Managing Asbestos in Buildings: A Guide for Owners and Managers 1

Managing Asbestos in Buildings:

A Guide for Owners and Managers

The Environmental Information Association, Inc.

ASBESTOS • LEAD • MOLD • INDOOR AIR QUALITY

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

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 info@eia-usa.org

Managing Asbestos in Buildings: A Guide for Owners and Managers 3

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.

INFORMATION REGARDING LINKS TO WEB PAGES IN THIS DOCUMENT

We made a significant effort to assure that all web page links in this document were func-tioning when we completed our editing process. It is likely that web links can change over time, especially those for federal and State/Local agencies. If a link does not appear to be working, copy the link from the text and paste it into your browser. This may be a matter of software as much as it could be a broken web page link. The reader should adjust securi-ty settings in software to assure web pages are not blocked because of web page content or a “pop-up blocker” setting. It is also possible that a web page could be unavailable because of periodic server maintenance. If the reader does ascertain that a web link is not functioning, please notify the EIA office. We will keep a list of any non-functioning web page links and will issue addendums periodically as a service to our readers.

4 Managing Asbestos in Buildings: A Guide for Owners and Managers

Copyright

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Managing Asbestos in Buildings: A Guide for Owners and Managers 5

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 PanelIn alphabetical order

Kevin Cannan, AAC Contracting, Inc., Rochester, New YorkBill Cavness, The Asbestos Institute, Phoenix, ArizonaRonald F. Dodson, Ph.D., F.C.C.P., F.A.H.A., Dodson

Environmental Consulting, Inc., Tyler, TexasWilliam M. Ewing, CIH, Compass Environmental, Inc., Kennesaw,

GeorgiaSteve M. Hays, PE, CIH, FACEC, FAIHA, Gobbell Hays Partners,

Inc., Nashville, TennesseeDavid W. Hogue, The Environmental Institute (a division of Cardno), Marietta, GeorgiaDavid Kahane, MPH, CIH, Forensic Analytical, Hayward, CaliforniaJ. Brent Kynoch, Environmental Information Association, Inc, Chevy Chase, MarylandThomas G. Laubenthal, The Environmental Institute (a division of Cardno), Marietta, GeorgiaJames R. Millette, Ph.D., D-IBFES, MVA Scientific Consultants,

Duluth, GeorgiaAndrew F. Oberta, MPH, CIH, The Environmental Consultancy,

Austin, TexasMichael W. Schrum, P.E., Terracon, Charlotte, North CarolinaJames S. Webber, Ph.D., Webber Environmental Health

Consulting, LLC, Pleasantville, NY.

Section AuthorsSummary of Guidance & Chapter 1Thomas G. Laubenthal, The Environmental Institute (a division of Cardno), Marietta, GeorgiaChapter 1 (Health Effects)Ronald F. Dodson, Ph.D., F.C.C.P., F.A.H.A., Dodson

Environmental Consulting, Inc., Tyler, TexasJeffrey 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, GeorgiaChapter 3Andrew F. Oberta, MPH, CIH, The Environmental Consultancy,

Austin, TexasJoy N. Finch, CET, Greenville Technical College, Greenville,

South CarolinaChapter 4 J. Brent Kynoch, Environmental Information Association, Chevy

Chase, MarylandMichael W. Schrum, P.E., Terracon, Charlotte, North Carolina

Chapter 5Peter DeLucia, AAC Contracting, Inc., Rochester, New YorkKevin Cannan, AAC Contracting, Inc., Rochester, New YorkChapter 5 (abatement final clearance issues)James R. Millette, Ph.D., D-IBFES, MVA Scientific Consultants,

Duluth, GeorgiaThomas G. Laubenthal, The Environmental Institute (a division of

Cardno), Marietta, Georgia

External Peer ReviewIn alphabetical order

Ronald Arena, Chem Scope Inc., North Haven CTThomas J. Broido, Cardno, Williston, VTDana Brown, GEBCO Associates, Hurst, TexasChris Davis, Belfor Environmental, Tucker, GeorgiaJohn Dietrichs, SafTech Consultants, Inc., Dunwoody, GeorgiaJoy N. Finch, CET, Greenville Technical College, Greenville,

South Carolina Sean Fitzgerald, PG, Scientific Analytical Institute, Inc.

Greensboro, North CarolinaMichael R. Gray, Alternative Actions, Inc., Hixson, TNMarianne Hillmann, CSP, CHMM, Hillmann Consulting, LLC,

Westfield, PennsylvaniaJeff Mlekush, QuanTEM Laboratories, LLC, Oklahoma City,

OklahomaRoger G. Morse, AIA, Morse Associates, Inc., Troy, NY

Additional AcknowledgementsPhotographsMany 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.

6 Managing Asbestos in Buildings: A Guide for Owners and Managers

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!

Preface

Managing Asbestos in Buildings: A Guide for Owners and Managers 7

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. LaubenthalEditor-in Chief

Message from the Editor-in-Chief

8 Managing Asbestos in Buildings: A Guide for Owners and Managers

Summary of GuidanceThis 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 ....................................................141.1.1 What is Asbestos?.........................................................141.1.2 The Regulatory Definition of Asbestos .........................151.2 Could I Have Asbestos In My Building? ........................161.2.1 ACM Found in Buildings ...............................................161.2.2 EPA Types of Asbestos Containing Materials (ACM) ...181.2.3 Does Having ACM in My Building Present a Problem? .201.2.4 Levels of Airborne Asbestos in Buildings ......................201.3 Diseases Associated with Exposure to Asbestos .........201.3.1 Size of Respirable Dusts ...............................................211.3.2 Routes of Entry into the Body-Respiratory and Digestive System ...................................................211.3.3 Defense Mechanisms of the Body against Inhaled Dust .221.3.3.1 General Structure of the Respiratory System ...............221.3.3.2 Mucociliary Escalator (mucus, cilia and clearance/translocation) ................................................231.3.3.3 Impact of Smoking on Risk of Disease Including

Asbestos-induced Diseases .........................................231.3.3.4 Body Defense Cells (Inflammation) ..............................231.3.4 Asbestos Exposure and Induction of Disease ..............241.3.4.1 Asbestos Exposure and Disease ..................................241.3.4.2 Period from Exposure to Development of Disease

(Latency) .......................................................................241.3.4.3 Diseases Associated with Asbestos Exposure .............241.3.5 Importance of Early Diagnosis and Clinical Annual Evaluations ...........................................251.3.5.1 Medical Surveillance Requirements .............................251.3.5.2 Good Clinical Practice ...................................................261.4 Federal Regulations Regarding Asbestos in Buildings ..261.4.1 United States Environmental Protection Agency (EPA) .281.4.1.1 EPA Asbestos NESHAP; 40 CFR Part 61, Subpart M .281.4.1.2 EPA AHERA “Asbestos in Schools”; 40 CFR Part 763 .291.4.1.3 EPA Worker Protection Rule (40 CFR Part 763, Subpart G) ......................................301.4.2 Occupational Safety and Health Administration (OSHA) ..........................................................................301.4.2.1 Asbestos General Industry Standard; 29 CFR 1910.1001 ........................................................311.4.2.2 Asbestos Construction Standard; 29 CFR 1926.1101 ........................................................311.5 State/Local Asbestos Regulatory Programs .................32

References ..................................................................................33Appendix 1: Representative List Of Materials Likely To Contain Asbestos ...........................................34

Chapter 2 Determining If Asbestos-ContainingMaterial (ACM) Is Present In Buildings

2.1 Planning the Survey ......................................................362.1.1 What is the Purpose of the Asbestos Survey? .............362.1.2 Different Types of Asbestos Surveys ............................372.1.3 Who Should Conduct the Asbestos Survey? ................372.2 Conducting the Survey ..................................................382.2.1 General Survey Elements .............................................382.2.1.1 Pre-Survey Planning .....................................................382.2.1.2 Building Document Review ...........................................392.2.2 Specific Survey Elements .............................................392.2.2.1 AHERA Surveys (as described in 40 CFR Part 763.86) .392.2.2.2 OSHA Surveys ..............................................................412.2.2.3 NESHAP “Thorough Inspection” Requirements ...........412.2.2.4 Pre-O&M Surveys .........................................................422.2.2.5 Abatement Design Surveys ..........................................422.2.2.6 Limited Area and Limited Material Surveys ..................432.2.2.7 ASTM Survey Standards ..............................................432.2.3 Special Survey Considerations .....................................442.2.3.1 Drywall/Taping/Joint Compound ...................................442.2.3.2 Vermiculite .....................................................................452.2.3.3 Soils ...............................................................................462.3 Bulk Sample Analysis ....................................................462.3.1 Polarized Light Microscopy (PLM) ................................462.3.1.1 Point Counting ...............................................................472.3.2 Transmission Electron Microscopy (TEM) ....................482.3.3 Laboratory Accreditation ...............................................482.4 Survey Report ...............................................................49

Chapter 3 Assessment of Asbestos Containing Materials

3.1 Why assess asbestos-containing materials?................503.2 What aspects of asbestos-containing materials are assessed? ...............................................503.3 How and when are asbestos-containing materials assessed? .....................................................513.3.1 What is an algorithm and how is it used? .....................513.3.1.1 An early algorithm .........................................................513.3.1.2 Two current algorithms ..................................................513.3.2 What is the AHERA protocol? .......................................513.3.3 What are the ASTM assessment protocols .................543.3.3.1 What is the E2356 qualitative protocol? .......................543.3.3.2 What is the E2356 quantitative protocol? .....................543.4 What conclusions can we draw about the assessment

protocols? ......................................................................56

Appendix A ...................................................................................57Appendix B ..................................................................................58

Contents

Managing Asbestos in Buildings: A Guide for Owners and Managers 9

Chapter 4 Establishing an Operations andMaintenance (O&M) Program

4.1 Purpose of an O&M Program .......................................594.2 Setting up the O&M Program ........................................594.2.1 Surveying the Building for Asbestos-Containing Materials (ACM) ............................................................594.2.2 Appoint an Asbestos Program Manager (APM) ...........594.2.3 Development of an O&M Program ...............................604.3 Elements of the O&M Program .....................................604.3.1 Written O&M Program ...................................................604.3.2 Work Permit System .....................................................604.3.3 Training ..........................................................................604.3.3.1 Types of Training for O&M Activities .............................624.3.3.2 Who Should Conduct Training ......................................634.3.3.3 Where to Find Training ..................................................634.3.4 Occupant and Contractor Notification ...........................634.3.4.1 Information for Occupants (Tenants and other occupants) .....................................634.3.4.2 Additional Information for Occupants (contractors and workers) .............................................634.3.5 Periodic Inspection ........................................................634.3.6 Asbestos O&M Work Practices .....................................644.3.6.1 When to Apply Special O&M Work Practices ...............644.3.6.3 Work Practices when Disturbance Is Possible or Intended .................................................654.3.6.4 Work Practices when Disturbance Is Unlikely ..............654.3.6.5 Work Practices Prohibited by OSHA .............................664.3.6.6 Air Monitoring for O&M Activities ..................................664.3.7 Procedures for Asbestos Fiber Release Episodes .......674.3.8 Procedures for Cleaning ...............................................674.3.9 Recordkeeping ..............................................................684.4 Addressing Asbestos during Demolition and Renovation Projects ...............................................68

Chapter 5 Abatement Methods: Characteristicsand Recommended Work Practices

5.1 What is Asbestos Abatement and when is Abatement Appropriate? ...........................705.1.1 What is Asbestos Abatement? ......................................705.1.2 When is Abatement Appropriate? .................................715.2 Planning the Asbestos Abatement Project ....................715.2.1 Credentials of the Project Designer ..............................715.2.2 What is an Asbestos Project Design? ...........................715.2.2.1 Project Scope ................................................................725.2.2.2 Schedule for Abatement- Timing and Phasing .............725.2.2.3 Specifications ................................................................735.3 Who Should do the Abatement Work? .........................735.3.1 In-house or Contracted .................................................745.3.2 Training, Licensing and Certification .............................745.4 Selecting a Contractor ..................................................745.4.1 Contractor Selection Criteria .........................................745.4.2 Pre-bid Walk-through ....................................................755.5 Abatement Methods and Control Options ....................755.5.1 Abatement Methods ......................................................775.5.1.1 Abatement Methods for Sprayed- or Troweled-on

Surfacing Material .........................................................785.5.1.2 Abatement Methods for Pipe and Boiler Insulation ......795.5.1.3 Abatement Methods for Other Types of ACM ...............805.5.1.4 Abatement Methods for Vermiculite ..............................805.5.2 Other Control Options ...................................................815.5.2.1 Enclosure ......................................................................815.5.2.2 Encapsulation ................................................................815.5.3 Project Notification Requirements ................................825.5.4 Disposal .........................................................................825.5.5 OSHA Required Exposure Assessments & Respiratory Protection ...............................................835.6 Managing the Work .......................................................845.6.1 Responsibilities for the Owner/Manager and Employers of

Other Employees Adjacent to the Abatement Work .......845.6.2 The Role of the Consultant ...........................................845.6.3 Project Monitoring & Visual Inspections .......................855.7 Final Clearance Testing and Air Sample Analysis ........865.7.1 Air Sample Analysis Options .........................................875.7.1.1 Other Available TEM Methods ......................................885.7.2 AHERA Method for Final Clearance Testing .................885.7.2.1 Requirements ................................................................885.7.2.2 Other Requirements ......................................................895.7.3 Final Clearance Air Sampling for Non-AHERA Abatement Projects .................................905.7.4 Sample Analysis of Final Clearance Air Samples .........905.7.5 Release Criterion ..........................................................905.7.6 Quality Assurance .........................................................915.8 Contractor Release and Recordkeeping ......................925.9 Replacement Materials Considerations ........................92

Appendix A Comparison tables of abatement options....................................94

Contents