Asbestos may be found in cement pipe, cement sheets, insulation, textured wall surfaces, sealants, resilient floor coverings (namely linoleum flooring and vinyl asbestos tile), roofing tiles, gaskets, certain adhesives and electrical equipment. Both the EPA and OSHA are responsible for regulating environmental exposure and for protecting construction workers from asbestos. OSHA is responsible for the health and safety of workers who may be exposed to asbestos in connection with their jobs. The EPA is responsible for developing and enforcing regulations necessary to protect the general public from exposure to airborne contaminants that are known to be hazardous to human health.
In addition to the complete regulation citations referenced below each topic area, you should check the air-quality regulations for your specific state to determine whether it applies to your facility.
Standards for Demolition and Renovation
Before any demolition and/or renovation occurs at a facility, the owner or operator needs to determine whether it is governed by the Code of Federal Regulations (40 CFR 61.145). This is generally accomplished by an asbestos survey, with testing to determine whether asbestos is present. Applicability depends on the amount of asbestos-containing materials (ACM) present at the facility. On both the federal and state levels, any existing requirements and procedures for asbestos emission control must be followed.
First, the owner or operator of the site of the ACM demolition and/or renovation must provide written notification to the Administrator of the EPA (40 CFR 61.145). This notification must occur at least 10 days prior to any activity that could break up, dislodge or similarly disturb the ACM. Notification should consist of the following:
- Any schedule changes
- A description of work practices and procedures
- Certification of the removal contractor
Requirements for Removal and Disposal of Asbestos
Facility demolition and/or renovation must also follow emission control procedures defined in the regulations. These practices include, but are not limited to:
- Utilizing a local exhaust ventilation and collection system
- Avoiding the damaging, crumbling or pulverizing of removed material
- Utilizing a glove-bag system to contain particulate asbestos material
- Utilizing leak-tight wrapping to contain all Regulated AsbestosContaining Material (RACM) prior to dismantlement
A Massachusetts regulation (310 CMR 7.15) forbids any person from contributing to air pollution in any way through the demolition/renovation, installation, re-installation, handling, transporting, storage or disposal of waste materials. It also requires owners or operators of facilities where ACM demolition and/or renovation activities are planned to provide 10 days written notice to DEP. They also must comply with any specified, applicable procedures for asbestos emission control, air cleaning, waste disposal, spraying and insulation. All ACM must be containerized, labeled and removed in accordance with DEP regulations (see 310 CMR 7.15). Further, the asbestos must be adequately wetted, to prevent fibers from being released, and sealed in leak-tight, properly labeled containers. If bags are used, they should be comprised of thick plastic, and asbestos waste should be double bagged. The same handling procedures are required for contaminated clothing and equipment. Containers must be labeled with an OSHA approved warning label.
Standard for Dust, Odor, Construction and Demolition
Construction work is subject to certain emission control standards in accordance with 310 CMR 7.09. This set of regulations applies to construction or demolition of residential buildings with 20 or more dwelling units. They require that 10 days’ notice be given to DEP before construction activities are initiated.
National Emission Standards for Hazardous Air Pollutants (NESHAP)
In response to the requirement included in Section 112 of the Clean Air Act (CAA), the EPA published a list of hazardous air pollutants and created the National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations. The NESHAP standards for asbestos (40 CFR 61, Subpart M) focus on demolition and renovation activities.
In these regulations, a distinction is made between building materials that have the potential to release asbestos fibers readily when damaged or disturbed (“friable” asbestos material) and those materials that are unlikely to release a significant amount of fibers (“non-friable” asbestos material).
Friable asbestos material means any material containing greater than 1 percent asbestos that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure. (The specified method is described in Appendix A, Subpart F, 40 CFR Part 763 Section 1, Polarized Light Microscopy.) Microscopic asbestos fibers from friable (loose or crumbling) asbestos can be suspended in air and inhaled. All friable asbestos material is considered RACM and is subject to the Asbestos NESHAP.
Non-friable asbestos material is further classified into Category I and Category II ACM, some of which is considered RACM. NESHAP covers notifications, removal activities, transportation and disposal activities, documentation, monitoring and sampling, and inspections.
Threshold amounts for NESHAP
NESHAP regulations for asbestos must be followed for all demolitions or renovations of facilities that have: at least 260 linear feet of RACM on pipes; at least 160 square feet of RACM on other facility components; or at least 35 cubic feet of facility components from which the amount of RACM previously removed (from pipes and other facility components) could not be measured before stripping. These regulations provide no numeric emission limit for the release of asbestos fibers during renovations or demolitions; they only require that action be taken to control emissions. NESHAP does specify, however, that visible emission to the outside air during the transportation and disposal of asbestos-containing waste must be zero.
40 CFR 61