Background
Asbestos is a natural, fibrous mineral that is very resistant to heat, electricity, and chemicals. The Centers for Disease Control and Prevention identify it as a human carcinogen. It is one of, if not the most, heavily regulated substances commonly in use on campuses. Federal regulations that apply to asbestos include
- Toxic Substances Control Act (TSCA — 40 CFR 763),
- two chapters of Occupational Safety and Health Administration (OSHA) regulations (29 CFR 1910.1001 and 1926.1101),
- the National Emissions Standard for Hazardous Air Pollutants standard in the Clean Air Act (40 CFR 60.140–167), and
- the Worker Protection Rule for employees not covered by OSHA (40 CFR 763.120–123).
As in most environmental programs, states may have additional asbestos management regulations. Usually, the combined federal regulations form the basis for these state programs.
The physical damage that results from abrasion, cutting, pounding, or grinding asbestos can release fibers. Water and air deterioration can also cause fiber releases. Asbestos regulations seek to reduce airborne asbestos fiber levels.
Key Concepts
Asbestos-Containing Material (ACM) and Asbestos-Containing Building Material (ACBM)
ACM is any material that contains asbestos, such as automotive brake linings. EPA defines ACMs as those that contain asbestos in concentrations of 1 percent or more. ACBMs are building materials that contain asbestos, including gypsum board, acoustic plaster, and thermal insulation. ACBM is a subset of ACM.
Presumed Asbestos-Containing Material (PACM)
Current best management practices for asbestos require building owners to presume that some building materials contain asbestos until laboratory analysis proves otherwise. These materials include thermal system insulation and surfacing materials (plasters, sprayed-on fireproofing, etc.) in buildings constructed before 1980. To rebut this presumption, all samples of a homogeneous building material must show asbestos levels below 1 percent. The size of the affected building material determines the number of samples.
Friable
ACM that is easily reduced to a powder, as by crushing, is friable. Best management practices consider pipe and boiler insulation, acoustic plaster, and fireproofing sprays friable.
Nonfriable
Nonfriable ACM is bound in a noncrushable material, such as floor tile, mastics, roofing felts, tars and asphalt, etc. However, demolition may render nonfriable materials friable, depending on work methods.
Abatement
Abatement is any project that reduces the risk of asbestos fiber release and airborne asbestos exposure. The most common kinds of abatement are removal, encapsulation, and enclosure. Removal is self-explanatory. Encapsulation is a treatment that reduces the friable nature of the asbestos. Enclosure involves construction of a structural barrier around exposed ACM.
Permissible Exposure Limit (PEL)
Regulatory agencies have determined an acceptable level of airborne asbestos fibers, or the PEL. Employers must maintain airborne asbestos fiber levels below the PEL. Currently, the PEL for asbestos is 0.1 fiber per cubic centimeter as an 8-hour time-weighted average. State standards for ambient air may be lower.
Negative Exposure Assessment (NEA)
The NEA is a series of air tests that demonstrates that a given work method results in airborne asbestos fiber levels below the PEL.
Does this apply to my campus?
Yes. Asbestos exists in over 3,500 different products used in construction. Frequently, campus buildings contain asbestos in acoustic spray, pipe and boiler insulation, and fireproofing and roofing material. Automotive brake pads and clutch linings usually contain asbestos. Ceiling tile, floor tile, plaster, drywall mud, and wiring insulation may also contain asbestos. Any activity that might disturb these materials must comply with all of the various applicable regulations.
What do I have to do?
OSHA and EPA rules require that employers train employees to recognize PACM and work safely around asbestos. In addition, both agencies require specific work practices. Review and understand these standards and ensure that campus operations function within them. Consult with legal counsel, outside specialists, and/or regulators to ensure compliance.
You or your contractor must notify EPA, or the designated state program agency, before most demolition or abatement work occurs. Use specifically trained employees or licensed asbestos abatement contractors when disturbing or working in the immediate area of ACM. Before you start work that might disturb friable asbestos, you must remove or protect the asbestos. If you intend to demolish a whole structure, remove all friable materials before demolition begins. Check with your state regulators to determine the scope of removal for nonfriable materials prior to demolition.
You must use specific work methods when abating or maintaining ACM. Conduct any work that damages any asbestos in containment to ensure that fiber levels outside the containment never exceed the PEL or any public exposure level determined by your state asbestos control agency. This usually requires performing any asbestos work inside negative pressure containment. The only exemption to this is available after performance of a successful NEA. If an NEA conducted within the containment indicates that a set of work methods does not release fibers above the PEL or public exposure level, the work method can continue without containment. NEAs have specific record-keeping and sampling and analysis requirements. You must perform a new NEA for any new situation, such as different tools, a different scope of work, or varied asbestos levels in the affected material.
Maintain records of asbestos abatement projects, including agency notifications, contractor and employee certifications, work activities, sample protocols with results, and disposal records. Keep these documents in accordance with your records retention policy.