OSHA Compliant Work Practices for Negative Exposure Assessment

OSHA Compliant Work Practices for Negative Exposure Assessment for Removal of Vinyl Asbestos Tile (VAT)

In 1995, federal OSHA entered into a formal agreement with manufacturers of resilient flooring products to the effect that any employer (contractor) who follows these compliant work practices and procedures may rely on them as constituting a negative exposure assessment based on air monitoring data in OSHA’s record. What this means is that OSHA is confident that by following these work practices during resilient flooring removal, there will be no exposure to the employees above the PEL. However, OSHA reserves the right to inspect work places to see that the procedures are followed. If they are not, and the employer is relying on this as an NEA, both worker exposure and a serious violation has occurred.

VAT REMOVAL The AHERA Inspector must document that the VAT is NESHAP Category I ACM. The OSHA Competent Person must determine that the VAT is intact and will remain intact. Definition of Intact: The ACM has not crumbled, been pulverized, or otherwise deteriorated so that it is no longer likely to be bound within its’ matrix.

VAT REMOVAL The Negative Exposure Assessment (NEA) is based on OSHA objective data, and is contingent on the following: - Intact - Worker Training - Compliant Work Practices

TRAINING Supervisor: AHERA certification…. . . Worker: OSHA 8 hour worker training specific for VAT removal THE ASBESTOS INSTITUTE

VAT REMOVAL COMPLIANT WORK PRACTICES: 1. HEPA vac entire floor (metal floor tool) 2. Wet methods - Misting - Not required for heat removal 3. Hand removal only 4. Substantially intact 5. Leak-tight waste container 6. Mastic removal - Wet scraping - Wet sand or chemical removal, low speed 7. HEPA vac dried floor (metal floor tool)

VAT REMOVAL The NEA exempts the regulatory requirement for the following: • Protective Clothing • Air Monitoring • Containment • Respirators • Decon

VAT REMOVAL Required jobsite inspections by the Competent Person: 1. Prior to work: - Assess for NEA 2. Upon employee request or upon condition change of the VAT: - Assess for validity of the NEA

VAT REMOVAL If the VAT becomes non-intact (friable): 1. Stop Work 2. May require NESHAP 10 - Day notice 3. Containment / Isolation 4. Comply with all OSHA Class II rules 5. Comply with all NESHAP RACM rules

VAT REMOVAL MECHANICAL CHIPPING IS ALLOWED ONLY IN NEGATIVE PRESSURE ENCLOSURE