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Lead Hazards and Asbestos Awareness Training


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Title: Lead Hazards and Asbestos Awareness Training

Lead Hazards and Asbestos Awareness Training
  • E Light Electric Services
  • E Light Wind and solar

Prevent lead intoxication and related injuries
during the use, handling, removal, and melting of
materials containing lead.
  • Lead is metallic lead, all inorganic lead
    compounds, and organic lead soaps.
  • Some of the properties of lead that make it a
    useful structural material are
  • Low melting point
  • Very abundant
  • High molecular weight
  • High density
  • Very malleable (easy to shape)

How lead gets into the body
  • Inhalation (breathing)
  • Ingestion (by mouth)
  • Lead is usually not absorbed through the skin
  • Once lead enters the body, it enters your
    bloodstream and is circulated throughout your
  • This lead then becomes stored in various organs
    of the body.
  • If you continue to be exposed to lead, you will
    begin to store more than your body can get rid of
    and you will begin to suffer the symptoms of lead

Common Uses For Lead
Batteries Ballast Weights
Radiation shielding Roof
flashings Paint filler Pipe joints
Acoustic insulation Ammunition
Solder Rubber anti-oxidant
Cable shielding
Lead Exposure Operations
  • Lead and Babbitt melting and casting
  • Ballast handling
  • Grinding, sanding material that contains lead
  • Soldering with torches
  • Lead-acid battery reclaiming
  • Machining lead
  • Contact with contaminated clothing
  • Removal of lead-based paints

Lead interferes with the formation of the
hemoglobin in blood and will cause anemia. Lead
causes cellular kidney damage which leads to
kidney failure. It can cause reduced sperm
count and decreased fertility.

Health Hazards cont'd
Lead can damage the nervous system, the blood
forming organs, kidneys, and reproductive
system. Chronic exposure initially damages the
blood forming and reproductive organs, and
eventually cause peripheral nerve and central
nervous system damage. Lead can pass from mother
to infant through the placenta.
Exceeding Exposure Limits
If Action Level is exceeded, it is necessary to
begin air monitoring, employee training, and
medical surveillance. Any employee known to have
been exposed to airborne concentrations exceeding
PEL, shall be notified in writing of the exposure
as soon as possible, but not later than 5 days
after the finding.
Reproductive System Effects
Exposure to lead can have serious effects on the
reproductive function of both males and
females. In males there can be a decrease in
sexual drive, impotence, decreased ability to
produce healthy sperm, and sterility. Women may
experience menstrual disturbance including
Dysmenorrhea (painful menstruation),
Menorrhagia (abnormally profuse blood flow), and
Amenorrhea (abnormal absence or suppression of
menstrual discharge.)
Reproductive System Effects (cont'd)
There is a higher frequency of sterility,
premature births, spontaneous miscarriages, and
stillbirths. Lead can alter the structure of
sperm cells raising the risk of birth
defects. Infants with mothers who had lead
poisoning have a higher mortality rate during the
first year and suffer from lower birth rates,
slower growth, and nervous system disorders.
Permissible Exposure Limits
The permissible exposure limit (PEL) for an 8
hour time weighted average (TWA) exposure to
airborne lead is 50 micrograms per cubic meter of
air. If an employee is exposed for more than
8 hours in a work day, the PEL shall be
determined by the following formula PEL
____________400________________ Number
of work hours per day
Action Level
The action level (AL) for an 8 hour TWA
exposure to airborne lead is 30 microgram/cubic
meter of air (without regard to respirator
use). Biological monitoring and medical
surveillance shall be initiated when an
employee's exposure exceeds the action level for
more than 30 days per year.
Permissible Exposure Limit
Where any employee is exposed to lead above the
PEL, but for 30 days or less per year,
the employer shall implement engineering
controls to reduce exposures to 200 mg/m3, but
thereafter may implement any combination of
engineering, work practice, and respiratory
controls to reduce and maintain employee exposure
to lead to or below 50 mg/m3.
  • All personnel who work in areas where the
    potential exists for lead exposure gt the
    Allowable Limit must receive
  • Initial training upon assignment
  • Annual training

T r a i n i n g cont'd
  • The minimum lead hazard training will
  • consist of
  • The specific nature of the operations where
  • lead is possible.
  • The purpose, proper selection, fit testing,
  • use, and limitations of respirators.
  • Contents of facilities' compliance plan.

General Workplace Control Practices
Use reduced lead paint coatings Only low lead
content paint shall be used in the interior of
residential structures or on other surfaces which
may pose an ingestion hazard.
When feasible, the heating of lead and leaded
materials shall be minimized through the use of
controlled heating or the removal of
lead-containing surface coatings prior to
heating. Procedures shall be established to
maintain work surfaces as free of lead dust as
practical. Lead dust shall be cleaned with HEPA
filtered vacuum cleaners.
General Workplace Control Practicescont'd
Wet sweeping and brushing may be used only
when vacuuming has been tried and found not to be
effective. Lead-containing scrap, waste, debris,
etc. shall be collected, sealed, and labeled in
leak proof containers. Hot work on lead and
abrasive lead removal operations shall,to the
extent possible, be isolated from other
To the extent feasible, fixed local exhaust
ventilation connected to HEPA filters or other
collection systems, approved by the cognizant
industrial hygienist, shall be provided at the
point of airborne particulate generation. Capture
velocities shall be high enough to draw in the
particulates, and the duct transport velocities
shall be high enough to prevent accumulation of
particulates in the duct. Clean out points must
be provided for periodic maintenance.
The ventilation systems shall be tested every 3
months and with 5 days of any change which may
result in a change of employee exposure. Test
records shall be retained for 50 years. The
recirculation of HEPA filtered air is not
Personal Protective Equipment
Personnel involved in work where the
concentration of lead exceeds the PEL or the
possibility of eye or skin irritation exists,
shall remove the clothing worn to and from work
and don protective clothing.
Personal Protective Equipment cont'd
Full body, one piece coveralls supplied and
laundered by the employer or a contractor shall
be used. Clothing must be waterproof when wet
lead is handled. One piece, disposable coverall
made of Tyvek or equivalent may also be
used. Durable gloves and head coverings shall be
used. Hoods shall extend beyond the collar of the
Personal Protective Equipment cont'd
Slip resistant shoe covers or lightweight rubber
boots shall be provided. Disposable shoe covers
may also be used. Face shield, vented goggles,
or other appropriate protective equipment shall
be provided and used whenever the possibility of
eye irritation exists. Clean protective clothing
shall be provided at lease weekly, or daily when
the 8 hr TWA concentration exceeds 200
Respiratory Protection
  • Personnel identified as working in lead hazard
    areas shall be
  • participants in the command's respiratory
    management program.
  • Personnel engaged in
  • - Unventilated hot operations, where
  • temperatures are not controlled.
  • - Melting operations without thermostatic
  • - Unventilated indoor or outdoor spray painting
  • shall wear positive-pressure supplied-air
  • Full face shields are required if lead aerosols
    cause eye or
  • skin irritation.

Limits of Respirator Usage
Engineering control measures shall be employed
to control and contain airborne lead particulates
to the lowest feasible level. Respirators alone
shall not be used to achieve compliance with
PELs except in the following cases - During
the time period necessary to implement
engineering control measures. - In work
situations in which the control methods
prescribed are not technically feasible, or are
not sufficient to reduce the airborne
concentrations to or below the PEL. - Whenever an
employee requests a respirator.
Respirator Fit Testing
Qualitative fit tests is required for all
respirator users at time of initial fitting and
at least every 6 months.
Warning Signs
  • Signs shall be provided and displayed at each
  • location where airborne lead may exceed the PEL.

Lead Work Area Poison No Smoking, Eating, or
  • The warning sign may contain a listing of
    required protective equipment.

Caution Labels
  • Affixed to containers of contaminated clothing,
    equipment, raw materials, waste, debris, or other
    products containing lead.

Clothing contaminated with lead Do not remove
dust by blowing or shaking Dispose of lead
contaminated wash water in accordance with
applicable local, state, of federal regulations.
Changing Facilities(are provided if level
exceeds PEL)
Change rooms shall be provided as close as
practical to the lead work area. There will be
protective clothing removal procedures posted. Re
moval of lead particles from clothing by
blowing or shaking is prohibited. Shower
facilities shall be located between the
"dirty" and "clean" change rooms.
Changing Facilities cont'd
Do not leave wearing any clothing that was worn
during the work shift. Lead contaminated
clothing will be laundered by informed and
capable contractors
Laundry Facility HOURS - 6 AM - 6 PM In
by 7, out by 5 We do Contaminated Clothing
Lunchrooms must be provided for employees who
work in areas where the airborne lead exposure is
above the PEL. These lunchrooms must have a
positive pressure, filtered air supply and be
readily accessible. Protective clothing and
equipment must be removed prior to entering the
  • In lead work areas, the following is prohibited
  • Eating
  • Drinking
  • Chewing or smoking tobacco
  • Applying makeup
  • Storage of food or tobacco
  • All lead workers must wash their hands and face
  • prior to eating, drinking, smoking, or applying
  • cosmetics.

Medical Surveillance Program
Three basic elements - Pre-placement medical
evaluation. All personnel must receive a
pre-placement evaluation prior to assignment to
a position involving potential exposure to lead
that equals or exceeds the action level -
Semi-annual blood lead monitoring unless air
monitoring indicates exposures above the
action level for more than 30 days per year.
- Follow-up medical evaluations and blood
lead analysis based on the results of blood
lead analysis physician's opinion.
Workplace Monitoring Plan
An Industrial Hygienist must evaluate all
workplaces at least annually, or more frequently
if necessary, where lead is used and shall
reevaluate the operation within 5 working days of
any work process or control change. The employee
or designated employee representative must be
given the opportunity to observe sampling or
monitoring. The employer must collect full shift
(7 continuous hours) personal samples including
at least one sample for each shift, for each job
classification, in each work area. Initial
determination is made if the employee is exposed
to lead at or above the action level.
OSHAs Asbestos Standard
  • For the
  • Construction Industry

What is Asbestos?
  • Asbestos is a name given to a group of naturally
    occurring, fibrous minerals that are uniquely
    resistant to heat, chemicals and electricity. The
    fibers are extremely fine and easily inhaled.

Typical Uses of Asbestos
  • Cement Pipes
  • Cement siding
  • Vinyl Products
  • Asphalt
  • Acoustical Tiles
  • High Temperature Tiles
  • Wallboard
  • Insulating materials of all types

Asbestos History
  • Asbestos is used in thousands of products.
  • In many of these products there is no substitute
    for the asbestos.
  • Asbestos was used far more prominently prior to
    1970 in construction materials requiring
  • In 1967, asbestos was recognized as a carcinogen

The Problems with Asbestos
  • The fine fibers, when inhaled, lodge themselves
    in the lung tissue. They stay there , unnoticed
    for many years.
  • Often cancer cells develop in the area with the
    lodged asbestos fiber leading to lung cancer.

Lawsuits and Regulation
  • The late 1960s and early 1970s saw thousands of
    law suites concerning asbestos and lung cancer.
    Most of the these suites were successful and most
    manufacturers changed processes to eliminate
    asbestos from their products.
  • However, the products that were already installed
    were still a hazard if they were disturbed or the
    asbestos fibers were released.

OSHA and Asbestos
  • OSHA came into existence in 1970 and the first
    product they decided to regulate was asbestos.
  • Respirator programs were develop based on
    asbestos regulations
  • MSDS came from asbestos regulations
  • Hazardous material clean up and management
    regulations came from asbestos regulations
  • In short, asbestos changed the construction

This Class
  • OSHA has separate standards for general industry
    and construction.
  • This program is going to deal strictly with the
    construction standards
  • What to do in the event you discover asbestos.
  • And some key facts about asbestos.

This Class
  • We will not discuss asbestos removal processes or
    how to mitigate asbestos as that is a subject for
    another class.
  • This class is asbestos awareness and what to do
    when you discover asbesto.

Types of Asbestos
  • Chrysotile
  • Amosite
  • Crocidolite
  • Termolite asbestos
  • Anthophyllite asbestos
  • Actinolite asbestos
  • Any product contains asbestos if it contains any
    of the products listed above.

  • Asbestos also includes presumed
    asbestos-containing materials. PACM
  • Defined as thermal system insulation (TSI) and
    surfacing material found in buildings constructed
    in 1980 or before.
  • Designation of material as PACM may be rebutted
    in accordance with OSHA regulations.

What this means to you
  • Unless an inspection of the premises has been
    completed by a certified expert in asbestos
    recognition and all the appropriate paperwork

What is a PACM
  • In both the OSHA Construction Asbestos Standard
    (29 CFR 1926.1101) and the General Industry
    Asbestos Standard (29 CFR 1910.1001) PACM is
    defined as thermal system insulation (TSI) and
    surfacing material found in a building
    constructed no later than 1980. TSI is the
    material applied to pipes, fittings (joints,
    "Ts", elbows, valves, etc.), boilers, breechings,
    tanks, ducts or other structural components,
    generally to prevent heat loss or gain.

Surfacing Materials
  • Surfacing material refers to materials sprayed,
    troweled-on or otherwise applied to surfaces
    generally for acoustical, fireproofing, or other
    purposes. Examples of surfacing materials include
    decorative finishes on ceilings and walls,
    fireproofing on structural members, and
    acoustical plasters.

OSHA Requirements
  • OSHA requires that building owners identify PACM
    in their buildings and treat the PACM as
    asbestos-containing materials (ACM) until the
    materials are proven not to contain asbestos.

Suspect Asbestos Containing Materials
  • The term "suspect ACM" does not appear in either
    of the OSHA standards. The term, however, has
    long been used by the asbestos industry to refer
    to any building material that is suspected of
    being asbestos-containing (based on appearance,
    usage, age of building, etc.), but has not been
    proven conclusively to be ACM (based on sampling
    and analysis, documentation, building records,

OSHA Requirements
  • For OSHAs purposes, suspect material would
    include any material (including TSI, surfacing,
    and flooring) that a building owner suspects of
    containing asbestos and is found in a building
    constructed after 1980, or any material
    (excepting TSI, surfacing, and flooring) found in
    a building constructed prior to 1981. Other
    typical suspect building materials would include
    ceiling tiles, asbestos-cement products
    (Transite), and joint compound

Owners Responsibilities
  • The exercise of due diligence (as noted in the
    OSHA asbestos standards) requires that, where a
    building owner knows or should have known that
    materials other than PACM are asbestos-containing,
    these materials must be treated as ACM until
    proven otherwise.

The Difference
  • A building constructed prior to 1981, therefore,
    could contain both PACM and suspect ACM. Newer
    buildings (constructed after 1980) would contain
    only suspect ACM.

Courses of Action
  • Building owners with identified PACM have two
    courses of action under the OSHA standards
  • 1) rebut or disprove the PACM designation or
  • 2) simply continue to treat the PACM as ACM (and
    follow all OSHA requirements for protecting the
    health and safety of workers and building

Rebutting the PACM
  • OSHA allows a building owner to rebut the
    designation of PACM in two ways
  • Have a complete building inspection conducted
    according to the requirements outlined in the EPA
    AHERA (Asbestos Hazard Emergency Response Act)
    regulation. Samples would have to be collected by
    an AHERA-accredited Asbestos Building Inspector.
    All PACM (and suspect ACM, for that matter) would
    accordingly be included in this inspection.

  • Collect and analyzing only samples of the PACM
    identified in a building. OSHA allows samples to
    be collected by either an accredited inspector or
    a CIH (Certified Industrial Hygienist). Samples
    must be collected in the manner described in

  • If the AHERA process has not been used to rebutt
    the PACM, the only other option is to consider
    the material to be asbestos containing and take
    all the precautions required.

Classifications of Asbestos Work
  • Class I Activities involving the removal of
    thermal system insulation, surfacing
    asbestos-containing material and presumed
    asbestos-containing material\
  • Class II Activities involving removal of ACM
    other than TSI or surfacing material.
  • Class III Repair and maintenance operations
    where ACM, including TSI and surfacing material
    is likely to be disturbed.
  • Class IV Maintenance and custodial activities in
    which employees contact but don not disturb ACM
    or PACM while cleaning up waste and debris

  • In other words, asbestos, if left alone is
    perfectly safe. It is when we disturb it and
    cause the fibers to fly into the air that it can
    become hazardous.

In other words.
  • The decision to leave asbestos alone, encapsulate
    it, or removing asbestos depends largely on the
    type of material, its location, its condition,
    and its exposure to mechanical damage or fiber
  • If you encounter asbestos products or products
    you suspect are asbestos, do not disturb the
    product and notify supervision immediately.

(k) Communication of Hazards - Employee Training
and Information - Basic Information
  • All employees covered by the standard must be
    informed of
  • Methods of recognizing asbestos, including PACM
  • Health effects
  • Relationship between smoking and asbestos in
    producing lung cancer
  • Operations that could result in exposure and
    protective measures and their use, as applicable
  • For Class III and IV work, information equivalent
    to the contents of EPA 20T-2003, Managing
    Asbestos In-Place
  • Purpose, proper use, fitting instructions, and
    limitations of respirators

What is a Carcinogen
  • A substance that can cause changes that lead to
    cancer are called carcinogens
  • Some carcinogens do not act on the DNA directly,
    but cause cancer in other ways, such as causing
    cells to divide at a faster rate

Carcinogens / Cancer Info
  • Carcinogens do not cause cancer in every case,
    all the time.
  • Substances classified as carcinogens may have
    different levels of cancer-causing potential
  • Some may cause cancer only after prolonged, high
    levels of exposure

Cancer Risks
  • For any particular person, the risk of developing
    cancer will depend on many factors, including
  • The length of exposure to the carcinogen
  • The intensity of exposure to the carcinogen
  • The persons genetic makeup

Determination of Substances as Carcinogens
  • Scientists obtain most data from lab studies
    (both culture animals)
  • In most cases, carcinogens are first found to
    cause cancer in lab animals and are later found
    to cause cancer in people

Basil cell skin cancer
Lab Studies
  • Most studies expose lab animals to doses that are
    higher than common human exposures
  • For most carcinogens, it is assumed that that
    those that cause cancer in animals, will cause
    cancer in humans.

Epidemiologic Studies
  • Epidemiologic studies look at the factors that
    might affect the occurrence of cancer in human

Study Summary
  • By combining data from both types of studies,
    scientists are able to make an educated
    assessment of a substances cancer causing
  • When the available evidence is compelling, but
    not felt to be conclusive, the substance may be
    considered to be a probable carcinogen.

How Are Carcinogens Classified
  • The most widely used system is IARC
    (International Agency for Research on Cancer).
  • Is a part of the WHO (World Health Organization)
  • IARC has evaluated the cancer causing potential
    of about 900 likely candidates in the last 30

Carcinogen Groups
  • Group 1 Carcinogen to humans
  • Group 2A Probably carcinogenic to humans
  • Group 2B Possibly carcinogenic to humans
  • Group 3 Unclassifiable as to carcinogenicity to
  • Group 4 Probably not carcinogenic to humans

National Toxicology Program (NTP)
  • Used in the U.S. NTP releases the Report on
    Carcinogens (RoC) every two years.
  • Identifies 2 groups of agents
  • Known to be human carcinogens
  • Reasonably anticipated to be human carcinogens.
  • Unlike IARC, RoC does not list substances that
    have been studied found not to be carcinogens.

Known Human Carcinogens
  • Arsenic
  • Asbestos
  • Benzene
  • Beryllium
  • Cadmium
  • Chromium
  • Ethylene Oxide
  • Nickel
  • Plutonium 239
  • And many others

  • Persons who smoke tobacco or other products have
    been shown to have a much higher risk of
    developing health problems including cancer when
    also exposed to asbestos.

How to Identify Asbestos?
  • 1. What is it used for?
  • 2. How old is it?
  • 3. Is it fibrous in nature?
  • 4. What color is it? Asbestos is typically white
    or gray in color where as fiberglass is typically
    yellowish in color.
  • 5. Sample testing to be sure.

OSHA Requirements
  • The following information is taken directly from
    the CFR 1926.1101 which is the Specific OSHA
    regulations concerning Asbestos.
  • When in doubt, check the OSHA regulations.

(c) Permissible Exposure Limits
  • Time-Weighted Average Limit 0.1 fiber/cubic
    centimeter as an 8-hour TWA
  • Excursion Limit 1.0 fiber/cubic centimeter as
    averaged over 30 minutes

(d) Multi-Employer Worksites
  • An employer whose work requires a regulated area
    shall inform other employers of
  • Nature of such work
  • Existence of and requirements pertaining to
    regulated areas
  • Measures taken to ensure that employees of other
    employers are not exposed
  • Abatement shall be by the contractor who created
    or controls the source of contamination

(d) Multi-Employer Worksites (contd)
  • All employers of employees exposed shall comply
    with applicable protective provisions
  • All employers of employees working adjacent to
    regulated areas established by another employer,
    shall daily ascertain integrity of the enclosure
    and/or other controls
  • All general contractors shall be deemed to
    exercise general supervisory authority over work
    covered by this standard and shall ascertain that
    the asbestos contractor is in compliance

(e) Regulated Areas
  • Class I, II, and III asbestos work also all
    other operations where PEL is or may reasonably
    be exceeded
  • Demarcated in any effective manner critical
    barriers or negative pressure enclosures may be
    used signs must be provided
  • Access limited to persons authorized by the
    employer or the OSH Act
  • Respirators to be provided based on (h)(2)
  • No eating, drinking, smoking, chewing tobacco or
    gum, or application of cosmetics
  • Work within regulated areas supervised by
    competent person

(f) Exposure Assessments and Monitoring - General
  • For each workplace or work operation where
    monitoring is required
  • Breathing zone samples representative of 8-hour
    TWA and 30-minute Excursion Limit of each
  • Excursion Limit samples for operations most
    likely to produce exposures above the Excursion

(f) Exposure Assessments and Monitoring - Initial
Exposure Assessment
  • Assessment by a competent person before or at the
    initiation of an operation -- so all appropriate
    control systems can be applied
  • Basis
  • Exposure monitoring if feasible
  • Observations, information, or calculations which
    indicate employee exposure, including any
    previous monitoring
  • Negative Exposure Assessment required to
    conclude that exposures are likely to be
    consistently below the PELs
  • Exposure above the PELs is assumed for Class I
    work until exposure monitoring documents
    otherwise, or employer makes a negative exposure

(f) Exposure Assessments and Monitoring -
Negative Exposure Assessment
  • An option only for jobs performed by employees
    who have been trained in compliance with the
  • Data to demonstrate that employee exposure will
    be below the PELs must conform to the following
  • Objective data that the product, mineral, or
    activity cannot release airborne fibers in
    concentrations gt PELs under the most severe
  • Monitoring data obtained within prior 12 months
    for work operations/conditions that closely
    resemble current operations and were conducted
    by employees no more trained/experienced than
    current employees
  • Results of initial exposure monitoring of the
    current job

(f) Exposure Assessments and Monitoring -
Periodic Monitoring
  • For Class I and II work in a regulated area
    daily monitoring representative of each
    employees exposure unless the employer has a
    negative exposure assessment for the entire
  • All other operations periodic monitoring
    sufficient to document the exposure
  • Exception employees doing Class I work who are
    using a control listed in (g)(4)(i), (ii), or
    (iii) and employees doing Class II work may be
    equipped with supplied-air respirators operated
    in the positive-pressure mode in lieu of daily

(f) Exposure Assessment and Monitoring - Other
  • If exposures are shown to be below the PELs by a
    statistically reliable method, monitoring may be
  • Additional monitoring is required whenever a
    change in process, control equipment, personnel,
    or work practice may produce exposures above the
  • Employees and their designated representatives
    may observe monitoring
  • Employers will notify affected employees of the
    monitoring results, in writing or by posting

(g) Methods of Compliance
  • Engineering controls and work practices required
    regardless of level of exposure
  • Vacuum cleaners with HEPA filters for cleanup
  • Wet methods or wetting agents during handling,
    mixing, removal, cutting, application, and
    cleanup, unless infeasible due to creation of
    other hazards see (g)(8)(ii) for roofing
  • Prompt cleanup and disposal of wastes and debris
    in leak-tight containers

(g) Methods of Compliance (contd)
  • Engineering controls and work practices required
    to achieve the PELs
  • Local exhaust ventilation with HEPA filter dust
    collection system
  • Enclosure or isolation of processes producing
    asbestos dust
  • Ventilation of the regulated area to move air
    from the employees breathing zone toward
    HEPA-filtered collection device or exhaust
  • Other controls that the Assistant Secretary can
    show to be feasible
  • If the above are not sufficient to reduce
    employee exposure to or below the PELs, they
    shall still be used and supplemented with
    respiratory protection

(g) Methods of Compliance (contd)
  • Prohibitions
  • High-speed abrasive disc saws that are not
    equipped with point of cut ventilator or
    enclosures with HEPA-filtered exhaust air
  • Compressed air to remove asbestos or ACM except
    in conjunction with an enclosed ventilation
  • Dry sweeping, shoveling, or other cleanup of ACM
    or PACM dust and debris
  • Employee rotation as a means of reducing employee

(g) Methods of Compliance - Class I Jobs
  • Supervision by a competent person
  • Critical barriers over all openings to regulated
    area, or another barrier or isolation method
    which prevents the migration of airborne asbestos
    from the regulated area
  • For Class I jobs involving the removal of gt25
    linear or 10 square feet of TSI or surfacing
  • For all other Class I jobs where there is no
    negative exposure assessment
  • For Class I jobs where employees are working in
    areas adjacent to the regulated area

(g) Methods of Compliance - Class I Jobs (contd)
  • Isolation of HVAC systems in regulated area
    (double layer of 6 mil plastic or equivalent)
  • Impermeable dropcloths on surfaces beneath
    removal activity
  • Covering all objects within regulated area with
    impermeable materials
  • Where employer cannot produce a negative exposure
    assessment, or where PEL is exceeded, ventilation
    of the regulated area to move air from the
    employees breathing zone toward HEPA-filtered
    collection device

(g) Methods of Compliance - Class I Jobs (contd)
  • One or more of the following specific control
    methods shall be used for Class I work
  • Negative Pressure Enclosure (NPE) Systems, where
    the configuration of the work area does not make
    erection feasible
  • Glove Bag Systems, for removal of PACM and/or ACM
    from straight runs of piping, elbows, and other
  • Negative Pressure Glove Bag Systems, for removal
    of ACM or PACM from piping
  • Negative Pressure Glove Box Systems, for removal
    of ACM or PACM from pipe runs
  • Water Spray Process System, for removal of ACM
    and PACM from cold line piping, where employees
    have completed a separate 40-hour training course
    in its use

(g) Methods of Compliance - Class I Jobs (contd)
  • A small walk-in enclosure accommodating no more
    than 2 persons, if the project can be completely
    contained in the enclosure
  • Alternative control methods that comply with the
  • Keep airborne asbestos dust from entering the
    breathing zone of employees
  • Are evaluated and certified by a CIH or licensed
    PE (or by a competent person if the material to
    be removed is lt or 25 linear or 10 square
  • Have the required evaluation/certification by a
    CIH/PE sent to the national OSHA Office of
    Technical Support

(g) Methods of Compliance - Class II Jobs
  • Supervision by a competent person
  • Critical barriers over all openings to regulated
    area, or another barrier or isolation method
    which prevents the migration of airborne asbestos
    from the regulated area
  • For all Class II jobs where there is no negative
    exposure assessment
  • For Class II jobs where there may be exposure
    above the PELs
  • For Class II jobs where the employer does not
    remove the ACM in a substantially intact state
  • Impermeable dropcloths on surfaces beneath
    removal activity

(g) Methods of Compliance - Class II Jobs
  • Additional specific controls are listed for
    various types of Class II work
  • Removal of vinyl and asphalt flooring materials
    which contain ACM or for which in buildings
    constructed no later than 1980, the employer has
    not verified the absence of ACM
  • Removal of roofing material which contains ACM
  • Removal of cementitious asbestos-containing
    siding and shingles or transite panels containing
  • Removal of gaskets containing ACM
  • Performing any other Class II removal of
    asbestos-containing material
  • Installation, removal, or repair of intact
    bituminous/resinous encapsulated roof flashings
    and asphaltic pipeline wraps

(g) Methods of Compliance - Class II Jobs
  • Class I methods may also be used for Class II
    work, except that glove bags and glove boxes are
    allowed if they fully enclose the Class II
    material to be removed
  • Alternative controls may be used if they comply
    with the following
  • Data representing employee exposure during the
    use of such controls indicate exposure will not
    exceed the PELs
  • A competent person evaluates and certifies such

(g) Methods of Compliance - Class III Jobs
  • Performed using wet methods
  • Performed using local exhaust ventilation, to the
    extent feasible
  • Where drilling, cutting, abrading, sanding,
    chipping, breaking, or sawing TSI or surfacing
    material, performed using impermeable dropcloths
    and mini-enclosures or glove bag systems or
    another isolation method
  • Where there is no negative exposure assessment or
    where the PELs are exceeded, performed using
    impermeable dropcloths and plastic barriers, or
    isolation using a control system specified for
    Class I jobs
  • Where TSI or surfacing material involved, or
    there is no negative exposure assessment, or PELs
    are exceeded, employees shall wear respiratory
    protection according to paragraph (h)

(g) Methods of Compliance - Class IV Jobs
  • Employees performing Class IV work must be
    trained according to paragraph (k)(9)
  • Employees cleaning up debris and waste in a
    regulated area where respirators are required
    shall wear respirators according to paragraph (h)
  • Waste and debris in areas where friable TSI or
    surfacing material is accessible shall be assumed
    to contain asbestos

(h) Respiratory Protection - General
  • Respirators shall be provided and used for
  • All Class I jobs
  • All Class II jobs where ACM is not removed in a
    substantially intact state
  • All Class II and III jobs not performed using wet
    methods exception sloped roofs
  • All Class II and III jobs where there is no
    negative exposure assessment
  • All Class III jobs where TSI or surfacing
    material ACM or PACM is disturbed
  • All Class IV work in regulated areas where
    employed performing other work are required to
    wear respirators
  • All work where PELs are exceeded
  • Emergencies

(h) Respiratory Protection - Selection
  • Employers shall provide respirators as specified
    in (d)(3)(i)(A) of 29 CFR 1910.134
  • Filtering facepiece respirators may not be used
    for asbestos
  • HEPA filters must be used for powered and
    non-powered air-purifying respirators
  • Tight-fitting, powered air-purifying respirators
    shall be provided in lieu of any
    negative-pressure respirator selected according
    to requirements of this section whenever
  • An employee chooses to use this type of
    respirator and
  • The respirator will provide adequate protection

(h) Respiratory Protection - Selection (contd)
  • Half-mask air-purifying respirators (other than a
    filtering facepiece respirator) equipped with
    high efficiency filters, shall be provided
  • For Class II and II jobs where there is no
    negative exposure assessment
  • For Class III jobs where TSI or surfacing ACM or
    PACM is being disturbed
  • Tight fitting powered air-purifying respirators
    or full-facepiece supplied air respirators
    operated in pressure-demand mode, with HEPA
    egress cartridges or an auxiliary positive
    pressure self-contained breathing apparatus,
    shall be used for Class I work in regulated areas
  • A negative exposure assessment has not been
    produced, and
  • Exposure assessment levels are lt or 1 fiber/cc
    for an 8-hour TWA

(k) Communication of Hazards - Duties of Building
and Facility Owners
  • Before work is begun, identify the presence,
    location, and quantity of ACM/PACM, including
  • All TSI and sprayed on/troweled-on surfacing
    materials in buildings or substrates constructed
    no later than 1980
  • All resilient flooring material installed not
    later than 1980
  • Notify the following persons of the presence,
    location, and quantity of ACM/PACM
  • Prospective employers applying for/bidding for
  • Employees of the owner who will work in or
    adjacent to areas containing such materials
  • All employers on multi-employer worksites whose
    employees will be performing work within or
    adjacent to areas containing such materials
  • Tenants who will occupy areas containing such

(k) Communication of Hazards - Duties of Building
and Facility Owners (contd)
  • Post signs at entrance to mechanical rooms/areas
    which employees may reasonably be expected to
    enter and which contain ACM and/or PACM
  • Identify material present, its location, work
    practices to avoid disturbance
  • Post signs or labels on previously installed
    ACM/PACM to inform employees of which materials
    are affected

(k) Communication of Hazards - Duties of
  • Before work, identify the presence, location, and
    quantity of ACM/PACM
  • Before work, inform the following persons of the
    location and quantity of ACM/PACM and the
    precautions to be taken to confine airborne
  • Owners of the building/facility
  • Employees who will perform work and employers of
    employees who work and/or will be working in
    adjacent areas

(k) Communication of Hazards - Duties of
Employers (contd)
  • Within 10 days of completion, inform the
    building/facility owner and employers of
    employees who will be working in the area of
  • Current location and quantity of ACM/PACM
  • Final monitoring results, if any
  • Within 24 hours of discovering ACM/PACM on a
    worksite, convey presence, location, and quantity
    of such newly-discovered materials to
  • Owner
  • Other employers of employees working at the
  • Post signs or labels on previously installed
    ACM/PACM to inform employees of which materials
    are affected

(k) Communication of Hazards - Signs
  • Warning signs must be used to demarcate regulated
  • Wording for signs
  • Additional wording where applicable

(k) Communication of Hazards - Labels
  • Labels must be affixed to
  • Products containing asbestos
  • Containers containing such products, including
    waste containers
  • Installed asbestos products, where feasible,
    including previously installed material
    identified as ACM/PACM
  • Exemptions from labeling include
  • Products where asbestos fibers have been modified
    by a bonding agent, coating, binder, or other
    material, if no concentration of fibers gt PELs
    will be produced during any reasonably
    foreseeable use, handling, etc.
  • Products where asbestos is lt 1.0 by weight
  • Installed materials where signs providing same
    information are posted

(k) Communication of Hazards - Labels (contd)
  • Wording on labels
  • Additionally, labels must contain a warning
  • statement against breathing asbestos fibers

(k) Communication of Hazards - Employee
Information and Training - General
  • Must be provided prior to or at time of initial
    assignment and at least annually thereafter
  • Must be conducted in a manner that the employee
    is able to understand

(k) Employee Information and Training - Basic
Information (contd)
  • Appropriate work practices for the job
  • Medical surveillance program requirements
  • Contents of the standard, including appendices
  • Names, addresses, and phone numbers of public
    health organizations providing information/materia
    ls/programs for smoking cessation
  • Requirements concerning signs and labels

(k) Employee Information and Training - Job Class
Specific Requirements
  • Training for Class I jobs must be equivalent to
    EPA Model Accreditation Plan asbestos abatement
    worker training
  • Training for Class II work must include
    hands-on training and specific work practices
    and engineering controls for the category of
    materials as well as basic information required
    for all employees
  • Training for Class II work with
    asbestos-containing roofing materials, flooring
    materials, siding materials, ceiling tiles, or
    transite panels must be at least 8 hours

(k) Employee Information and Training - Job Class
Specific Requirements (contd)
  • Training for Class III jobs must be consistent
    with the EPA training course for local education
    agency maintenance and custodial workers who will
    disturb ACM or PACM (40 CFR 763.92(a)(2))
  • Must include hands-on training and take at
    least 16 hours
  • Exception If a competent person determines the
    EPA curriculum is not adequate, training must
    include the basic information as well as specific
    applicable work practices and controls and
    hands-on training

(k) Employee Information and Training - Job Class
Specific Requirements (contd)
  • Training for Class IV jobs must be consistent
    with the EPA requirements for training local
    education agency maintenance and custodial
    workers who contact but do not disturb ACM or
    PACM (40 CFR 763.92(a)(1))
  • Must be at least 2 hours
  • Must include
  • Location of ACM/PACM, asbestos-containing
    flooring material, or flooring material where
    absence of asbestos has not been certified
  • Instruction in recognition of damage,
    deterioration, and delamination of
    asbestos-containing building materials
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