Presenter

1. Presenter Marc Soutra recently retired as a teacher in the Ct. Public Schools. During his tenure he won numerous awards for innovations in teaching and curriculum development and was nominated Teacher of the Year 3 times, winning twice. For the past 29 years he has and continues to be an adjunct professor at Springfield Technical Community in Springfield Ma. He recently returned from teaching in Jiangmen China on a grant from the University of Vermont Asian Studies Program. Marc joined ATC Associates in 1996 primarily as a Project Monitor on asbestos abatement projects that focused heavily in public schools. Now full time with ATC he is certified in both Ma. and Ct. as a project monitor, technician and inspector. He has been a primary instructor with ATC for the past 2 years teaching 2, 16, 32 and 40 hr. courses for workers, technicians and consultants.

2. MASBO:AHERA UPDATEAsbestos Agenda March 13, 2012 ASBESTOS-CONTAINING MATERIALS IN SCHOOLS MARC SOUTRA Environmental Educator, Industrial Hygienist, Registered Analyst • Definition of asbestos-containing material (ACM). • Types of ACM that may be present in school buildings. • Regulations: EPA, OSHA. • Types of inspections to identify ACM • AHERA (EPA) compliance, with update. • Methods of controlling asbestos in schools, Operations and Maintenance responses and emergency situations. • Question and Answer

3. What is Asbestos? • Definition • A naturally occurring fibrous mineral

4. Asbestos Properties • Heat Resistant • Electrical Resistant • Sound absorbing • Tensile Strength • Chemical Resistant • Abundant world-wide • Inexpensive to produce

5. Asbestos • Six Types of Asbestos • Serpentine • Chrysotile • Amphibole • Amosite • Crocidolite • Actinolite • Anthophyllite • Tremolite

6. Health Effects • How does Asbestos Effect our Bodies once inhaled? • What is the Latency Period for Asbestos? • 10-40 years • Main Diseases • Asbestosis • Lung Cancer • Mesothelioma • Other Diseases • Esophagus, Stomach, Colon and Pancreas Cancers • Pleural Plaques

7. Friable • Material, when dry, can be crushed, pulverized or reduced to powder by hand pressure • Friable ACM can release fibers into the air more readily than non-friable. • Non-friable materials can release fibers into the air if disturbed

8. ACM & PACM • ACM (EPA/OSHA) • Materials containing greater than one percent asbestos • PACM (OSHA) • Installed prior to 1980 • Surfacing Material • Thermal System Insulation (TSI) • Resilient Flooring

9. Types of ACM in Buildings • Surfacing • Material sprayed-on or trowelled on • Thermal System Insulation • Material used to prevent heat loss or heat gain • Miscellaneous • Everything else

10. Surfacing Material • Fireproofing • Decorative Coating • Plaster

11. Thermal System Insulation • Pipes • Boilers • Tanks • Ducts • HVAC

12. Miscellaneous • Floor Tiles & Mastic • Ceiling Tiles • Roofing Products • Glue Daubs and Adhesives • Window Caulking and Glazing • Sheetrock and Joint Compound • Electrical Components • Exterior Siding • Transite Pipes • Tar Vapor Barrier Coatings 3000+ man-made products

13. Bans of Asbestos • 1973 - Asbestos Spray-on Fireproofing • 1976 - Premolded Pipe Insulation • 1978 - Spray applied decorative coating and acoustical products • In 1989 EPA banned the use of asbestos • However, in 1991 the Supreme Court overturned the ban

14. Products Not Banned • Asbestos-cement corrugated sheet • Asbestos-cement flat sheet • Asbestos clothing • Pipeline wrap • Roofing felt • Vinyl asbestos floor tile • Asbestos-cement shingle • Millboard • Asbestos-cement pipe

15. Products Not Banned • Automatic transmission components • Clutch facing • Friction materials • Disc brake pads • Drum brake linings • Brake blocks • Gaskets • Non-roof coatings • Roof coatings

16. Major Regulatory Agencies • Occupational Safety and Health Administration(OSHA) • United States Environmental Protection Agency (USEPA) • United States Department of Transportation (DOT) • Consumer Products Safety Commission (CPSC) • State and Municipal Agencies

17. Measurement of Asbestos • OSHA • Permissible Exposure Limit (8Hr) • 0.1 fiber per cubic centimeter • Excursion Limit (30 minute) • 1.0 fibers per cubic centimeter • EPA/States • Clean Air • PCM – 0.01 fiber per cubic centimeter • TEM – <70 structures per millimeter squared

18. Asbestos Containing Materials (ACM) • Those materials that are >1% asbestos • NESHAP (EPA) 40 CFR Part 61 • Friable and non-friable asbestos-containing material (ACM & RACM; R “Regulated”) • AHERA (EPA) 40 CFR Part 763 • Friable and non-friable asbestos-containing building material (ACBM) • OSHA 29 CFR 1910.1001 & 1926.1101 • Asbestos-containing material (ACM) & Presumed asbestos-containing material (PACM) • “intact” versus “friable”

19. Asbestos Containing Materials (ACM) • Sample Analysis • ACM has to be identified using laboratory techniques, not by “naked” eye • “Bulk” samples are analyzed by polarized light microscopy (PLM) • Results contain type and percentage of asbestos and other fibrous material

20. Asbestos Inspections Types of Asbestos Inspections • Limited Screening – Real Estate Transactions (accessible materials, limited investigation and number of samples). Not intended for compliance inspections. • OSHA – Hazard Assessment for worker safety and data to rebut Presumed Asbestos-Containing Materials. • AHERA Survey – Private and public schools grades K through 12. Hazard Assessment and Management Plans. • NESHAP Inspection – Renovation or demolition requires extensive investigation and sampling for interior and/or exterior ACM discovery and abatement.

21. AHERA Asbestos Hazard Emergency Response Act 40 CFR Part 763

22. EPA AHERA Regulation • Asbestos Hazard Emergency Response Act • Management of Asbestos in Schools (Grades K-12 Public and Private) • Surveys • Notifications to Parents, Guardians, and Staff • Periodic Surveillances • 3 Year Reinspections • Management Plans • O&M Program • Recordkeeping • Assigning Designated Person

23. APPLICABLITY • All public and private elementary and secondary schools in the U.S., its territories, and on military bases in foreign countries

24. Scope and Purpose • This rule requires Local Education Agencies to identify friable and nonfriable asbestos-containing material (ACM) by visually inspecting school buildings for such materials, sampling such materials if they are not assumed to be ACM, and having samples analyzed by appropriatetechniques referred to in this rule • LEA’s submit management plans to Governor of their State by October 12, 1988. Implement plans by July 9, 1989.

25. Requirements • Survey buildings for ACM • Initial Inspection - Collect bulk samples or assume material to contain asbestos • Periodic surveillance every six (6) months • Reinspection every three (3) years • Develop and implement a Management Plan • Assign a Designated Person • Implement response actions • Develop and implement O&M procedures • Recordkeeping

26. LEA Responsibilities • Ensure activities are performed according to regulations • Inspections • Reinspections • Periodic Surveillance • Develop and Update Management Plans • Develop and Implement response actions • Ensure custodial and maintenance staff is properly trained

27. LEA Responsibilities (cont.) • Inform workers, building occupants, or their legal guardians, at least once a year about the management plan and asbestos activities that are planned or are in progress. • Short-term workers who may come in contact with asbestos are informed of ACBM or suspect ACBM locations • Warning labels are affixed adjacent to ACBM material

28. LEA Responsibilities (cont.) • Ensure availability of the Management Plan • Ensure designated person receives adequate training to perform their duties according to the regulation

29. Inspections • Inspect school buildings that are leased, owned, or used as a school building for friable and nonfriableACBM. • In an emergency, if a building needs to be used as a school an inspection shall be performed within 30 days after commencement. • Assure that an accredited inspector will perform the inspection.

30. Inspections - Exclusions • An accredited inspector has determined that based on sampling records, friable and non-friable ACBM was identified in an inspection conducted prior to December 14, 1987 • An accredited inspector has determined that no ACBM is present based on sampling and inspection records in an inspection conducted prior to December 14, 1987

31. Inspections - Exclusions • An accredited inspector has determined that, based on records of an inspection conducted before December 14, 1987, suspected ACBM is assumed to contain ACM • An accredited inspector has determined based on abatement and clearance records that no ACBM is present in the area where asbestos removal was performed before December 14, 1987

32. Inspections - Exclusions • An architect or project engineer responsible for the construction of a new school building built after October 12, 1988, or an accredited inspector signs a statement that no ACBM was specified as a building material in any construction document for the building, or, to the best of his or her knowledge no ACBM was used as a building material in the building.

33. Inspections • Person performing an inspection shall: • Visually Inspect the area • Touch all suspected ACBM to determine friability • Identify homogeneous areas of friable and non-friable suspected ACBM • Assume that some or all of the homogenous areas are ACM, if not assumed collect bulk samples and submit for analysis • Assess friable material that are assumed or identified as containing asbestos.

34. Inspections • Report submitted to the designated person within 30 days. • Accredited inspectors who performed the inspection • Dates and location of samples • Sample results (chain-of-custody) • List homogenous areas and categorize as (SM, TSI, Misc.) • Assessments(condition) of friable material

35. Reinspections • Performed once every three years after a management plan is in effect • Visually reinspect and reassess all friable known or assumed ACBM • Visually inspect material that has been previously considered non-friable ACBM and touch the material to determine friability • Identify any homogenous material that has become friable since the last inspection • For each homogenous area of newly friable material that is assumed to be ACBM, bulk samples may be collected.

36. Reinspections • Assess newly friable material in areas where samples are collected • Submit report to designated person within thirty days

37. EPA – NESHAP • Inspection Requirement Before Disturbance (Renovation/Demolition) • Accredited Inspector • Trained Person On Site • Similar to OSHA Competent Person; Must be Trained on NESHAP Requirements

38. EPA - NESHAP • Federal Notification Requirements • 10 Working Days in Advance • Required for ALL demolition projects: Demolition is altering a structural member • For Renovation, required for RACM that is: • > 160 square feet • > 260 linear feet • > 35 cubic feet • Many states require notification based on lesser quantities (CT 10 linear/25 square ft)

39. EPA - NESHAP • Air Limit • No Visible Emissions • Disposal Bag • Generator information • This must be filled out or labels applied on each bag or bundle • DOT label requirements • OSHA label requirements • If waste is bundled; each bundle must be labeled. States vary if bundles are placed into a lined “dumpster”

40. OSHA Regulations • OSHA • Who do they protect? • The workers and employees • Reading the regulations Code of Fed Reg Regulation Section Agency Standard in The Reg. 29 CFR 1926. 1101 (g) (4) (ii) Specifies the Section Sub-Sections

41. OSHA • OSHA Classes of Work • Class I • Removal of surfacing material, TSI or PACM • 4 day worker, 5 day supervisor • Class II • Non “high risk” removal: RFM (flooring), siding, mastics, roofing • Intact “incidental” roofing excluded (coatings, cements, mastics) • Single media (task) 8 hr min worker training plus additional 4 hours for supervisor (minimum!!)

42. OSHA • Class III • Asbestos Inspection • Maintenance & Repair • Non-removal (same as AHERA O&M) • 1 glovebag, mini-enclosures (2 workers max.), 1 waste bag 1/3 – 1/2 full, 60”x60” bag max • 16 hour training • Class IV • Maintenance & custodial cleaning activities, incidental contact or incidental to construction (Class I, II, III) • 2 hour awareness training

43. Major Elements of an Asbestos O&M Program • Documentation Of Building Survey • Notification, Warning, Labels • Training • Respirator And Medical Surveillance Programs • Special Cleaning Procedures • Response to major/minor fiber releases • Work Permit System • Re-inspection And Re-cleaning • Recordkeeping

44. Control Options • Removal • Repair • Encapsulation • Enclosure • O&M Program

45. OSHA Regulations • Other Requirements of the Owner that can Impact the Workers • Inspect for ACM/PACM Prior to Disruption • “Before work subject to this standard is begun, building and facility owners shall determine the presence, location, and quantity of ACM and/or PACM at the work site…” 1926.1101(k)(2)(ii) • In most cases, per AHERA and ASHARA, this will require an accredited inspector.

46. OSHA Regulations • Other Requirements of the Owner, 1926.1101 (k)(2) • Notify the Following: • Prospective Employers applying or bidding for work • Employees of the Owner • Multi-employer worksite employers and employees • Tenants (commercial)

47. OSHA Regulations • Employers working at the Owner’s site have responsibilities, 1926.1101 (k)(4) • …all employers who discover ACM and or PACM shall convey information concerning the presence, location & quantity the newly discovered ACM/PACM to the owner, other employers of employees within 24 hours.

48. OSHA Regulations • Regulated Areas • Class I, II, or III Activities • Where the PEL or EL may be exceeded • Area must be demarcated • Authorized personnel only • Respirators and PPE may be required • Supervised by Competent Person

49. Work Practices • Housekeeping Requirements • All surfaces shall be maintained as free as practicable of ACM waste and debris and accompanying dust. • All spills and sudden releases of material containing asbestos shall be cleaned up as soon as possible. • Surfaces contaminated with asbestos may not be cleaned by the use of compressed air.

50. Work Practices • Housekeeping Requirements • Vacuuming. HEPA-filtered vacuuming equipment shall be used. • Shoveling, dry sweeping and dry clean-up of asbestos may be used only where vacuuming and/or wet cleaning are not feasible. • Asbestos waste or contaminated waste material shall be disposed of in impermeable containers.