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Air Indoor Resources - Asbestos

Asbestos Response Actions & Operations and Maintenance

After the Management Planner has outlined detailed response action recommendations, the LEA shall select and implement response actions sufficient to protect human health and the environment as outlined in the written assessment report. Persons who design response actions must be an accredited Project Designer, although a written design is not mandated it is highly encouraged.

Damaged TSI should be repaired or removed to achieve intact and undamaged covering. Friable surfacing and miscellaneous ACM can be encapsulated, enclosed, removed or repaired. Significantly damaged friable items require restricted access and immediate isolation of the area from the functional space. Response actions are dictated by local circumstances such as occupancy, use, economic considerations, and short- and long-term cost.

The O&M program is implemented when any friable or soon to be considered friable ACBM is present. For ACM that is friable surfacing, TSI or miscellaneous that can be potentially damaged, the LEA is required to implement an Operation and Maintenance Program:

  1. Through preventive measures appropriate to eliminate the reasonable likelihood the ACM or its covering will not become significantly damaged, deteriorated, or delaminated.
  2. Removal of the material as soon as possible if appropriate preventive measures cannot be effectively implemented, or unless other response actions are determined protective enough to human health and the environment.
  3. Response actions including removal, encapsulation, enclosure, or repair, other than small-scale, short-duration repairs, shall be designed and conducted by accredited personnel.
  4. OSHA’s 29 CFR 1926.58 asbestos worker protection standards for construction applies as well as EPA’s 40 CFR part 763, subpart G asbestos worker protection standards for public employees, and 40 CFR part 61, subpart M, National Emission Standards for Hazardous Air Pollutants--Asbestos.
  5. Upon completion of response actions, the person designated by the LEA shall visually inspect each functional space remediated to determine whether the action has been properly completed.

Final air clearance is required for projects involving more that 160 square feet or 260 linear feet of ACBM. LEA is to have post-remedial air monitoring using transmission electron microscopy (TEM) analysis for bulk material sampling and final clearance after each removal, encapsulation, and enclosure accredited by the National Institute of Standards and Technology (NIST) under the National Voluntary Laboratory Accreditation Program (NVLAP).

The removal, encapsulation, or enclosure of ACBM shall be considered complete when the average concentration of asbestos of five (5) air samples collected within the affected functional space analyzed by the TEM method are not statistically or significantly different from five (5) air samples collected at the same time outside the affected functional space and analyzed in the same manner and comparing the average asbestos concentration of the three field blanks. Further specifications are found in CFR Part 763.90, Response Actions.

For the smaller than aforementioned projects the American Industrial Hygiene Association Proficiency Analytical Testing Program for phase contrast microscopes (PCM) analysis for clearance can be used. The PCM method involves the collection of at least five (5) samples inside the work area, but does not require the samples to be averaged. The clearance standard is 0.01 fiber per cubic centimeter of air; if all five (5) samples pass the standard the response action is complete.

An Operations and Maintenance (O&M) program involves protocols to keep a building free of asbestos fibers and is designed to specifically address the ACBM present. Minimization of asbestos is instituted through proper work practices until removal or before the demolition. The O&M program should involve: cleaning using methods 763.91(c) as explained below, proper work practices with regard to disturbing ACBM, training and emergency response procedures.

Certified Asbestos Abatement Workers are required to oversee LEA for small-scale and short duration projects with regards to cleaning of areas with friable or damaged ACBM after the completion of the inspection, before the initiation of the response action(s) and other O&M repair activities for small projects:

  1. HEPA-vacuum or steam-clean all carpets and HEPA-vacuum or wet-cleaning all other floors and horizontal surfaces;
  2. Dispose of all debris, filters, mop-heads, and cloths in sealed, leak-tight containers;
  3. Accredited Management Planner’s written recommendation to the LEA whether additional cleaning is needed

Special work practices

Other O&M program elements should include: notifications of activity, labeling, employee protection and medical surveillance. Special work practices and procedures described below protect building occupants during O&M activities that disturb friable ACBM:

  1. Restrict entry into the area by persons other than those necessary to perform the maintenance project, either by physically isolating the area or by scheduling;
  2. Post signs to prevent entry by unauthorized persons;
  3. Shut off or temporarily modify the air-handling system and restrict other sources of air movement;
  4. Use work practices or other controls, such as, wet methods, protective clothing, HEPA-vacuums, mini-enclosures as necessary to inhibit the spread of any released fibers;
  5. Clean all fixtures or other components in the immediate work area;
  6. Place the asbestos debris and other cleaning materials in a sealed, leak-tight container.

Once ACBM is discovered, the LEA must provide an annual written notification to building occupants, employees and parents as to the location of ACBM, the availability of the management plan and recent or upcoming asbestos projects. Labels must be prominently displayed and readily visible. Employee protection and medical surveillance program requirements are provided under OSHA. For those work in an environment that exceeds the Permissible Exposure Limit (PEL) employees are required to participate in a respiratory protection program and respiratory protection program.

Per OSHA stripping of floor finishes should use low abrasion pads at speeds lower than 300 rpm with the wet methods.

Vinyl Asbestos Tile

Maintenance of Vinyl Asbestos Tile (VAT) flooring is considered the most prevalent source of ACM. Although not considered friable, routine floor-care can release fibers from frictional force of the floor buffer, if used aggressively with abrasive pads.

It is recommended to remove the wax or finish coat at low speed ranging between 175 to 300 rpm during stripping operations. There is a direct correlation between buffer speed and release of asbestos fibers. Never perform dry stripping, always strip the floor when wet. After stripping, the floor should be cleaned while wet preferably with a Wet-Vac HEPA filter vacuum system finishing the floor with 2 to 3 coats of sealant. Dry burnish floors are lowest speed possible (i.e., 1200 to 1750 rpms) with least abrasive pads possible.

Keep the flooring clean by door entrances to lessen scuffing of the floor by abrasive sand with frequent wet mopping of floors to minimize damage to floors. Chair and desk glides should be in good condition so as not to gouge flooring.

O&M Emergency Response Procedures Minor Release Episodes

The response action for any small-scale, short-duration maintenance activities that disturbs ACBM, other than maintenance activities, shall be designed by persons accredited for response actions and conducted by persons accredited to conduct response actions. Minor fiber release episodes are for example the falling or dislodging of three (3) square or linear feet or less of friable from O&M activity; however, the LEA shall ensure that the procedures are followed as described below:

  1. Thoroughly saturate the debris using wet methods;
  2. Clean the area, as described above in this section;
  3. Place the asbestos debris in a sealed, leak-tight container;
  4. Repair the area of damaged ACM with materials such as asbestos-free spackling, plaster, cement, or insulation; or seal with latex paint; or encapsulation; or immediately conduct the appropriate response action

Major Release Episodes

The LEA must ensure that the procedures described below are followed in the event of a major fiber release episode (i.e., the falling or dislodging of more than three (3) square or linear feet of friable ACBM):

  1. Restrict entry into the area and post signs to prevent entry into the area by persons other than those necessary to perform the response action;
  2. Shut off or temporarily modify the air-handling system to prevent the distribution of fibers to other areas in the building;
  3. The response action for any major fiber release episode must be designed by an accredited Project Designer and conducted by persons accredited to conduct response actions.

All minor or major fiber-releases must be documented and documented in the management plan.

Contact Information

Wendy Murphy
325 West Gaines Street
Suite, 1054
Tallahassee, FL 32399
Phone: (850) 245-9295