Questions and Answers on the Asbestos Standard | Workplace Hazards

Scope

Q.	Are marine terminals and longshoring covered by the General Industry standard?
A.	Marine terminals and longshoring are covered by the General Industry standard if asbestos is being loaded, unloaded or stored.
Q.	What work activity is most affected by the General Industry asbestos standard?
A.	Brake and clutch repair in the General Industry standard is the activity engaged in by the largest group of asbestos exposed workers, although most of them are exposed sporadically and at low levels. The next largest group consists of custodial workers who do not perform their duties as part of construction activities, but clean surfaces, sweep, buff and vacuum floors and wash walls and windows in manufacturing plants and a wide variety of public and commercial buildings.
Q.	Is housekeeping work covered under the General Industry standard or the Construction standard?
A.	Housekeeping work which is not related to a construction activity, is regulated under the General Industry standard. Housekeeping work which is related to construction activities at a construction site is covered by the Construction standard.
Q.	What other industries are covered by the General Industry standard?
A.	Primary and secondary manufacture of asbestos-containing products.
Q.	What activities does the Construction standard (29 CFR 1926.1101) cover?
A.	The construction standard explicitly states that it covers, but is not limited to, the following activities involving asbestos: demolition, removal, alteration, repair, maintenance, installation, clean-up, transportation, disposal, and storage. It has been redesignated 29 CFR 1926.1101.

Q.	If construction activities are performed in a facility normally covered by the General Industry standard, which standard applies?
A.	Asbestos work which involves removal, repair, maintenance or demolition is explicitly regulated by the Construction standard even if such work is performed within a facility otherwise regulated under the General Industry standard.
Q.	Does the standard apply during earthmoving projects, drilling, blasting or sawing where natural deposits of asbestos occur?
A.	The record indicates that certain construction sites in mostly well-defined areas contain deposits of naturally occurring asbestos. In such cases, wetting of the excavation site, often required by local authorities, should be sufficient to suppress measurable airborne asbestos concentrations. No other actions are required by the standard.
Q.	In the above case is the employer required to take any action if there is no information readily available indicating asbestos contamination of the soil?
A.	In the absence of actual knowledge or information showing asbestos contamination of soil in the immediate vicinity of a construction site, the employer is not required to take any action under this standard.

Summary of the EPA Asbestos Training Course

The EPA Model Accreditation Plan for asbestos worker training is based on the following specific occupations that have some level of asbestos involvement and exposures.

Asbestos Abatement Workers

A four day training course that includes:

1. At least 14 hours of hands-on training that provides asbestos workers with actual experience performing tasks associated with asbestos abatement work.
2. Topics for the course are to include the physical characteristics of asbestos, potential health effects related to asbestos exposure, employee personal protective equipment, work practices, personal hygiene, medical monitoring, air monitoring, relevant state, local, and federal standards, respiratory protection programs and medical monitoring programs, additional safety hazards on asbestos abatement projects.
3. Course review, and an examination (50 multiple choice questions with 70 percent correct).
4. Individual respirator fit-testing.
5. The EPA training course requirements are found on pages 5252 and 5253 of the February 3, 1994 Federal Register.

An annual refresher training session is required which is to be one full day. The refresher courses are to be conducted as separate and distinct courses, not to be combined with any other training during the period of the refresher course. The refresher course shall review and discuss changes in regulations, developments in state-of-the-art procedures, and a review of key aspects of the initial training course. A recertification examination is at the option of the state.

Awareness Training for Maintenance and Custodial Workers

This training is detailed in 40 CFR 763.92(a)(1). EPA specifies that the training is to be two hours in length and must include, but not be limited to:

1. Information regarding asbestos and its various uses and forms.
2. Information on the health effects associated with asbestos exposure.
3. Locations of asbestos-containing building material identified throughout each school building in which the employee works.
4. Recognition of damage, deterioration, and delamination of asbestos containing building material.
5. Name and telephone number of the person designated to carry out general local education agency responsibilities under 40 CFR 763.84 and the availability and location of the management plan.

EPA does not specify refresher training for this category.

Operations and Maintenance Training Course

The training required by EPA for this course is detailed in sections 40 CFR 763.92(a)(1) and 763.92(a)(2). This course is to be a total of 16 hours, which is two hours for the awareness level portion and 14 hours for the additional training required for operations and maintenance personnel.

The training has to include the same requirements for awareness training, as well as the following additional requirements:

1. Descriptions of the proper methods of handling asbestos containing building material.
2. Information on the use of respiratory protection and other personal protective measures.
3. The provisions of 40 CFR 763.92 and 40 CFR 763.91, Appendices A, B, C, D, EPA regulations contained in 40 CFR Part 763, subpart G, and in 40 CFR Part 61, subpart M, and OSHA regulations contained in 29 CFR 1926.58.
4. Hands-on training in the use of respiratory protection, other personal protective measures, and good work practices.
   
   

Comprehensive Course for Supervisors

The five day training course for supervisors includes:

1. Lectures and demonstrations on the physical characteristics of asbestos and asbestos-containing materials, potential health effects related to asbestos exposure, employee personal protective equipment, work practices, personal hygiene, medical monitoring, air monitoring, relevant state, local, and federal standards, respiratory protection programs and medical monitoring programs, insurance and liability issues, recordkeeping for asbestos abatement projects, supervisory techniques for asbestos abatement activities, and contract specifications.
2. Fourteen hours of hands-on training must permit asbestos workers actual experience in performing tasks associated with asbestos abatement.
3. Individual respirator fit-testing.
4. Course review.
5. Written examination (100 multiple course questions with a passing score of 70 percent).

One full day of refresher training. The refresher courses are to be conducted as separate and distinct courses and not combined with any other training during the period of the refresher course. The refresher course reviews and discusses changes in regulations, developments in state-of-the-art procedures, and reviews key aspects of the initial training course. A recertification examination is at the option of the state.

Recordkeeping | Workplace Hazards

Each employer having exposed employees is responsible for keeping accurate records of all measurements taken to monitor employee exposure to asbestos. These documents must be kept for 30 years and include the following information:

• Date of measurement, operation involving exposure, sampling and analytical methods used, and evidence of their accuracy;
• Number, duration, and results of samples taken;
• Type of respiratory protective devices worn;
• Name, social security number, and the results of all employee exposure measurements.
  
  

Medical Surveillance Records

It is essential to keep an accurate record for each employee subject to medical surveillance. OSHA requires that medical surveillance records include:

• Name and social security number of the employee;
• Physician's written opinions;
• Any employee medical complaints related to exposure to asbestos; and
• Additional information provided to the examining physician.

Medical surveillance records have to be retained for the duration of employment plus 30 years.

Other Records

According to the requirements of the asbestos standard, the employer has to maintain all employee training records for one year beyond the last date of employment by that employee.

Records must be made available to the OSHA, NIOSH, affected employees, former employees, and designated representatives. When the employer ceases to do business and there is no successor to receive the records for the prescribed period, the employer must notify the Director of NIOSH at least 90 days prior to disposal of records.

Note: The employer may utilize the services of competent organizations such as industry trade associations and employee associations to maintain the records required by this section.

Medical Surveillance | Asbestos

A medical surveillance program has to be developed for all employees who are exposed to airborne concentrations of asbestos at or above the action level. All examinations must be performed under the supervision of a licensed physician at no cost to the employee and at a reasonable time and place.

Pre-Placement Physical Examination

Before an employee is assigned to a job with airborne concentration exposures of asbestos fibers at or above the TWA and/or excursion limit, a pre-placement medical examination must be provided or made available by the employer. Examinations will include a complete physical examination with emphasis on the:

• Respiratory system,
• Cardiovascular system,
• Digestive tract,
• Chest X-ray; and
• Pulmonary function test.

Each employee also has to complete a respiratory disease questionnaire.

These examinations must be made available annually following the employee's first exposure to asbestos. If the employee is terminated, he or she must be examined within 30 days before or after the date of termination. The employer must give the examining physician a copy of the standard and appendices; a description of the employee's duties relating to the employee's asbestos exposure; the exposure level or anticipated exposure level; a description of any personal protective and respiratory equipment used or to be used; and information from previous medical examinations.

Physician's Opinion

The employer is further responsible to get a written, signed opinion from the physician which contains:

• The results of the medical examination and the physician's opinion as to whether the employee has any detected medical conditions that would place the employee at an increased risk from exposure to asbestos;
• Any recommended limitations on the employee or upon the use of personal protective equipment such as clothing or respirators;
• A statement that the employee has been informed by the physician of the increased risk of lung cancer attributable to the combined effect of smoking and asbestos exposure; and
• A statement that the employee has been informed by the physician of the results of the medical examination.

The physician is not to reveal in the written opinion given to the employer specific findings or diagnoses unrelated to occupational exposure to asbestos. The employer must provide a copy of the physician's written opinion to the affected employee within 30 days after its receipt.

Information,Training & Communicating Hazards to Employees | ASBESTOS

Communicating Hazards to Employees

Employers and building owners are required to treat installed thermal system insulation (TSI) and sprayed on and troweled-on surfacing materials as asbestos containing material (ACM). Treat asphalt and vinyl flooring material installed no later than 1980 as asbestos-containing.

Employers and building and facility owners must exercise due diligence in complying with requirements to inform employers and employees about the presence and location of ACM and presumed asbestos containing material (PACM).

Building Owner Responsibilities

Building and facility owners have to maintain records of all information required concerning the presence, location and quantity of ACM and PACM in the building/facility. Such records need to be kept for the duration of ownership and must be transferred to successive owners.

Building and facility owners have to inform employers of employees with potential exposure risks. Those employers must inform their employees who will perform housekeeping activities in areas which contain ACM and/or PACM of the presence and location of ACM and PACM in these areas. Identification of ACM and PACM should be made by industrial hygienists, or by persons whose skill and experience in identifying asbestos hazards is the equivalent to that of industrial hygienists.

Information and Training

All employees who are exposed to airborne concentrations of asbestos at or above the action level must be properly trained about asbestos hazards. Training has to be provided prior to or at the time of initial assignment, and at least yearly thereafter.

Training Program Elements

An effective training program must provide employees with information about the health hazards of asbestos exposures and include the following elements:

• Relationship between asbestos and smoking in producing lung cancer;
• Operations which could result in asbestos exposure;
• Engineering controls and appropriate work practices associated with the employee's job assignment;
• Purpose, proper use, and limitations of respirators and protective clothing;
• Medical surveillance program;
• Emergency and clean-up procedures;
• Names, addresses, and phone numbers of public health organizations which provide information, materials, and/or conduct programs concerning smoking cessation; and
• A review of the procedures contained in OSHA's asbestos standard at §1910.1001.

All training materials must be available to the employee without cost and, upon request, to OSHA and NIOSH representatives.

Personal Protective Equipment

Respiratory protection

Exposed employees have to wear respirators:

1. While feasible engineering and work practice controls are being installed or implemented;
   
   
2. During maintenance and repair activities or other activities where engineering and work practice controls are not feasible;
   
   
3. If feasible engineering and work practice controls are insufficient to reduce employee exposure; and
   
   
4. In emergencies.

See the PERSONAL PROTECTIVE EQUIPMENT for guidance in developing a respirator program.

Employees who use an air purifying respirator must change filters whenever an increase in breathing resistance is detected. Employees who wear respirators must be allowed to wash their face and respirator face-piece whenever necessary to prevent skin irritation associated with respirator use. An employee must not be assigned to tasks requiring the use of respirators if a physician determines that the employee is unable to function normally wearing a respirator or that the employee’s safety and health or that of others would be affected by the employee’s use of a respirator.

In this case, the employer must assign the employee to another job or give the employee the opportunity to transfer to a different job which does not require the use of a respirator. The job must be with the same employer, in the same geographical area, and with the same seniority, status, and rate of pay, if such a position is available.

The employer must assure that a respirator issued to an employee fits properly and exhibits minimum face-piece leakage. Following a medical evaluation, each employee who will wear a respirator on the job must have a quantitative or qualitative fit test. This has to be done at the time of initial fitting and at least every six months for each employee wearing a negative pressure respirator.

Protective clothing

For any employee exposed to airborne concentrations of asbestos that exceed the PEL, protective clothing must be provided and required to be worn. The clothing may include coveralls or similar full-body clothing, head coverings, gloves, and foot coverings. Wherever the possibility of eye irritation exists, face shields, vented goggles, or other appropriate protective equipment must be provided and worn.

Asbestos-contaminated work clothing has to be removed in change rooms and placed and stored in closed containers which prevent dispersion of asbestos into the ambient environment. Protective clothing and equipment must be cleaned, laundered, repaired or replaced to maintain its effectiveness. The employer must inform any person who launders or cleans asbestos contaminated clothing or equipment of the potentially harmful effects of exposure to asbestos. Contaminated clothing and equipment needs to be transported in sealed impermeable bags or other closed impermeable containers and appropriately labeled.

Engineering and Work Practice Controls | Asbestos

To help reduce worker exposure to airborne fibers, asbestos must be handled, mixed, applied, removed, cut, scored or otherwise worked in a wet state. This “wet” method must also be used when products containing asbestos are removed from bags, cartons, or containers. If this is not possible, removal must be done in an enclosed or well ventilated area.

Asbestos containing materials must not be applied by spray methods. Compressed air can be used to remove asbestos or asbestos containing materials only if the compressed air is used in conjunction with an enclosed ventilated system designed to capture the dust cloud created by the compressed air.

To the extent feasible, engineering and work practice controls need to be used to reduce employee exposure to within the PEL. Respirators may be used where engineering controls have been instituted but are insufficient to reduce exposure to the required level. It is the employer’s responsibility to implement a written program to reduce employee exposure to or below the PEL by means of engineering and work practice controls and by the use of respirators.

Written plans must be reviewed and updated as necessary to reflect significant changes in the asbestos program. Employee rotation cannot be used as a means of compliance with the permissible exposure limit.

Asbestos Monitoring & Regulated Areas

Asbestos Monitoring

OSHA requires employers to perform initial monitoring for each job classification to determine the airborne concentrations of asbestos to which employees may be exposed. If exposures exceed the TWA permissible exposure limit and/or excursion limit, periodic monitoring must be conducted at intervals no greater than every six months.

If either initial or periodic monitoring indicates that employee exposures are below the TWA permissible exposure limit and/or excursion limit, monitoring can be stopped for those employees whose exposures are represented by such monitoring. The employer must initiate monitoring whenever there has been a change in the production, process, control equipment, personnel or work practices that may result in new or additional exposures to asbestos. 

Monitoring should also occur when the employer has any reason to suspect that a change may result in new or additional exposures above the PEL. Employees must be notified of the results of asbestos monitoring, in writing, either individually or by a posted notice, within 15 working days after receiving the test results.

Regulated Areas

Covered employers have to establish a regulated area(s) where airborne concentrations of asbestos exceed the permissible exposure limit (PEL). Only authorized personnel may be allowed enter regulated areas and they must use respirators. No smoking, eating, drinking, chewing tobacco or gum, or applying cosmetics is permitted in regulated areas. Warning signs have to be displayed at each regulated area and must be posted at all approaches to regulated areas.

Employers must ensure that employees working in and around regulated areas comprehend the warning signs. Methods to ensure employee comprehension may include the use of languages other than English, pictographs, and graphics. These signs must contain the following information:

Warning labels have to be placed on all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers. The label must include the following information:

Asbestos

Introduction

“Asbestos” is a generic name given to a fibrous variety of six naturally occurring minerals that have been used for decades in the development of thousands of commercial products. The term “asbestos” is not a mineralogical definition but a commercial name given to a group of minerals that possess high tensile strength, flexibility, resistance to chemical and thermal degradation, and electrical resistance. These minerals have been used in many products, including insulation and fireproofing materials, automotive brakes and textile products, and cement and wallboard materials.

The asbestos minerals have a tendency to separate into microscopic-size particles that can remain in the air and are easily inhaled. These fibers can become embedded in the tissues of the lung and digestive system. Once the fibers become trapped in the lung’s alveoli (air sacs), they cannot be removed. Persons occupationally exposed to asbestos have developed several types of life-threatening diseases, including lung cancer. Although the use of asbestos and asbestos products has dramatically decreased, they are still found in many residential and commercial settings and continue to pose a health risk to workers and others.

Asbestos workers have increased chances of getting two principal types of cancer:

• Cancer of the lung tissue itself, and
  
  
• Mesothelioma, a cancer of the thin membrane that surrounds the lung and other internal organs.

Other diseases related to asbestos exposure are asbestosis, an emphysema-like condition; and gastrointestinal cancer which is caused by ingesting asbestos-contaminated food. These diseases do not develop immediately following exposure to asbestos, but appear only after a number of years.

Summary of OSHA’s requirements for asbestos exposure among workers in general industry and describes the steps an employer must take to reduce the levels of asbestos, tremolite, anthophyllite, actinolite, or a combination of these minerals in the workplace.

This is followed by selected excerpts from the OSHA compliance directive for asbestos, CPL 2-2.63. It is a document developed to establish policies for OSHA enforcement of the asbestos standard, but it can be very helpful to know how the standard is being enforced.