RFM Inc. | |
| Asbestos Compliance | Basic Facts |
| For Facility Owners | White Paper |
Final Remarks
Asbestos has been around for a very long time, probably even since the dawn of time. While it has gone from a mysterious wonder material
to a known health hazard, one thing remains true...it is likely to be around for a lot longer and will continue to be studied and debated.
About the Author: William A. Onderick is President of RFM Inc., a consulting firm formed in 1991 specializing in strategic
asbestos management compliance for facility owners. Mr. Onderick is the former Corporate Asbestos Issue Manager for the DuPont Company. He spent nearly
10 years leading an internal effort in DuPont to manage the asbestos issue smarter. He is a frequent speaker and author on asbestos management and asbestos
replacements offering both a facility owner and consultant's perspective to the issue. For more information, he can be reached by phone at (800) 870-9161,
by e-mail at rfmnet2@att.net or through RFM's website at www.RFMnet.com.
| Chart 1 - World Production of Asbestos (1995) |
|
| Country | Metric Tons |
| Russia | 1,000,000 |
| Canada | 510,800 |
| China | 250,000 |
| Brazil | 180,000 |
| Zimbabwe | 145,000 |
| South Africa | 100,000 |
| Greece | 50,000 |
| Swaziland | 30,000 |
| India | 25,000 |
| United States | 9,000 |
| Colombia | 5,000 |
| Romania | 3,000 |
| Yugoslavia | 1,000 |
|
Source: The Asbestos Institute, Canada
| Chart 2 - Commercial Asbestos Fiber Types |
|
| Mineral Name | Commercial Name | Mineral Group | Chemical Formula |
| Chrysotile | Chrysotile | Serpentine | Mg6(OH)8Si4O10 (± Fe) |
| Riebeckite | Crocidolite | Amphibole | Na2(Fe3+)2(Fe2+)3(OH)2Si8O22 (±Mg) |
| Grunerite | Amosite | Amphibole | Fe7(OH)2Si8O22 (± Mg, Mn) |
| Anthophyllite | Anthophyllite | Amphibole | (Mg, Fe)7(OH)2Si8O22 |
| Actinolite | Actinolite | Amphibole | Ca2Fe5(OH)2Si8O22 (± Mg) |
| Tremolite | Tremolite | Amphibole | Ca2Mg5(OH)2Si8O22 (± Fe) |
|
Source: Health Effects Institute Asbestos Research Program, United States
| Chart 3 - Common Asbestos Containing Materials |
|
| Asbestos Types | Generic Name | Asbestos % | Dates of Use |
| Surfacing Materials | Sprayed/Trowelled-On | 1-95% | 1935-1970 |
| Thermal Insulation | Batts, Block and Pipes | 10-30% | 1926-1971 |
| Textiles | Curtains, Gloves | 60-65% | 1945-Present |
| Cement Products | Extrusion Panels | 8-10% | 1965-1977 |
| Corrugated | 20-45% | 1930-Present |
| Flat | 30-50% | 1930-Present |
| Pipe | 15-20% | 1930-Present |
| Paper Products | Corrugated | 35-90% | 1935-Present |
| Millboard | 80-85% | 1925-Present |
| Asbestos Compounds | Adhesives | 5-25% | 1945-Present |
| Joint Compound | 3-5% | 1945-1975 |
| Flooring | Vinyl Asbestos Tiles | 10-30% | 1960-Present |
| Sheet Goods | 30-40% | 1950-Present |
| Paints and Coatings | Roof Coatings | 5-10% | 1900-Present |
|
Source: Environmental Protection Agency, United States, 1985
| Chart 4 - EPA Asbestos Ban & Phase-Out Rule Summary |
|
| Background
In the November 5, 1993 Federal Register, EPA announced it's determinations concerning the regulatory status of
asbestos containing products originally banned in it's original Ban and Phase Out Rule. EPA has concluded that several asbestos containing
product categories were not being manufactured, processed and imported on July 12, 1989 and thus are still subject to the ban.
EPA also concluded that certain asbestos containing product categories were being manufactured on July 12, 1989
and thus are no longer subject to the ban meaning they still could be manufactured and installed in buildings and facilities today. The
products in each of the categories are listed below:
|
|
| Banned | Not Banned |
| Corrugated Paper | Asbestos Cement |
| Specialty Paper | Asbestos Clothing |
| Commercial Paper | Pipeline Wrap |
| Rollboard | Roofing Felt |
| Flooring Felt | Vinyl Asbestos Floor Tile |
| New Uses of Asbestos | Asbestos Cement Pipe |
| Millboard |
| Automatic Transmission Components |
| Clutch Facings |
| Friction Materials |
| Disc Brake Pads |
| Brake Blocks |
| Gaskets |
| Roof Coatings |
| Non-Roof Coatings |
|
|
Source: Federal Register, United States, 1993
| Chart 5 - OSHA Asbestos Standard Summary Highlights - 1994 |
|
| Scope |
Demolition, maintenance, repair and renovation that may encounter ACM, emergency spill and clean-up. |
| Effective Date |
October 1, 1995 |
| Permissible Exposure Limit |
The PEL decreased from 0.2fibers/cc to 0.1fibers/cc as an 8 hour Time Weighted Average (TWA). The 30 minute excursion limit remains at 1
fiber/cc. |
| Multi-Employer Worksites |
Inform all employees on the site, including tenants and visitors about the asbestos hazard and when work will be done on asbestos containing
materials. |
| Work Classifications |
Class I asbestos work includes activities involving the removal of asbestos containing materials (ACM) or Presumed Asbestos Containing
Materials (PACM) found in thermal system insulation and surfacing materials. Most Class I work requires the use of Negative Pressure
Enclosures (NPE's).
Class II asbestos work includes the removal of other types of ACM such as resilient flooring, ceiling tiles, gaskets, roofing and cementi-tious
products such as transite.
Class III asbestos work includes those activities involving repair and maintenance where ACM/PACM is disturbed. This work activity must not
generate waste greater than one waste or glove bag will hold.
Class IV asbestos work involves custodial activities where employees contact ACM?PACM as a result of a Class I, II or III work activity. |
| Exposure Assessments |
Initial exposure assessments are required until a negative exposure assessment (NEA) has been made. Negative exposure assessments must be
based on objective data - no older than 12 months. |
| Methods of Compliance |
Engineering controls and work practices that must be used regardless of exposure levels are:
- Vacuum cleaners equipped with High Efficiency Particulate Air (HEPA) filters.
- Wet methods
- Prompt clean-up and disposal of waste and debris
Controls to be used if over the PEL:
- Local exhaust ventilation
- Enclosure or isolation of area
- Ventilation of regulated area to pull air away form the breathing zone
Prohibitions:
- Use of high speed abrasive disc saws not equipped with point source ventilation, compressed air, dry sweeping, shoveling or other dry clean up.
There are specific requirements depending upon which Class (Class I-IV) of asbestos work is being performed. |
| Respiratory Protection |
Respirators must be worn in just about all work with asbestos. If respirators are not worn, several criteria must be met, such as valid negative
exposure assessment data and approval of the competent person on the job. Respiratory protection also involves annual fit-testing as part of
OSHA's respiratory protection standard: 1910.134. |
| Protective Clothing |
Employees working with asbestos must wear coveralls, head and foot coverings and gloves. There are separate provisions for laundering
contaminated clothing. |
| Hygiene Facilities and Practices |
Decontamination areas must be established consisting of equipment room, shower area and a clean change room. This is mandatory. Smoking
or eating of food or drink is not permitted in these asbestos control areas. |
| Communication of Hazards |
Requires building owner to inform occupants of asbestos in a building as well as when asbestos work will take place. It also specifies the
language on asbestos warning signs and labels. Lists the required time, frequency and topics for employee training. |
| Housekeeping |
Permits only HEPA vacuuming.
Specifies care of asbestos floor tiles:
- No sanding of floor
- Stripping of finishes using wet methods and low abrasion pads are to be used at speeds less than 300 rpm.
- Burnishing and dry buffing only when the floor has a sufficient finish of 3 layers of wax.
Janitorial workforce must be trained about asbestos hazards - 2 hours of asbestos awareness training is required. |
| Medical Surveillance |
Specifies requirements for medical exams and frequency. |
| Recordkeeping |
Lists information that must be kept and for what duration. |
| Competent Person |
Required for every asbestos job. |
|
Source: Adapted from the August 10, 1994 US Federal Register
Part1/Part2/Part3
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