vacuum for negative air pressure. A mini-enclosure looks like a plastic closet. Line a wood or plastic frame with two layers of plastic. There are also mini-enclosures that have metal frames with springs. The HEPA vacuum used for negative air pressure and filtration should be attached at the back of the mini-enclosure towards the bottom. The vacuum itself stays outside and the hose is put through the poly. The entrance from the decon area to the work area should be through a double flapped doorway just as it would be on a large job. If the decon area is enclosed, it too should have a double flapped doorway leading from the outside. A small job is a lot like a large job. Use two layers of poly on the floor and walls of the minienclosure. Just like any other asbestos job, you have to wet the asbestos. You have to put it in asbestos waste bags. You have to scrub the surface clean. You have to lock down the asbestos fibers you can' t see with a lockdown sea lant. In a mini-enclosure, you need these tools: a spray bottle for amended water a HEPA vacuum a labeled waste bag scrapers nylon bristle brushes 190
You may need these tools too: a ladder power tools with HEPA vacuums attached A mini-enclosure does not have a full decon. When you finish, clean off the suit with a HEPA vacuum or a damp rag. Stand on a piece of poly or in the equipment room. Wipe off your respirator. Take the suit off and put it in an asbestos waste bag. Use one or more HEPA vacuums for negative air-pressure in a mini-enclosure. The only differences between a mini-enclosure and a large job are 1) there is not a 3 stage decon and 2) negative air pressure comes from a HEPA vacuum. When you have finished decontaminating yourself, disassemble the decon chamber or un-tape and roll up the poly on the floor and dispose of it as asbestos-containing waste. Your respirator remains on your face until the decon is disassembled and removed. In a mini-enclosure: you still have wear respirators and protective suits you can' t eat, drink, or smoke you have to put up warning signs and barriers you have to use electricity safely Glove Bags A glove bag is a large plastic bag with gloves built into it. Glove bags are good for taking off insulation around a valve, pipe elbow, or a pipe. The asbestos inside the bag is contained. The bag is sealed air tight to the pipe. Your bare hands never touch the asbestos. You do the work through the gloves. Glove bag jobs must be done with two people! Use a garden sprayer and a HEPA vacuum to keep asbestos out of the air. You must wear a disposable protective suit and at least a PAPR respirator when working with a glove bag. This chapter tells you how to use one glove bag to take off a small amount of asbestos. These small jobs are all maintenance jobs --you take off the asbestos so someone else can fix the pipe. 191
Glovebags can also be used on larger jobs but the following things must be done: set up a negative air machine setupa3stagedecon take clearance air samples set up a full containment Glove bags come in many sizes and shapes. They are usually made of poly with latex gloves. They have a warning label printed on them. Some companies make glove bags from thicker poly. There are special glove bags for work on vertical pipes, small pressure vessels, and for four man operations. You may only use a glove bag once. After you are done, dispose of it with the asbestos. Never move or slide a glove bag down a pipe to remove more insulation; put up a new one. A glove bag can only be used on a cool pipe. Poly burns at 150 degrees. Glove bags can usually be used on hot water pipes that are usually about 120 degrees or less. A glove bag cannot be used on a hot steam pipe. Steam pipes are about 300 degrees. If you take asbestos off a steam pipe, turn the steam off and let the pipe cool for at least 12 hours and then verify that the pipe is cool enough for the glove bag. The typical glove bag is open at the top and has a tool pouch inside the bag. Some of the bags come with their sides pre cut. If not, cut the sides of the bag at the top. Attach the top of the bag to the pipe with duct tape. Next insert the HEPA vacuum nozzle and garden sprayer nozzle into the bag. Then put your hands inside the gloves and take off the asbestos. Asbestos doesn' t get into the air because it is trapped inside the bag.when you are done, pull the air out of the glove bag with a HEPA vacuum. Dispose of the glove bag in a sealed asbestos waste bag. Just like any other asbestos job, 40% of a glove bag job is preparation When you use a glove bag, follow the same 6 basic rules you do for any job: keep the asbestos wet, contain the work area, filter the air, and use negative air pressure, practice good housekeeping, and cleanup and dispose of all waste properly. With a glove bag, the bag contains the work and a HEPA vacuum supplies the negative air filtration. Because the HEPA vacuum will suck the air out of the bag, it should not be turned on until the job has been completed. Just like any job, you need to clean the pipe until all the asbestos is gone. Pay attention to pipe threads and similar conditions that could retain asbestos fibers. Wash the area to clean off any asbestos. Spray a lockdown sealant that is compatible with the temperature of the pipe. Cover up the edge of the insulation where you cut it with a non- asbestos containing substitute material. Put the asbestos in a sealed, labeled waste bag. 192
The following illustrations go through a glove bag job step by step. Use any combination of duct tape, staples, or spray glue to seal up the bag, as long as it is sealed totally airtight. 1. Put up barrier tape and warning signs. 2. Put on a PAPR respirator. 3. Put on a disposable suit. 4. Set up a decon area. 5. Deactivate HVAC system and lock out controls, then tape plastic over heating and ventilating system. 6. Clean the area. 7. Put a piece of poly on the floor beneath (and along the wall if the pipe is near a wall) 8. Inspect the bag. Fix any holes or tears. 9. Use duct tape to strengthen the bottom of the bag. Cut a slit about 12 inches down each side of the bag (if not already pre cut). 10. Put a razor knife, nylon bristle brush, bone saw, wire cutters, lockdown sealant, paper towels, etc. inside the tool pouch. 11. Put tape around the pipe where you will attach the bag. 12. Tape the bag onto the tape on the pipe. 13. Fold down the top edge of the bag about one inch. Duct tape or staple it shut. Fold the stapled or taped edge down again. Tape or staple it again. Tape over the seam and all staples. 14. Fold in the sides of the bag about one inch, and staple or tape. Tape over the side seams and all the staples. 15. Tape the nozzle of the garden sprayer into the side of the bag. Tape the nozzle of the HEPA vacuum into the other side of the bag. 193
16. Puff ventilation smoke into the bag to check for leaks. Squeeze the bag to move the smoke around in the bag. Fix any leaks. 17. Wet the asbestos with amended water. Cut the asbestos off the pipe carefully. Continue to wet the asbestos throughout the operation. Lower the asbestos to the bottom of the glove bag. 18. Brush off all the asbestos that' s stuck to the pipe. 19. Rinse all the asbestos off the pipe. Rinse the sides of the bag. 20. Spray a lockdown sealant to seal the fibers you can' t see onto the pipe. 21. Seal the cut edge of the insulation with an encapsulant. 22. Grab the tools in your hands, and pull the gloves inside out. Turn on the HEPA vac and pull the air out of the bag. 23. Twist the gloves (with the tools inside) and tape them shut like an umbilical cord. Cut the gloves off the bag. 24. Turn the vacuum on again. Twist the bottom of the glove bag shut. Put tape around the twist. 25. Put a waste bag under the glove bag. With the vacuum on, carefully cut the glove bag off the pipe. Lower it into the waste bag. 26. Cut the tape holding the vacuum hose and sprayer hose onto the bag. 27. Use the vacuum to pull the air out of the waste bag. Twist the waste bag shut. Remove the HEPA vac and tape the bag shut. 28. Fold over the top of the waste bag and tape it down (gooseneck the bag.) 29. Open up the gloves in a bucket of soapy water. Clean the tools. 30. Clean and take the poly off the floor (but not the DECON area) and air vents. 31. In most cases for a small glovebag job (less than 25 linear feet), your decon area will be a piece of poly on the floor. Wet wipe and HEPA vacuum your suit and respirator. Remove your suit inside out. Any amounts above 3 linear feet will require additional glove bags and be considered Class I work. 194
32. Make sure the decon area is cleaned and disposed of as asbestos waste. 33. Seal up the poly, gloves, and suit in a waste bag. 34. Remove your respirator, making sure to cover the filters with duct tape. 35. Remove signs and barriers. Problems with glove bags There are some problems with glove bags. It can be clumsy to use your hands inside the gloves. When the bags get wet, it is hard to see the pipe inside. If the pipe is hot, the bags can fog up. A glove bag can melt on a hot pipe inside. The seams on the bags can leak. The gloves can tear off. Glove bags work well if the work is done right. But this is often not the case. Whether you use a mini-enclosure or a glove bag, do all the same things you do on a large job to keep asbestos out of the air. On a small job, you just adapt those methods. Instead of a negative air machine, use a HEPA vacuum for negative air pressure. As long as there are no major breaks in the glove bag or mini-enclosure, you can use a piece of poly on the floor and a HEPA vacuum and damp rags to clean yourself off instead of a 3-stage decon. Repairing asbestos Another kind of maintenance-related work is repairing asbestos. It is usually the pipe covering or jacket that is repaired, not the friable asbestos itself. (Sprayed-on insulation can' t be repaired.) You must wear a respirator when doing repairs. You will also need to wear a protective suit. Repairs are usually done by putting a canvas or fiberglass patch over the torn jacket or covering. Sometimes it is necessary to patch a hole in the insulation itself. Mastic or glue is painted over the patch. You may use fiberglass that has glue already in it (wettable cloth). Dipping the patch in water activates the glue. All repairs must be done inside a glove bag or mini-enclosure. If you have to remove crumbling plaster or other materials to do a small repair, use a mini-enclosure. Use a HEPA vacuum to clean any dust off the surface. Mist the torn covering with amended water. Be careful not to tear the asbestos or the covering. Work carefully and make the patch airtight. For large repairs (more than 25 feet long or 10 feet square), use a negative pressure machine, put poly on the walls and floor, and build a 3 stage decon. This size job will require the use of an accredited Project Designer. A large-scale repair is just like any other large job. 195
MAINTENANCE-RELATED REMOVAL Mini-enclosures and Glove Bags Key Facts To take off small amounts of asbestos, follow the same 6 basic rules you do on a large job: keep the asbestos wet contain the work filter the air with HEPA filters use a HEPA vacuum for negative air pressure practice good housekeeping properly cleanup and dispose of all waste When you work on a small job, you must wear a respirator and a disposable suit A mini-enclosure is the same as a full containment without a 3-stage decontamination unit. Use a HEPA vacuum for negative air pressure in a mini-enclosure. A glove bag will melt on a pipe above 120 degrees F. With a glove bag, your hands never touch the asbestos inside the bag. When you are done, pull the air out of the glove bag with a HEPA vacuum. Throw out the glove bag in a sealed asbestos waste bag. 196
Glove bag exercise This is not a test. It is an exercise on the use of the glove bag. Use it to see for yourself how well you understand the procedures for safely doing glove bag removal of asbestos insulation. Read over all of the steps below. Put these steps on order by writing a number in the space before each item to show the order in which each step would be performed. Clean the area Put tape around the pipe where you will attach the bag. Staple and tape the glove bag closed. Tape the bag to the tape on the pipe Reinforce the bottom of the bag with tape. Cut about a foot down the sides of the glove bag (if not already pre cut). Place tools inside the pouch. Put on a respirator and disposable suit. Do a negative and positive pressure fit check. Put up barriers and hang asbestos warning signs. Cut two small holes in the bag and insert the nozzles of the HEPA vacuum and the sprayer. Seal the openings with duct tape. Smoke test the bag to ensure that it is sealed airtight. Set up DECON area Break the insulation away from the pipe and lower it to the bottom of the bag. Put poly under pipe, also up the wall if pipe is close to a wall. Spray the inside of the bag with water to wash any asbestos to the bottom of the bag. Deactivate HVAC system and lock out controls, then tape plastic over vent Spray the insulation with amended water, being sure to soak the area to be cut. Cut the insulation with a bone or camper saw at each end of the section to be removed. Put encapsulant paint on the cut edges of the asbestos on the pipe. Clean and remove plastic under pipe/on wall 197
Grab the tools in your hands and pull the gloves inside out. Remove the rest of the air in the bag by briefly turning on the HEPA vacuum. Twist the sleeve and tie it off with two pieces of duct tape. Cut the sleeve at the twist. Put the sleeve containing the tools in the next glove bag to be used or open it in a pail of water for cleaning. Spray, scrub, and wipe the exposed pipe to remove any asbestos on the pipe. Use a brush with nylon or fiber bristles. Spray lockdown on the pipe. Vacuum the work area and your clothes. Remove rope and signs from the work area. Turn the HEPA vacuum on again. Twist the bag below the pipe and tape it closed. Slip a large plastic disposal bag around the glove bag. Remove the glove bag from the pipe and fold it into the disposal bag. Seal and label the bag. Wipe your respirator with a damp cloth. Remove your suit inside out and place it in a disposal bag with contaminated rags and used filters. Seal and label the bag for disposal. Remove your respirator. Clean and remove DECON area 198
Discussion Questions 1. When you use a HEPA vacuum for negative air pressure in a mini-enclosure, where do you put it? At the top of the mini-enclosure? At the bottom? In the decon room? 2. How do you use a mini-enclosure to string cables above a drop ceiling? Do you need an enclosure at both ends? How can you set up negative air pressure? 3. What kind of enclosure would you use to take asbestos off one small boiler in a large basement? 4. How would you set up negative air pressure on this job? How would you decontaminate? For more information * OSHA Asbestos Standard, 29 CFR 1926.1101 * Your instructor has a copy for you to look at. 199
Chapter 12 OTHER HEALTH AND SAFETY PROBLEMS In this chapter you will learn about these dangers on asbestos jobs: Problems with heat. Chemicals. Electrical shocks. Fires. Confined spaces. Dangers from scaffolds and ladders. Slips and trips. Other health and safety problems Asbestos is a slow danger on a removal job. But short-term hazards, such as electrocution and fires can hurt you much more quickly. Asbestos removal is demolition work. Demolition is the most dangerous type of construction work. Here are some of the short-term dangers on asbestos jobs: 1. Heat stroke, heat exhaustion, and heat cramps 2. Chemicals other than asbestos 3. Electrical shocks 4. Fires and explosions 5. Confined spaces 6. Dangers from scaffolds and ladders 7. Slips and trips Heat Your body tries to cool itself by sweating and the evaporation of sweat. On the job, you work in a suit that doesn' t let your body heat escape and evaporation of sweat cannot take place. Your lungs have to work harder to pull air through a respirator. The air conditioning must be shut off. You work very hard. If your body overheats, you can get very sick. Overheating can cause heat cramps, heat exhaustion, or heat stroke (a medical emergency). 200
Heat stroke happens when your body can' t control its temperature. You stop sweating. Sweating is the main way your body cools itself. Your body overheats. Heat stroke can kill you or cause permanent brain damage. Here are some signs of heat stroke: hot skin headache dry skin dizziness flushed skin nauseous (feel sick to stomach) confusion fainting elevated core body temperature Heat stroke is a medical emergency! If a worker shows signs of heat stroke, get the person to the hospital right away. Unless the victim is treated quickly, he or she could die. Call an ambulance. Until the ambulance comes, you need to cool the person. Get the worker out of the work area and into a cooler location. (Due to the life threatening nature of the emergency, proper decon takes a back seat). Take off the suit and respirator. Be sure that the person is still breathing. Fan the person. DO NOT COOL THE PERSON WITH COLD WATER! You could cause them to go into shock and worsen their condition. Also, Do not attempt to give a drink to a person who is unconscious. You could cause them to choke. Heat exhaustion is less serious than heat stroke. Heat exhaustion happens when you lose a lot of water from sweating. Sometimes you lose a lot of salt, too. Here are some signs of heat exhaustion: cool, clammy skin headache sweaty skin dizziness pale skin nauseous (feel sick to stomach) a feeling of weakness Do these sound familiar? The last three signs of heat exhaustion: headache, dizzy, and nauseous are also signs of heat stroke? If a worker has hot, dry, flushed skin, he or she probably has heat stroke - get the person to the hospital. If the person has cool, clammy, pale skin, he or she probably has heat exhaustion. Get the worker out of the work area and into a cooler area. 201
Take off the suit and respirator and give the person cool (NOT COLD) water to drink. If the worker faints, call an ambulance. He or she may have heat stroke. Do not give a drink to an unconscious person. You may cause them to choke. Watch out for these warning signs of a person being over-come by heat: less alert less coordinated gets a headache feels sick to stomach This could be the beginning of heat stroke or heat stress. Get the person out of the work area and into a cooler area. Heat can make you less coordinated, and this can cause other accidents. Heat can also cause muscle cramps or heat rash. These are uncomfortable, but they are not serious. Heat can also make a worker faint. Take the worker out of the work area. Be sure that a person who has fainted does not have a more serious problem. Preventing heat problems Take breaks and drink water to prevent problems with heat! Here are some ways to prevent heat problems: Drink lots of water - Your body loses lots of water when you sweat. It is best to drink every half-hour in an uncontaminated area (outside the work area). But you probably won' t be able to go through the decon that often. Drink 8 to 16 ounces of water at every break. (Sometimes sports drinks can be helpful). Drink some orange juice and eat bananas. Or eat potato chips or one salty food once a day. Your body may need a little extra salt. But most Americans already eat too much salt. If you are on a low-salt diet for your heart, do not eat extra salt. Salt tablets are very dangerous. Do not take them. Take breaks - Your body will handle heat better if it can cool down sometimes. At least two breaks a day and a lunch break will help your body handle heat better. You will need to go through proper decontamination procedures every time you take a break. 202
Make sure you go to a cooler area to take your break. The supervisor should make sure that employees take regular breaks and not wait until signs of heat stress show up. Get use to the heat gradually - It takes about two weeks for your body to get used to working in the heat. Your body can get unused to heat in about 4 days. New workers should only work a half-day in the heat for the first few days. They should not work a full shift until the end of their first workweek. Use cooling vests - There is some new equipment that can help keep you cool. Cooling vests have ice packs in them. When you are working in very hot areas, cool vests can prevent heat problems. Cut down on alcohol - Alcohol dries out your body and can increase your body temperature. Even if you only have two beers the night before work, you are more likely to have problems with heat. In addition some prescription and over-the-counter medications can lessen the body s ability to handle the heat II. Chemicals other than Asbestos An asbestos filter on your respirator will not protect you from other chemicals. You have learned about some dangerous chemicals used at work: surfactant (in amended water) fiberglass (for replacing asbestos) solvents(for taking off floor tile glue) encapsulants (bridging, penetrating, and lockdown) carbon monoxide (from motors) An asbestos filter on your respirator will not protect you from other chemicals. For any chemical you work with, check with the manufacturer to determine which type of respirator is necessary. For example, you might need both a black filter (for solvents) and a purple or magenta filter (for asbestos). You might need both a green filter (for ammonia) and a purple or magenta filter (for asbestos and fiberglass). Some of these combination filters are gray. You may also remove asbestos some place where other chemicals are used. You need to know what you are working with. Your employer must have you trained about the chemicals you work with. This is called Right - To - Know training. See SEC 4 for more about your right to know about chemicals. 203
Carbon Monoxide Carbon monoxide is a poisonous gas you can't see or smell. Carbon monoxide is a dangerous gas. It can poison you. It can cause permanent brain damage and can even kill you. It has no smell, taste, or color. It comes from motors (engines), such as air compressors and generators. It can be a real problem if you are using Type C respirators. Here are some signs of carbon monoxide poisoning: Suddenly you begin to feel drunk and dizzy and you may start swaying back and forth. Your thinking gets foggy. You may feel that you are coming down with the flu. You may even begin to act crazy and can fall unconscious. You may feel: faint headache throw up nauseous (sick to stomach) sleepy dizzy like you have the flu Does this sound familiar? Three signs of carbon monoxide poisoning: headache, nausea, and dizziness are also signs of heat stroke and heat stress. If a worker has these signs, get them out of the work area and take off their respirator. If they faint, call an ambulance. If a person does not respond to you when you call their name and shake them, they are unconscious. If a worker becomes unconscious because of carbon monoxide poisoning, they may need CPR. (cardio-pulmonary resuscitation). CPR is a way to get someone' s heart and lungs working again when the heart stops. There should always be someone on your crew who has CPR certification. Taking CPR classes can certify you. If you begin to have signs of carbon monoxide poisoning and you are wearing a Type C respirator, turn on your escape gear and disconnect your airline. Alert your co-workers and get out of the work area. Help your co-workers to get out and have the air purification system checked. (This is why the State Employees Asbestos Program has recommended in the past that you use grade D bottled air instead of a gasoline powered compressor). 204
III. Electrical shocks An electric shock can stop your heart. One of the measures for electricity is in volts. Even a few volts can kill you if the electricity goes through your heart. Electricity follows the easiest path - to the earth. It is very easy for electricity to travel through water. If you are wet and you touch electricity, it may travel through your body. A wire with electricity going through it is called a "live" wire. If a tool or an extension cord is broken, it may have a short. This means that the electricity doesn' t flow through the right wires. It may flow through the tool and into your body. Electricity is a problem on asbestos jobs for many reasons: a lot of water is used power may not be shut off power tools are used extension cords are used metal tools may be used wires are exposed when the asbestos is removed Electricity and water are a deadly combination! Water - Don' t use more water than you need to. Don' t use so much water that there are puddles on the floor. Clean up small amounts of water with a wet/dry HEPA vacuum. Neverusewateraroundlivewiresorpowertools. Shut off the power - Lock the electrical box. Your employer should have an electrician come in and test the wires. Never assume that the power has been shut off. You might think that all the power is shut off, but it may not be. You could be in for a big surprise. Cover electrical outlets - Be sure that electrical outlets and boxes are covered watertight. Use safe power tools - Power tools should be double insulated. This means the outside of the tool doesn' t touch the wires in the cord.tools could also be grounded. This means there is an extra wire in the cord. If there is a short, electricity will travel through the extra wire. Electricity should not go into your body. A grounded tool has three prongs on the plug (instead of two.) Never cut the third prong off a grounded plug. Use an adapter. Attach the wire on the adapter to the plate on the outlet. 205
Keep power tools in perfect shape - It is much easier to get a shock from a broken tool. Broken tools should be taken off the job. They should have a DO NOT USE tag on them. Do not try to fix a broken tool unless you have been trained and authorized to do so. Always unplug a tool before trying to fix it. Some companies cut the cord of a broken tool so no one can use it. Here are some ways to keep power tools in perfect shape inspect the tool before you use it have broken tools taken out of service and repaired be sure the tool is sharp - the motor has to work harder if it is dull don' t carry a tool by its cord don' t unplug a tool by pulling on the cord store tools where they won' t be damaged Use safe extension cords - Heavy-duty wire (i.e. Romex) is not meant for temporary wiring. Your employer must give you extension cords with plugs for power tools. Your employer should give you grounded extension cords. Keep extension cords in perfect shape - There may be a lot of extension cords on the job. The negative air machine or HEPA vacuum needs one. So do power tools and lights. Extension cords need to be taped to the wall. If a scaffold runs over the cords, it could cut them. Never hang extension cords with wire. This could cause a shock. When you attach a tool to an extension cord put electrical tape around the joint. Do this when you attach two extension cords together or when you tape them to the wall. Never use metal hand tools or ladders - Electricity travels through metal. If you touch a live wire with a metal shovel, you could get a bad shock. Your employer should give you plastic or wood tools. Metal tools with plastic handles are safer. Metal ladders are also dangerous. Your employer should give you fiberglass ladders. Wires in walls or ceilings - When you scrape asbestos off a ceiling, you might uncover hidden wires. It is very important to shut off the electricity, lock out the circuit, and have an electrician test it. If a worker has been shocked, do not touch him. You might get a shock yourself. Shut off the power first. Then use a dry non-conductive pole to move the worker away from anything metal. Someone on the job should be trained to do CPR. (CPR stands for Cardio - Pulmonary Resuscitation.) A person trained in CPR can keep someone breathing and keep his/her heart going until an ambulance comes. Do not try CPR unless you have been trained. 206
Preventing Electrical Shocks Use Ground Fault Interrupters to prevent shocks The best way to protect workers from shocks is to prevent shocks. OSHA says your employer has to prevent shocks. Your employer can use a sensitive circuit breaker or a written program. Using a GFCI is more effective than just a written program. A Ground Fault Circuit Interrupter (GFCI) is a very sensitive circuit breaker. If there is a short, the GFCI should shut off the power before it can hurt your heart. A Ground Fault Circuit Interrupter is a very good way to prevent shocks. Each extension cord should have its own GFCI. GFCI s must be tested before each use or in accordance with the manufacturer s recommendations to ensure that they work. Your employer can also use a written program. With a written program, you count on a person (instead of a piece of equipment) to keep you safe. Written programs may not be a good way to protect workers from shocks! Because of this the State Employees Program stresses the use of GFCI' s. Protection A competent person must also be knowledgeable in electrical safety must supervise all work. Preventing shocks is the best way to protect yourself. It is essential to have all sources of electricity in the work area identified and locked out. Each worker should have his or her own lock and tag. (procedures should follow OSHA s electrical safety work practices standard 29 CFR1910.333) Circuit testing equipment is also necessary to ensure that the electrical lines have been deactivated REMINDER: State Employees cannot do asbestos jobs where the electricity cannot be shut off. IV. Fires and Explosions Prevent fires: keep flames, sparks, and red hot surfaces out of the work area and the decon A fire on an asbestos job is very dangerous. Poly, duct tape, and disposable suits burn fast. Poly will melt and can burn at about 150 degrees. The negative air machine makes the fire spread faster. The work area can be dark and there is usually only one exit. The best way to deal with fires is to prevent them. Any fire needs three things: fuel (something that burns), heat (the heat, flames or spark that starts the fire), and oxygen (in the air). 207
Preventing fires means keeping fuel, heat, and oxygen from coming together. FUEL HEAT OXYGEN poly welding air duct tape cutting torches negative air machine encapsulant electrical wires disposable suits lights wood broken tools solvents operating machines cigarettes Welding and cutting - These are often used in demolition. If needed, this should only be done with the knowledge and approval of the Agency Safety & Health Specialist. A worker must stand by with a fire extinguisher in case any sparks fly. Electrical wires and lights - An ordinary lamp on the floor can start a fire. Never wrap lights in poly. Heat will build up and can set the poly on fire. Your employer must use safety lights. The lights have cages that keep the hot bulb from starting a fire. Tools - If tools are kept in perfect shape, they are not likely to start a fire. Operating machines - These need extra protection during setup. For example machines with moving parts or those that will overheat when covered in plastic. Do not smoke on the job!! Cigarettes - These are not allowed on asbestos jobs. Do not smoke during setup. Poly and solvents both catch fire very easily. There are some new products, which can help prevent fires. Fireresistant poly doesn' t burn as easily. New chemicals that don' t burn as easily are available. However, both will still burn under the right conditions. In case of Fire Look at the escape plan when you start the job 208
If there is a fire in the work room or decon, GET OUT! The fire will spread very quickly. You may have to cut through the poly to get out of the work area or decon. Your employer must have a fire extinguisher and an escape plan. Fire extinguishers need to be able to put out wood, chemical, and electrical fires. These are called ABC - type fire extinguishers. Your Agency Safety & Health Specialist should be consulted to ensure that you have the right capacity rating for the job. If there are sprinklers, your employer should try to leave them in service as long as possible. The escape plan (emergency action/ fire prevention plan) includes a work area map with directions for exiting the area and emergency phone numbers. The plan should be hung both inside and outside the decon. When you start a job, look at the map. Figure out how you would get out in an emergency. Do you have to dial "9" to make a phone call outside of the building? Is there an emergency exit from the work area? Are there arrows made out of tape on the walls to show you how to get out? If the fire started near the decon, you will not be able to get out that way. Where is the fire extinguisher? Do you know how to use it? Remember: In case of a fire emergency GET OUT, don t worry about proper decontamination procedures. V. Confined Spaces There are a few rare cases where you work in a small area that is hard to get out of. This might happen if you are taking asbestos off the inside of a steam tunnel crawl space, trench, etc. It is hard to get out of these confined spaces. They also may have very little oxygen in them. You can use up all of the oxygen in the space very quickly. Many people die in confined spaces. A confined space is defined as a space that has a limited means of entry or exit, cannot achieve adequate dilution ventilation through natural or mechanical means, and can have an oxygen deficiency or an unsafe accumulation of toxic and/or combustible agents. It can also include trenches, pits, crawl spaces, attics, silos, or open surfaces greater than four feet in depth. If you work inside of a confined space, you should wear either a Self-Contained Breathing Apparatus (SCBA) or an Airline respirator with at least a 5 to 15 min. escape tank of air if there is the possibility that the atmosphere could turn Immediately Dangerous to Life or Health. You must wear a rescue harness assembly. There must be another worker outside who remains in constant communication with you all of the time. He can pull you out or get help if something goes wrong. There also must be adequate lighting and someone trained in CPR. No one should go into a confined space to rescue a worker unless he has been trained and is properly equipped. Many people die trying to rescue workers from confined spaces. 209
In addition, any utility or process that contains a harmful agent that enters a confined space must be completely isolated from entering the confined space. All electrical service and equipment must be locked and tagged out of service. The atmosphere inside the confined space must be tested for oxygen deficiency then for toxic or combustible gases. Under the Federal confined space regulation (29 CFR 1910.146) some spaces require permits. These would include spaces which has the potential to contain a hazardous atmosphere, contains a material which could engulf a person who enters the space, has a configuration that could trap or asphyxiate a person, and/or contains other serious health or safety hazards. Additional information can be found in the state COMAR 09.12.35 and federal 29 CFR 1910.146 standards. VI. Ladders You already know not to use metal or wooden ladders. Electricity passes through them, and it can shock you. Also be sure that ladders are in perfect shape. Every time you use a ladder, check for these things: broken steps or rungs broken hinges broken feet wobbly ladder no rubber safety feet water on the ladder (slippery) Here are some ways to use ladders safely: Don' t lean a stepladder against a wall. Use a ladder that' s made to lean against a wall. When you lean an extension ladder against a wall, set it up so that the top of the ladder is four times higher than the distance from the wall to the base of the ladder. Only use one side of a stepladder. The other side isn' t made to hold a person.face the ladder. Don' t stand on it backwards.don' t stand higher than two steps fromthe top of a stepladder. Get a taller ladder. Don' t use a ladder as a platform. 210
VII. Scaffolds Scaffolds on wheels are common on asbestos jobs. All scaffolds should have guardrails! You can' t tell whether a scaffold is safe by looking at it. Someone with experience must put scaffolds together. All the parts must fit perfectly. Someone other than the person who built them should inspect them. Here are some rules about scaffolds on wheels: All scaffolds should have railings. These keep you from falling over the side. Scaffolds more than 10 feet high must have railings and toeboards. The scaffold parts must be locked together with pins Manually propelled mobile scaffolds shall be provided with positive locking devices such as wheel brakes and locks, to hold the scaffold into position. Workers should not be on a scaffold when it is moving. Scaffolds may not be more than 4 times higher than the minimum base dimension. For example, a 6 - foot wide scaffold may not be more than 24 feet high. Platforms shall be tightly planked for the full width of the scaffold except for necessary entrance opening Platforms shall be secure in place. Boards shall extend over their end supports not less than 6 inches or more than 12 inches. Otherwise, if you step on the end of the board, the board could tip over and you would fall. It is safer to use scrapers with long handles than to work on a scaffold. If you are using supplied air respirators, it is easy for the hose to be caught on the scaffold. Protect those hoses from damage. Be sure there is enough hose for you to move around. It is even more important not to fall off scaffolding. If you fall, the hose may trap you. It can pull the respirator off your face or knock you off balance. The hose could pull other people off the scaffold. 211
VIII. Slips, trips, and falls When you work, you wear slippery booties on your feet, the floor has plastic on it, and there is water on the floor. This combination contributes to slips, trips, and falls. You may drag a 300-foot long air hose behind you. You could trip on the hose or it could get tangled. You could fall down and, for example, break your arm. Here are some ways to prevent falls on the job: Don' t use more water than you needo t keep the asbestos adequately wet. Use a wet/dry HEPA vacuum to pick up small amounts of water. When you set up the job make sure that the poly on the floor is as smooth and straight as possible. Clean up asbestos and other debris as you are working Wear boots outside your booties. You cannot wear these boots outside an asbestos job. Tape extension cords up on the walls Keep boxes, bags, and other items out of the way Keep airlines from getting tangled Back Injuries Don't fill bags more than one-third full Back injuries are very common and very painful. They are hard to treat. It is much easier to prevent back problems than to treat them. Here are some ways to prevent back problems: Don' t fill bags more than 1/3 full. Figure out how much you can comfortably lift. Figure out a way to lift that' s comfortable foryou. 212
Try to keep your back straight when you lift, use your legs to lift. Don' t lift, twist, and turn at the same time. Get help to lift heavy bags. Use a hand truck or a dolly. 213
OTHER SAFETY AND HEALTH PROBLEMS Key Facts Short - term dangers on an asbestos job can be worse than the asbestos. Heat Stroke: a medical emergency, call an ambulance -hot skin, dry, skin, flushed skin Get the person out of the work area and into a cooler area. Take off the suit and respirator. Fan the person until help arrives. DO NOT USE COLD WATER TO COOL THE PERSON! If they are not unconscious, give the person a cool drink. To prevent heat problems: Drink lots of water, Get used to the heat gradually over 2 weeks, take breaks Chemicals: An asbestos filter on your respirator may not protect you from other chemicals. Carbon monoxide is a dangerous gas. Signs of carbon monoxide poisoning: headache, nauseous, dizzy, sleepy, faint, nausea. Get the worker out of the work area and take off the respirator. It is very important to identify potential sources of carbon monoxide before the job begins and eliminate them. Electricity: An electric shock can stop your heart. If youarewetandyoutouchelectricity, it will travel through your body. Prevent electric shocks: never use water around live wires. Shut off power and lock the electrical box. Use tools that are double insulated and grounded. Never use metal hand tools or ladders. Use Ground Fault Circuit Interrupters (GFCI) on all circuits. If a worker has been shocked shut off the power and use a dry non-conductive pole to move the worker. Fires: Prevent fires by: Having a worker stand by with a fire extinguisher when welding or cutting torches are used. Having an ABC rated fire extinguisher on the job. Ladders: Inspect ladders every time you use them. All scaffolds should have railings. Lock the wheels when people are on the scaffold. Scaffolds may not be more than 4 times higher than their minimum base dimension. 214
Safety and Health exercise This is not a test. It is an exercise. Use it to see for yourself how well you understand the material in the chapter. 1. Why is electricity a hazard? 2. Why do you need Ground Fault Circuit Interrupters (GFCIs) for extension cords? 3. How do GFCIs protect against electrical shocks? 4. What other protection can you use against electrical shocks? 5. Why shouldn' t you use metal ladders? 6. Why are scaffolds on wheels dangerous? 7. How do you protect yourself from these dangers? 215
8. Name two common tripping hazards on asbestos jobs. 9. Why is fire safety a problem on removal jobs? 10. What type of fire extinguishers should be used on an asbestos job? 11. Why is heat stress a problem on asbestos jobs? 12. What are the symptoms of heat stress? 216
Discussion Questions 1. Some employers want workers to work for 6 hours without a break. Do you think this causes more heat problems than working 8 hours and taking breaks? Why do employers do it? 2. Is it necessary to drink an electrolyte drink when you are working in the heat? 3. Which do you think is safer for workers using Ground Fault Interrupters (sensitive circuit breakers) or a written Grounding Program? Why? 4. Why should a different person than the one who put it together inspect a scaffold? 5. What would you look for if you were inspecting a scaffold? For More Information *USDOL, "Protecting Workers in Hot Environments," USDOL Fact Sheet #84-16. *NIOSH, "Work in Hot Environments," Publication No. DHHS (NIOSH) 86-112. *OSHA Electrical Standards, 29CFR1926.400 to.449 *OSHA, "Controlling Electrical Hazards," Publication No. OSHA3075. *OSHA, "Ground Fault Protection on Construction Sites," Publication No. OSHA3007. *OSHA Ladder Standard, 29CFR1926.450. *OSHA Scaffold Standard, 29CFR1926.451. *NIOSH, "General Safety Considerations," Appendix E to EPA/NIOSH, "A Guide To Respiratory Protection in the Asbestos Abatement Industry," Publication No. EPA-560- OPTS-86-001. *Your Instructors have a copy of these publications for you to look at. 217
CHAPTER 13 CONTRACT SPECIFICATIONS In this chapter you will learn: - Recognize the importance of well-designed detailed contract specifications. - Understand the reasons why specifications must be designed for each project. - Become familiar with the content of guideline contract specifications. - Be aware of key items in the contract specifications that can greatly affect project cost and performance. - Recognize the importance of strict enforcement of the specifications. - Further recognize the need for interdisciplinary approaches to asbestos abatement. Contract Specifications Contract specifications permit the contractor to provide the building owner or architect with an accurate estimate for a bid for completing the project. Key items the contractor should look for include: Drawings and specifications that match the pre bid survey Checking the criteria used to judge the cleanliness of the work area Arrangements for TEM usage and support Well-planned detailed project designs provide the overall guidance for each asbestos abatement project. With few exceptions two separate designs (or sets of specifications) will be required for those projects requiring outside contractors. One is for the asbestos abatement contractor and the other is for an industrial hygiene-monitoring firm, which will be hired to monitor the abatement contractor' s activities on behalf of the Owner. Poorly - designed specifications will result in a poorly - executed project. If any details are omitted in the specifications or if the procedures are unclear, the work may not be done the way it was intended to be done. The National Institute of Building Sciences (NIBS) "Guide Specifications for Asbestos Abatement Projects" may be a helpful reference document for individuals designing projects. It is a useful tool, which a knowledgeable accredited project designer can use to select applicable language for directing work on the project. A knowledgeable accredited project designer is a person who knows the regulatory requirement for asbestos work as well as the basic health and safety requirement common to construction activities. 218
Since regulations are the minimum criteria for any job activity, the knowledgeable accredited project designer must understand practices consistent with state-of-the-art work methods and implement these same procedures, which are often beyond those required by regulations, when they are necessary to protect human health and the environment. Finally, it is important to note that development of specifications cannot occur in a vacuum. The project designer must have comprehensive knowledge of conditions at the planned work site. Note that per ASHARA regulations, an accredited project designer must design asbestos abatement projects in public and commercial buildings. This is an individual who has taken and successfully completed an AHERA Accredited Project Designer course and who has maintained his/her accreditation though attendance of the required annual Refresher Course. CONTRACT SPECIFICATIONS (PROJECT DESIGNS) Contract specifications (project designs) are a written set of standards and procedures informing the contractor or supervisor of materials and operations necessary to successfully complete an abatement project. Typically, these documents cover the entire spectrum of an abatement project; from site investigation by the contractor or supervisor to use and application of replacement materials. The specifications are usually prepared in book form and along with drawings and any addenda or change orders constitute the project design. During the preparation of the design, conflicts may result between the specs and the drawings. Thus, it is extremely important that the project designer review both the specifications and drawings for errors and omissions prior to advertisement for bids. At the conclusion of this review process, there should not be any conflicts between the specifications and the drawings. When designing a project, it is recommended that language be used directing that conflicts among contract documents be referred to the architect or the Owner for resolution. Remember that any changes after the contract is signed will result in either increase cost or project time, or both. If a change is made to the design or specs during the time period that outside contractors have to bid on a project, the change is called an addendum. Should a change be necessary after the contract has been awarded, it is called a modification to the contract. A change order is the procedure generally used for a contract modification. Information, which is often included in the development of contract specifications, is contained on the following pages. It is important for an asbestos abatement project designer to keep in mind that no two-abatement projects will be identical. Various aspects of a project may be similar from job to job, but no one set of specifications can be used from project to project without modification or large scale changes. Hence, it is extremely important that the person who develops the specifications know the conditions present at the work site and the specific work details needed to successfully accomplish the project. 219
ELEMENTS OF THE SPECIFICATIONS Elements in the specifications should address the statement of work, extent of damage and contamination, location of asbestos containing materials, architectural engineering drawings, reference to inspections, and should indicate the specifications types. Contract specifications for a project, which will be handled by an outside firm, will be packaged into a project manual and released for bid. The Project Manual will consist of the following parts: Bidding Requirements, consisting of Advertisement InstructiontoBidders Information Available to Bidders Bid Forms and Attachments Bid Security Forms (e.g. Bid Bonds) Contract Forms, consisting of Agreement Performance Bond Payment Bond Certifications (e.g., Affidavits, Contractor License Certificate, Minority Business Enterprise Utilization Forms and other stipulated requirements specified which the bidder must have in order to be awarded the contract Conditions of the Contract General Conditions (i.e., often AIA s Form 201 for private sector contracts, or the General Conditions issued by the Department of General Services, or other agency having procurement authority, on public sector projects. Specifications Drawings Supplementary General Conditions (which modify the General Conditions and fine-tune them for the specific project at hand. If an addendum or modification is issued on the project, they will be incorporated into the Project Manual 220
In the private sector, often, in order to become a qualified bidder attendance at a pre-bid meeting or site inspection will be required of the contractor. THIS IS NOT THE CASE AS FAR AS CONTRACTS FOR THE STATE OF MARYLAND GO. Procurement Regulation COMAR 21.05.02.07 States "Attendance at a pre-bid conference may be encouraged, but may not be made mandatory". By having a site inspection or attending a pre-bid meeting, the contractor becomes familiar with the conditions of the project, including the physical condition of the site, access to water and electricity, as well as the character and quantity of the ACM involved in the abatement project. This meeting will also inform bidders of the requirements of the contract as presented by the Owner s representative. It is perhaps the best time to address questions regarding the project so that clarifications can be issued if necessary though an addendum. Regardless of whether or not a site investigation is specified, a prudent contractor will want to become familiar with the project. The same holds true for supervisors of Level II jobs. It is very important for the Level II supervisor to assess the work site and clarify the work procedures that must be implemented, prior to actual commencement of work. The project "scope of work" will be laid out in the specifications (design). This section will include a description of ACM locations (which may or may not, also be provided on drawings), the general type of abatement procedures to be used in a particular area, and any restoration requirements that may be necessary. A "description of work" section will detail abatement measures for each work area. Additionally the contractor or supervisor will be required in this section to arrange for or supply all labor, materials, services, insurance, equipment, etc. necessary to carry out the work in accordance with the specs and all applicable laws. Any special conditions, which may be encountered on the project (i.e. high temperatures, operational equipment, etc.), will be detailed. This section also will include the requirement that the contractor or supervisor restore the abatement area to conditions equal to or better than the original ones. The Scope of Work and the Description of Work are found in Division 1 of the Specifications. Division 1 is the part of the specifications that provides directives and requirements for work covering the entire project. It includes language on contract administration as well as technical requirements such as temporary facilities, temporary enclosure, personal protective equipment, decontamination procedures, and clean up and clearance criteria. Detailed work practices are included in other Divisions of the contract ranging from Division 2 - Site Work (where specific asbestos abatement specifications are found) to Division 15 and 16 (which include mechanical and electrical work, respectively). The specific language that will be used to construct the specifications will depend to a large extent on the approach the project designer takes. Specifications are often written following three approaches. The first is a Means & Method type of specification. 221
Under this approach, the project designer tells the contractor exactly what to do --the materials to be used and specifically how the work will be done. The second approach is a Performance type of specification. Under this approach, the project designer specifies the objective or end results for the project, but allows the contractor the flexibility on how he/she will achieve these end results. The third approach represents a combination of a Means & Method and a Performance specification. This is frequently the type used in many asbestos abatement projects. It sets specific work requirements for environmental and worker safety but allows the contractor to be creative in removing the asbestos containing materials. Because of the potential liability associated with asbestos work, that the Owner s representative should evaluate and approve performance work practices proposed by the contractor, in order to ensure that safety will be maintained on the job. Therefore, the specifications should stipulate that the contractor must submit an overall work plan to the Owner s representative prior to commencement of the work. Submittals and notices are important in getting the abatement project off to a smooth start. The contract documents (project design) will usually spell out the contractor/supervisor' s responsibility for properly notifying applicable regulatory agencies. For asbestos abatement work performed by an outside contractor, the firm awarded the contract must notify EPA s Region III Office in Philadelphia, and the Maryland Department of the Environment in Baltimore. These notifications must follow procedures required under NESHAP (the National Emission Standard for Hazardous Air Pollutants -- Asbestos, 40 CFR Part 61) and Maryland s Control of Asbestos Regulation (COMAR 26.11.21). In addition, the co ntractor must secure the necessary resources for waste handling and disposal according to State and federal regulations. Documentation that employees on the job have been properly trained and medically monitored under applicable regulations will also be submitted to the Owner s representative for inclusion into the project records. It is also important that any existing damage be documented by the contractor/supervisor and submitted to the Owner s representative prior to any work commencing since the contractor or Level II supervisor will be responsible for any damage that occurs on the project unless such damage is specifically identified as existing prior to commencement of the work. Included in the contractor' s submittals will be a list of equipmento be used along with any certification documents, which the specs call for. (For example: HEPA -vacuums conforming to ANSI standards). This will include respirators as well as other equipment for the project. During the abatement activity itself, the periodic progress reports on abatement status, transport manifests and waste disposal receipts, monitor logbooks, bulk and air samples results, and documentation of HEPA-filter changes may be required by the Owner s representative. The Supervisor on Level II projects should document all the equipment used on the job and show that such equipment conforms to that specified under the State Employees Asbestos Program. Since Level II jobs will be of short duration, weekly progress meetings will not occur. 222
However, at the completion of each Level II project, the Supervisor should submit a written report to the appropriate authority at the facility, detailing what was done, how it was done, what people were involved, the protective measures used to protect human health and the environment, and the amount of asbestos waste generated and how it was handled. In addition to requirements for the contractor/supervisor, the project specifications will sometimes require the Owner s representative to perform certain functions. This may include notification of building occupants of the work to be performed and making arrangements for temporary relocation. Additionally, the Owner s representative will usually have to make available to the contractor the results of any pre-abatement air sampling or bulk sampling tests. Level II supervisors should look for these historic records, and if they exist, incorporate this information in their approach to the abatement activity. An area of concern for the Owner s representativ e and the Contractor or Supervisor is site security and emergency planning during the abatement project. The specifications should say that only authorized personnel would be allowed access to the work site (employees of the Owner s representative, contra ctor, etc.). This is done to limit the liability of the parties involved and to prevent any worksite problems. Emergency planning will include written notification of police, fire, and emergency medical personnel as well as the facility s on -site security office, of proposed abatement activity. The plan must include the proper procedures to follow if an emergency situation arises. For example, the contractor or supervisor must survey the work area prior to commencement of work in order to identify potential safety hazards that are present, and then ensure that appropriate procedures are in place that will mitigate their occurrence. In addition, procedures must be in place to minimize adverse consequences should an accident occur. MATERIALS, EQUIPMENT, AND SUBSTITUTE SPECIFICATIONS Material specifications will include requirement on the quality of materials used on the job as well as how they must be stored at the site. Specific materials will be detailed in part two -- PRODUCTS in each Section of the specifications. (Note: each section of a specification is divided into three parts, Part 1 General Requirement, Part 2 pertaining to Products to be used, and Part 3 Execution which involves the work to be performed.) Proprietary specifications will require the use of a specific material from a specific manufacturer, whereas nonproprietary specifications will indicate materials or performance requirements and will allow the selection of materials, which perform to those limits. Equipment specifications will detail the performance requirements of units such as negative air filtration units, Type C respirators and associated compressed air systems, and protective clothing and safety equipment such as footwear, hardhats, and eye protection. 223
Equipment used in the actual removal of ACM will also be specified such as scaffolds, ladders, sprayers, and their capacity ratings, and any other equipment deemed essential for proper completion of the job. In the event that a substitution of materials or equipment is necessary, specifications will usually call for the submission of complete technical data and information on the substitution from the outside contractor or supervisor to the Building Owner. The Building Owner will then review the information and have the authority to approve or disapprove such substitution. It is important to keep in mind that the terms "or equal" and "or equal as approved by Owner" do not mean automatic Owner approval of substitutions. Any material or equipment which the outside contractor or supervisor feels is equal to what has been specified should be approved by the Owner in writing before being used. There have been many instances where a contractor has had to redo work when unapproved substitutions were found to have been made. SPECIFICATIONS FOR THE EXECUTION OF WORK Procedures for preparation of the work area will be specified in the project design (specs). The specs will include the shutting down and locking out of electrical power to the area, if possible. Provisions for temporary power and lighting will be made, usually by the Building Owner. The HVAC system of the building will also need to be shut down or modified to prevent spread of contamination to other areas of the building. This is an especially important consideration in buildings where adjacent areas will remain occupied. Considerations will be detailed for furniture, machinery, etc., which will be cleaned and sealed using specified methods. Specifications will often detail the construction design of the decontamination facilities, including location, size of chambers, and number of airlocks. Additionally, entry and exit procedures will be set forth, with provisions for waste material removal and storage. The work area will be prepared according to project specs, which will usually state polyethylene sheeting thickness, layers, and seam overlap. Maryland asbestos regulations, as well as state-of-the-art practices, require polyethylene sheeting to be at least 6 mils thick. Special considerations for equipment, which cannot be shut down and removed from the work area (computers, communications switching equipment), and for work areas with adjacent occupied space will also be specified. It is vital that contractors, supervisors, and any other abatement professionals become familiar with any special considerations. Once the preparation of the work area is complete, specifications will usually detail the methods and order of removal of contaminated materials in the work area. Any encapsulation or enclosure of asbestos containing material will be specified. 224
Once removal, encapsulation, and/or enclosure are complete, the waste material will be transported out of the work area and disposed of in an approved landfill. Proper documentation and retaining of receipts from disposal practices are specified to be delivered to the building owner. RESPIRATORY PROTECTION Specifications for respiratory protection may vary with either the type of abatement activity or with fiber concentrations. For example, HEPA filtered powered air purifying respirators (PAPR' s) may be specified for use during work area preparation and/or following complete removal of gross contamination and during cleaning, while Type C air-supplied respirators may be specified from the beginning of actual ACM removal until gross contamination has been cleaned-up and removed from the area due to higher fiber concentrations in the air. Level II activities usually don' t require the use of Type C respirators except in confined spaces or grossly contaminated areas. Full-face piece PAPR s are considered the minimum requirement on Level II jobs. For outside contractor, Maryland s Control of Asbestos Regulation requires that respirators and disposable clothing be used regardless of the concentration of airborne asbestos fibers. Likewise, the Governor s Executive Order 01.01.1987.22, requires that all State employees who work with asbestos (Level II personnel) use respirators and disposable clothing whenever there is a possibility of exposure to airborne asbestos. Selection of appropriate respiratory protection is a complicated process, which should involve participation of a professional industrial hygienist. In general, the respirator used must provide a protection factor, which will maintain a fiber concentration inside the mask as low as possible, but no higher than 0.01 f/cc. Daily fluctuations in fiber concentrations necessitate that respirators selected will have the capacity to provide protection against the upper range of the airborne concentrations anticipated on the job. For outside contractors, the project designer should specify that a negative exposure assessment be included in the initial submittals for the job. (A negative exposure assessment is basically documentation that the anticipated airborne levels will likely be below the permissible exposure level (PEL) using the equipment and work procedures designated for the upcoming project. This evidence frequently takes the form of air sampling data on a previous job in which similar work practices were used. It is important to note that regardless of whether asbestos is being abated by a private contractor or by Level II employees, the degree of protection afforded by respirators is only as good as the fit the individual can achieve. Therefore, the project designer must be sure the specifications contain detailed language requiring the contractor to implement a comprehensive respiratory protection program and to provide the Owner with evidence of compliance with this requirement. 225
Likewise, the supervisor on Level II projects must ensure and document that his/her workers have the appropriate respirators, that they are in proper working condition, and that each individual has received and successfully passed a fit test using a challenge agent (i.e., a qualitative fit test or a quantitative fit test) within the last year. When work actually begins the Owner s representative inspection operations of an outside contractor or supervisor must be alert to work practice infractions that will compromise the level of respiratory protection, and must immediately order corrective action. CLEARANCE AIR TESTING The procedures to be followed for final air clearance testing should always be thoroughly spelled out in the specs. Sampling locations and the number of samples to be collected will sometimes be specified although the exact locations are frequently left to the professional judgment of the Industrial Hygiene Services Contractor monitoring the job on behalf of the Owner. Sampling methods (aggressive or non-aggressive) analytical techniques (PCM or TEM), and length of the tests will be specified according to applicable regulations. The specs should also state very clearly what would be considered "clean" in regard to airborne fiber levels. Additionally, specifications should include requirements that the Owner' s Representative prior to final air clearance testing conduct a complete and thorough visual examination of the work area. WASTE DISPOSAL Contract specifications will indicate the use of an EPA authorized landfill (one which will accept asbestos waste and follow EPA requirements). A record keeping procedure whereby all receipts and manifests will be retained and delivered to the Building Owner will be included. Specific requirements for the transportation of asbestos waste will include preparation of the waste containers and truck, proper loading and unloading procedures, personal protective equipment that must be worn by waste handlers, and decontamination procedures for the transport vehicle. MATERIAL REPLACEMENT Material replacement such as re-fireproofing, reinsulation, reinstallation of a drop or suspended ceiling, or any other renovation work will be completed following passage of clearance testing. This work may be covered under the original specs or may be under a separate set of specs. Selection of appropriate replacement materials must take applicable building fire protection and other codes into consideration. Specification of new fireproofing materials as well as wall and ceiling materials must have acceptable flame spread criteria and fire rating times equal to or better than that required by applicable building, life safety, and fire protection codes. Acoustical, thermal insulation, and aesthetic factors may also need to be considered in certain circumstances. 226
In situations that involve life safety issues, the project designer must have the input and approval of a licensed professional engineer or licensed architect. Following the completion of replacement, or if no additional work is to be done, the contractor or Level II supervisor will be required to re-secure any objects or fixtures taken from the area, replace furniture and fixtures in their former positions, and re-establish the HVAC, electrical, and any plumbing systems to their proper working order. Finally, any damage resulting from the contractor or supervisor' s abatement activities will be repaired. OTHER ABATEMENT PROFESSIONALS Specifications will specify the qualifications and responsibilities of other abatement professionals associated with the particular project. These other persons will include the Asbestos Project Manager -usually the Owner or Owner' s representative. The Project Manager who will be responsible for assisting in decision making; developing, implementing, and enforcing the contract specs, inspecting the work areas and critical barriers; and possibly coordinating bulk and air sampling collection as well as other duties. The Industrial Hygiene Services Contractor engaged by the Owner will be in charge of collecting air sampling in accordance with the project specifications. The types of sampling: pre-abatement, area sampling, personal, and any air volume requirements or associated sampling strategies will be outlined. The procedures to be followed for final air clearance testing will be detailed in accordance with applicable Federal and State regulations. The laboratory services utilized will be specified as having to be accredited for both bulk and air sample analysis. In general, the laboratory should be listed under the National Voluntary Laboratory Accreditation Program (NVLAP) sponsored by the National Institute of Standards and Technology (NIST). It is recommended that individual industrial hygienist who analysis air samples on-site, be successful participants of the Asbestos Analyst Registry Program sponsored by the American Industrial Hygiene Association (AIHA). Turnaround time for samples may also be specified, as well as accreditation requirements for individual analysts. A well-designed and organized set of specifications will provide for a successfully completed abatement project. However, it is important for a contractor or supervisor to remember that not all regulations and requirements will be included in project specs. For this reason a contractor or supervisor should become familiar with any Federal, State, and Local laws which apply to his or her situation. 227
(1) Amount of material to be removed (2) Difficulty removing material FACTORS AFFECTING COST (a) (b) (c) (d) Irregular Surfaces Embedded utilities (e.g. electrical/water lines, etc.) Height above the floor Poor accessibility (i) (ii) (iii) Obstructions Close quarters (e.g. attics, crawlspaces, etc.) Need to remove ducts or other structures to get to ACM (e) Condition of Material (i) (ii) (iii) Previously encapsulated Non-friable/slightly friable (e.g. pipe elbows, floor tile etc.) Material difficult to detach from substrate (3) Difficulty with containment (a) Plenum extending beyond work site (e.g. walls in project area extending just up to suspended ceiling, open plenum area above suspended ceiling) (b) Multi services area for HVAC system (c) Excessive penetrations through critical barriers (e.g. large number of pipes, ducts, and/or conduits penetrating the walls, floor and/or ceiling which could serve as pathways for contamination.) (d) Substantial changes in pressure between the work site and adjacent areas (consider the presence of elevator shafts, infitration/exfiltration through the building envelope, unbalanced air handling systems in the building etc.) (4) Protection of special finishes (a) (b) (c) (d) Carpets Hardwood Floor Wood Panels Other easily damaged materials 228
(5) Special Environmental Problems (a) (b) (c) (d) (e) Elevated heat Confined spaces Toxic materials (in tank or other containers and/or applied with the space such as pesticides) Pressurized vessels, pipes, etc. Electrically energized equipment and/or utilities (6) Special Decontamination Problems (a) (b) (c) (d) (e) High probability that the interior of duct is contaminated Contaminated dirt floor Contaminated ceiling tiles Debris and contamination beyond the site of damage Mechanical equipment with contamination between flanges, or other components that will require it to be dismantled to abate contamination. (7) Tight time frame for completion of the work (a) (b) Double or Triple shifts per day Work six or seven days a week (8) Entrance/Exits (a) For workers (i) (ii) Insufficient entrances and exits for worker decontamination chamber and waste transfer chamber Excessive difficulty in moving waste in multi story building (e.g. more than three stories) necessitation for outside elevator or other waste transfer system (b) For Occupants (i) (ii) Abatement activities will take a fire exit out of service, restricting occupancy per life safety codes Alternative fire exits not feasible if one or more building exits taken out of service 229
(9) Disposal problems (a) (b) No landfills willing to accept asbestos waste in jurisdiction Special handling (10) Requirement for scale labor (e.g. project greater than $500,000) 230
1. Misinterpretation of the scope of work ESTIMATING PITFALLS 2. Omission or improperly defined scope of work 3. Poorly defined or overly optimistic schedule 4. Inaccurate work break down 5. Applying improper skill levels to tasks 6. Failure to account for risks 7. Failure to understand or account for cost escalation and inflation 8. Failure to use correct estimating technique 9. Failure to consider costs associated with over head, general and administrative and indirect costs 231
CONTRACT MANAGEMENT BASIC KNOWLEDGE 1. Know ALL provisions of the contract specifications 2. Know ALL conditions at worksite EVALUATE SPECIFICATIONS WITH SITE CONDITIONS 1. Know of conditions which could potentially injure workers and/or contaminate the property 2. Know the circumstances to be better able to rule on change order requests SPECIFIC KNOWLEDGE 1. Up Front Information a. Bonds & Insurance, etc. received and approved b. Board approval to authorize funds c. Submittals received & approved according to the provisions of the contract d. Date of notice to proceed e. Schedule f. Joint site inspections for damage 2. In Process Information a. Inspection reports b. Material evaluation c. Schedule compliance - if deviations- the reason(s) why d. Work performance matching payment request 3. Close Out Information a. Site inspection for compliance with contract b. Receipt of all submittals - Tests and independent inspection agency reports - Records which contractor had to keep - Manufacturer' s literature, instruction manuals, etc. for materials and/or equipment installed on the job c. Joint site inspection for damage d. Punch list finished e. Area clean 232
PROJECT NAME: PROJECT NUMBER: ASBESTOS ABATEMENT PROJECT DOCUMENTATION CHECKLIST DATE: COMPLETED BY: ITEM SUBMITTED NOT SUBMITTED PRE ABATEMENT SUBMITTALS 1. COPY OF NOTIFICATION (To Whom Sent) 2. COPY OF PERMITS (Permits Due) 3. INSURANCE DOCUMENTS 4. CONTRACTOR' S LICENSE NUMBER 5. SCHEDULE OF VALUES 6. DRAWINGS OF DECON AND CONTAINMENT AREAS 7. EMPLOYEE TRAINING DOCUMENTATION (State(s)) 8. MEDICAL MONITORING DOCUMENTATION (Physician' s Statement) 9. AUTHORIZED PERSONNEL LIST 10. EPA & OSHA DOCUMENTS 11. WORKER DECONTAMINATION PROCEDURES 12. EQUIPMENT DECONTAMINATION PROCEDURES 13. LANDFILL MANIFEST FORM 14. RESPIRATORY PROTECTION PROGRAM 233
15. EQUIPMENT LITERATURE (List Equipment) 1. 2. 3. 4. 5. 6. 16. REPLACEMENT MATERIALS SUBMITTALS (List Materials) 1. 2. 3. 4. 5. POST ABATEMENT SUBMITTALS 17. DAILY REPORTS 18. DAILY SIGN-IN SHEETS 19. NEGATIVE AIR PRESSURE STRIP CHARTS 20. PERSONAL MONITORING RESULTS 21. COMPLETED LANDFILL MANIFESTS/RECEIPTS 22. INSPECTION REPORTS FROM PERMITTING AGENCIES (If Required) 23. 24. 25. 234
CHAPTER 14 LEGAL AND INSURANCE CONSIDERATIONS In this chapter you will learn: - Grasp an overview of common and statutory law, including tort litigation and regulatory compliance. - Discover the value of record keeping and documentation. - Learn the "State of the art obligation". - Appreciate asbestos abatement contract specifications and documents. - Understand bonding, worker' s compensation, and insurance requirements. - Avoid legal pitfalls on asbestos abatement projects. LEGAL PROBLEMS IN ASBESTOS ABATEMENT (The remarks contained in this section are, by nature, general and do not attempt to specifically explore the law of any state. Moreover, these remarks are not intended to constitute a specific legal opinion on any asbestos abatement project. The sole purpose of these remarks is for the general guidance of those involved in asbestos abatement work. Specific legal advice on any matter should be obtained from competent legal counsel.) The owner or manager of a building facing the presence of asbestos has many potential problems. A major area of concern for building owners is the legal implications of asbestos present in buildings. In general, the problems can be divided into two areas. One broad area is the law of torts or legal wrongs. This could include the possibility of an owner being sued for failure to properly abate or contain asbestos. It could also include a cost recovery action by an owner who has or will perform asbestos abatement. The second broad area of concern to owners is the area of contractual liability as related to asbestos abatement programs. This is the area of emphasis in this section. TYPES OF CONTRACTS Once a building owner has decided to begin an asbestos abatement program, the owner is faced with many practical questions. The first of these relates to contract documents. In the private sector, a typical contract used for this type of work is the American Institute of Architects (A.I.A) form contract. 235
This will frequently consist of A.I.A. Form 101 ("Owner-Contractor Agreement Form--- Stipulated Sum"), a four-page document that typically contains the name of contracting parties, the contract amount, the start and completion date and other general data. Accompanying the A.I.A. Form 101 is the A.I.A. Form 201. This is a 19-page document, which contains the General Conditions to the Contract. Because these provisions are consistent from contract to contract, it contains much of the "boiler plate" language pertaining to construction type contracts. A.I.A. has additional forms, which the Owner can use as guidelines for developing Supplementary General Conditions, which modify the General Conditions to meet specific requirement of the job. A.I.A. Form 201 has been around for many years. Its clauses have been frequently litigated and lawyers and building owners are familiar with the normal interpretation placed on the language in A.I.A. 201. This provides for a degree of certainty, which is desirable. Of course, disputes do arise under these clauses. However, it is much easier for counsel and a building owner and a contractor to resolve differences in this known area than in the unknown areas of a job specification on an asbestos abatement contract. Asbestos abatement in State owned buildings would use General Conditions to the Contract developed by the Department of General Services or other agency with procurement authority (e.g., the University of Maryland and the Department of Transportation), instead of the A.I.A Contract Forms. These public agencies utilize their own forms for the Agreement between the State and the Contractor as well as other pertinent components of the contract. The third document that will typically be included in an asbestos abatement contract is the job specifications. These documents are intended to provide very detailed information on materials and work procedures involved with the job. Thus, the set of specifications may end up being a thick book. Specifications can be generated from scratch using the spec writer s knowledge of construction techniques, or they can be based on templates found in Guide Specifications, such as those published by the National Institute of Building Sciences (NIBS) or from Federal Agencies (e.g., Corp of Engineers, General Services Administration, etc.). Since each project is unique, the skill of the spec writer is critical to the success or failure of the project specifications. If guide specifications are used, the spec writer must select the appropriate sections from the guide document, tailor the language to match requirements for the project, and review the final draft to find and correct provisions that conflict with other parts of the document. In addition to conflicts, it is important to check draft specifications for errors and omissions. For example, a common mistake is to specify removal of material in the description of work, but to forget to specify re-insulation after the asbestos has been removed. When preparing job specifications, it is important to remember the 5 Cs of spec writing. That is, job specifications must be complete, concise, clear, comprehensive, and comprehensible. Note that once job specifications become incorporated into a contract, they are legal documents. Mistakes are almost always costly and create legal problems for the Owner. 236
CONTRACT SPECIFICATIONS One of the primary areas in specifications is the work description. Typically, if work is throughout a vacant building, and the material to be removed is open and accessible, the work description may not be a problem. However, if a contractor is being asked to remove only a segment of a portion of a building, serious misunderstands may result that could lead to disastrous consequences. If the building is partially occupied, the risk increases substantially. Any defect or failure associated with work site isolation procedures could lead to claims of asbestos exposure among the general building population. As a result the Owner may be facing third party tort liability issues. In addition there may be project delays as the contractor stops work to deal with contamination that has spread beyond the work site boundaries. Another issue that frequently arises is that of existing furniture, fixtures, and equipment in the work area. Most asbestos abatement projects require the removal and then the reinstallation of furniture, fixtures, and equipment after clearance levels have been achieved. To minimize the Owner s liability, articles that are potentially contaminated with asbestos, must be decontaminated before they leave the work area. This operation is very labor intensive and thus may represent increased cost for the project. The owner should make a realistic assessment of whether salvaging of fixtures is feasible based on the age and condition of the equipment, and the utilitarian value for the potentially contaminated articles. It is important to note that job specifications are the ordering document in which the contractor must follow to fulfill his/her obligation under the contract. The contractor does not have to do any work that is not written in the specifications. If the Owner wishes to have additional work done, or different quantity/quality of materials supplied, the contractor will be glad to do this after a change order has increased the price and time period of the contract. Likewise, the contractor' s per ception of quality may not be the same as that of the Owner. If the specification just said to provide a car, the contractor is free to provide a 15-year-old subcompact, instead of the new Cadillac, which the Owner expected. Thus, if the Owner wants a new Cadillac, he/she must specify a new Cadillac in the specifications. This concept is very important if performance type specifications are use. The bottom-line is that the Owner must put his/her expectations for the job in writing, and the place to do this is in the job specifications. SITE SECURITY Site security is another issue that should be specifically addressed in the specifications. Obviously jobs in prisons and mental health hospitals will require special security measures. However, security is necessary on any type of construction project. When these construction projects involve asbestos, it is extremely important to prevent building occupants and the general public from entering the work area. 237
Airborne asbestos fibers likely to be present in the work area represents a serious health hazard to people not wearing personal protective equipment. This is a risk over and above normal safety hazards common to construction sites. Thus, the specifications must prescribe appropriate means to restrict access to the asbestos abatement work site. Besides the concern for intruders, additional off-hours security measures may be needed to monitor for various emergencies. For example, the negative air pressure devices must remain running for the duration of the asbestos removal process. If there is a possibility of a power failure once the contractor has left the site for the evening or weekend, the specifications should detail the security mechanism that must be in place in order to detect the problem in a timely fashion, and to alert the contractor to initiate timely corrective action. This may include use of the Owner s existing security staff, or it may mandate that the contractor provide separate security arrangements. After hours security duties may also involve a fire watch detail under certain circumstances where work is being done in an occupied building. Both OSHA and Maryland s Control of Asbestos regulations require posting of warning signs on asbestos abatement projects. The job specifications must be sure these are included, and the Owner s representative who inspects the project must ensure that they remain posted throughout the course of the project. It is important to note that these regulatory warning signs are the minimum actions that must be taken. The Owner must take appropriate steps to be sure building occupants are informed of the dangers associated with the project. This may take the form requiring additional warning signs. A public awareness meeting is often useful to acquaint building occupants with the contractor and the methods that will be use to protect them from asbestos hazards. "STATE OF THE ART" CONSIDERATIONS Each owner must participate, if only through his architect or engineer representative, in equipment requirement decisions on an asbestos abatement project. The decision about the number of negative air pressure units, what type of respiratory protection equipment is required, what type of clothing is sufficient, what number of HEPA vacuum units are necessary and other similar equipment requirements are very important to the success and safety of the job. From a legal standpoint, it can be very effectively argued that "state of the art" equipment should be employed. OSHA requirements again should be viewed as minimal requirements, and the Owner has a legal and moral obligation to ensure that work incorporates the standard of care that a prudent person would be expected to take in order to protect human health and the environment. In some cases, these actions may be above and beyond that required by regulations, since regulatory requirement are the basic minimum and are frequently out-of-date. 238
If one is not going to employ "state of the art" technology, that decision must be justified and thoroughly discussed with the Owner s attorney. It is fool -hearty to embark on a course of action that ultimately could result in third party litigation in the future. Remember that a jury will establish whether the Owner exercised the proper standard of care when abating asbestos from his/her building. Their decision will likely be based on the standards at the time of the trial not necessarily the standards in place during the period when the abatement occurred. The testimony of the plaintiff s expert witness i s likely to be much more convincing than the Owner s claim that I complied with the regulation. There may be times when trade-offs may be appropriate. For example, Type "C" respiratory protection may not be required, during glovebag projects. The counterbalancing danger of employee accidents from hoses on scaffolding might possibly outweigh the necessity for an air-supplied respirator. The owner or his representative must be prepared to justify such decisions. The bottom-line is that trade-off in work practices must provide sufficient verifiable protection of workers and building occupants. Of course, if the decision to employ less than maximum protection is justified, cost is a reasonable factor to be considered, although costs savings must never be made if protection of human health and the environment is to be compromised. INSURANCE A major issue for asbestos abatement contractors is insurance. At present, the insurance "crisis" is easing and contractors who have not been able to obtain liability insurance now have it more readily available. From the owner or contractor' s perspective, it is first important to understand what the insurance requirements may be. The first issue is who must be protected. Generally speaking, the owner will want to require protection for himself, the contractor, and the workers of the contractor. This will mean that the owner will wish to be an additional insured under the contractor' s policy and to be furnished acertificate of insurance. It is important that the certificate of insurance specify the types of coverage afforded along with any exclusion clauses. If the certificate of insurance is not completely clear, that owner should request a copy of the contractor' s insurance policy. An attorney or other professional knowledgeable of insurance issues, particularly pertaining to the construction and asbestos abatement industries should evaluate such policies. This is particularly true with asbestos work exclusions now appearing in such policies. In lieu of a review of the policy, an affirmative representation from the insurer that the work includes asbestos abatement coverage may suffice; however, in most cases, a legal opinion will be necessary. This is particularly important if the risks will be high, such as when asbestos is to be abated from an occupied building. 239
Insurance must protect the insureds from both personal injury and property damage claims. For example, Automobile Insurance is an example of insurance normally required in State of Maryland Asbestos Abatement Contracts. Additional types of personal injury/property damage insurance may be required from time to time when unique risk factors are present. These can include Comprehensive General Liability Insurance that protects against bodily injury and most property damage claims and Standard Liability Insurance that protects against specific claims. Such policies in personal injury claims often have a pollution exclusion of coverage for asbestos related claims and in property damage coverage. Therefore, the owner must be sure that he is protected from the real hazards presented by asbestos abatement. The Procurement Officer along the Owner s representative and/or attorney will help make the decision about which coverage is necessary. Of course, it is also necessary to insure against the normal construction hazards as well. Another very important point is to determine for what length of time the insurance will be in place. Clearly, the insurance should be in force during the contract. However, it is most important that the coverage continue after that contract is completed. This will insure that, if the contractor fails to completely abate the asbestos problem and the owner fails to discover the contractor' s oversight, the owner will nonetheless be protected. Closely related to this is the need to determine whether the insurance is "claims made" or "occurrence" coverage. "Claims made" coverage will insure for claims made during the policy period. "Occurrence" coverage will insure for an occurrence taking place during the policy period, whether or not the claim is made during that time. This is very important because of the long latency period associated with asbestos diseases. If the insurance is "claims made" insurance and the policy expires or lapses, the owner may not be protected many years later when the claim is actually made. This matter should be carefully reviewed with the insurance representative and with legal counsel. Thus, the owner needs liability insurance coverage for both personal injury and property damage risks, a builder' s risk policy, which protects against the particular risks occurring during construction. In addition, professionals (like architects, engineers, project designers etc.) involved with the project may need Errors and Omissions Insurance coverage. It is a type of professional liability insurance such as the malpractice coverage that a doctor would have. Workers compensation insurance is mandated by law, and contractually specified in the General Conditions to the contract. In most states, worker' s compensation covers injuries received on the job by employees. Firms engaged in asbestos abatement activities should be aware that some states do not cover occupational diseases that arise many years after employment has terminated. Further, some states permit lawsuits to be filed against the employer by the employees. 240
Since this complex issue exceeds the scope of this manual, employers involved in asbestos abatement should include worker' s compensationin their discussions with their legal counsel. One other important aspect of specification writing and interpretation is the clean air standard to be used. Again, the safest legal path is going to be "state of the art". "State of the art" according to many industrial hygienists and other professionals requires the use of Transmission Electron Microscopy (TEM). to clear asbestos abatement projects. If one is going to conduct an asbestos abatement project most specifications will call for the use of TEM. Advise from a professional industrial hygienist will be useful in specifying air sampling procedures and clearance criteria on asbestos abatement projects. SUPERVISION AND TRAINING The care and skill exercised by the supervisor and workers who remove asbestos containing materials are the heart of any asbestos abatement project. Although equipment is important, good equipment will not save the job. If a contractor uses a competent supervisor, skilled workers, and appropriate abatement equipment, the chances for a successful project are greatly enhanced. Maryland and federal regulations require that workers and supervisors be trained in asbestos issues, prior to commencement of work. In general, these courses consist of four or five days of training for workers and supervisors, respectively. Although these courses offer a good introduction into the asbestos abatement process, they cannot create instant experts. Because of the wide diversity, which will be encountered on asbestos abatement projects, no training course can cover all the situations that may occur when doing asbestos abatement work. These people who are just entering the asbestos abatement work force are marginally trained and thus, may not have the knowledge or experience to deal with complex abatement situations. In many respects, the success of the project often hinges on the competency and experience of the contractor s superintendent and supervisor(s). 241
From the owner' s perspective, it is vital that the job superintendent be an experienced asbestos abatement worker. He or she must have had the experience on various projects and under various conditions. The owner should require documentation of this experience. It will behoove the owner to check on the quality of the preceding jobs. The superintendent is the key to the work. Many jobs are sufficiently extensive to require a job superintendent and a job foreman. The latter person typically will be in the containment area actually supervising the workers while the job superintendent may be in and out of the area at various times. If a job foreman is required, he or she too, should be experienced and able to instruct the workers on site and personally supervise actual preparation, removal and follow-up cleanup activities. It is desirable to contractually require that both of these positions be filled by qualified individuals. Many owners are now asking for contractors with experienced work crews. It is possible to contractually require such, although the price of the job will go up compared to the rip and skip abatement contractors who use marginally trained workers. This should not be viewed as an increase in price. It is basically the cost of hiring a reputable contractor who will do safe and cost effective work. From a legal standpoint those who are marginally trained are the weakest link in the chain. Both AHERA and the OSHA Asbestos regulations stipulate that all abatement workers be accredited by completing at least a 4 day EPA approved training course, including lectures, demonstrations, hands on training, respirator fit testing, and a course examination. From a legal standpoint, it is most important that records be kept to document training was given to each worker. In addition to training pertaining to asbestos issues, the contractor must provide training on other job hazards that may be encountered during the project. Information on Right-To-Know Training and other safety training should be required in the specifications. Legal concerns may arise if the Owner fails to warn the contractor of known hazards on the job, and if the Owner does not enforce provisions in the contract specifications requiring the Contractor to provide a safe and healthful work place. The contract specifications should be written in a manner, which will allow the Owner to inspect the contractor s records and to make appropriate copies as deemed necessary. This should apply to personnel records, project activity records, and financial records pertaining to the project. This will avoid the problem if the contractor goes out of business and then an asbestos claim is made against the owner many years, based upon an alleged failure to warn, train, or institute appropriate protective measures. RECORDKEEPING It is essential to maintain permanent records on all phases of the job. It is not enough to maintain these records for a few years. Federal regulations requires that asbestos related exposure and medical monitoring records be maintained for at least 30 years beyond termination of employment, since asbestos disease latency periods may extend 30 years or more beyond the work date. However, from a practical point of view, these records should be made permanent and kept indefinitely 242
ADEQUATE TIME FOR JOB PERFORMANCE One of the most difficult problems in asbestos abatement work is that of time. Once the owner has decided to conduct an asbestos abatement program, project time becomes very important. In some circumstances, there may be fixed windows of opportunity in which work can be accomplished. For example, abatement in schools or universities may be limited to the times between semesters. The Owner may have a keen interest in the duration of the project, if for no other reason, because this is the period in which the Owner is most at risk for accidental fiber releases to occupied portions of a building. To avoid contractual disputes, it is desirable for the owner to specify enough time to allow the project to be completed. Questions of access, other contractors and the owner' s employees must be considered. There are several scheduling techniques, which can be employed to help gauge the appropriate amount of time for various work tasks on the abatement project. A key element for such a determination is an adequate assessment of the work, which must be performed in terms of the amount of work involved, and the various steps that need to be implemented to accomplish these tasks. Generally speaking, qualified abatement contractors will proceed quickly once they begin a job. It can be disastrous if insufficient time is allotted to the project. However, there are negative consequences for allotting excessive time for the work. Project designer should estimate the appropriate amount of time it will take a reputable contractor to complete the job prior to procurement. During the pre-bid conference, legitimate feed back from bidders may suggest the project time needs to be adjusted. Once the project is awarded, the asbestos abatement contractor should be required to furnish the Owner with an estimated schedule for the work. When the proposed schedule is validated, the Owner should institute appropriate project management procedures to track work progress on the job. This way there may be early warning signs when the project may begin to get off schedule. The contractor then can institute appropriate counter measure to bring the work back on schedule. Owners must work with the contractor to help ensure project begin on schedule. It is important that the Owner s staff fulfill their obligatio ns outlined in the job specifications or reached though mutual agreement. Thus the Owner should have a checklist of all of the tasks that must be performed, such as moving furniture, deactivation of HVAC equipment, and providing staging areas, etc. If the Owner is responsible for delaying the contractor s work, the Owner can expect a change order request to cover the cost created by the Owner s actions. To mitigate delay damages, many owners choose to use liquidated damages as a vehicle to make sure that contractors finish the job. Liquidated damages are the costs incurred by an owner to cover expenses resulting from a contractor' s failure to complete the project on time. Note that liquidated damages are not to be used as a penalty fee. In order to claim liquidated damages, the Owner must demonstrate the actual loss, which will occur if the project fails to be finished on time. For example, if the Owner must rent space to carry on an operation if the project completion date is exceeded, such rental cost could be included in liquidated damage charges. It is important that the Owner accurately estimate the amount of money that will be needed if the project is not completed on time. If the projections are wrong, 243
the liquidated damages may not suffice to cover the actual damages. In these instances, the owner may find that he is limited to damages, which are less than what he needs. DISPOSAL OF ASBESTOS CONTAINING WASTE Another important issue is that of materials handling. The asbestos material must be properly containerized, labeled, and shipped to an approved licensed landfill. Job specifications must be very specific regarding disposal of asbestos waste. No building Owner would want the expense of digging up improperly buried asbestos and transporting it to a licensed landfill for proper disposal. There are also severe fines associated with improper disposal. EPA s NESHAP regulation for asbestos (40 CFR 61) prescribes the required manifest, which must be used to transport and dispose of asbestos containing materials. The owner should obtain receipts to show the delivery and disposal of the materials. It will be desirable for the Owner' s representative to have an inventory of the drums or bags to compare to the manifests returned from the hauler and landfill operator. Besides being good management practice, receipt and retention of disposal manifest are required by regulation. In fact the Owner must notify the EPA, if asbestos manifests are not returned within 45 day from the shipment date. SELECTION OF QUALIFIED CONTRACTORS Another problem peculiar to public works is the low bid problem. Low bid may equate to an unqualified asbestos abatement contractor. If the bid is substantially low, the Owner s representative should contact the contractor and require that the contractor valid his/her bid. Under this process, the contractor must present evidence to the Owner that all job requirements outlined in the project specifications can be met within the price frame offered in the bid. Perhaps the contractor made a mistake in formulating the bid. In this case it is up to the procurement officer and agency attorney to decide if the bid should be rejected. Remember that there is nothing that requires the contractor to make a profit. In some cases, a contractor may accept a job at a slight loss in order to demonstrate his/her ability, with the hope that a successful project will lead to further work in the future. However, if the contractor will suffer a substantial loss, there may be some question whether the job can actually be performed. For example, if the bid is less than the cost of the new fireproofing specified for the job, there should be serious concern. The contractor could either take short cuts to make up the difference, or get in the middle of the project and demand a significant change order to complete the work. The worst situation will be that the contractor will go bankrupt in the middle of the job and leave before the site is decontaminated. The way to resolve the low bid problem is to pre-qualify the contractor. Pre-qualification should consist of various requirements outlined in the bid document. These may include experience, training, formal education (for instance, attending seminars), and insurance. This can be done for contracts for both the public and private sectors. However, in the public sector, requirements must be reasonable, and avoid situations where competition will be limited to just one or two firms. A review by the Agency' s Attorney General will help avoid 244
this potential problem. Another method is to bid the project as a multi-step sealed competitive bid. Under this procedure, bidders must submit a technical proposal along with a sealed price bid. The technical proposal will be evaluated against a set of pre-established criteria. The price proposals of those bidders whose technical proposal meets or exceeds the minimum technical score specified in the solicitation, are opened, the firm with the lowest offered price is selected for the award of the contract. The price proposals of bidders whose technical proposal fails to meet the minimum technical are return to the bidder unopened. For State of Maryland projects, there are other means of selecting a contractor without resorting to the lowest sealed competitive bid approach. There can be found in the State Procurement Regulations. The Agency s procurement officer and attorney general should be consulted if one of these other methods is desired. The private sector has similar means and generally can employ them with more flexibility. However, regardless of the situation, both public and private buildings Owners need to consult legal council before beginning any procurement process. Frequently, an asbestos abatement contractor may be coupled with other renovation work. It is virtually always necessary to have some replacement structures for the asbestos containing structures that are removed. The private sector has more flexibility as to whether the asbestos contractor should be as subcontractor of a general construction contractor, or if the asbestos abatement contractor should be the prime contractor. On State of Maryland projects, the Asbestos Abatement Contractor must be the prime contractor. Some firms have their own forces, which can re-insulate and restore the site after asbestos abatement is complete. Other firms rely on subcontractors to perform re-insulation and restoration work. It is up the Owner s contract manager to work with the contractor to coordinate work between the various trades needed on the project. CLEANLINESS OF THE JOB SITE One final note is that of the completion of the job by obtaining "clean air"(the legal clearance standard as defined by regulation). Actually, the contractual requirements should be a combined requirement of clean air and clean surfaces. Clean surfaces mean no visible residue (regardless of content). It is possible to have acceptable air monitoring tests and still have dangerous levels of asbestos containing materials present within the building. In fact, once an abatement project is undertaken, the disturbing of surfaces frequently makes the remaining material, if not removed, more friable. Therefore, the owner or his representative must be sure that the contractor has thoroughly removed all material through a comprehensive visual inspection and that the air is clean using procedures outlined in the specifications which in turn should be based on sound industrial hygiene principles. AIR MONITORING Air sampling should be part of the work performed by an industrial hygiene firm engaged exclusively by the Owner. The individual hired for this purpose must have appropriate 245
training and documented evidence of proficiency. For example, the State of Maryland contracts for industrial hygiene services requires the individual to have successfully completed a course on the collection and analysis of airborne asbestos samples. This course must be equivalent to NIOSH s 582 course, which is the industry standard. The State also requires air samples that will be analyzed by phase contrast microscopy (PCM) to be done on site in order to get timely data. To help ensure quality, the State requires the industrial hygienist performing the work to be a successful participant in the Asbestos Analyst Registry Program operated by the American Industrial Hygiene Association (AIHA). In order to be accepted under this program an individual is given as series of samples that he/she must analyze. Results of these samples must be with established parameters set by AIHA. This way the State can have some confidence in the accuracy of air sample results being analyzed on the job site. Clearance air samples are generally collected and sent to a laboratory for analysis by transmission electron microscopy (TEM). The State requires that the lab performing the TEM analysis be listed in the National Voluntary Laboratory Accreditation Program (NVLAP) operated by the National Institute for Standards and Technology (NIST). Again, this is done to help ensure quality pertaining to air sample results. The approach taken by the State of Maryland for asbestos abatement in its own buildings represents prudent management. The private sector should follow this example. However, note that regulations do not require the Owner to take any action regarding air sampling. The regulatory burden is on the contractor to monitor exposure of his/her workers and to take appropriate clearance samples. For liability purposes, and to avoid the perception of a conflict of interest, it is prudent practice to have at least the clearance samples taken by a firm solely responsible to the Owner. Likewise it is prudent practice, but not required by regulation, to collect air samples during the course of the project in the occupied space outside the regulated work area. Again, for building occupants to have confidence in the results, it is important that the individual collecting the samples not be associated with the contractor. BONDING The difficulties in obtaining insurance have spread to the bonding industry. Traditionally, three types of bonds have been required in the construction industry to protect the owner or lender against the contractor' s financial default: - payment bonds, under which a surety company agrees to pay for labor and materials supplied to a project in the event the contractor fails to do so; and - performance bonds, under which a surety company agrees to complete performance of a project, if the contractor fails to do so. - bid bonds, under which the Owner is protected from increase cost it the bidder fails to enter into a contract agreement. The surety company pays the Owner the difference between the low bidder and the next highest bidder. 246
Abatement contractors who have had their insurance canceled or not renewed are experiencing difficulties in obtaining bonding. Bonding companies rely on the financial ability of the principal (the contractor) to respond to claims under payment and performance bonds. If a company is not insured against catastrophic liability, the financial underpinnings of the company are weakened, and the bonding company becomes apprehensive over issuing bonds. In a similar vein, lenders are reacting adversely to the no insurance/no bonding problems of such companies. Lenders are advising companies who find themselves in such positions that lines of credit will not be renewed, for the same reasons given by the bonding companies. The difficulty being encountered by asbestos abatement contractors in obtaining bonding is severe. For reasons similar to those which caused the asbestos abatement insurance crisis, many contractors are unable to obtain sufficient bonding and, in some cases, any bonding. In addition to the general underwriting concerns about the contractor' s ability to perform the work, another reason some bonding companies are unwilling to write bonds for asbestos abatement relates directly to liability insurance problems. Because the bonding contract often has requirements for the contractor to obtain and maintain certain liability insurance coverage on the project, the bonding companies fear that if the contractor has insurance problems, such as improper coverage or cancellation during the policy period, the potential loss that may otherwise be covered by liability insurance might be covered by the contractor' s performance bond. While the traditional concepts of bond underwriting may not be applicable to abatement contractors, it is nevertheless useful to understand them. The primary considerations of the bonding company in determining whether to bond a contractor are the ability of the contractor to perform the work and the contractor' s financial ability. A proven track record of successfully completed projects, without ensuing litigation, is very helpful to the contractor in demonstrating to the bonding company its ability to perform the work. Financial stability is important not only with respect to the contractor' s ability to perform the work, but also its ability to satisfy its indemnity obligation to the bonding company in the event a loss is suffered under the bonds. Unlike insurance, a payment or performance bond gives the bonding company the right to recover back against the contract for any losses sustained by it under the bond. A somewhat more intangible, yet important, factor is the contractor' s good character. Despite satisfactorily proving all of these items, however, a contractor may still not be able to obtain sufficient bonding in today' s market. In such events, an owner may waive or refuse bonding requirements or arrange other contractual mechanisms to assure payment or performance. There are numerous legal considerations involved in the evaluation of insurance and bonding coverage. The cost of insurance for asbestos abatement is significant, and if such expense is going to be undertaken, the coverage obtained should be satisfactory. While there are no easy 247
solutions in this decision-making process, it is mandatory that contractors, consultants, and owners undertake to become knowledgeable purchasers of insurance. The shift in the types of coverage written for the contracting industry from occurrence to claims made, and the difficulty in obtaining bonds have placed greater emphasis on the contractor' s commitment to the performance of work in a quality manner, the carrier' s commitment to continuing to insure asbestos abatement contractors, and the quality of the carrier' s coverage and insurance program in general. This makes the process of purchasing insurance more complicated, but a thorough review of the considerations outlined above will greatly assist the contractor, consultant, or owner in making a knowledgeable choice. 248
CHAPTER 15 SUPERVISORY TECHNIQUES A competent person (aka supervisor) not only needs to know the requirements of the regulations and work practices, but also how to enforce them. It is extremely important that the supervisor establish an effective, progressive disciplinary program to enforce proper work practices. Such a program may include such things as a verbal warning, a written warning, a day off w/out pay, and so on up the line. This should also be documented in writing so that you can show that supervision and discipline were given. Discipline must also be consistent in order to be considered effective. You can t enforce something one time and then overlook it the next. Aside from the negative aspects of discipline it is also an excellent idea to look for and reward correct use of safe work practices. Even if it is just a simple recognition, this can go a long way in encouraging safe work practices. It is important that the supervisor makes sure that his/her employees know what they are supposed to do and how to do it. A clear understanding of duties will help employees to avoid mistakes and poor work practices. In the beginning it may be necessary for the supervisor to take a more hands on approach until he/she feels comfortable that employees know what and how to do their jobs. Periodic checks in accordance with OSHA requirements may then be all that is necessary to ensure good work practices. However, these are only minimum requirements and the supervisor should feel free to make more frequent inspections of the work as necessary. Below are specific policies required by the State Employees Asbestos Program. It is important that the supervisor be familiar with these as well as other regulations so that they may be properly enforced. 249
STATE EMPLOYEES ASBESTOS PROGRAM SUMMARY OF MAJOR POLICIES TRAINING - All new Level II employees or employees who transfer into Level II positions must be trained during their probationary period in a Level II training program approved by the Department of the Environment (MDE). - No employee shall work with asbestos until he/she has been trained by the MDE and has passed a written examination - If training is not provided, the employee has the right to refuse the assignment. - All Level II building maintenance employees must be retrained annually by MDE and successfully meet the objectives of the Level II Retraining Program before engaging in asbestos-related work assignments. All Level II automotive employees must be retrained annually by their Agency Safety & Health Specialist. - A standardized written examination will be provided at the end of both the initial and refresher training. These exams are administered and retained confidentially for three years by MDE. DEFINITIONS LEVEL I WORKER - Any worker with the potential for asbestos exposure because of workrelated activities, but who does not normally break, cut into, tear out, or otherwise disturb asbestos or asbestos-containing materials. LEVEL II WORKER - Any worker whose job activity causes him/her to break, cut into, tear out, or otherwise disturb asbestos or asbestos-containing materials, or who must work in areas where this activity takes place or who must enter an area restricted due to asbestos contamination. INCIDENTAL JOB ACTIVITIES - Those job activities, which happen as a result of or in connection with, the performance of an employee' s normal duties that are unavoidable because of the nature of that job activity. 250
MEDICAL MONITORING - Post-probationary Level II employees who cannot be medically approved for respirator use will be reassigned, within classification, to other available work not involving Level II activities. - The medical monitoring contractor will provide all Level II workers with preplacement and periodic examinations. Termination examinations will be offered when the employee leaves Level II work. - All Level II employees must participate in the Medical Monitoring process. Level II employees are not to perform Level II asbestos duties until their Medical Monitoring exam approves them to use respiratory protective equipment. - An employee who participates in the medical monitoring program, but refuses any components of the examination, will be advised that the refusal may compromise his health status. - All Level II new hires should meet the prerequisites for both Medical Monitoring and Training during the Probationary Period. The probationary period can be extended if necessary. - If an employee refuses to work with asbestos, he will not be eligible for medical monitoring. This refusal will be documented. - If an employee can document previous Level II exposure as a State employee and no longer works with asbestos, he shall be entitled to medical monitoring on a voluntary basis. - Confidentiality of all medical records will be assured by maintaining medical records separately from personnel records and limiting access to medical personnel, the employee, and the employee' s designated representative. 251
WORK PRACTICES - State employees will be assigned work with Asbestos only when it is incidental, but necessary for the performance of their normal job functions, and where the amount of asbestos is less than 160 sq. ft., 260 lin. ft., or 35 cu. ft. per bldg. per year. Activities involving larger amounts are to be contracted out. - Employees found to be unable to wear respirators, or otherwise medically unfit for potential asbestos exposure, shall not be permitted to work with asbestos. - Disposable protective clothing shall be provided and worn when performing Level II activities. - State employees can volunteer to perform non-incidental work less than 160 sq. ft., 260 lin. ft., or 35 cu. ft. per building per year, with notification to and approval by their Agency Safety & Health Specialist. - Type C full-face airline respirators with pressure demand regulators are to be used when performing Level II Operations/Maintenance activities. When necessary for safety considerations, a full-face powered air-purifying respirator (PAPR) may be substituted. - Negative pressure half-face air purifying respirators with HEPA cartridges (or equivalent) are to be used when performing brake-repairs using an enclosed cylinder/vacuum system or an approved wet system. They may also be used by building inspectors taking 3 samples or less per building. PAPR s are to be used when the brake or clutch enclosure or wet system is not possible and when changing vacuum filters. An employee in lieu of a half-faced negative pressure respirator can also request a PAPR. - The State Employees Asbestos Program prohibits facial hair, which prevents direct contact of bare skin with the respirator sealing surface. - All occupants in the vicinity of an asbestos-related job should be evacuated to another area. If evacuation is not possible, appropriate fail-safe enclosures shall be used to prevent exposure. - All non-essential movable objects should be removed and all electrical equipment, outlets and ventilation systems must be properly deactivated, locked out, and isolated with 2 layers of 6 mil. poly for the project. 252
- A clean uncontaminated change area must be set up on all asbestos-related jobs. This must be a 3-stage decontamination area on jobs larger than 10 sq. ft. or 25 lin. ft. Otherwise an equipment room or area is sufficient. - OSHA warning signs must be posted on all asbestos related jobs. - Under no circumstances will Level II employees be allowed to perform asbestos jobs where wetting is not feasible. - An asbestos work differential of 50% will be paid to Level II employees in 1/10 hour increments, for time spent by the employee performing asbestos-related activities, and for time spent changing into and removing specified clothing and equipment. - Upon completion of initial Level II training, (i.e., the old 2 day Level II class), each employee hired prior to March 15, 1985 had 15 days to decide his/her option to sign a formal work refusal form and turn it into their maintenance/automotive supervisor. Failure to turn in this form implied a consent to perform Level II work if required. - Employees who were hired after March 15, 1985 do not have the option to refuse to work with asbestos when such employees have been duly informed of Level II job requirements and have been trained, medically monitored, respirator fit tested, and provided with appropriate safety equipment. They also have the right to refuse if they were not given the opportunity to read and have explained to them the required consent form. 253
GLOS S A R Y ABATEMENT: ACOUSTICAL INSULATION: AEROSOL: AGGRESSIVE SAMPLING: AHERA: AIHA: AIR CELL: AIR LOCK: AIR MONITORING: AIR PLENUM: AIR-PURIFYING RESPIRATOR: AIR SAMPLING: Lessening the HAZARD of ASBESTOS. Includes ENCAPSULATION, ENCLOSURE, REPAIR, and REMOVAL of ASBESTOS. The general application or use of asbestos for the control of sound due to its lack of reverberant surfaces. Particles, either solid or liquid, suspended in air. A way of taking AIR SAMPLES where the air is stirred up using fans and leaf blowers. Aggressive sampling is used for CLEARANCE AIR SAMPLES. The Asbestos Hazard Emergency Response Act - The EPA law covering ASBESTOS in schools. American Industrial Hygiene Association. Insulation normally used on pipes and ductwork comprised of corrugated cardboard and frequently impregnated with asbestos fibers. An empty room/space located between the CHANGE ROOM and the SHOWER ROOM and the SHOWER ROOM and the EQUIPMENT ROOM in some DECONS. Workers pass through the double flapped doors one at a time. The process of measuring the fiber content within a specific volume of air. Any space used to convey air in a building or structure. The space above a suspended ceiling is often used as an air plenum. A piece of protective equipment, which is a facemask with filters that you wear. It filters or purifies the air before the worker inhales it. Measuring the amount of ASBESTOS in the air using a pump. 254
AIR-SUPPLIED RESPIRATOR: ALVEOLI: AMBIENT AIR: AMENDED WATER: AMOSITE: ANSI: APPROVED LANDFILL: AREA AIR SAMPLE: ASBESTOS: ASBESTOS ABATEMENT: ASBESTOS FIBERS: A protective face mask that supplies clean air to you from outside the work area via a hose, using a compressor, or air tanks. Tiny air sacs found in your lungs. They are important areas where gas exchange occurs. The surrounding air or atmosphere in a given area under normal conditions. Water plus a chemical called a SURFACTANT. Amended water soaks into ASBESTOS faster than plain water. An asbestiform mineral of the amphibole group containing approximately 50% silicon and 40% iron III oxide, made of straight, brittle, fibers that are pale gray to pale brown in color. American National Standards Institute A site for disposing of asbestos containing waste that is licensed and follows EPA guidelines. An AIR SAMPLE taken from one spot in a room. It is used for measuring how much ASBESTOS is in the room during work. A naturally occurring mineral used for insulation in many buildings. Asbestos breaks into fibers. It causes lung cancer and other diseases. Varieties regulated by OSHA include chrysotile, crocidolite, amosite, anthophylite, actinolite, and tremolite. Procedures to control fiber release from asbestoscontaining materials in buildings. Fibers generated from asbestos-containing materials with their length being greater than 5 microns and a length to width ratio of at least 3:1. 255
ASBESTOS STANDARD: ASBESTOS-CONTAINING MATERIAL (ACM): ASBESTOS-CONTAINING WASTE MATERIAL: ASBESTOSIS: AUTHORIZED PERSON: B READER: BARRIER: BREATHING ZONE: BRONCHI: BUILDING/FACILITY OWNER: BULK SAMPLE: CANCER: Reference to the OSHA requirements in the general industry and construction standards regarding asbestos exposure (29 CFR 1910.1001, 29CFR 1926.1101) and EPA requirements (NESHAP, AHERA, and ASHARA). Any material containing more than 1% by weight of asbestos of any type or mixture of types. Any material, which is or is suspected of being asbestos or any material contaminated asbestos, which is to be removed from a work area for disposal. A disease caused by ASBESTOS. It is the scarring of the lungs, also known as white lung. Any person authorized by the employer and required by work duties to be present in regulated areas. A doctor who has had special training and has been certified to identify signs of occupational diseases on X- rays. Any surface that seals off the work area to inhibit the movement of fibers. A hemisphere forward of the shoulders with a radius of approximately 6 to 9 inches. Two main branches of the windpipe where air travels to your lungs. The legal entity, including a lessee, which exercises control over management and record keeping functions relating to a building and/or facility. A thumbnail sized piece of material, which is sent to a lab to test it for ASBESTOS. A large group of diseases where cells grow abnormally, rapidly and out of control. 256
CARBON MONOXIDE: CARTRIDGE: CERTIFIED INDUSTRIAL HYGIENIST (C.I.H.): CILIA: CLASS I ASBESTOS WORK: CLASS II ASBESTOS WORK: CLASS III ASBESTOS WORK: CLASS IV ASBESTOS WORK: CLEAN ROOM: CLEARANCE AIR SAMPLE: A colorless, odorless, tasteless poisonous gas. A filter used on an AIR-PURIFYING RESPIRATOR. An industrial hygienist, who after successfully passing an examination in the comprehensive practice of industrial hygiene, is certified by the American Board of Industrial Hygiene (ABIH). Very tiny hairs that line the walls of your windpipe and BRONCHI. They beat automatically and move mucus up your windpipe to remove objects from your respiratory system. Activities involving the removal of Thermal System Insulation (TSI) and Surfacing ACM or PACM as defined by OSHA Activities involving the removal of ACM that is not TSI or surfacing material as defined by OSHA This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics. Repair and maintenance operations, where "ACM," including thermal system insulation and surfacing material, is likely to be disturbed as defined by OSHA. Housekeeping (not clean up) that takes place after a Class I, II, or III job has been completed. Does not include picking up and bagging of asbestos debris/dust during Class I, II, or III operations as defined by OSHA The last room in the DECON (going out) which is uncontaminated. Has facilities for the storage of employees' street clothing and uncontaminated materials and equipment. An AREA AIR SAMPLE taken at the end of an abatement job. It tells the building owner whether the room has been cleaned adequately after the asbestos removal. 257
CLOSELY RESEMBLE: COMPETENT PERSON: Means that the major workplace conditions, which have contributed to the levels of historic asbestos exposure, are no more protective than conditions of the current workplace. In the OSHA regulations, a trained supervisor who makes sure that rules are followed and equipment works, is capable of identifying existing asbestos hazards in the workplace and selecting the appropriate control strategy for asbestos exposure; and who has the authority to take prompt corrective measures to eliminate them. In addition, for Class I and Class II work, is specially trained in a training course which meets the criteria for EPA' s Model Accreditation Plan (40 CFR 763) for project designer or supervisor, or its equivalent; and for Class III and Class IV work, is trained in an operations and Maintenance (O&M) course developed by EPA [40 CFR 763.92 (a)(2)]. CONTAINMENT: CONTRACT MANAGER or DESIGNEE: CONTRACT SPECIFICATIONS: (SPECS.) CONTROL METHODS: Isolating the work area from the rest of the building. Usually done by putting POLY on the walls and floors and using a NEGATIVE AIR MACHINE. This keeps ASBESTOS FIBERS inside the work area. The person assigned to be responsible for certain defined functions in administering the Contract, and is the only authorized person to make certain decisions, such as, but not limited to: approving deviations from technical Contract requirements and approving changes to the Contract sum. A written plan for the job. The contractor must follow the specs. Ways of controlling ASBESTOS. Includes ENCAPSULATION, ENCLOSURE, REPAIR, REMOVAL, RESTRICTION, and O&M. 258
CRITICAL BARRIER: CHRYSOTILE: CUBIC CENTIMETER: DECONTAMINATION UNIT or AREA (DECON): DEMOLITION: DIRTY ROOM: DISPOSAL BAG: Airtight barrier of 2 layers of 6 mil sheet plastic, which separates the contaminated work area from any other air space. Installed first, this barrier covers items such as, but not limited to: windows, doors, HVAC components, floor drains, and containment walls. The only asbestiform mineral of the serpentine group, which contains approximately 40% each of silica and magnesium oxide. It is the most commonly used form of asbestos in buildings. A space about the size of a sugar cube. Asbestos in the air is measured in Fibers per Cubic Centimeter. The DECON has three enclosed rooms consisting of the DIRTY (EQUIPMENT) ROOM, SHOWER ROOM, and CLEAN ROOM that are adjacent to and connected to the regulated area. Everyone must enter and leave the work/regulated area through the DECON. The wrecking or taking out/removal, together with any related handling operations, of any building component, system, finish, or assembly and any related razing or stripping of asbestos products within the building. The last room in the DECON (going in). Workers take their suits off in the dirty room on their way to the shower. Dirty hard hats and tools are also stored there. Also called: EQUIPMENT ROOM. A properly labeled, 6 mil thick, leak-tight plastic bag used for transporting asbestos waste from the abatement work area to a disposal site. 259
DISTURBANCE: DOSE: DOSE-RELATED: DUCT TAPE: DUST MASK: ELECTRON MICROSCOPE: EMPLOYEE NOTIFICATION: Contact, which releases fibers from ACM or PACM or debris, containing ACM or PACM. This term includes activities that disrupt the matrix of ACM or PACM, render ACM or PACM friable, or generate visible debris. DISTURBANCE includes cutting away small amounts of ACM or PACM, no greater than the amount that can be contained in one standard sized glove bag or waste bag in order to access a building component. In no event shall the amount of ACM or PACM so disturbed exceed that which can be contained in one glove bag or waste bag which shall not exceed 60 inches in length and width. The amount of a substance that you are exposed to during a specific time period. A relationship between the amount of a substance you are exposed to and the reaction your body has to that exposure. Sticky, often silver colored tape. Used to attach POLY among other uses. Also known as a filtering face piece usually made of paper or other fibrous material. It is not legal for ASBESTOS work. It does not provide adequate respiratory protection against asbestos because it doesn t fit tightly to your face. A microscope, which beams electrons (instead of light) at a sample. Electron microscopes are more exact than light Microscopes. Informing employees and building occupants of the presence of asbestos within their building. They also must be informed of the hazards associated with asbestos exposure, what is being done to eliminate the hazards, etc. 260
ENCAPSULANT: A material that surrounds or embeds asbestos fibers in an adhesive matrix and prevents release of fibers. Removal encapsulant: a penetrating encapsulant specifically designed for removal of asbestos-containing materials rather that for encapsulation in place. Bridging encapsulant: an encapsulant that forms a discrete layer on the surface of an in situ asbestos matrix. Penetrating encapsulant: an encapsulant that is absorbed by the asbestos matrix without leaving a discrete surface layer. Lockdown encapsulant: an encapsulant that is used after asbestos has been removed from the substrate to "lockdown" any stray asbestos fibers. ENCAPSULATION: ENCLOSE: ENCLOSURE: ENGINEERING CONTROLS: Treatment of asbestos-containing materials, with an encapsulant. To build an airtight box around ASBESTOS. A way to control ASBESTOS without removing it. The construction of an airtight, impermeable, permanent barrier around asbestos-containing material to control the release of asbestos fibers into the air. Ways of controlling airborne levels of asbestos such as, building barriers, using negative air ventilation systems, etc. Are to be determined and utilized before respirators may be used. ENVIRONMENTAL PROTECTION AGENCY / EPA: A U.S. government agency that protects the environment and citizens from pollution. EQUIPMENT ROOM / CHANGE ROOM: A contaminated room located within the decon that is supplied with impermeable bags or containers for the disposal of contaminated protective clothing and equipment. 261
EXPOSURE: FIBER: FIBER CONTROL: FIBERS PER CUBIC CENTIMETER (F/CC): FIBROSIS: FILTER: FITTING: FRIABLE ASBESTOS MATERIAL: FULL-FACE RESPIRATOR: The amount of ASBESTOS fibers in the air within a worker' s breathing zone determined by air monitoring and calculated as if the worker was not wearing a respirator. A single strand of ASBESTOS. ASBESTOS fibers are so small they are invisible to the naked eye. From the OSHA standard, it must be at least 5 microns long with a length-to-width aspect ratio of 3 to 1. Minimizing the amount of asbestos fiber generation through the application of amended water onto asbestoscontaining materials, or enclosure (isolation) of the material. The unit of measure of reporting the concentration of airborne ASBESTOS fibers in the air. A pump pulls contaminated air through a filter. The number of FIBERs on the filter are counted by using a microscope. The amount of air is measured in CUBIC CENTIMETERS. A disease where scar tissue is formed in the connective tissue of the lungs. A media component used in respirators, HEPA vacuums, negative air machines, and air samples to remove solid or liquid particles from the air. Any valve, tee, elbow, flange, union, reducer, or other piping connector within any piping system, which may be insulated with asbestos. Material that contains more than 1% asbestos by weight, and that can be crumbled, pulverized, or reduced to powder by hand pressure when dry. A facemask that covers the full area of your face from the hairline of your forehead to under your chin. GENERAL SUPERINTENDENT: The CONTRACTOR' S representative at the work site. This person will generally be the COMPETENT PERSON required by OSHA in 29 CFR 1926. 262
GLOVEBAG: GRADE D AIR: GROUND FAULT CIRCUIT INTERRUPTER (GFCI): HALF-MASK RESPIRATOR: HAZARD: HEAT STRESS: HEPA FILTER VACUUM COLLECTION EQUIPMENT (or vacuum cleaner): HIGH-EFFICIENCY PARTICULATE AIR FILTER (HEPA): A sack (typically constructed of 6 mil transparent polyethylene or polyvinyl chloride plastic) with two inward projecting long sleeve gloves, which are designed to enclose an object from which an asbestoscontaining material is removed. Air for an AIR-SUPPLIED RESPIRATOR. Grade D air has specific maximum levels of specific chemical gases, oil, and water filtered out so that it is safe to breathe. A sensitive circuit breaker for tools, equipment, and extension cords. A GFCI will stop the flow of electrical current before the worker is shocked or electrocuted. Must be used for all asbestos abatement jobs because water is present. A facemask that covers half of your face. It covers your nose and mouth from the bridge of your nose to your chin. A danger or a risk from an unsafe or unhealthy condition. An illness caused by working in a hot area. Has 3 levels or degrees of effect, which are HEAT CRAMPS, HEAT EXHAUSTION, and HEAT STROKE. HEAT STROKE is the most serious and may necessitate a medical emergency because of a body s inability to cool itself. High efficiency particulate air filtered vacuum collection equipment with a filter system capable of collecting and retaining asbestos fibers. Filters should be 99.97% efficient at retaining fibers of 0.3 microns or larger. A filter which removes from air 99.97% or more of monodispersed dioctyl phthalate (DOP) particles having a mean particle diameter of 0.3 micrometer. 263
HOMOGENEOUS: HVAC SYSTEM: IMMEDIATELY DANGEROUS to LIFE or HEALTH: LATENCY PERIOD: LOCAL EXHAUST VENTILATION: LUNG CANCER: LOCK-OUT/TAG-OUT (LOTO): MEDICAL HISTORY: MDE: MESOTHELIOMA: METHOD 7400: MICRON: Building material that is similar in appearance, texture, and color throughout and has the same date of application. Heating, Ventilation, and Air Conditioning system A condition where a hazardous atmosphere exists and exposure to the condition will result in serious injury or death in a very short time. The time from first exposure to disease development; e.g. cancer. The mechanical removal of air contaminants from the point of operation. An uncontrolled growth of cells in the lungs, which could result in the death of the host. Installation of a locking or tagging device to prevent activation of an electrical circuit or mechanical system, which has been deactivated for safety reasons. Always utilized in conjunction with established procedures by those employees who have access to these energy systems. Refer to OSHA 29 CFR 1910.147, "Control of Hazardous Energy Source." A record of a person s past health, including all the hazardous materials that they might have been exposed to and also any injuries or illnesses which might dictate their future health status. Maryland Department of the Environment A relatively rare form of cancer, which develops in the chest or abdominal lining with no known cure. NIOSH sampling and analytical method for fibers using phase contrast microscopy. One millionth of a meter. 264
MIL: MINERAL WOOL: MOSH: MSDS: MUCO-CILIARY ESCALATOR: NEGATIVE EXPOSURE ASSESSMENT: NESHAP: NIOSH: NEGATIVE PRESSURE: NEGATIVE PRESSURE USER SEAL CHECK: Prefix meaning one thousand. One thousandth of a meter. A commonly used substitute for asbestos. Maryland Occupational Safety & Health Material Safety Data Sheet One of the body s defense mechanisms against asbestos. Consists of tiny hair cells called cilia and mucus, which are in the windpipe. Upon breathing, fibers attach to the mucus and an upward movement of the cilia transfers the fibers and mucus to the throat where the mixture is either coughed out or swallowed. Demonstration by objective data, or by prior and representative sampling data, or by initial exposure monitoring that employee exposures during an operation are expected to be consistently below the PELs. National Emission Standard for Hazardous Air Pollutants, EPA Regulation 40 CFR Part 61 subpart M, National Institute for Occupational Safety & Health The official approving agency for respiratory protective equipment that tests and certifies respirators. An atmosphere created in the work area enclosure such that airborne fibers will tend to be drawn through the filtration system rather than leak out into the surrounding areas. The air pressure inside the work area is less than outside the work area. One of two fit checks to test the seal of a respirator to a wearer' s face. The check involves covering and sealing the filter openings/inhalation valves, and sucking in. The respirator should collapse slightly against the face. 265
NEGATIVE PRESSURE RESPIRATOR: NEGATIVE PRESSURE VENTILATION SYSTEM: OIL LESS COMPRESSOR: O&M PLAN / OPERATIONS AND MAINTENANCE PLAN: A respirator in which the air pressure inside the respirator inlet covering is positive during exhalation in relation to the air pressure on the outside; and negative during inhalation in relation to the air pressure on the outside of the respirator. A pressure differential ventilation system consisting of a housing holding a fan and motor; a series of filters which clean contaminated air. It ventilates this air to another location, which creates a negative pressure differential. An air compressor that is not oil lubricated and does not allow carbon monoxide to be generated in the breathing air. A plan for controlling the ASBESTOS that remains in a building. This plan includes: 1) Where asbestos is found in the building. ACM may need to be labeled. 2) The amount of training that workers must receive to work with the material. 3) A permit that must be obtained before working with asbestos. 4) Accepted ways to work with asbestos safely. This includes equipment, worker protection, training, and medical exams. 5) When and how to check the condition of asbestos materials and record any changes. OSHA / OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION: OSHA STANDARD: The Occupational Safety & Health Administration. A U.S. government agency within the Department of Labor that covers worker safety and health on the job. An OSHA regulation, for example, the OSHA Asbestos Standard, 29 CFR 1926.1101. 266
PARTICULATE CONTAMINANTS: PACM / PRESUMED ASBESTOS-CONTAINING MATERIAL: PAPR / POWERED AIR PURIFYING RESPIRATOR: PCM / PHASE CONTRAST MICROSCOPY: Minute airborne particles given off in the form of dusts, smoke, fumes, or mists. Thermal system insulation and surfacing material found in buildings constructed no later than 1980. An air-purifying respirator (a facemask with a filter) that has a motor. Contaminated air is pulled through filters where it is cleaned; the clean air goes to the face piece. Level II employees are required to wear this type of respirator or an AIRLINE/SUPPLIED AIR RESPIRATOR while working with asbestos. The analytical laboratory method used to count asbestos fibers for area and personal air samples. PELs / PERMISSIBLE EXPOSURE LIMITS: The OSHA PELs are 0.1 fibers per cubic centimeter of ( for asbestos) air as an 8-hour Time-Weighted Average (TWA) and 1.0 fiber per cubic centimeter of air within any 30-minute period of an 8-hour day called the Excursion Limit (EL). PERSONAL AIR SAMPLE: PERSONAL MONITORING: PERSONAL PROTECTIVE EQUIPMENT: An AIR SAMPLE taken in a worker' s breathing zone. This is a measure of how much asbestos the worker is exposed to. Personal air samples must be taken on a percentage of workers during every day according to the OSHA Standard on Asbestos, 29 CFR 1926.1101. Sampling of the asbestos fiber concentrations within the breathing zone of an employee. Any material or device worn to protect a worker from exposure to, or contact with any harmful material or force. 267
PLM / POLARIZED LIGHT MICROSCOPY: PIPE LAGGING: POLY or POLYETHYLENE SHEET PLASTIC: POSITIVE-PRESSURE USER SEAL CHECK: POSTING: PRE-CONSTRUCTION CONFERENCE: PRESSURE-DEMAND AIR-SUPPLIED RESPIRATOR: PRIMARY BARRIER: The analytical laboratory method used on BULK SAMPLES of asbestos, which is reported as a percentage of asbestos to the total sample. The insulation wrapping around a pipe. Six-mil sheet plastic taped to surfaces to prevent ASBESTOS from contaminating other outside areas. One of two fit checks to test the seal of your RESPIRATOR to your face. You check for leaks by covering the exhalation valve(s) with your hands and blowing into the face piece without breaking the seal; the mask puffs out. Once the mask puffs out, hold your breath and sense for leaks. Refers to danger or notification signs, which must be posted in any area in which asbestos removal is occurring, or at the entrance to the building where such work is taking place. A meeting held before any work begins between a contractor and a building owner at which time the job specifications are discussed and all details of the work agreed upon. A facemask with air supplied to the mask through a hose from outside the work area via a compressor or bottled air. The amount of air that is supplied to you is based on what you need to breathe. A regulator senses the amount of air that you need to breathe. Sheet plastic barriers installed after critical barriers, which protect building components and non-movable objects from water damage and asbestos contamination. The primary barrier is normally two independent and overlapped sheets. 268
PROTECTION FACTOR: PROTECTIVE CLOTHING: PULMONARY FUNCTION TEST: PURPLE BOOK: QUALITATIVE FIT TEST: QUANTITATIVE FIT TEST: RECORD KEEPING: The ratio of the ambient concentration of an airborne substance to the concentration of the substance inside a sealed respirator. The protection factor is a measure of the degree of protection provided by a respirator to the wearer. Protective lightweight disposable garments such as Tyvek or Kleenguard worn by workers performing asbestos abatement to keep gross contamination off their body. A breathing test to see how well your lungs are working. It measures how much air you can breathe in and out. It can tell you if there is a problem with your lungs. EPA publication June 1985 entitled Guidance for Controlling Asbestos-Containing Materials in Buildings, 1985 edition. A test that tells you if you have any leaks in your RESPIRATOR. You are tested by someone who follows the OSHA protocol. The test uses an irritant smoke, banana oil, saccharin or bitrex. If you smell or taste the testing substance, you have a leak which means the respirator does not fit. You must have a qualitative fit test for any NEGATIVE-PRESSURE RESPIRATOR that is issued to you. A test that tells you if you have any leaks in your RESPIRATOR. It is a more accurate test. A probe and analytical equipment is used to determine the amount of testing agent inside the mask and compares this inside level to the amount of testing agent outside of the mask. It gives you a personal PROTECTION FACTOR for the respirator you use. Detailed documentation of all program activities, decisions, analyses, and any other pertinent information regarding asbestos management. 269
REGULATED AREA: REMOVAL: REPAIR: RESPIRATOR: RESPIRATOR PROGRAM: RESTRICTION: SECONDARY BARRIER: SHOWER ROOM: SPRAYBACK: STRUCTURAL MEMBER: According to OSHA, an area established by the employer to demarcate areas where Class I, Class II, and Class III asbestos work is being conducted, and any adjoining area where debris and waste from such asbestos work may accumulate; and a work area within which airborne concentrations of asbestos, exceed or there is a reasonable possibility they may exceed, the permissible exposure limits. All operations where ACM and/or PACM are taken out or stripped from structures or substrates, and includes demolition operations. Returning damaged ACM to an undamaged condition to prevent fiber release. A device designed to protect the wearer from the inhalation of harmful contaminants. Must be approved by NIOSH and used in accordance with the employer' s respiratory protection program and manufacturer' s procedures. A written program established by an employer who provides for the safe use of respirators on their job sites. An area of a building or an entire building that has RESTRICTED ACCESS to only those Level II employees who wear a RESPIRATOR and DISPOSABLE PROTECTIVE CLOTHING. 6 mil sheet plastic installed surfaces of a containment during removal activities to protect primary layers. A room between the equipment and clean rooms in a worker decontamination system in which workers shower when leaving the work area. New insulation put up on ceilings, beams, and columns after ASBESTOS is removed and the job passes the CLEARANCE AIR SAMPLE. Any load supporting member such as beams and load supporting walls of a building. 270
SUBSTRATE: SURFACING MATERIAL: SURFACTANT: SURGICAL REMOVAL: TEM / TRANSMISSION ELECTRON MICROSCOPY: TESTING LABORATORY: TIME-WEIGHTED AVERAGE (TWA): THERMAL SYSTEM INSULATION (TSI): TYPE C RESPIRATOR: The material or existing surface located under or behind the asbestos-containing material. Material that is sprayed, troweled-on or otherwise applied to surfaces (such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, and other purposes). A chemical wetting agent added to water to improve penetration into an asbestos-containing material, thus reducing the quantity of water required for a given operation or area. Breaks down the surface tension of water. A process by which small amounts of asbestos are removed with extreme care from substrates to which critical barriers or other seals are to be applied. This process usually involves scraping with small hand tools directly into the inlet of a HEPA vacuum The analytical laboratory method to identify asbestos fibers in an air sample. It is the most accurate test because it only identifies asbestos fibers and is reported by the lab as structures per square millimeter or "s/mm 2 " of air that is sampled. An entity engaged to perform specific inspections or tests of the work, either at the project site or elsewhere; and to report and (if required) interpret results of those inspections or tests. The average concentration of a contaminant in air during a specific time period. ACM applied to pipes, fittings, boilers, breaching, tanks, ducts or other structural components to prevent heat loss or gain. An AIR-SUPPLIED RESPIRATOR. 271
WATER DAMAGE: WET CLEANING: WHITE BLOOD CELLS: WORK AREA: WORK HISTORY: WORK PRACTICES: VISIBLE EMISSIONS: VISUAL INSPECTION: Deterioration or delamination of wall, ceiling, flooring or other materials due to leaks from plumbing or cracks in the roof or floor. The process of eliminating asbestos contamination from building surfaces and objects by using cloths, mops, or other cleaning utensils which have been dampened with amended water or diluted removal encapsulant and afterwards thoroughly decontaminated or disposed of as asbestos-contaminated waste. A part of the body' s defense system. They attack foreign objects like bacteria or ASBESTOS. Also known as Phagocytes. The area where asbestos-related work or removal operations are performed which is designed and/or isolated to prevent the spread of asbestos dust, fibers or debris, and entry by unauthorized personnel. Work area is a Regulated Area as defined by 29 CFR 1926.1101. Part of a medical exam. Lists what you have worked with, when, and where. This helps the doctor look for job-related diseases that you might have. Ways of doing work that affect how safe it is. For example, keeping ASBESTOS wet is a good work practice. It keeps ASBESTOS out of the air. Any emissions containing particulate asbestos material that are visually detectable without the aid of instruments. A walk-through type of inspection by the competent person and/or the building owner s representative to detect incomplete work, damage, or inadequate clean up of the work area. 272