How to Tell If Your Asbestos Activities Fall Under D&R Requirements

The first step in determining NESHAP applicability is to determine if the project meets the definition of demolition or renovation.

Demolition is the wrecking or taking out of any load-supporting structural member of a facility together with any related handling operations or the intentional burning of any facility.

Renovation is defined as altering a facility or one or more facility components in any way, including the stripping or removal of regulated asbestos-containing material (RACM) from a facility component. RACM is any of the following:

• Friable asbestos material. Friable asbestos material must contain more than 1 percent asbestos that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.
• Category I nonfriable ACM that has become friable. Category I nonfriable ACM is asbestos-containing packings, gaskets, resilient floor coverings, and asphalt roofing products containing more than 1 percent asbestos.
• Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading.
• Category II nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the force expected to act on the material in the course of demolition or renovation operations. Category II nonfriable ACM is any material, excluding Category I nonfriable ACM, containing more than 1 percent asbestos that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

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The type and category of asbestos that is involved in the project must be determined using the polarized light microscopy method specified in Appendix E of 40 CFR 763 Subpart E.

NESHAP Training Requirements for Asbestos

Owners or operators of an asbestos demolition or renovation activity have specific training requirements. Here’s what you need to know.

A foreman or management-level person or other authorized representative must be present when regulated ACM is stripped, removed, or otherwise handled or disturbed at a facility. The training involved for this must include, at a minimum: applicability, notifications, material identification, and control procedures for removals. You’ve also got to post evidence that the required training has been completed and make it available for inspection at the demolition or renovation site.

And then there’s refresher training. EPA wants the trained on-site foreman or management person to receive refresher training every 2 years.

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Asbestos Training Requirements Checklist

Here’s an easy checklist to make sure you’ve got all of EPA’s requirements covered under 40 CFR 61.145.

Has at least one on-site representative, such as a foreman or management- level person or other authorized representative, received the following training:

• Initial training on:
• Applicability of the asbestos standards for demolition and renovation?
• Notifications required by the asbestos standards for demolition and renovation?
• Regulated asbestos-containing material (RACM) identification?
• Control procedures for RACM removal including wetting, local exhaust ventilation, negative pressure         enclosures, glove-bag procedures, and High Efficiency Particulate Air (HEPA) filters?
• RACM waste disposal work practices?
• Reporting and recordkeeping required by the asbestos standards for demolition and renovation?
• Asbestos hazards and worker protection?

• Refresher training at least every 2 years?

If your remediation or abatement of asbestos activity is taking place in a school, commercial, or public building there are even more EPA training requirements. See tomorrow’s Advisor for a training checklist for those activities.