Floor Tile Frenzy

Ask a maintenance person in a building or plant what’s the most difficult asbestos material to deal with and you’re likely to hear the words vinyl asbestos floor tile (VAT) mentioned. The same may be true from the environmental or safety manager’s vantage point. Not only are floor tiles plentiful but can be difficult to get up during renovation. Also each state looks at asbestos floor tile removal differently from a regulatory stand-point. Let’s take a closer look at this issue.

From 1940 to the 1980’s, asbestos floor tiles were manufactured by companies like Armstrong World Industries, Congoleum, Flintkote and GAF to name a few. Similarly, these companies and others manufactured mastics containing asbestos used as an adhesive to lay tiles. As a general rule of thumb, 9x9" floor tiles often contain asbestos, however, that’s not a hard and fast rule. The newer tiles are typically 12x12" and usually are non-asbestos, but again that is not always the case. Add in adhesives and it’s difficult to know for sure if floor tiles are asbestos free by appearance, size or by the time period they were installed. The only foolproof way to know for sure is to have a licensed building inspector collect a small sample of both the tile itself and a scraping of the mastic and then have it analyzed by an accredited laboratory. If asbestos is found, you then have regulatory issues as well as practical issues to face. Let’s delve into each.

Under OSHA’s Asbestos Construction Standard (29CFR 1926.1101), removal of asbestos flooring materials are classified under Class II work requirements. Class II asbestos work involves removal of any asbestos containing material that is not thermal system insulation or surfacing materials. EPA refers to these as Miscellaneous materials and classifies asbestos VAT as a Category I non-friable material. According to the EPA, vinyl asbestos floor tiles typically do not need to be removed during renovation or demolition, because they generally do not release significant amounts of asbestos fibers. However, if they are in poor condition or likely to become friable during work activities, they must be removed. Also, if VAT’s are sanded, ground, abraded or chipped, they must be considered friable (which means the material can be crumbled or pulverized by hand pressure), and stricter work practices will apply. There has been much debate over the last few years about how much fibers are released when asbestos floor tiles are removed. As such, almost each state has taken a different stance on the issue. Recently, the state of Illinois has adopted the position that any breakage constitutes friability. Here’s a recap of how each state views asbestos floor tile work activities from a regulatory standpoint. Note that many states have different threshold amounts that vary from the Federal regulations of 160 square feet of material that trigger notification requirements. Also, some states have different notification timelines for asbestos floor tile work and different training requirements.

According to the Resilient Floor Covering Institute (RFCI) there are two categories that each state falls into in the charts that follow:

Category 2 - 9 States States which do require licensed asbestos abatement contractors to remove asbestos floor tiles using RWP’s:

Arkansas Delaware New York California New Jersey (19) Pennsylvania Connecticut New Mexico Wisconsin

1. Colorado: 10 day prior notification for removals of 32 sq. ft. or more of VAT’s must be provided to the Department of Health, Air Pollution Control Division.

2. District of Columbia: 10 day prior notification of 18 sq. ft. or more of VAT’s must be provided to the Department of Consumer and Regulatory Affairs.

3. Florida: 8-hour worker and 12 hour supervisor training in the RWP’s and asbestos awareness is required by state laws for VAT removals. Three day prior notification must be provided to the Department of Business and Professional Regulation.

4. Georgia: Licensed asbestos abatement personnel are not required if non-friable VAT’s are not rendered friable during removal (e.g., no extensive breakage) and there are no visible emissions of asbestos fibers. Flooring personnel must take the industry-sponsored RWP training course. Seven day advance notification should be submitted to the state EPA’s Asbestos Licensing and Certification Unit.

5. Kansas: Licensed asbestos abatement personnel and notification requirements do not apply to removals of VAT using RWP’s, but do apply for asbestos sheet vinyl flooring.

6. Kentucky: Licensed asbestos abatement personnel not required if: (a) VAT’s are non-friable and in good condition; (b) RWP’s are strictly followed by trained workers and extensive breakage does not occur (extensive breakage is considered less than 5 pieces); (c) extra caution is used when removing multi-layered floors, and (d) 10 day notification for VAT removals over 160 sq. ft. (3 sq. ft. in schools) is provided to the Department of Environmental Protection.

7. Maryland: Licensed asbestos abatement personnel required for removal in schools.

8. Mississippi: Two working days prior notification for a VAT removal must be made to the Mississippi Commission on Environmental Quality.

9. Montana: Asbestos abatement project permit and licensed personnel generally not required if the RWP’s are used to remove non-friable VAT’s because RWP’s help keep breakage to a minimum. However, a permit and licensed personnel are required if greater than 10% of the floor tile removed is broken. Permits and licensing do not apply to VAT removal by private homeowners in private residences.

10. North Carolina: Licensed asbestos personnel not required for the removal of non-friable VAT’s that remain or will remain intact during removal. The Department of Environment, Health and Natural Resources (DEHNR), has stated that in the majority of cases, if RWP’s are followed, then the licensing requirements do not apply.

11. Oklahoma: Licensed personnel and prior notification do not apply to removals of VAT and associated adhesives using the RWP’s, but do apply to removal of sheet vinyl flooring. How-ever, complete removal of adhesive using the floor machine and cutting sand cannot be per-formed without a license. A license is not required for removals in private residences or apartments with fewer than 6 units.

12. Oregon: Licensed personnel and prior notification do not apply to removals of VAT’s using RWP’s or to wet scraping of adhesives which are pliable and tacky or rendered that way by use of solvents, water/liquid detergent solution. However, a license and prior notification is required for removals of sheet vinyl flooring and adhesives which remain hard and brittle. Asbestos licensing requirements do not apply to removals in private residences by owner-occupant Oregon OSHA sets forth RWP’s with two differences: (1) Trash bags are labeled "Danger, Contains Asbestos Fibers, Avoid Creating Dust, Cancer and Lung Disease Hazard, and (2) Work clothes to be vacuumed with HEPA-vacuum prior to removing or leaving the work area.

13. Rhode Island: Licensed personnel and state approved asbestos abatement plan required for removals of more than 25 sq. ft. of floor tile in poor condition, except for removals in private residences.

14. South Carolina: Licensed personnel and 10 day advance notification do not apply to removals of VAT provided RWP’s are strictly followed. However, these requirements do apply for removals of sheet vinyl. In removing small amounts of "cutback" asphaltic adhesive, the adhesive must be pliable and the bumps and ridges must be carefully scraped, after misting rather than chipped. Complete removal of adhesive with a floor machine and cutting sand cannot be done without an asbestos license. Residue from solvent-based remover must be completely cleaned up to prevent solvents from attacking new adhesive and to all new flooring to bond to the subfloor. Flooring removals in private residences are exempt from these requirements unless performed by licensed asbestos abatement personnel.

15. Texas: 8-hour training in the RWP’s is required by state law before a person may remove VAT’s in public buildings, and it must be analyzed for asbestos content. Ten day prior notification must be provided to the Department of Health, Asbestos Licensing Section.

16. Virginia: A Roofing, Flooring and Siding (RFS) license is required which involves 8-hour worker and 12-hour supervisor training in the RWP’s and asbestos awareness.

17. Washington: Licensed personnel and prior notification requirements do not apply to removals of VAT’s using the RWP’s, however they do apply to removals of sheet vinyl and adhesives.

18. West Virginia: Licensed personnel and 10 day prior notification requirements do not apply if removals of VAT’s in single family dwellings if the flooring personnel obtain a special worker license by taking an approved training course for such removals. However, all licensing and notification requirements apply for VAT removals in all other public buildings.

19. New Jersey: The Department of Health has the power to exempt certain asbestos related activities from asbestos licensing and permit requirements, however, at this time there are no exemptions for VAT removal.

Glance through these charts and the footnotes and one will quickly see that asbestos floor tile work is a regulatory jungle. One might also notice the term RWP’s or Recommended Work Practices used throughout. It would be wise for any facility owner contemplating asbestos floor tile removal work to either be familiar with RWP’s by contacting the state where you are located or seeking help from the Resilient Floor Covering Institute (RFCI). RFCI is located in Maryland and they can be reached at (301) 340-8580. Whether performing this work internally or hiring an asbestos abatement contractor to remove asbestos floor tiles, it’s smart someone from your organization be familiar with these rules. Otherwise, state agency enforcement personnel might be spending more time than you’d like at your facility.

Once you have navigated your way through the regulatory maze, you must still deal with the issue of carefully removing and disposing of asbestos floor tiles. If the state Recommended Work Practices (RWP’s) are followed, there shouldn’t be much difficulty in accomplishing the work activity safely. Preparing the floor for a new carpet or new tiles by removing all of the adhesives may be the most difficult task at hand. Make sure not to sand or grind the floors without taking the proper precautions because that’s when airborne fibers could be released. If shot blasting and mastic grinding are conducted using the circular head adapters on floor scrubbers, you can almost be certain that OSHA and state agencies will consider this a friable removal activity. Also be careful about selecting the proper solvents for removing mastics. Some products can penetrate air handling systems and could cause respiratory irritation among sensitive personnel. Stick with some of the citrus based solvents. There are several that do the job and are not as harmful an irritant as traditional solvents. Solvents also need to be examined in how they might affect the new product being reinstalled. There’s been a number of cases where flooring manufacturers, particularly carpet tiles, may void their warranties if solvents are used. They’re concerned about the solvents soaking into the porous concrete and leaching out later, causing failures with their products. So the removal solvent should be compatible with the new mastic that is used to adhere your replacement choice.

Facility owners should also know that OSHA’s housekeeping rules require that certain precautions are taken when cleaning asbestos floor tiles. This is a requirement in OSHA’s Asbestos General Industry Standard (29CFR 1910.1001). Strip floors using the least abrasive pad and the low speed setting of (175-190 rpms). Make sure to keep the floor adequately wet during the entire stripping operation. Remove all dirty stripping solution with a wet vacuum or strip mop. Also, OSHA recommends 3 layers of wax on asbestos floor tiles before buffing. Although not required, dry buffing should be done using low abrasion pads at speeds no higher than 300 rpm. There have been several studies showing elevated airborne asbestos levels when using high speed buffing machines (1000-1500rpm). If you do use high speed machines, conduct some air monitoring in order to prove levels are lower than the Permissible Exposure Limit (PEL) of 0.1f/cc and so you're armed with adequate Negative Exposure Assessment (NEA) data, i.e., objective data collected within the last 12 months

All in all, asbestos floor tile work can be a breeze if procedures are followed. Ignore them and your world could quickly turn into a tornadic event.

For more information about RFM’s prescriptive asbestos floor tile procedure as well as other asbestos and RCF work procedures, click on Procedures. To see other Articles or White Papers , click on either title.

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 Program 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.