ROOFING REMOVAL OSHA COMPLIANCE NESHAP COMPLIANCE DISCUSSION ISSUES

ROOFING REMOVAL OSHA COMPLIANCE NESHAP COMPLIANCE

DISCUSSION ISSUES q Inspection q Type of ACM q Competent Person q Worker Training q Work Procedures q Negative Exposure Assessment

Inspection § § Assume Positive or Certified Inspection § § OSHA. 1101(k)(1), (2), (3) OSHA Class of Work § § Class II NESHAP Category of Waste § § § RACM Category II

TYPE OF ACM § TRANSITE § § OSHA Class II work NESHAP Category II waste § § Remove intact Carefully lower to ground Maintain in a non-friable condition to the waste site The waste is not regulated

TYPE OF ACM § ASPHALTIC ROOFING § § OSHA Class II Work NESHAP Category I waste § As long as the waste remains Category I (non-friable), it is not regulated

NESHAP § § § If the roof is at least 5580 s. f. , and the roofing is cut into sections for handling, the sawdust is RACM, and must be generated wet. The sawdust must be wet wiped or HEPAvacuumed, and contained in leak-tight labeled containers. The sawdust must be disposed of as ACWM at a NESHAP landfill, even though it is a small amount.

NESHAP § If the roofing is friable to start with, or will become friable: § § § 10 day notice Adequately wet Leak-tight containers Labels Waste Shipment Record Regulated asbestos landfill

WORKER TRAINING § OSHA Class II Work § § One day (8 hour) training OSHA required elements Address roofing work specifically Maintain documentation of training

COMPETENT PERSON § § EPA Certified as AHERA Contractor/Supervisor under the Model Accreditation Plan The OSHA Competent Person is responsible for OSHA compliance at the work site, whether he is on-site or not

WORK PROCEDURES § § 29 CFR 1926. 1101(a)(8) exemption 29 CFR 1926. 1101(g)(1), (3), (7), (8) § § (8)(ii) For removing roofing material Review standard

WORK PROCEDURES § § § § Remove in an intact state. Wet methods if non-intact (as feasible). Mist cutting machines continuously. Clean cut line with HEPA-vac or wet wipe. Immediately bag & label sawdust. Do not drop or throw material from roof. Non-intact kept wet or bagged on roof.

WORK PROCEDURES § § Lower all waste to ground by end of shift. Unbagged material lowered to ground must be contained to avoid dust. Shut down & isolate rooftop HVAC intakes Removal / repair jobs less than 25 s. f. must be done with no dust, and do not require HEPA-vac or wetting. 25 s. f. includes all work on one roof in one day.

NEGATIVE EXPOSURE ASSESSMENT § § Initial exposure assessment must be made and documented for each job. Negative exposure assessment must be verified by air monitoring. Repeating jobs may use repeat documentation if everything is the same. Use the forms.