Veterinary Compliance Assistance

Asbestos

Overview
What is asbestos?
Where is asbestos found?
Regulations
More Resources
About NESHAP
Asbestos Worker Protection Resources
Other Useful Resources

 

Overview

Asbestos is a mineral-based substance commonly found in older building materials (most buildings constructed before 1973 have some asbestos-containing materials), such as pipe insulation, although it can also be found in some new building materials (2,400 tons of asbestos were imported into the US during the year 2005 – 30% for roofing materials, 30% for coatings and compounds, 40% for other applications).

Working with asbestos can pose significant health hazards, especially when asbestos-containing materials are exposed during routine facility maintenance, or during renovation and demolition projects.  If inhaled, asbestos accumulates in the lungs, creating scar tissue.  This condition not only makes it more difficult to breathe – it can also lead to a type of lung cancer called mesothelioma, which is almost always fatal by the time it is diagnosed.  Recent research has also linked asbestos to certain gastro-intestinal cancers. Therefore, asbestos is extensively regulated and its removal must be performed by licensed and trained professionals.

What is asbestos?

"Asbestos" is not a single, specific material – it is the name given to a group of naturally occurring minerals.  The following are varieties of commercial asbestos, meaning they are used in commercial products or are asbestos contaminants found in commercial-grade asbestos:

  • Chrysotile
  • Amosite
  • Crocidolite
  • Tremolite asbestos
  • Anthophyllite asbestos
  • Actinolite asbestos
  • Other "asbestiform" minerals, including winchite, richterite, edenite, and erionite.

Typically, asbestos appears as a whitish, fibrous material which may release fibers that range in texture from coarse to silky.  Note that you can't always rely on visual cues to tell you whether you are at risk – airborne fibers that can cause health damage may be too small to see with the naked eye.

Where is asbestos found?

Asbestos is commonly found in old buildings, including hospitals built in the 1940's to 1973 (even some new building materials contain asbestos –- the best way to determine if a building contains asbestos is to have it inspected by a licensed and trained asbestos building inspector).  In 2006, New York City officials reported that a survey of city-administered hospitals turned up asbestos problems at 10 of their 15 facilities (more).

Veterinary maintenance workers and engineers can be unknowingly exposed to asbestos from many possible areas and sources. Engineers can be exposed while working in furnace rooms where boilers are insulated with asbestos, or when making repairs to old piping or doing minor renovations.  Significant asbestos exposures can occur when insulation in buildings is removed during renovations.  Asbestos is used in making building materials because high tensile strength, flexibility (woven), resistance to chemical and thermal degradation, and high electrical resistance. of its high tensile strength, flexibility (woven), resistance to chemical and thermal degradation, and high electrical resistance. The most common sources of asbestos in veterinary facilities include:

  • Pipe insulation
  • Building materials (siding, wall board or spackling compounds, floor tile, ceiling tile)
  • HVAC duct insulation
  • Boiler insulation
  • Cooling towers
  • Electrical wiring insulation

Pipe insulation (i.e., "pipe wrap") is a very common building material found insulating boilers and pipes in most commercial and industrial buildings as well as many residential structures. It is highly friable (can be reduced to powder by hand pressure), indicating that asbestos fibers are readily dispersed from the material when it is disturbed. There are many other building materials containing asbestos, and which may release asbestos if disturbed or if impacted by renovations. These include transite siding, asbestos cement, vinyl asbestos floor tile, paints and coatings, roofing materials, vermiculite insulation, carpet mastics and glues, popcorn ceiling textural coatings, and others.

Workers may intentionally expose and disturb building materials while unaware that these materials contain asbestos. In such cases, personal protective equipment that is effective against worker asbestos exposure is rarely in place for the workers, much less for other building occupants (who may be unknowingly exposed to asbestos fibers through the central air handling and ductwork system.

Asbestos removal can be a costly undertaking because of the precautions that must be implemented and the ultimate cost it is often tricky to project.  For example, in 2005, at Evansville State Hospital, asbestos removal following the demolition of a number of old buildings cost over five and a half million dollars; more than double what officials originally expected.

Regulations

There are two primary sets of rules.  One set, developed and administered by the Environmental Protection Agency (EPA), was designed to protect the general public.  The other, by the Occupational Safety and Health Administration (OSHA), is directed toward protecting workers.

  • The EPA rules were established under the authority of the Clean Air Act (CAA). These rules are referred to as the Asbestos NESHAP (National Emissions Standards for Hazardous Air Pollutants). They cover work practices to be followed during demolition and renovation and other activities involving the processing, handling, and disposal of asbestos-containing material.
  • The OSHA rules establish strict worker exposure limits and set out requirements for employers regarding exposure assessment, medical surveillance, recordkeeping, and hazard communication.

The EPA rules under the Asbestos Hazard Emergency Response Act expands health and safety standards to state and local government employees (see 40 CFR Part 763). OSHA rules cover private sector workers.

In addition to EPA and OSHA rules, the Department of Transportation regulates the transportation of asbestos-containing waste material (requires waste containment and shipping papers).

It is important to note that state and local rules may establish stricter and more diverse requirements well beyond what are required at the Federal level.

More Resources

EPA and OSHA asbestos regulations have been in place for some time, and a lot of useful compliance assistance resources have been developed. In order to help you find those items which are likely to be most useful to you, this section presents a selection of the resources that VetCA considers the best and most relevant to the veterinary industry.

Please note that the information presented below applies only to federal regulations.  State (and sometimes local) asbestos regulations are often more stringent and far reaching than the federal regulations. Therefore, you should also use the Asbestos State Regulation Locator to learn about the rules in your state.

Asbestos NESHAP

  • Demolition Practices Under the Asbestos NESHAP. A plain language summary of the Asbestos NESHAP covering pre-demolition activities, demolition practices by type of ACM and by method, waste handling, and disposal practices.
  • Common Questions on the Asbestos NESHAP.  A web page that covers questions raised in recent years by demolition and renovation contractors . Most relate to how a demolition or renovation contractor or building owner can best comply with the regulation. The responses assume that the questioner has a basic understanding of the Asbestos NESHAP and demolition and renovation practices. A brief glossary of terms is also included at the bottom of the web page.
  • Asbestos NESHAP Adequately Wet Guidance.  The Asbestos NESHAP requires friable asbestos containing material (ACM) to be "adequately wet".  The purpose of this web page is to provide guidance to asbestos inspectors and the regulated community on how to determine if work practices are meeting the requirement.

Asbestos Worker Protection Resources

  • OSHA's Hospital eTool – Asbestos Exposure.  A useful overview of the issues and possible solutions.
  • Self-Inspection Checklist: Asbestos. OSHA. Use this checklist to determine compliance to the asbestos standard.
  • Asbestos Worker Protection; EPA's Final Rule, 40 CFR Part 763.  In this Final Rule, EPA amends both the Asbestos Worker Protection Rule (WPR) and the Asbestos-in-Schools Rule. The WPR amendment protects State and local government employees (construction work, custodial work, and automotive brake and clutch repair work) from the health risks of exposure to asbestos to the same extent as private sector workers by adopting for these employees the Asbestos Standards of the Occupational Safety and Health Administration (OSHA).
  • Asbestos Advisor (OSHA software).  The Asbestos Advisor is an interactive compliance assistance tool. Once installed on your PC, it can interview you about buildings and worksites, and the kinds of tasks workers perform there. It will produce guidance on how the Asbestos standard may apply to those buildings and that work. Its guidance depends on your answers. It can provide general guidance and may, also, be focused on a particular project.
  • VetCA Asbestos State Resource Locator.  Use this resource to locate points of contact in your state regarding asbestos regulations.

Other Useful Resources

  • EPA Asbestos Website. This is a resource where you can get more detailed information about asbestos.

 

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