Galbestos In Fire

Question: A building with asbestos/asphalt/steel (galbestos) siding was involved in a fire. The siding is intact but some of the siding has friable asbestos exposed. If asbestos-trained roofing workers screw new siding onto the existing galbestos, is that regulated work?

Situation

Galbestos siding was a widely used building material in this part of the country. It is panels of corrugated coated with an asphalt-asbestos material which provides protection against corrosion. The coating is nonfriable, but weathering, or in this case fire, can reduce the amount of asphalt to the point at which some friable material is present. In the current situation the amount of material affected exceeds 160 SF, but is patchy and does not warrant removal of the material. The owner would like to panel over the siding but needs advice regarding who is allowed to perform the work and whether it is regulated.

Recommendations

  1. The work would be regulated by the NESHAP if the workers would disturb more than 160 SF of friable material. However, from the description of the material provided, that is unlikely to happen. They will actually be disturbing only the material they are screwing, and it is always useful to recall that it takes 734 quarter-inch screw holes to exceed 1 sf or 117,342 holes to exceed 160 SF!
  2. The work requires accredited workers if it involves encapsulation, enclosure, or removal of any material or repair or maintenance of more than 3 SF or 3 LF of friable material. The proposed work is not enclosure, since adding siding will not create an impermeable, air-tight barrier. And, again the actual number of holes drilled through friable material should not exceed the 3 SF/3LF limits for a minor O&M project.
  3. The work is certainly regulated by OSHA. Thus, the work must use the standard protections (wet methods, HEPA vacs, and prompt waste disposal); a competent person and workers must be trained; and the competent person must perform an initial exposure assessment. Because this is outside work, if wet methods and HEPA vacs are used to prepare the siding, the PELs should not be exceeded; however, this should be checked by doing an initial test using a couple of workers. Since the project does not involve removal, and since the amount of asbestos waste generated should not exceed the one-waste-bag-one-glove-bag limit, this would be a Class III O&M Project. OSHA requires that the competent person have at least 16 hours of training, but because of the limited nature of this work, the workers can be trained for fewer hours (at least 4 hours if an NEA is achieved, 8 or more otherwise) and the training must include the specific work practices and PPE to be employed. (Because of the limited nature of the disturbance and the fact that the work will be done outside, engineering controls -- unless you want to count drop cloths as an engineering control -- would not be feasible.)

Analysis

The Law.

  1. OSHA regulates all work done on ACM, so employee protection is always required where the employer knows that the material contains asbestos. However, the level of protection varies with the material being disturbed, the reason for the disturbance, and the amount of material disturbed. Since this is not thermal system insulation and will be left in place, the most stringent rules (Class I) as well as the somewhat less stringent Class II rules would not apply. Note that although U.S. EPA would classify galbestos as a surfacing material (it is applied to a surface), it certainly does not meet the OSHA definition for a surfacing material. However, since the material will be disturbed during the work, the employer must treat it as an O&M and repair project. Since the material will suffer only minor disturbance (the asbestos waste generated will fit in a single standard waste bag), the Class III rules would apply. As a unique type of project, initial exposure monitoring should be done to obtain a negative exposure assessment. During this part of the work protective clothing and respirators should be used, but this can be discontinued once the NEA is demonstrated. At that point only the three standard work practices and the use of trained workers is mandated.
  2. IDEM requires NESHAP supervision and work compliance for work exceeding 3 SF of surfacing material disturbed. As noted above, the covering work should not disturb this much material, so the work practices would not be clearly required. However, since OSHA requires the work practices regardless of the size of the job, the point is moot.
  3. IDEM requires NESHAP notification for all renovations exceeding 160 SF of RACM disturbed. However, this is certainly far beyond the level of disturbance expected, so no prior notification is required.
  4. IDEM requires licensing for all removals, encapsulation, and enclosures, but--as noted above--this is none of the above. Major O&M projects also require licensing, but the limited nature of the work means this is not an issue. It is important to note that in most states licensing is never required for outdoor projects; Indiana's licensing program is unique in this requirement.

The Issues: As in all asbestos work not clearly specified in the rules, the principal issues to be addressed are the classifying the affected material (EPA Category II nonfriable miscellaneous material, OSHA other material), defining the type of work being done (not a removal and not an enclosure, hence an O&M project), and establishing the amount of material to be disturbed (less than one glovebag/one wastebag and less than 3 SF of friable). Once these three issues are defined, the question of training, supervision, and work practices can be dealt with correctly.

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