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Introduction Exposure to asbestos can cause serious health problems such as asbestosis (scarring of the lung tissue) and certain types of cancer. Epidemiological studies completed during the 1960s and early 1970s confirmed this relationship between exposure and disease. As a result, the Occupational Safety and Health Administration (OSHA) established the first federal regulation governing occupational exposure to asbestos in 1971. Since then, the U.S. Environmental Protection Agency (EPA) and OSHA have promulgated rules and updated regulations designed to limit the release of asbestos into the atmosphere, reduce worker exposures to asbestos, regulate the disposal of asbestos, and ensure asbestos hazard response actions are carried out by qualified and trained personnel. Along with the EPA and OSHA, some States have also established asbestos requirements that augment and extend the federal requirements. The Air Force has also established a framework for asbestos management within its facilities under an Air Force Instruction (AFI) and an Air Force Occupational Safety and Health (AFOSH) Standard. These requirements generally mirror those of the federal government and serve mainly to establish roles and responsibilities within the Air Force organizational structure. This fact sheet will provide general information on asbestos, summarize federal laws affecting asbestos, outline training requirements, and provide an overview of Air Force-related asbestos issues. It also provides a list of key terminology. General Information Asbestos is the generic name for a group of minerals. It is distinguished from other minerals by the fact that it forms crystals with a long, thin fibrous shape. The most common type of asbestos is the mineral chrysotile, which is found in the majority of asbestos applications in the U.S. Amosite, crocidolite, anthophyllite, actinolite and tremolite are other asbestos minerals. This naturally occurring group of minerals has been used for over 2000 years because it has the ability to withstand fire and insulate against heat. The word "asbestos" is derived from a Greek adjective meaning "inextinguishable." Asbestos is used in over 3,600 commercial and industrial products because it is readily available, low in cost, nonflammable, strong, flexible, a good thermal and sound insulator, and resistant to chemical corrosion. The programs and regulations outlined in this fact sheet apply equally to all the asbestos minerals, which are referred to as simply "asbestos" throughout the text. Asbestos was sprayed on steel beams in buildings to prevent structural members from collapsing in case of fire. Asbestos cement products were used to enhance strength in siding and roofing shingles, wallboard, and pipes. Asbestos has also been added to asphalt, vinyl, and other materials to make products such as roofing felts, exterior siding, floor tile, joint compounds, and adhesives. Asbestos was also used as a thermal insulator on boilers and pipes and as a sound insulator in plaster. For automobiles, asbestos was used as body filler and in brake shoes. Exposure to friable asbestos can lead to asbestosis and several forms of cancer; diseases that typically strike 20-30 years after exposure. Additionally, smokers exposed to asbestos fibers are fifty times more likely to develop lung cancer than the general public. The EPA attempted to eliminate the use of asbestos in 1989 by issuing a final rule under Section 6 of the Toxic Substances Control Act (TSCA) to prohibit the future manufacture, importation, processing, and distribution of asbestos in almost all products. The Asbestos Ban and Phaseout Rule (Title 40 Code of Federal Regulations [CFR] 763.160) was scheduled to eliminate asbestos in most commercial products in three stages over seven years beginning in 1990 and ending in 1996. EPA's asbestos rule was challenged in U.S. Court by the asbestos industry. In October 1991, the U.S. Fifth Circuit Court of Appeals vacated and remanded most of the ban and phaseout rule. Because of the court decision, most asbestos products are no longer subject to the ban and phaseout rule. However, consumption of asbestos products in the U.S. has declined due to a number of technological, regulatory and economic factors. U. S. manufacturers have modified product designs to either accommodate the use of asbestos substitutes or eliminate the need for asbestos materials altogether. List of Suspect Asbestos Containing Materials (ACM) [Note: The following list (compiled by EPA Region 6) is intended as a general guide to show which types of materials may contain asbestos. It does not include every product or material that contains asbestos.]
Important Terms [The following definitions are summarized from various OSHA, EPA, and Air Force sources and are presented here for general information purposes only. Readers should refer to applicable statutes, regulations, and standards for situation-specific meanings of terms.]
ACM (Asbestos-containing material) - a material containing more than 1 percent asbestos as determined using EPA-approved polarized light microscopy methods.
Asbestos - includes the minerals chrysolite, amosite, crocidolite, tremolite, anthophyllite, actinolite, and any of these minerals that have been chemically treated and/or altered.
Bulk sample - a solid quantity of insulation, floor tile, building material, etc., suspected of containing asbestos fiber and that would be analyzed for the presence, quantity, and type of asbestos.
Exposure assessment - an assessment conducted to determine if the potential exists for the exceedance of regulated exposure limits during an asbestos project.
Friable ACM - Dry ACM that may be crumbled, pulverized, or reduced to powder by hand pressure.
Nonfriable ACM - dry ACM that cannot be crumbled, pulverized, or reduced to powder by hand pressure. Nonfriable asbestos is further divided into Categories I (packings, gaskets, resilient floor covering, and asphalt roofing) and Category II (any non-friable material not in Category I).
PEL (permissible exposure limit) - a time-weighted average (TWA) exposure limit above which a worker cannot be exposed. In the case of asbestos, it is 0.1 fibers per cubic centimeter of air as an eight hour TWA.
RACM (Regulated ACM) - 1) Friable ACM; 2) Category I Nonfriable ACM that has become friable due to destructive handling; 3) Category I Nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading; or 4) Category II Nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation.
Regulated area - a demarcated area established by the employer where Class I, II, and III asbestos work is conducted; any adjoining area where debris and waste from such asbestos work accumulate; and a work area where airborne concentrations of asbestos exceed, or there is a reasonable possibility they may exceed, the PELs.
Time weighted average (TWA) - eight-hour average concentration for which the average is mathematically adjusted for the duration of exposure.
Title 29, OSHA Asbestos Standards
The construction industry asbestos standard (Title 29 CFR 1926.1101) provides detailed work practice and engineering control requirements based on four classifications of asbestos work. The classifications were developed by OSHA with Class I presenting the greatest risk and Class IV presenting the least. The classes are summarized below:
The asbestos NESHAP requires the owner or operator of a demolition or renovation activity, prior to the commencement of the demolition or renovation, to thoroughly inspect the affected facility or part of the facility where the demolition or renovation operation will occur for the presence of asbestos, including Category I and Category II nonfriable ACM. If a threshold amount of asbestos will be disturbed during the renovation or demolition activity, then the owner or operator must provide written notification to the local Pollution Control Agency responsible for NESHAP enforcement in accordance with Title 40 CFR 61.145(b), "Notification requirements." The owner/operator must also comply with asbestos emission control requirements contained in Title 40 CRF 61.145(c), "Procedures for asbestos emission control." If less than the threshold amount of asbestos will be disturbed in a building being demolished, only the reporting requirements of Title 40 CFR 61.145(b) apply. Neither the reporting or emission control requirements apply if less than the threshold amount of asbestos is disturbed in a building undergoing renovation.
The threshold asbestos amounts that trigger the reporting requirements are at least 80 linear meters (260 linear feet) of regulated asbestos-containing materials (RACM) on pipes, 15 square meters (160 square feet) of RACM on other facility components, or at least one cubic meter (35 cubic feet) of facility components where the amount of RACM previously removed from pipes and other facility components could not be measured before stripping. In June of 1994, the EPA provided additional guidance for roof removal operations where all or part of the roof structure contains asbestos. This rule, Appendix A to Subpart M, Interpretive Rule Governing Roof Removal Operations, outlines alternative procedures for determining whether or not threshold amounts of asbestos will be disturbed during roof removal operations.
The asbestos NESHAP also requires certain procedures to control emissions of asbestos during renovation and demolition. These requirements include mandatory removal of certain types of asbestos prior to renovation or demolition and ensuring ACM remains adequately wetted to inhibit asbestos fiber release.
Finally, the asbestos NESHAP specifies that asbestos-containing debris from renovations and demolitions must be treated as asbestos-containing waste. The debris must be adequately wetted and bagged for disposal. The debris is then transported in covered vehicles and it must not emit visible emissions to the outside air. The waste must be deposited at an acceptable waste disposal site. State and local agencies which require handling and licensing procedures for landfills can supply a list of "approved" or licensed asbestos disposal sites upon request.
Title 40 CFR Part 763, Subpart E, ACMs in Schools
The Asbestos School Hazard Abatement Reauthorization Act (ASHARA) amended TSCA and required EPA to revise its asbestos model accreditation plan under AHERA to extend training and accreditation requirements to include persons performing certain asbestos-related work in public and commercial buildings. It also increased the minimum number of training hours required for accreditation. These newer requirements are found in Appendix C to Subpart E, Asbestos Model Accreditation Plan. Therefore, even though the basic regulation applies only to schools, the training and accreditation requirements outlined in Appendix C apply to anyone performing abatement, supervision, inspection, management planning, or project design in public or commercial buildings. For the purposes of Appendix C, Public and Commercial Building means the interior space of any building that is not a school building, except that the term does not include any residential apartment building of fewer than 10 units or detached single-family homes. The term includes, but is not limited to: industrial and office buildings, residential apartment buildings and condominiums of 10 or more dwelling units, government-owned buildings, colleges, museums, airports, hospitals, churches, preschools, stores, warehouses and factories. Interior Space includes exterior hallways connecting buildings, porticos, and mechanical systems used to condition interior space.
Title 40 CFR Part 302, Designation, Reportable Quantities, Notification
Title 40 CFR Part 373, Reporting Hazardous Substance Activity When Selling or Transferring Federal Real Property
Title 40 CFR Part 141, National Primary Drinking Water Regulations
General Awareness: Two hours of training annually must be completed by personnel who perform Class IV asbestos work.
Operations and Maintenance: Sixteen hours of training shall be completed by personnel who perform Class III asbestos work. Annual refresher training is required, but no minimum number of hours is specified. The "competent person" makes the final determination of the level of training required for operations and maintenance personnel.
Asbestos Abatement Worker: Thirty-two hours of training must be completed by personnel who perform Class I and Class II asbestos work. Class I and II asbestos work includes removal or encapsulation of ACM when the project is being performed with the sole intent of abatement of asbestos. Eight hours of refresher training are required annually for certification to be maintained.
Asbestos Contractor/Supervisor: 40 hours of training must be completed by personnel who supervise Class I and II asbestos work. Eight hours of refresher training are required annually for certification to be maintained.
Asbestos Inspector: Training must be completed by personnel who perform building inspections for ACM including such tasks as measurement, quantification, physically touching, or collecting bulk samples of building materials. Initial training consists of a 3-day (24-hour) inspector course given by an EPA or State approved training center, depending on local requirements. Four hours of refresher training are required annually for certification to be maintained.
Asbestos Management Planner: All persons who prepare management plans must be accredited. All persons seeking accreditation as management planners shall complete a 3-day inspector training course as outlined above and a 2-day (16 hour) management planner training course. Possession of current and valid inspector accreditation is a prerequisite for admission to the management planner training course. Four hours of refresher training are required annually for certification to be maintained.
Asbestos Project Designer: Individuals who design any of the following activities with respect to friable ACM in a school, or public and commercial building, must complete accredited project designer training: (1) A response action other than a small scale short duration (SSSD) maintenance activity, (2) a maintenance activity that disturbs friable ACM other than a SSSD maintenance activity, or (3) a response action for a major fiber release episode. All persons seeking accreditation as a project designer shall complete at least a minimum 3-day training course. Eight hours of annual refresher training must be completed to maintain accreditation.
Civil Engineering Work Orders: All work orders which can disturb asbestos-containing material should be coordinated with Bioenvironmental Engineering Services and the Environmental Management Flight of Civil Engineering.
Complete Removal of Asbestos is not required: Bases will control hazardous asbestos-containing material through inventory management, isolation, and containment. Bases must remove asbestos-containing material likely to release airborne asbestos fibers that cannot be reliably maintained, repaired, or isolated.
Custodial and Maintenance Workers: Custodial and maintenance workers in primary and secondary schools on military installations who work in buildings with asbestos-containing building material (ACBM) must have 2 hours of awareness training, and if they conduct activities that may result in disturbance of ACBM, they must have an additional 14 hours of training.
Demolition and Renovation: The quantity and type of asbestos (friable/nonfriable) in structures to be demolished or renovated must be determined before starting the project.
Demolition by Intentional Burning: All RACM must be removed before burning.
Along with Civil Engineering, Bioenvironmental Engineering Services examines friable asbestos-containing material and decides whether repair, maintenance, or removal of the material is necessary; and whether extraordinary precautions, such as frequent monitoring, removal of personnel from the area, temporary controls, or other protective measures are necessary to protect personnel until recommended actions are completed. "Must remove" mandates will be issued by the installation commander with advice from Bioenvironmental Engineering Services and the Base Civil Engineer and are based on a direct evaluation of the facility.
AFOSH Standard 48-8, Controlling Exposures to Hazardous Materials, 1 September 1997
Mr. Jimmy D. Langwell, CIH
Mr. Gary L. Jacks
Captain Steve Novak |