OSHA 29 CFR 1926 1101 Asbestos Regulations For

OSHA 29 CFR 1926. 1101 Asbestos Regulations For The Construction Industry

CONTRACTOR ISSUES • PEL: -TWA 0. 1 f/cc -EL 1. 0 f/cc • Competent Person • NEA • Regulated Areas • Training • Std. Control Methods • Comply with specifications.

BUILDING OWNER ISSUES • • PACM: TSI & Surfacing Resilient Flooring Predating 1981 “Due Diligence” Identification Notifications – – Contractors Maintenance Employees Adjacent Contractors Commercial Tenants • Recordkeeping

THE OSHA REGULATION BY SECTION (a) Scope and Application (b) Definitions (c) Permissible Exposure Limits (PEL’s) (d) Multi-employer Worksites (e) Regulated Areas (f) Exposure Assessments and Monitoring (g) Methods of Compliance (h) Respiratory Protection (i) Protective Clothing

THE OSHA REGULATION (cont. ) (j) Hygiene (k) Communication of Hazards (l) Housekeeping (m) Medical Surveillance (n) Recordkeeping (o) Competent Person (p) Appendices (q) Dates

(a) SCOPE AND APPLICATION Employers must protect employees wherever they may be exposed to asbestos in construction: i. e. . . : Demolition, Construction, Maintenance, Cleanup, Application, Transportation, Etc. . . , etc. . …. . .

(b) DEFINITIONS Defines terms by which regulatory application is made: i. e. . . : Building/facility owner Employee Exposure Class I Work Intact Class II Work PACM Class III Work TSI Class IV Work Surfacing Competent Person ACM Disturbance NEA

CLASSES OF WORK DEFINITIONS Class I Work The removal of TSI, fireproofing or popcorn Class II Work The removal of anything else Class III Work The small scale, short duration disturbance of ACM Class IV Work Contact, but no disturbance, or cleanup of previously generated debris

CLASSES OF WORK Class II Work Class IV Work Competent Person In All Classes Class I Work APPLICATION Requires NPE, shower decon, full PPE, certified people, air monitoring, Negative Exposure Assessment (NEA) No initial NPE, NEA exemptions for shower decon, PPE, certified workers, air monitoring. One day training. Requires PPE for TSI & Surfacing, NEA exemptions for all other ACM. Two day training. SS, SD only. Requires NEA, all exemptions allowed, 2 hour training required.

(c) PERMISSIBLE EXPOSURE LIMITS THERE ARE TWO PEL’s: 1. Time Weighted Average (TWA): 0. 1 f/cc 2. Excursion Limit (EL): 1. 0 f/cc Both must be measured for. If either one is exceeded, the PEL has been exceeded, and certain controls must be implemented.

(d) MULTI-EMPLOYER WORKSITES Each contractor is responsible for their own employees, the abatement contractor is responsible for the integrity of his work area, and the general contractor is responsible for everyone. The general contractor is responsible for the compliance of the abatement contractor.

(e) REGULATED AREAS All Class I, II and III Work requires a regulated area It must be demarcated and “regulated” by the Competent Person DANGER ASBESTOS No: Eating Drinking CANCER AND LUNG DISEASE HAZARD Smoking AUTHORIZED PERSONNEL Chewing ONLY Cosmetics

(f) EXPOSURE ASSESSMENTS AND MONITORING An Initial Exposure Assessment must be made and documented. It will either be negative or not (positive), and the project will be designed and operated by the competent person accordingly. It needs to be negative! A Negative Exposure Assessment must be proven valid by one of the following: (A) Objective Data (B) Historical Data (C) Air monitoring on this job

(g) METHODS OF COMPLIANCE • General “spec” requirements and prohibitions for all asbestos work, regardless of exposure. • Class I work requirements • Class III work Requirements • Class IV work requirements • Special methods for certain roofing and pipeline coatings THIS IS THE “CONTRACTOR’S SECTION” OF OSHA

(g) METHODS OF COMPLIANCE (1) Requirements (3) Prohibitions (i) HEPA-vacuums (i) High-speed disc saws (ii) Wet methods (iii) Prompt clean-up in labeled, leak-tight containers (ii) Compressed air (iii) Dry sweeping or clean-up (iv) Employee rotation for PEL compliance

(g) METHODS OF COMPLIANCE (g)(2) only applies when the PEL is exceeded or there is no Negative Exposure Assessment (NEA). If there is no air monitoring data on a construction site which disturbs asbestos, exposure is assumed and the (g)(2) controls are required.

Specific Control Methods (g) METHODS OF COMPLIANCE (cont. ) CLASS I REQUIREMENTS • Negative Pressure Enclosure • Glovebag • Negative Pressure Glove Box • Water Spray Process • Mini-Enclosure OR: • Alternative Control Methods

(g) METHODS OF COMPLIANCE (cont. ) Specific Control Methods CLASS II REQUIREMENTS: “Spec” requirements for: • Vinyl and Asphalt Flooring • Roofing Material • Transite siding, Shingles or Panels • Gaskets • Any other Class II Material • Alternative Control Methods

(g) METHODS OF COMPLIANCE (cont. ) CLASS III REQUIREMENTS: • Competent Person • NEA • Regulated Area • Wet Methods • HEPA Exhaust • Isolation (Mini-Enclosures or Glovebags) • Respirators & Protective Clothing • Prompt Clean-up of Waste

(g) METHODS OF COMPLIANCE (cont. ) CLASS IV REQUIREMENTS • Competent Person • NEA • Training • Wet Methods • HEPA Vacuum • Prompt Clean-up

(g) METHODS OF COMPLIANCE(cont. ) Roof Flashing & Pipeline Coatings • Intact Material Only • Competent Person • Training • Work Methods To Maintain Material Intact • No Other OSHA Requirements

(h) RESPIRATORY PROTECTION Respirators required: • Class I Protection Factors: • Class II Non-intact • Half-Mask 10 • Class I & II Dry • Full Face 50 • Class II & III w/o NEA • PAPR 1000 • Class III TSI & Surfacing • Class IV Where Required Other Issues: • Exposure Above PEL NIOSH Approval • Emergencies Written Program Medical Exam Fit Test

(i) PROTECTIVE CLOTHING “Whole Body Covering” Required: • No NEA • Above TWA • Class I > 25 l. f. or 10 s. f. Competent Person must ensure immediate repair or replacement of non - intact clothing.

(j) HYGIENE FACILITIES & PRACTICES Full Decontamination Required For Class I Work > 25 l. f. or 10 s. f. ROOM SHOWER Regulated Issues: • Entry / Exit Procedures • Shower Configuration & Use EQUIP. ROOM WORK AREA CLEAN

(j) HYGIENE FACILITIES & PRACTICES (CONT. ) “Drop Cloth Decon” Required For • Class I Work < 25 l. f. or 10 s. f. • Class II & III @ PEL • Class II & III Without NEA • Class IV Cleanup Work Area HEPA/CLEAN PERSON, EQUIPMENT, WASTE BAGS, TOOLS MUST ENTER & EXIT HERE Drop Cloth

(k) COMMUNICATION OF HAZARDS The Building Owner Is A “Statutory Employer”, and must notify persons of ACM before it is disturbed. ALL TSI, SURFACING & RESILIENT FLOORING IN BUILDINGS BUILT THROUGH 1980 MUST BE PRESUMED TO BE, AND TREATED AS ASBESTOS! Prior to disturbance, the owner must notify: • Contractors • In - House Maintenance • Adjacent Contractors on Multi-Employer Worksites • Commercial Tenants “THE BUILDING OWNERS SECTION”

(k) COMMUNICATION OF HAZARDS (cont. ) PACM may be rebutted by: • Referring to an AHERA report, OR • Sampling per 40 CFR 763. 86 THE SAMPLING INSPECTOR MUST BE AHERA ACCREDITED

(k) COMMUNICATION OF HAZARDS (cont. ) Building Owner Must Post Mechanical Rooms To Identify ACM Or PACM! Wording For Regulated Area Poster: DANGER ASBESTOS CANCER AND LUNG DISEASE HAZARD AUTHORIZED PERSONNEL ONLY and, where required: RESPIRATORS AND PROTECTIVE CLOTHING REQUIRED IN THIS AREA

(k) COMMUNICATION OF HAZARDS Label for waste containers on site and installed products (where feasible) : DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD AVOID BREATHING ASBESTOS FIBERS

(k) COMMUNICATION OF HAZARDS (cont. ) WORKER TRAINING: • CLASS I: AHERA Worker Accreditation • CLASS II: 4 or 8 hr. specific • CLASS III: AHERA 16 hr. O & M • CLASS IV: AHERA 2 hr. awareness Training required prior to work and annually thereafter

(l) HOUSEKEEPING 1. Vacuuming must be by HEPA-vac 2. ACM waste in labeled, leak-tight containers 3. Special care of ACM resilient flooring 4. Dust / debris in areas of accessible TSI, Surfacing or damaged ACM must be treated as asbestos

(m) MEDICAL SURVEILLANCE 1. Required for use of negative pressure respirator, or Class I-III work 30 days a year. 2. Prior to work and annually thereafter. - OSHA questionnaire - Pulmonary function test - Physical exam 3. Employer information to physician. 4. Physician’s written opinion

(n) RECORDKEEPING Contractor Records: 1. Objective or Historical data (30 years) 2. Air Monitoring data (30 years) 3. Medical Surveillance records (30 years) 4. Training records (2 years) Building Owner Records: 5. Data to rebut PACM 6. Records of Notifications

(o) COMPETENT PERSON The Competent Person must have the knowledge, foresight & authority to plan & run the job correctly. He is responsible for safety, health, engineering controls and work practices at the site. TRAINING: Class I & II : AHERA Contractor/Supervisor Class III & IV : AHERA 16 hr. O & M

(p) APPENDICES • Mandatory: A, C, D, E • Non-mandatory: B, F, H, I, J, K A: Air Monitoring B: Air Monitoring C: Reserved D: Medical Questionnaire E: Interpretation of Xrays F: Class I Work G: Reserved H: Asbestos Information I: Medical Surveillance Guidelines J: Smoking Cessation Information K: PLM Analysis

(q) DATES The final rule became effective October 1, 1995