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Asbestos Inspections

You can't tell if most products contain asbestos just by looking at them.

Many products look the same, whether they do or do not contain asbestos. The only way to tell for sure is to have a bulk sample collected and analyzed by an accredited laboratory. A licensed asbestos inspector carefully collects a bulk sample from a material in a controlled fashion to minimize fiber release.

Suspected Asbestos-Containing-Materials (ACM) are categorized into two classifications; Friable and Non-Friable Materials. Friable materials are materials that can be crushed or crumbled by hand pressure. A friable material is more likely to get in the air. Pipe and boiler insulation materials, sprayed-on fireproofing materials, plaster and cement surfacing materials are examples of friable materials. Non-friable materials are materials that need mechanical equipment to be crushed such as floor coverings, roofing materials, mastics and caulking materials. Non-Friable materials do not release airborne fibers unless these materials are sanded, scrapped or sand blasted, which increase the potential for fiber release.

Bulk samples that are classified as friable materials are analyzed by Polarized Light Microscopy (PLM Analysis). The New York State Department of Health has issued the following requirements regarding PLM Analysis "Polarized Light Microscopy is not consistently reliable in detecting asbestos in non-friable materials (i.e. floor tiles, roofing materials). Before these materials can be considered or treated as non-asbestos-containing, analysis must be made by quantitative Transmission Electron Microscopy (TEM analysis). All non-friable bulk material samples found to be negative for asbestos content under PLM analysis must be re-analyzed by TEM analysis.

ASBESTOS RULES AND REGULATIONS

Federal regulatory agencies governing asbestos in buildings include the US Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA).

These regulations focus on controlling asbestos in buildings, protecting the public from asbestos and regulate the protection of workers in the workplace. Specifically, there are four federal regulations governing asbestos:
EPA - Asbestos Hazard Emergency Response Act (AHERA), 40 CFR Part 763, Subpart E
EPA - National Emissions Standards for Hazardous Air Pollutants (NESHAPS), 40 CFR Part 61, Subpart M
OSHA Construction Standards, 29 CFR 1926.1101
EPA Worker Protection Rule, 40 CFR Part 763, Subpart G

In addition there are state and local regulations that include:

New York State Industrial Code Rule 56
New York City Title 15 Chapter 1
State and City regulations are most often more stringent than the EPA and OSHA Regulations.

Why inspect for Asbestos? IT'S THE LAW!

The following inserts are taken directly from federal, state and local regulations describing the requirements on when, where and who needs to perform an Asbestos Investigation;

NYC Regulations 15RCNY 1-23
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'1-23 Alteration/Renovation and Modifications "as early as possible before an alteration, renovation, or modification takes place, or changes in an alteration, renovation or modification occur, the building owner shall be responsible for determining the absence or presence of friable asbestos-containing material which will be disturbed during the course of the alteration, renovation or modification activities. The owner of the building or the authorized agent shall comply with the notification requirements of this section regarding friable asbestos-containing material."

NYS Regulations NYS DOL ICR 56-5.1
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'56-5.1 Asbestos Survey Requirements for Building/Structure Demolition, Renovation, Remodeling and Repair "an owner or an owner=s agent, except the owner of one and two-family dwellings who contracts for, but does not direct or control the work, shall cause to be conducted, an asbestos survey completed by a licensed asbestos contractor using inspectors certified in compliance with Section 56-3.2(d), to determine whether or not the building or structure, or portion(s) thereof to be demolished, renovated, remodeled, or have repair work, contains ACM, PACM or asbestos material. This asbestos survey shall be completed and submitted as indicated in Subdivision (g) of this Section, prior to commencing work. All such asbestos surveys shall be conducted in conformance with the requirements of Subdivision (e) of this Section."

US EPA Regulations 40 CFR 61.145
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'61.145 Standard for demolition and renovation.
to determine which requirements of paragraphs (a), (b), and 8) of this section apply to the owner or operator of a demolition or renovation activity and prior to the commencement of the demolition or renovation, thoroughly inspect the affected facility or part of the facility where the demolition or renovation operation will occur for the presence of asbestos, including Category I and Category II nonfriable ACM. The requirements of paragraphs (b) and 8) of this section apply to each owner or operator of a demolition or renovation activity,including the removal of RACM.

US EPA Regulations 40 CFR Part 763
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'763.80 Scope and purpose.
this rule requires local education agencies to identify friable and nonfriable asbestos-containing material (ACM) in public and private elementary and secondary schools by visually inspecting school buildings for such materials, sampling such materials if they are not assumed to be ACM, and having samples analyzed by appropriate techniques referred to in this rule.

OSHA Regulations 29 CFR 1926.1101
'1926.1101 (k) (1) Communication of hazards.
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this section applies to the communication of information concerning asbestos hazards in construction activities to facilitate compliance with this standard. Most asbestos-related construction activities involve previously installed building materials. Building owners often are the only and/or best sources of information concerning them. Therefore, they, along with employers of potentially exposed employees, are assigned specific information conveying and retention duties under this section. Installed Asbestos Containing Building Material. Employers and building owners shall identify TSI and sprayed or troweled on surfacing materials in buildings as asbestos-containing, unless they determine in compliance with paragraph (k)(5) of this section that the material is not asbestos-containing. Asphalt and vinyl flooring material installed no later than 1980 must also be considered as asbestos containing unless the employer, pursuant to paragraph (g)(8)(i)(I) of this section determines that it is not asbestos-containing. If the employer/building owner has actual knowledge, or should have known through the exercise of due diligence, that other materials are asbestos-containing, they too must be treated as such. When communicating information to employees pursuant to this standard, owners and employers shall identify "PACM" as ACM. Additional requirements relating to communication of asbestos work on multi-employer worksites are set out in paragraph (d) of this section."

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