Managing Asbestos in Buildings: A Guide for Owners and Managers

Managing Asbestos
in Buildings:
A Guide for Owners
and Managers
A Revision to the United States
Environmental Protection Agency’s
1985 document Guidance for Controlling
Asbestos-Containing Materials in Buildings
(EPA 560/5-85-024) Known as the Purple Book
The Environmental Information Association, Inc.
ASBESTOS • LEAD • MOLD • INDOOR AIR QUALITY
Managing Asbestos in Buildings: A Guide for Owners and Managers 1
Managing Asbestos
in Buildings:
A Guide for Owners
and Managers
A Revision to the United States Environmental
Protection Agency’s 1985 document
Guidance for Controlling
Asbestos-Containing Materials in Buildings
(EPA 560/5-85-024) known as the Purple Book
First Edition, March, 2015
A product of volunteer effort by:
The Environmental Information Association, Inc.
6935 Wisconsin Avenue, Suite 306
Chevy Chase, MD 20815-6112
[email protected]
A NOTE FROM THE EIA TO THOSE
THAT MANAGE SCHOOL PROPERTIES (K-12):
This document is a general treatment of asbestos issues to assist those that own or manage
buildings that can contain asbestos-containing materials. Much of the information included
here would also be germane to these issues in school properties. But do be advised that
this document does not specifically enumerate the responsibilities for the management of
asbestos issues on school-related properties. The Environmental Protection Agency (EPA)
has long established asbestos control regulations and guidance for schools. The EPA has
a very helpful web page to guide those that are responsible for school properties and their
regulatory responsibilities regarding asbestos management issues. Please take the time to
open this web page and look for the section called “School Buildings.”
http://www2.epa.gov/asbestos
DISCLAIMER
The authors of this document have created this publication to provide the owners and
managers of properties that are known to have, or may contain, asbestos-containing
materials with general guidance concerning the management of these materials. It was
not written to serve as a technical document for asbestos control specialists. Reprinted
material is quoted with permission and sources are indicated. Reasonable efforts have
been made to publish reliable data and information but the authors cannot assume
responsibility for the validity of all materials or typographical errors. Where interpretations
of federal regulations have been made those interpretations reflect a consensus of
opinions by the authors and asbestos control industry experts who peer reviewed this
document and are not intended to represent a legal interpretation of the regulations. No
attempt has been made incorporate regulations found at the State and Local level. If legal
advice or other expert assistance is required, in relation to specific issues raised in this
document, the services of a competent professional should be sought. Efforts were made
to assure that all photographs used in this document were clear of copyright violations. If
any photograph used in this document is in violation of any copyright we will remove the
item or properly cite its reference in the next document revision.
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Managing Asbestos in Buildings: A Guide for Owners and Managers 3
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4 Managing Asbestos in Buildings: A Guide for Owners and Managers
Acknowledgements
Many individuals contributed their volunteer time and efforts for this document revision. Without their generous efforts we would not have
been able to complete this project. The contributors to this document span a wide collection of talents from those that serve as physicians,
medical researchers, architects, engineers, industrial hygienists, consultants, laboratory scientists, contractors, and training specialists. Our
goal was to gather a wide variety of experiences and perspectives to be able to provide technically accurate and up-to-date information
from the consensus of industry professionals. The EIA thanks each for their contribution to the successful completion of this important
project.
EIA Steering Panel
In alphabetical order
Kevin Cannan, AAC Contracting, Inc., Rochester, New York
Bill Cavness, The Asbestos Institute, Phoenix, Arizona
Ronald F. Dodson, Ph.D., F.C.C.P., F.A.H.A., Dodson
Environmental Consulting, Inc., Tyler, Texas
William M. Ewing, CIH, Compass Environmental, Inc., Kennesaw,
Georgia
Steve M. Hays, PE, CIH, FACEC, FAIHA, Gobbell Hays Partners,
Inc., Nashville, Tennessee
David W. Hogue, The Environmental Institute
(a division of Cardno), Marietta, Georgia
David Kahane, MPH, CIH, Forensic Analytical,
Hayward, California
J. Brent Kynoch, Environmental Information Association, Inc,
Chevy Chase, Maryland
Thomas G. Laubenthal, The Environmental Institute
(a division of Cardno), Marietta, Georgia
James R. Millette, Ph.D., D-IBFES, MVA Scientific Consultants,
Duluth, Georgia
Andrew F. Oberta, MPH, CIH, The Environmental Consultancy,
Austin, Texas
Michael W. Schrum, P.E., Terracon, Charlotte, North Carolina
James S. Webber, Ph.D., Webber Environmental Health
Consulting, LLC, Pleasantville, NY.
Section Authors
Summary of Guidance & Chapter 1
Thomas G. Laubenthal, The Environmental Institute
(a division of Cardno), Marietta, Georgia
Chapter 1 (Health Effects)
Ronald F. Dodson, Ph.D., F.C.C.P., F.A.H.A., Dodson
Environmental Consulting, Inc., Tyler, Texas
Jeffrey L. Levin, MD, MSPH, FACOEM, The University of Texas
Health Science Center at Tyler, Tyler, Texas Paul P. Rountree, MD, FACOEM, The University of Texas Health
Science Center at Tyler, Tyler, Texas
Chapter 2
David W. Hogue, The Environmental Institute (a division of
Cardno), Marietta, Georgia
Chapter 3
Andrew F. Oberta, MPH, CIH, The Environmental Consultancy,
Austin, Texas
Joy N. Finch, CET, Greenville Technical College, Greenville,
South Carolina
Chapter 4
J. Brent Kynoch, Environmental Information Association, Chevy
Chase, Maryland
Michael W. Schrum, P.E., Terracon, Charlotte, North Carolina
Chapter 5
Peter DeLucia, AAC Contracting, Inc., Rochester, New York
Kevin Cannan, AAC Contracting, Inc., Rochester, New York
Chapter 5 (abatement final clearance issues)
James R. Millette, Ph.D., D-IBFES, MVA Scientific Consultants,
Duluth, Georgia
Thomas G. Laubenthal, The Environmental Institute (a division of
Cardno), Marietta, Georgia
External Peer Review
In alphabetical order
Ronald Arena, Chem Scope Inc., North Haven CT
Thomas J. Broido, Cardno, Williston, VT
Dana Brown, GEBCO Associates, Hurst, Texas
Chris Davis, Belfor Environmental, Tucker, Georgia
John Dietrichs, SafTech Consultants, Inc., Dunwoody, Georgia
Joy N. Finch, CET, Greenville Technical College, Greenville,
South Carolina
Sean Fitzgerald, PG, Scientific Analytical Institute, Inc.
Greensboro, North Carolina
Michael R. Gray, Alternative Actions, Inc., Hixson, TN
Marianne Hillmann, CSP, CHMM, Hillmann Consulting, LLC,
Westfield, Pennsylvania
Jeff Mlekush, QuanTEM Laboratories, LLC, Oklahoma City,
Oklahoma
Roger G. Morse, AIA, Morse Associates, Inc., Troy, NY
Additional Acknowledgements
Photographs
Many thanks to the following for their assistance in providing
photographs in this document:
Anthony Rich of Livonia Michigan was extremely helpful in
proving many pictures to help illustrate ACMs in current and
historical use.
Many more excellent pictures of many aspects of asbestos
history and the products produced can be found at the link
below. We suggest that those new to the asbestos issue
spend some time here for an overview of the vast array of
ACMs found in buildings:
https://www.flickr.com/photos/asbestos_pix/
Ben Greene of Grayling Industries, Inc. for all pictures of
glovebags used in this document.
Darryl Watson, CIH, CSP, JD, Cardno, Marietta, GA for his
assistance in providing assistance with text in the Disclaimer
Additionally, the pictures used in the Health Effects section
of Chapter 1 and those found in Chapters 3 and 5 were
principally provided by the section authors.
Managing Asbestos in Buildings: A Guide for Owners and Managers 5
Preface
Thank you for purchasing the Environmental Information Association, Inc.’s (EIA) document
“Managing Asbestos in Buildings: A Guide for Owners and Managers.” We sincerely hope you will
find this document informative and helpful for your management of asbestos issues in the properties
you own or manage.
This project was based upon a realized need within the leadership of the EIA and the asbestos–
control industry to update the topics originally addressed in a 1985 United States Environmental
Protection Agency (EPA) document entitled “Guidance for Controlling Asbestos-Containing
Materials in Buildings” (EPA 560/5-85-024). The industry has referred to this original document as
the “Purple Book” due to the color of its cover. When this document was published by the EPA,
it was the principal source of information on basic asbestos issues faced by industry. Since the
original publication of the Purple Book, the regulatory landscape has changed dramatically and
our knowledge of asbestos control has improved significantly. For those that own and/or manage
properties, there really has been a need for an updated Purple Book-type document that contained
current information and guidance on asbestos control issues. This is our effort to provide that
information to building owners and managers in a similar format to that of the original document.
This project was not undertaken to merely update the original information found in the EPA’s
Purple Book. The information is this document contains significant revisions to that of the original
EPA publication. This project was undertaken entirely by volunteers from EIA’s leadership and
membership with no outside funding.
On July 20, 2009, the EIA convened a steering committee meeting of senior asbestos-control
industry leaders to review the need for this project. The consensus was that industry would benefit
by our undertaking this process. From that point, all of the sections were written by volunteers
that generously gave of their time and expertise in authorship and multiple reviews. The EIA also
arranged and conducted a detailed peer review of the written materials. Peer-reviewers were
chosen from applications sent by EIA members to best represent a cross section of professionals
within the asbestos-control industry. They also gave generously of their time and expertise as
volunteers.
This document was written for the general guidance of the owners and managers of properties
that do or may contain asbestos-containing materials. It was not written to serve as a technical
document for asbestos control specialists. The document was specifically written to address federal
regulatory requirements, not the wide varieties of regulations found at the State and Local level. It
is mentioned many times in this document that the reader has the responsibility to know regulatory
variations at the State or Local level with the recognition that the most stringent guidelines are those
applicable to given circumstances. The reader will find many helpful hyperlinks to web pages to
assist in their information gathering. This document was written and peer-reviewed by asbestos
control industry experts. As such, what the reader will find is that within this guidance we have
agreed to a consensus of opinion. We did not try to incorporate every variation of opinion that
can exist in how asbestos is controlled or perceptions of regulatory compliance. Because each
chapter was written by volunteers, the reader will find some variation in writing style and subsection
numbering. Despite our best efforts to provide technically accurate information in this document,
we realize that errors may be found. We plan to have subsequent updates in the future to address
technical errors or changes in federal asbestos regulations.
This project was not funded by the EPA or any other source. Further, the EPA had no part in its
revision or peer-review. We make no claim of EPA endorsement of this document. It was produced
by the EIA and its members and leadership to service the building owners and managers in the
United States. In this we hope we can assist the building owner/manager community to make
informed decisions that will keep them in compliance with regulations, manage asbestos effectively
and protect their workers and occupants from asbestos exposures.
We hope you find this document of value!
6 Managing Asbestos in Buildings: A Guide for Owners and Managers
Message from the Editor-in-Chief
This document would not have been possible without the foresight and leadership of dedicated
senior members of EIA leadership. It started out with a conversation between friends at an EIA
conference and with much effort and time passed we have produced what we hope will be a
standard in the asbestos control industry for many years. We will be updating this document
periodically and will improve our explanations and graphics as revisions are made; we are
dedicated to that effort.
My personal thanks to the following people that were of great help to me over the long haul in
producing this first edition of Managing Asbestos in Buildings: A Guide for Owners and Managers:
My co-workers at The Environmental Institute; Dave Hogue, Rachel McCain and Lisa Bucher.
Their patience with my long hours of writing and then performing multiple rounds of editing was
instrumental to my being able to complete my tasks to bring this document together. Without their
support, this project would not have been completed.
Andrew Oberta, MPH, CIH; many thanks for Andy’s willingness to pick up his phone and help me
hash out many details on regulatory compliance matters. Andy’s service to the asbestos-control
industry is surpassed by few.
Tom Broido is a coworker with Cardno who manages an office in Vermont. Tom provided me
much appreciated patient guidance and mature wisdom when frustrations in sorting out materials,
and divergent opinions, became difficult.
Joy Finch, CET, is a colleague in the environmental training industry based in Greenville, South
Carolina. There were many that provided helpful editing assistance via peer review activities, but
few have the talent Joy exhibited. Her assistance made for a better document.
There are many others I could name, but the list would become quite long; thanks to all that
helped along the way. I do offer many thanks to the long hours and time donated by those that
served on the Steering Committee, section writers and peer reviewers. Without all of their effort
and vast expertise the technical excellence we planned for would not have been possible.
I thank the EIA leadership and its members for allowing me the honor to have served in the role of
management of this project to produce what we hope will be long lasting asbestos guidance to the
building owners and managers of the United States and our neighbors.
The honor has been to serve…
Thomas G. Laubenthal
Editor-in Chief
Managing Asbestos in Buildings: A Guide for Owners and Managers 7
Contents
Summary of Guidance
This section provides a simple overview of the topics that will be
covered in this document.
Chapter 1
Background on Asbestos in Buildings
1.1
Asbestos in Buildings.....................................................14
1.1.1 What is Asbestos?.........................................................14
1.1.2 The Regulatory Definition of Asbestos..........................15
1.2 Could I Have Asbestos In My Building?.........................16
1.2.1 ACM Found in Buildings................................................16
1.2.2 EPA Types of Asbestos Containing Materials (ACM)....18
1.2.3 Does Having ACM in My Building Present a Problem?..20
1.2.4 Levels of Airborne Asbestos in Buildings.......................20
1.3 Diseases Associated with Exposure to Asbestos..........20
1.3.1 Size of Respirable Dusts................................................21
1.3.2 Routes of Entry into the Body-Respiratory
and Digestive System....................................................21
1.3.3 Defense Mechanisms of the Body against Inhaled Dust..22
1.3.3.1 General Structure of the Respiratory System................22
1.3.3.2 Mucociliary Escalator (mucus, cilia and
clearance/translocation).................................................23
1.3.3.3 Impact of Smoking on Risk of Disease Including
Asbestos-induced Diseases..........................................23
1.3.3.4 Body Defense Cells (Inflammation)...............................23
1.3.4 Asbestos Exposure and Induction of Disease...............24
1.3.4.1 Asbestos Exposure and Disease...................................24
1.3.4.2 Period from Exposure to Development of Disease
(Latency)........................................................................24
1.3.4.3 Diseases Associated with Asbestos Exposure..............24
1.3.5 Importance of Early Diagnosis and
Clinical Annual Evaluations............................................25
1.3.5.1 Medical Surveillance Requirements..............................25
1.3.5.2 Good Clinical Practice....................................................26
1.4 Federal Regulations Regarding Asbestos in Buildings...26
1.4.1 United States Environmental Protection Agency (EPA)..28
1.4.1.1 EPA Asbestos NESHAP; 40 CFR Part 61, Subpart M..28
1.4.1.2 EPA AHERA “Asbestos in Schools”; 40 CFR Part 763..29
1.4.1.3 EPA Worker Protection Rule
(40 CFR Part 763, Subpart G).......................................30
1.4.2 Occupational Safety and Health Administration
(OSHA)...........................................................................30
1.4.2.1 Asbestos General Industry Standard;
29 CFR 1910.1001.........................................................31
1.4.2.2 Asbestos Construction Standard;
29 CFR 1926.1101.........................................................31
1.5 State/Local Asbestos Regulatory Programs..................32
References...................................................................................33
Appendix 1: Representative List Of Materials
Likely To Contain Asbestos............................................34
8 Managing Asbestos in Buildings: A Guide for Owners and Managers
Chapter 2
Determining If Asbestos-Containing
Material (ACM) Is Present In Buildings
2.1 Planning the Survey.......................................................36
2.1.1 What is the Purpose of the Asbestos Survey?..............36
2.1.2 Different Types of Asbestos Surveys.............................37
2.1.3 Who Should Conduct the Asbestos Survey?.................37
2.2 Conducting the Survey...................................................38
2.2.1 General Survey Elements..............................................38
2.2.1.1 Pre-Survey Planning......................................................38
2.2.1.2 Building Document Review............................................39
2.2.2 Specific Survey Elements..............................................39
2.2.2.1 AHERA Surveys (as described in 40 CFR Part 763.86)..39
2.2.2.2 OSHA Surveys...............................................................41
2.2.2.3 NESHAP “Thorough Inspection” Requirements............41
2.2.2.4 Pre-O&M Surveys..........................................................42
2.2.2.5 Abatement Design Surveys...........................................42
2.2.2.6 Limited Area and Limited Material Surveys...................43
2.2.2.7 ASTM Survey Standards...............................................43
2.2.3 Special Survey Considerations......................................44
2.2.3.1 Drywall/Taping/Joint Compound....................................44
2.2.3.2Vermiculite......................................................................45
2.2.3.3Soils................................................................................46
2.3
Bulk Sample Analysis.....................................................46
2.3.1 Polarized Light Microscopy (PLM).................................46
2.3.1.1 Point Counting................................................................47
2.3.2 Transmission Electron Microscopy (TEM).....................48
2.3.3 Laboratory Accreditation................................................48
2.4
Survey Report................................................................49
Chapter 3
Assessment of Asbestos
Containing Materials
3.1 3.2 3.3 3.3.1 3.3.1.1 3.3.1.2 3.3.2 3.3.3 3.3.3.1
3.3.3.2 3.4 Why assess asbestos-containing materials?................50
What aspects of asbestos-containing
materials are assessed?................................................50
How and when are asbestos-containing
materials assessed?......................................................51
What is an algorithm and how is it used?......................51
An early algorithm..........................................................51
Two current algorithms...................................................51
What is the AHERA protocol?........................................51
What are the ASTM assessment protocols..................54
What is the E2356 qualitative protocol?........................54
What is the E2356 quantitative protocol?......................54
What conclusions can we draw about the assessment
protocols?.......................................................................56
Appendix A....................................................................................57
Appendix B...................................................................................58
Contents
Chapter 4
Establishing an Operations and
Maintenance (O&M) Program
Chapter 5
Abatement Methods: Characteristics
and Recommended Work Practices
4.1 4.2 4.2.1 4.2.2 4.2.3 4.3 4.3.1 4.3.2 4.3.3 4.3.3.1 4.3.3.2 4.3.3.3 4.3.4 4.3.4.1 4.3.4.2 4.3.5 4.3.6 4.3.6.1 4.3.6.3 4.3.6.4 4.3.6.5 4.3.6.6 4.3.7 4.3.8 4.3.9 4.4 5.1 5.1.1 5.1.2 5.2 5.2.1 5.2.2 5.2.2.1 5.2.2.2 5.2.2.3 5.3 5.3.1 5.3.2 5.4 5.4.1 5.4.2 5.5 5.5.1 5.5.1.1
Purpose of an O&M Program........................................59
Setting up the O&M Program.........................................59
Surveying the Building for Asbestos-Containing
Materials (ACM).............................................................59
Appoint an Asbestos Program Manager (APM)............59
Development of an O&M Program................................60
Elements of the O&M Program......................................60
Written O&M Program....................................................60
Work Permit System......................................................60
Training...........................................................................60
Types of Training for O&M Activities..............................62
Who Should Conduct Training.......................................63
Where to Find Training...................................................63
Occupant and Contractor Notification............................63
Information for Occupants
(Tenants and other occupants)......................................63
Additional Information for Occupants
(contractors and workers)..............................................63
Periodic Inspection.........................................................63
Asbestos O&M Work Practices......................................64
When to Apply Special O&M Work Practices................64
Work Practices when Disturbance
Is Possible or Intended..................................................65
Work Practices when Disturbance Is Unlikely...............65
Work Practices Prohibited by OSHA..............................66
Air Monitoring for O&M Activities...................................66
Procedures for Asbestos Fiber Release Episodes........67
Procedures for Cleaning................................................67
Recordkeeping...............................................................68
Addressing Asbestos during Demolition
and Renovation Projects................................................68
What is Asbestos Abatement
and when is Abatement Appropriate?............................70
What is Asbestos Abatement?.......................................70
When is Abatement Appropriate?..................................71
Planning the Asbestos Abatement Project.....................71
Credentials of the Project Designer...............................71
What is an Asbestos Project Design?............................71
Project Scope.................................................................72
Schedule for Abatement- Timing and Phasing..............72
Specifications.................................................................73
Who Should do the Abatement Work?..........................73
In-house or Contracted..................................................74
Training, Licensing and Certification..............................74
Selecting a Contractor...................................................74
Contractor Selection Criteria..........................................74
Pre-bid Walk-through.....................................................75
Abatement Methods and Control Options.....................75
Abatement Methods.......................................................77
Abatement Methods for Sprayed- or Troweled-on
Surfacing Material..........................................................78
5.5.1.2 Abatement Methods for Pipe and Boiler Insulation.......79
5.5.1.3 Abatement Methods for Other Types of ACM................80
5.5.1.4 Abatement Methods for Vermiculite...............................80
5.5.2 Other Control Options....................................................81
5.5.2.1 Enclosure.......................................................................81
5.5.2.2 Encapsulation.................................................................81
5.5.3 Project Notification Requirements.................................82
5.5.4Disposal..........................................................................82
5.5.5 OSHA Required Exposure Assessments
& Respiratory Protection................................................83
5.6 Managing the Work........................................................84
5.6.1 Responsibilities for the Owner/Manager and Employers of
Other Employees Adjacent to the Abatement Work........84
5.6.2 The Role of the Consultant............................................84
5.6.3 Project Monitoring & Visual Inspections........................85
5.7 Final Clearance Testing and Air Sample Analysis.........86
5.7.1 Air Sample Analysis Options..........................................87
5.7.1.1 Other Available TEM Methods.......................................88
5.7.2 AHERA Method for Final Clearance Testing..................88
5.7.2.1 Requirements.................................................................88
5.7.2.2 Other Requirements.......................................................89
5.7.3 Final Clearance Air Sampling for
Non-AHERA Abatement Projects..................................90
5.7.4 Sample Analysis of Final Clearance Air Samples..........90
5.7.5 Release Criterion...........................................................90
5.7.6 Quality Assurance..........................................................91
5.8 Contractor Release and Recordkeeping.......................92
5.9 Replacement Materials Considerations.........................92
Appendix A
Comparison tables of abatement options....................................94
Managing Asbestos in Buildings: A Guide for Owners and Managers 9