FACILITIES
ENVIRONMENTAL
SAFETY
Get Ready for the New Asbestos
Standard
Four options are available for complying with the presumed
asbestos-containing material rule, which is one of the major changes
in the revised regulations
WILLIAM A. ONDERICK, RFM, Inc., West Chester, PA
On October 1, OSHA's revised asbestos rules became law, and with them are many changes
from the previous 1986 standard.
The presumed asbestos-containing material (PACM) rule is one of the bigger changes in the
revised standard. OSHA has declared that owners must presume that there are certain
high-risk asbestos-containing materials (ACM) in facilities built prior to 1981, unless bulk
sample results prove them to be nonasbestos.
The impact of this provision forces companies to think carefully before presuming where
asbestos is or where it is not. Companies must also heed the EPA Asbestos National Emission
Standards for Hazardous Air Pollutants (NESHAP), which require inspections and bulk
sampling to identify materials prior to renovation or demolition.
Compliance Options
Short and long term needs should be examined when analyzing how to comply with the PACM
provision. There are four options available.
Option 1. Ignore the standard and face potential enforcement fines.
Some owners practice crisis management, and only act when pressured by the situation.
Companies thinking this is a realistic option are opening themselves up to potential liability. The
likelihood that a company can escape from complying with the PACM provision is more
doubtful than ever.
Option 2. Presume all materials in pre-1981 buildings contain asbestos and simply post
additional warning signs.
Another change in the standard requires owners to increase the number of signs indicating
where asbestos is located in a given area (piping, surfacing materials, etc.), and a contact to call
prior to doing work in the area. This requirement is a major change from the 1986 ruling.
OSHA recently clarified its position, saying additional warning signs must be posted at strategic
locations where people might be exposed (entrances to mechanical rooms, lab hoods, etc.).
One sign posted at the entrance gate of the plant or in a lobby won't cut it. On the other hand,
OSHA does not expect companies to post signs in every room where there is floor tile.
Companies must use common sense in warning people about PACM. Just posting warning
signs in pre-1981 buildings does not guarantee a quality asbestos management program. It only
means you are in compliance with the PACM rule.
There are pros and cons to just putting up more warning signs. While it makes employees more
aware, it also has the potential to scare people and cause concern about working in an area
where there is asbestos.
Simply posting signs is not a cure-all and owners should be aware of its limitations.
Option 3. Survey or resurvey the facilities to be in compliance with the PACM ruling.
Almost every building owner has done some survey work in the past. Conducting mini-surveys
to verify asbestos locations is a more accurate step owners should consider. The goal of this
approach is to locate the predominant material in a given area, versus presuming asbestos is
everywhere as in Option 2.
Mini-surveys provide a comfort level about the accuracy of past survey information. Inaccurate
data often exist in old surveys, especially if the information is not kept current.
In the early days of conducting surveys, inspectors routinely took portions of insulation
materials instead of full core samples. This technique could result in an asbestos layer
underneath being missed.
Also, older facilities have a lot of patchwork insulation. Many past surveys overlooked this fact,
and there may be asbestos in nonasbestos designated areas or vice versa.
Undersampling was the rule of thumb in past surveys. Not taking enough samples to accurately
characterize an area could result in accidental exposure.
In addition, inaccurate bulk sample results were common in the past. Poor quality from labs
performing polarized light microscopy may be the weakest link in a successful asbestos
management program. Past lab results should be verified during mini-surveys.
The time period a survey was conducted might be a clue to accuracy. Prior to 1980, if a bulk
sample contained 5% or less asbestos, it was classified as nonasbestos. Today, a material is
considered asbestos if it is 1% or greater. In fact, some states say 0.1% is an asbestos material.
If conducting a PACM Verification Study or mini-survey, four major action steps should be considered.
Step 1: Define homogeneous areas in pre-1981 buildings. This step is nothing more than dividing the facility into smaller and like areas so survey data can be managed more efficiently.
Step 2: Conduct a walkthrough to verify where asbestos or nonasbestos is located in homogeneous areas. This step is more of a visual walkthrough, but may also require additional sample taking.
Step 3: Verify labeling needs while verifying where PACM exists.
Step 4: Verify condition of materials and damage. This step is not required as part of the
PACM rule, but it is a smart approach to take while verifying other information.
If work is performed in an area designated as PACM without really knowing for sure, you
could end up spending money for no reason. Presuming a material is asbestos can be costly.
You might be removing nonasbestos material using expensive control practices, putting workers
in personal protective equipment which can trigger expensive medical surveillance, or deposit
nonasbestos waste in more costly landfills. The survey determines the facts as they exist today.
Owners should consider putting survey information in a computer database to keep it current.
Option 4: Conduct more comprehensive surveys. Taking this step requires considering how
long you plan to stay in the building, degree of renovation work expected over the next several
years, and how accurate current survey information is.
Unless the company has embarked on a total removal campaign, it has probably conducted a
full-site survey or done partial survey work due to renovation or to be in compliance with the
EPA Asbestos NESHAP. Regardless of the situation, now might be the best time to rethink the
company's asbestos management philosophy and to upgrade current survey data records to be
in compliance with this PACM rule.
Some companies have decided to beat the regulation instead of just meeting it. With EPA
recently issuing a testing consent order on refractory ceramic fibers (RCFs), and the
on-again/off-again OSHA Reform Bill in Congress proposing new permissible exposure limits
for RCFs, mineral wool, and fibrous glass, it may not be too long until these respirable fibers
are regulated as well. Including other fibers in surveys should be considered.
Combination Approach
The four basic options can be combined in various forms. For example, an owner might only
conduct comprehensive surveys when an area or individual building is undergoing extensive
renovation or a shutdown is scheduled. Perhaps the company might only conduct a verification
study in pre-1981 buildings that have a high concentration of employees or traffic. In areas
where there are few or no employees, an owner may decide to just post signs.
Owners should carefully evaluate their options in order to comply with the new PACM
provision, and be smart about where to spend money. However, regardless of budget
limitations, nothing is more important than protecting the health and safety of employees and
visitors.
--Edited by Ron Holzhauer,
Managing Editor, 708-390-2668
New OSHA Asbestos Standard Highlights
- A competent person must oversee all asbestos control procedures. Training for this
individual must meet EPA's Model Accreditation Plan criteria.
- Owners must identify or presume suspect materials contain asbestos. OSHA's PACM
provision requires owners to presume that thermal system insulation, surfacing materials,
and certain miscellaneous materials installed prior to 1981 contain asbestos, unless bulk
sampling survey information or other objective data proves it to be nonasbestos.
- Tougher rules for warning signs and notification of employees and other building
occupants of the presence of ACM/PACM to ensure the material will not be disturbed.
OSHA dropped its large and small-scale work definitions and created more specific work
practices and procedures. Now all asbestos work is grouped into four classifications.
Class I: Removal of high-risk ACM/PACM, mainly thermal system insulation (TSI) and
surfacing materials (friable materials).
Class II: Removal of ACM/PACM other than TSI or surfacing materials, such as floor tile,
transite, and gaskets (nonfriable materials).
(Although OSHA has eliminated the terms friable and nonfriable, they are used here for clarity.
These terms are still used by EPA.)
Class III: Repair/maintenance of ACM/PACM generating no more than one waste bag.
Class IV: Clean up debris containing ACM/PACM or custodial activities near damaged or
friable asbestos caused by a Class I, II or III activity.
- Lower permissible exposure limits (PEL) took effect on Oct. 11, 1994: PEL: 0.1f/cc -
8-hr TWA (reduced from 0.2f/cc) 30-min excursion limit: 1f/cc.
- Conduct assessments before each asbestos job to determine exposure levels,
requirements, and work practices.
Increase in training requirements:
Class I and II -- 32-hr worker training
Class III -- 16-hr worker training
Class IV -- 2-hr awareness training.
For more information...
The author is willing to answer technical questions concerning the PACM rule and other
requirements in the revised OSHA asbestos standard. Mr. Onderick is available at
800-870-9161.
Plant Engineering - Oct
09, 1995
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