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Corporate Asbestos Review Anthony Peltier 11/2012. Identification. Asbestos-containing material (ACM) , means any material containing more than one percent asbestos Facilities constructed prior to 1980 need to have a baseline asbestos survey Retain records at facility
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Identification • Asbestos-containing material (ACM), means any material containing more than one percent asbestos • Facilities constructed prior to 1980 need to have a baseline asbestos survey • Retain records at facility • Inspect on an M36 to ensure ACM is not in a condition that will generate fibers
Signage • Place signage at areas known areas with ACM or PACM • Warning labels will provide the following information • Danger, Contains Asbestos Fibers, Avoid Creating Dust, Cancer and Lung Disease Hazard
Handling • If you suspect materials you are handling contain asbestos: • Discontinue work, vacate the area, do not disturb the material • Reduce airflow by shutting off fans or sealing the area if applicable • Contact HS&E to determine if sampling is required. Sampling must be completed by a qualified and competent person • Accredited inspector or CIH must collect samples
Handling (Cont.) • No employee may disturb or work on ACM unless trained to the level of work activity as classified by Federal or State regulators. • Verification of worker training must be available at the work site where workers are actively involved with the removal and handling of ACM
Classification • Before beginning any asbestos handling or related activities the type of work must be classified: • Class I Asbestos work: Removal of Thermal System Insulation and Surfacing ACM • Class II Asbestos work: The removal of ACM which is not thermal system insulation or surfacing material. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tiles, roofing and siding materials, and construction mastics.
Classification (Cont.) • Class III Asbestos work: Repair and maintenance operation where ACM, including TSI and Surfacing ACM/PACM, is likely to be disturbed. This work activity must not generate waste greater than one glove bag will hold. • Class IV: Maintenance and custodial activities during which employees contact but do not disturb ACM or PACM and activities to clean up dust, waste, and debris resulting from previously conducted Class I, II, III.
Classification (Cont.) • We must also classify per EPA guidelines: • Friable ACM • Any ACM that when dry can be crumbled, pulverized, or reduced to powder by hand pressure • Category I Non-Friable • Asbestos containing packaging, gasket, resilient floor covering or asphalt roofing products • Category II Non-Friable • All other material
Classification (Cont.) • Regulated Asbestos Containing Material • All Friable ACM • All Category I non-friable ACM that has become friable or that will be or has been subjected to mechanical processes such as sanding, grinding, cutting or abrading • All Category II non-friable ACM with a high probability of becoming friable or has been crumbled, pulverized or otherwise reduced to powder by the forces exerted on the material during the course of demolition or renovation • Non-regulated Asbestos containing materials • All Category I and Category II non-friable ACM that do not meet the criteria listed above
Work Requirements per Classification • Class I & II and Friable or Non-Friable category I or II RACM: • Must be completed by an approved contractor • TC employees will not be expected to be involved with class I or II asbestos work • Those employees who are properly trained may conduct class III and IV operations and maintenance work
Class III and IV operations and maintenance work • Wear approved respirator with P100 cartridges and other applicable PPE • Wet down material prior to handling so that airborne release is minimized • Do not dust/sweep area with ACM; use HEPA vacuum
Class III and IV operations and maintenance work • Do not clean areas with compressed air • Properly decontaminate yourself prior to leaving the area where asbestos work is taking place • Place all waste asbestos-containing material into impervious containers (double plastic bags) and seal • Label bags: “CONTAINS ASBESOTOS, CANCER HAZARD, AVOID BREATHING”
Sample Collection • If bulk sampling is required: Contact your regional HSE Coordinator to arrange for an Accredited Inspector or CIH to collect samples in accordance with 40 CFR 763 Subpart E
Pre-Removal Requirements • Written notification to EPA is required if during the calendar year the following thresholds for the removal of ACM are met: • 260 linear feet on pipes or • 160 Sq Ft on other facility components or • 35 cubic feet off facility components where the length cannot be measured • EPA requires a 10 working day notification prior to beginning work
Example Friable TSI underneath protective covering
How would you handle • Muffler to be removed: • Classification? • Friable/Non-Friable • Regulated or Non-Regulated • Precautions? • Training Requirements?
Questions??? • Contact • Anthony Peltier, Safety Specialist