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Asbestos has been regulated under CAA’s air toxics program since 1973, when the first asbestos NESHAP was promulgated. Since then, several amendments have been added, including cross-references to asbestos rules under the Occupational Safety and Health Administration (OSHA), the Department of Transportation (DOT), and related EPA rules.
The asbestos NESHAP for renovation and demolition in 40 CFR Part 61.145 separates nonfriable asbestos-containing materials into two categories (as determined by using Polarized Light Microscopy):
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“Category I nonfriable asbestos-containing material (ACM) means asbestos-containing packings, gaskets, resilient floor covering, and asphalt roofing products containing more than 1 percent asbestos…”
“Category II nonfriable ACM means any material, excluding Category I nonfriable ACM, containing more than 1 percent asbestos…”
The NESHAP defines “regulated asbestos” as follows:
“Regulated asbestos-containing material (RACM) means (a) Friable asbestos material, (b) Category I nonfriable ACM that has become friable, (c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or (d) Category II nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations regulated by this subpart.”
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In general, the NESHAP requires that before beginning any asbestos-related work, “the owner or operator of a demolition or renovation activity” must inspect the affected facility for both friable and nonfriable asbestos. Following inspection, additional steps are defined by the amount of asbestos, the structural integrity of the building, and whether it is to be a renovation or a demolition project.
However, all RACM activities require prior written notice of intended operations to the Program Administrator (state or federal), usually within at least 10 days of the start date. Additional requirements apply to changes to the start date, emergency situations and updates required when the “amount of asbestos affected” increases by at least 20 percent.
When performing asbestos activities, the NESHAP requirements set “procedures for asbestos emissions control.” These procedures include specific directives for determining if, when and how to “wet” RACM to reduce air emissions during removal, acceptable use of local exhaust ventilation collection systems, gloved-bag systems and leak-tight wrapping, procedures for stripping RACM and related exceptions, rules for demolition by intentional burning of structures containing asbestos, and requirements for work- site posting, labeling, recordkeeping, and training/refresher training.
In addition to Asbestos Awareness Training, accreditation is required by the ASHARA. Under ASHARA, the Asbestos Model Accreditation Plan (MAP) provides minimum requirements for State asbestos accreditation programs. The MAP accreditation is required for workers, contractors and supervisors, inspectors, management planners, and project designers “conducting asbestos inspections or designing or conducting response actions at schools and public and commercial buildings.” The MAP has nine components:
- Definitions
- Initial Training
- Examinations
- Continuing Education
- Qualifications
- Recordkeeping Requirements for Training Providers
- Deaccreditation
- Reciprocity
- Electronic reporting
In addition to MAP accreditation training, EPA strongly recommends that asbestos-related activities conducted at public and commercial buildings follow the protocol for management and removal of asbestos-containing materials described in the Asbestos-Containing Materials in Schools Rule (40 CFR Part 763).
Although this overview is of federal laws only, it is important to understand that many states have been delegated authority by the EPA for asbestos enforcement through their own programs, including accreditation for workers involved in asbestos activities in schools and other public and commercial buildings.