Document 2Rz8Np94aEgaRq7BJzavB0QB6

U), Wc&M-j Ain Ind ll>g J 4'(jt).4V?*5ll4 | Ij Non-Occupational Exposure to Asbestos in Buildings: A Practical Risk Management Program JEFFREY MARK l'U I I. MORION CORN. I'L HR N I I I IN jnd I'A I RICK V BREYSSl Department ol Environmental Health Sciences. School ol Hygiene and Public Health. I he Johns Hopkins l niversity. PI5 V Wolle Stieel. Baltimore. Ml) :i205 Current federal regulations do not address non-occupational exposure to asbestos. In the absence of such regulations, if asbestos-containing materials are present in a building, it is advisable to develop a management program to ensure that the inhalation risk to building occupants does not increase with time and that appropriate steps are taken during activities which have the potential to release asbestos fibers to air. When numerous areas of a building contain asbestos, priorities must be established for selecting and implementing appropriate surveillance or interventions for control. We present a framework for implementing an Asbestos Risk Management Program, the primary objective of which is to minimize the risk of employee and public exposure to asbestos in air. The program includes a decision framework fur evaluating and ranking building areas according to the asbestos fiber release potential, and assigns priorities for control interventions. Another decision framework is presented for selecting an air monitoring strategy and for making appropriate decisions based upon measured airborne fiber concentrations. Procedures are included for minimizing employee exposure, operating a maintenance permit system and maintaining an episode response plan. Procedures for employee education and training, medical surveillance programs, asbestos monitoring and record keeping also are presented. Introduction The Environmental Protection Agency <EPA) has estimated that approximately 733.000(20</() of all government, residen tial, and private nonresidential buildings in the U.S. contain some type of friable asbestos-containing material -- sprayedon or troweled-on material or pipe or boiler insulation."1 Although EPA regulations restrict the use of asbestos in new buildings, specify work practices during removal ofasbes tos from existing buildings and require the identification of asbestos in schools.'* *' regulations have not been promulgated by the federal government regarding asbestos exposure in non-occupational environments. Several states, including Rhode Island. Maryland. New Jersey and Massachusetts, have adopted a "clearance" standard of eitherO.OI fiber cc orO.I fiber cc for airborne fiber concentrations in buildings following asbestos removal.* For the occupational environment, the Occupational Safety and Health Administration (OSHA) specifies stan dards for worker exposure to asbestos."'The application of these standards to non-occupational environments is inap propriate for several reasons, including the following: 3) The measurement technique for analysis of airborne asbestos fibers specified by the OSHA standard can not distinguish between asbestos and non-asbestos fibers. This situation has engendered uncertainty on the part ol building managers regarding those circumstances when asbestos-containing materials should be of concern to build ing occupants, and how to manage any risk they may pose. The purpose of this paper is to present a set of operational guidelines lor the management of health risk in buildings and other indoor environments where non-occupational exposure to asbestos may occur. The concentration ol asbestos in the air ol buildings varies with the nature of the application of the asbestos-containing material, its condition and a host of other factors such as building activity and airflow patterns; however, within this context it is known that asbestos concentrations in nonoccupational settings are far below those ol occupational environments. 1) The current OSHA asbestos standard was designed to protect workers, not the general public: 2) The permissible exposure limit adopted as part of the standard was established to protect workers by reducing the risk of incurring asbestosis; it docs not address or consider the risks of bronchogenic cancer or mesothelioma, although reduction of exposure reduces these risks: and Non-occupational settings such as residential buildings, offices and schools containing asbestiform materials have been associated with airborne asbestos liber concentrations in the range of0.00006 to 0.004 fiber. cc(>5 jim in length). Outdoor concentrations are generally lower than indoor, with these airborne fiber concentrations in the range ol 0.00002 to 0.00075 fiber cc. Airborne asbestos concentra tion ranges and median values for outdoor, indoor, and occupational environments are summarized in Table I.1" At present, it is not possible to relate effects from exposure For example, see Rhode Island Act *6260 relating to Asbestos Abate to low- airborne concentrations of asbestos in office buildings, ment. adopted 198S. public buildings or schools directly to the manifestations Copyngnt 1996 America* industrial Myg.*ri* Association Am Ind Hyg Assoc J (47) August 1986 10003231 497 TABLE I Summary of Environmental Asbestos Exposure LevelsA Type ol Environmental Measured Concentration Exposure (ng/m') Equivalent Concentration (flbers/cc)" Range Median Range Median Outdoor. Urban Indoor, Asbestos-Containing Materials Present Occupational 0.7- 22.5 1.8- 121.5 2.1 0.00002 - 0.00075 0.00007 18.0 0.00006 - 0.004 0.0006 3 000 - 30 000' 15 000" 0.1 - 1.0 0.5" AAdapted from National Research Council. National Academy of Sciences (Ref. 6). "Based on conversion factor of 30 pg/mJ = 1 fiber/cc (> 5 *im length). 1 Highly variable and dependent on fiber size resulting from particular industrial process. "Median concentration levels for occupational exposures estimated from the average concentration range in fibers/cc. of asbestos disease associated with earlier exposures to much higher concentrations of asbestos in air in the work place. Therefore, all estimates of the possible impact of asbestos exposure in non-occupational environments, such as those of the National Research Council.15' the Occupa tional Safety and Health Administration'16' a2n3d4th5e Canadian Province of Ontario Royal Commission'7' are predicated on the assumption that the same effects, with proportionately lower incidence, will occur to those exposed to asbestos at lower concentrations in air as occurred to those exposed at higher workplace concentrations. The estimates of risk for non-occupational exposures are derived by linearly extrapo lating downward the dose, response curve derived from ear lier. high exposures of asbestos workers. Asbestos Risk Management Program Administration of the Program It is advisable to establish an effective asbestos risk man agement program in facilities where asbestos is present to assure that asbestos exposures of employees and the general public are minimized or avoided. Thccomplexitics in the development and implementation of such a program require that a qualified safety and health professional be designated to serve as the Asbestos Control Program Manager (ACPM). The responsibilities of the ACPM include the following: 1) Developing scope and funding requirements for the program; 2) Selecting appropriate technical experts and health professionals to administer the program: 3) Training and supervising control program stall and providing for education ol employees; 4) Identifying, labeling and evaluating potential asbes tos hazards; 5) Determining abatement priorities, if deemed neces sary. and implementing ingredients of a short- or long term control program; 491 6) Evaluating the alternative options of abatement or leaving in place, and selecting qualified contractors to perform abatement, if it is necessary; 7) Identifying employees to be included in a medical surveillance program: and 8) Implementing a comprehensive recordkeeping and reporting system. Effective planning and coordination of each of these activ ities by the ACPM are essential if the asbestos risk manage ment program is to be successful. Assessing the Degree ol Potential Hazard Figure 1 is a decision matrix for evaluating and prioritizing asbestos in buildings, if it is present. Determining its pres ence or absence is the first step in the decision-making proc ess. Several sequential survey activities are performed, including the determination of the following: 1) The location(s) of the asbestos: 2) The condition of the asbestos; 3) The number of persons potentially exposed to the asbestos, and 4) The concentrations of asbestos fibers in the air. A comprehensive survey of the presence of suspected asbestos-containing materials is performed first. The pres ence of asbestos, its type, and percentage content are deter mined by laboratory analysis of bulk samples of the mate rials. Then a complete inventory of all asbestos-containing materials in an area or building is prepared. Qualitative Evaluation Procedure Once the loeation(s) and amount(s) of asbestiform materials have been determined (Step I), each area containing these materials then is evaluated qualitatively with regard to the condition of the asbestos (Step 2). The number of persons potentially exposed and their duration of exposure are then determined (Step 3). These three steps provide information for estimating the fiber release potential of the asbestos and the potential exposure of building occupants to asbestos. 10003252 Am ina Hn Assoc J (47; AuguM. 1986 lorstogcncu'ca numerical index lot the potential ha/aid ol the particular building or building area. Seveial tv pcs ol hazard asse"ment algorithms have been utilized, including the Terris Index and modified Ferris Index used hv the Massachusetts Asbestos Commission and the Colorado Department n! Education, respectiveiv."'*' the El'A's Asbes tos Hazard Evaluation Algorithm""'and the l .S. Navv Asbestos Hazard Index."1' I hese algorithms contain (actors relating to the amount ol asbestos present, its current condition, the v ulnciabilitv ol the material to phvsieal damage and air movement, and the degree ol potential exposure. The (actors aie scored and combined into an ov erall index, thereby providing a mecha nism lor evaluating and comparing the potential hazard ol asbestos-containing materials in various locations within a single building, or in diflcrcnt buildings. Because several subjective factors such as material friabil ity . accessibility, and condition enter into algorithm usage, the resultant indices provide relative rather than absolute rankings of hazard potential. Judgment also should be exer cised in selecting or modifying an existing hazard algorithm or in devising a new one. in order to insure that the algorithm is capable of welding reliable results that are related to the degree of potential hazard. A wide range of highly variable results, for both untrained and trained observers, coupled with poor correlation with experts'scores, led the EPA to withdraw its Asbestos Hazard Evaluation Algorithm as an assessment tool.'1*'' and thus far. attempts have not been made to validate the other algorithms. The numerical scores derived from the use ol an appro priate asbestos assessment algorithm may be grouped into categories (low. medium, high) according to the degree ol potential hazard represented by their numerical ranking (Figure I). Despite the current unsatisfactory state-of-the-art of these algorithms, we lind them useful for orientation purposes and recommend that the Ferris or modified Ferrisand Nav v algorithms be used. Only when the rating ol a particular building or location is ranked consistently bv all three algo rithms do we gain some confidence in the qualitative appraisal. Figure 1 -- Decision matrix (or evaluation and ranking of building areas according to health hazard potential. Hazard Assessment Algorithms In order to set priorities where one must deal with multiple buildings or multiple areas in a building containing asbestos, algorithms have been utilized which combine relevant lac- Am tnd H)g Assoc J I4?i Augusl 1986 Quantitative Hazard Assessment We recommend that airborne liber concentrations be meas ured in addition to performing a qualitative asbestos hazard assessment. The results ol air monitoring serve two primary purposes. First, thev esta blish the degree oiac tual hazard present in building areas by determining the airborne concentrations of asbestos libers that arc present in the breathing zones ol employees and or the general public occupying those areas. Second, air samples obtained at this stage establish hat Agruund concentrations ol asbestos in an pnoi to unv 10003253 planned or unplanned modilication of asbestos materials, thereby providing a yardstick by which to measure such lactorsas contractor perlorma nee following asbestos remov al. Following asbestos removal, airborne asbestos concen trations should not exceed those measured before removal work began, i.e.. removal efforts should not contribute to increasing airborne asbestos fiber concentrations above background. Airborne concentrations such as 0.01 liber, cc (>5 pm in length), or 100 ng, m presently are being applied or are being considered as post-removal acceptance concen trations or "control levels" bv several slate regulatory agen cies. however. I hesc concentrations are often higher than pre-removal concentrations in most facilities (Tabic I). The classilication scheme depicted in Table II permits rankingof building ureas toestablish management program priorities, based on the ratio of background building air borne asbestos concentrations to concurrently measured ambient asbestos concentrations. The background building concentration of airborne asbes tos is evaluated using transmission electron microscopy (I EM) to analyze air samples. TEM is used because, in areas of buildings not undergoing some form of penetration of asbcstilorm materials, accurate determination ol asbestos fibers in air requires a more sensitive analytical method for air samples than the phase contrast light microscopy (PCM) method used by OSHA to analyze air samples obtained in occupational environments. Also. PCM is a non-specific method in which all fibers are counted as asbestos. This may produce misleading results in non-occupational environments. At this time I EM analysis is preferred over other electron microscopy techniques, such as scanning electron micros copy (SEM). because recommended standard procedures for TEM analysis have been developed by the EPA'^'and others.'"' An Asbestos International Association Recom mended Technical Method exists for asbestos fiber analyses by SEM. but it has not been recognized by the EPA.11'' Prioritizing Building Areas lor Asbestos Bisk Management Strategies When numerous areas ol single or multiple buildings are involved, priorities must beset lor monitoring building areas and. il necessary, lor initiating specific management pro gram ingredients. I he decision tree depicted in Figure I summarizes pre viously discussed assessment procedures and utilization of results lor setting priorities. Those areas showing evidence of badly deteriorated friable asbestos are scheduled for imme diate asbestos removal. All other areas are subject to the evaluation of hazard potential by the use of qualitative assessment algorithms. The performance of air monitoring may be prioritized on the basis of hazard assessment algo rithm results, with those areas showing the highest ranking scheduled first in the sequence for air monitoring, and the lowest ranked areas scheduled last. Air monitoring results then may be used in conjunction with asbestos hazard assessment rankings to determine a priority ranking scheme for initiating program ingredients and scheduling removal, if removal is the favored option. Building areas with the highest concentrations of asbestos in air arc scheduled for earlier interventions to reduce the airborne concentrations. If average airborne concentrations in two or more areas cannot be differentiated statistically w ithin predetermined confidence limits, they then are assigned priorities on the basis of their qualitative hazard assessment rankings. Building areas ranked cither medium or low from the qualitative asbestos hazard assessment, but hav ing an unex pectedly high classification based upon the results of air sampling, should be investigated for possible sources of fiber release. Once the source of airborne contamination has been located and corrected, the area should be re-monitored to ensure that airborne concentrations arc consistent with the low degree ol potential hazard predicted by the assessment algorithms. Short-Term Management Approach For those building areas classified as hav ing high airborne fiber concentrations (>0.01 liber cc. >5 pm. by TEM). it is necessary to institute a short-term management plan in order to achieve a significant reduction in airborne concentration, before a long-term management or removal plan is imple mented. This short-term plan includes such procedures as TABLE II Ranking Building Areas for Management Programs According to Airborne Asbestos Fiber Concentrations Priority Ranking Ratio ol Indoor Airborne Asbestos Fiber Concentration to Outdoor Fiber Concentration' Asbestos Concentration Approximate Equivalents' liber/cc ng/m Low Moderate High Less than 10 times Between 10 and 50 times Greater than 50 times 0 - 0 002 f/cc 0 002 - 0 05 f/cc ^0 05 l/cc 0-60 ng/m 60 - 300 ng/m ^300 ng/m 'A high outdoor urban asbestos concentration of 0 0002 fiber/cc is used here as a guide Actual outdoor concentrations at the site should be used Based on a conversion factor of 30 jjg/m - 1 fiber/cc ( 5 *.m in length) The con centration levels m the table represent values based upon 8-hr TWA concentrations with samples analyzed by TEM 10003254 soo Am Uni Hi, J i-i/, >i ]<rib covering and scaling damaged or exposed surfaces ol ashosliform materials. substituting appropriate cleaning methods such as the use ol HEI'A-vaeuunis. and controlling ol episodic sources ol contamination, such as removing asbestoscontaining debris Irom above suspended ceilings and ait plenums. Long-Term Management Approach One ol the primary purposes ol the Asbestos Risk Manage ment Program is to implement a satisfactory long-term management approach lor controlling exposure to the asbestos which is retained in a building. The management program must encompass all asbestos-containing material, including that w hich is in good condition, not damaged and not likely to be disturbed. Where large areas ol asbesliform materials are relatively intact but contain small areas ol deteriorated friable mate rial. removal or repair of these affected sections is usually advisable. Removal ol entire installations arc not triggered, pro lorma. by small subsections ol unacceptable asbestos I ire-proofing, insulation, coated ceiling or other applications. If the material is in otherwise good condition and unlikely to be disturbed and if airborne fiber concentrations arc in the low category (see Table II). a special operations, main tenance. and periodic rcinspcction program can be selected as the long-term management strategy. Deferment of removal for these "low- priority" installa tions is an attractive option. This option has the advantage ol avoiding the expense, disruption and possible building contamination associated with removal. As the asbestos removal industry matures, removal projects probably will improve in general quality. If the deferral option is selected, a sound and thorough ongoing management program must be instituted, including: discussed. Detailed implementation plans are presented elsew here..... Minimizing Access.and Exposure All building maintenance, custodial, and service personnel should be informed of the known locations of asbestoscontaining materials and instructed to report areas contain ing damaged insulation or suspected asbestos-containing friable materials to the ACPM. These personnel should be included in a (raining and education program which, among other topics, addresses safe work practices which minimize exposure to asbestos. In addition, precautionary signs should be posted at entrances to areas which have damaged exposed friable materials until such time as these materials can be covered or repaired. Warning labels should be affixed to asbestos-containing materials until removal takes place in order to prevent accidental disruption. Labels should be of the type specified by OSHA. Permit System A permitting si stem should be instituted as part of the risk management program. Permits contain such information as building location, presence of asbestilorm materials, dcscription of the work to be performed, and nature of the control methods to be employed to control access and limit accidental disruption ol asbestos-containing materials. Hor purposes of the permitting procedure, all maintenance, ren ovation and repair work is classified as cither major or minor Taking measures to minimize access to material: Operating a permit system to prevent the accidental penetration of asbestos-containing materials during building maintenance and renovation and ensuring that those permitted utilize appropriate work practices: Maintaining an episode response plan: Providing for instruction and training of employees who must have access to the material: Providing a medical surveillance program lor those employees exposed to "significant" concentrations of airborne asbestos (at or above 0.1 fiber/cc > 5 jim, TWA. by PCM); Implementing a continuing environmental monitor ing and surveillance program: Implementing procedures to prevent overexposure of personnel during small asbestos removal activities; and Maintaining a comprehensive recordkeeping and reporting system. These specific program elements will now be briefly Am Ind Hyg Aaoc J (4?) August 1986 Figure 2 -- Decision matrix for selecting an appropriate air monitoring and intervention strategy according to hazard potential resulting from material disturbance. 10003295 SOI by the AC'PM. Minor work includes such activities as rou tine maintenance performed above a suspended ceiling, while major work includes such activities as asbestos remov al or major renovation. Minor renovations arc distinguished from major renova tions in that they do not involve penetration or disruption of intact asbestos-containing materials, they present only a minimal potential for causing significant fiber release, and air monitoring generally is not performed. Minor work procedures involve work practices which are least likely to cause fiber release or to disturb settled dust containing asbestos, and may include the welting of surfaces, the use of containment bags, and vacuuming, using HEPAcquipped filtration. Major renovations require more elaborate control tech niques, similar to those used for an asbestos removal project, and air monitoring is required. Episode Response Plan If episodic asbestos contamination occurs in a building (e.g.. friable material distributed above a suspended ceiling is released into an occupied area), monitoring should be conducted immediately to evaluate the airborne concentra tion of asbestos fibers. Whereverair sampling results exceed a control level of 0.01 fiber, cc by PCM analysis or there is visible asbestos contamination of work surfaces, the ACPM should arrangeto relocate personnel from thcalfected areas. I hc ACPM also should control access to all contaminated areas, post warning signs at all entrances, and inform employees in writing ol any exposure to asbestos above 0.1 liber, ccfsee Medical Surveillance Program). Prior to decontamination of the area, airlocks should be constructed at all entrances and exits, and the ventilation system to the area should be shut down and scaled off to prevent contamination ol other building areas. All contaminated surfaces (including desks, chairs, shelves, books and equipment) should be cleaned thoroughly by HEP A vacuuming of all visible material, followed by wet wiping. If a carpet can be seen to be contaminated, sequen tial vacuuming followed by "aggrcssive"air sampling should be performed until significant airborne concentrations of asbestos fiber (0.01 fiber, cc. >5 pm. by TEM) are not detected at breathing height. Air sampling of contaminated areas should be conducted under conditions w hich simulate periods ol high activity in the affected areas. Employee Education and Training Program Employee education and training are essential components ol an asbestos control management program. Several levels ol training should be incorporated into the overall program. Level I ol the training program should be ollered to all employees w ho are assigned to work in buildings undergoing long-term asbestos management. It piovides awareness homing to those needing general orientation to the nature ol the potential asbestos problem. I raining locuses on the uses and applications ol asbestos materials in the particulai ladl in'. the steps employees can lake to minimize then evposuic sot to asbestos and Ihc ways they can reduce asbestos-exposure inside and outside the building. Level 2 training is for those who pcrlorm maintenance and repair work in buildings in which there is potential lor asbestos exposure. This group would include personnel, such as maintenance employees, custodial stall, carpenters, elec tricians. plumbers, and other service personnel, such as out side contractors and utility service personnel. In addition to Level I training, they would be instructed on the practicali ties of performing maintenance on asbestos-containing materials. These employees should be given training and instruction in the use of wet-cleaning methods and special equipment such as HEPA filtered vacuums. They should be cautioned about removing suspended ceiling panels, installing lighting or plumbing fixtures, repairing air handling systems or. in general, engaging in any activity that might damageasbestoscontaining materials and release fibers. Instruction and training also should address proper use of protective equip ment and respirators, personal hygiene techniques, the use ol maintenance permits, reporting procedures, and com pliance with relevant regulations. Annua) retraining is recommended. Level 3 training is designed for management personnel who have responsibility for overseeing the health and safety ol employees under their supervision or asbestos work tak ing place in their facilities. It includes the equivalent of both Levels I and 2 training, in addition to instruction on the policies and procedures adopted by management for con trolling asbestos-related hazards. Medical Surveillance Program I hc current OSHA asbestos standard requires medical sur veillance for employees exposed to "airborne concentrations of asbestos." which has been interpreted by OSHA as representing concentrations in excess ofO.I fiber cc. Here OSHA assumes that exposure measured on a single day is representative of exposures at other limes, although this is seldom the case lor non-occupaiional exposures. In instances where significant exposure to airborne asbes tos fibers has taken place, affected individuals should be informed of their exposure and advised of their option to obtain the services of a licensed physician specializing in occupational medicine. Wc recommend that the option for inclusion in a medical surveillance program should be offered to all employees exposed to asbestos concentrations at or above 0.1 fiber, cc. 8-hr TW A on at least two or more days during any one year period. The major objective ol medical surveillance is to insure proper-management of individuals who may show evidence ol reaction to past exposure to asbestos. Medical manage ment may range from recommendations lor job placement, improved work practices and personal hygiene habits (such as cessation ol smoking) to spccilic therapy for asbestosrelated disease or its complications. A board-certtlied occu pational health physician should establish the medieal sur veillance protocol and the frequency ol any recommended clinical tests. 10003256 Am mo zljjoc j /J// -ut.i i I^bo Periodic Monitoring and Surveillance In those buildings where asbestos removal is not under taken. management has a responsibility to determine, on an ongoing basis, that asbestos exposure in the building does not change. Thcrclorc. one year after background monitor ing is performed, certain facilities will be triggered into a surveillance mode. Building vibration, damage to materials from accidental or mechanical contact, and aging of materials may alter the liber-release potential of asbestiform materials. It is there fore necessary to repeat air sampling annually in all building areas having cither a high or medium ranking from qualita tive hazard assessment to determine if airborne concentra tions of asbestos have changed. Low-ranked building areas should be re-evaluated qualitatively on an annual basis. They do not require annual air sampling unless their hazard ranking is raised to a higher category. Of course, ongoing visual surveillance will occur in all facilities. If repeated results of annual sampling indicate that airborne asbestos concentrations arc not changing, the sampling frequency may be reduced to a bi- or tri-annual basis. Asbestos Abatement Monitoring Procedures Intervention options to reduce building average asbestos concentrations are encapsulation, enclosure or removal. Encapsulation, while involving a somewhat lower initial cost, necessitates an ongoing control program because dam age to the asbestos matrix still can occur if theencapsulant is penetrated or water damaged. Prior to the start of an inter vention. the ACPM should establish criteria for determining successful project completion. During asbestos removal, a strict set of operating proce dures must be followed to restrict any fiber release to the immediate sealed-off work area. These operating proce dures.cited indetailelsewhere."' 191 include the construction and maintenance of containment barriersand decontamina tion enclosures, the posting of warning signs, the appro priate use of protective equipment, the use of HEPAfiltration equipment and ventilation units, wet-removal methods and the proper disposal of asbestos-contaminated wastes. The purpose of air monitoring during abatement projects is to detect asbestos contamination outside the perimeter of the enclosed work area in order to implement immediate, effective interventions to control the sources) of contamina tion. Perimeter sampling during major renovations is most useful when same-day analysis of samples is performed. In this way, corrective actions may be taken to prevent the spread of fiber release from the work area as soon as possi ble. For this reason and because airborne fiber concentra tions during a contamination ``event*' will exceed ambient levels. PCM is the analytical method of choice for analysis of perimeter air samples. Figure 2 displays the decision matrix for selecting an appropriate air monitoring strategy and taking appropriate action based upon measured airborne fiber concentration from disturbance of asbestos-containing material. Am Ind Wyg Assoc J (47) August 1966 In the absence ol stale or federal regulations, we utilize the following fiber concentrations as guidelines to evaluate the effectiveness of asbestos containment procedures. When airborne asbestos fiber concentrations outside of a contain ment work area arc found to exceed an alert level of 0.04 fiber/cc by PCM analysis during a major renovation or asbestos-removal project, the sourcesfs) of asbestos contami nation should be investigated, located and controlled. When fiber concentrations outside of the containment area exceed an action or ceiling level of0.1 fiber/cc by PCM, work should be halted immediately until the source of contamination can be diagnosed and corrected. This concentration is also the action level for the triggering of medical surveillance. Air monitoring for asbestos removal projects differs from monitoring for other major renovations in one important respect. Following removal, airborne fiber concentrations determined byTEM should meet a specified clearance level. Ideally, the pre-removal background concentration may serve as the clearance level for each area, although for rea sons concerning administrative and technical practicality, it may be necessary to set the clearance concentration at a predetermined level (e.g.. 0.003 f/ cc or 100 ng, m3). which is independent of pre-abatement concentrations for each area. During major renovations, which generally occur more fre quently and involve a smaller work area than an abatement project, sample analysis by PCM may be sufficient. In these cases, the area may be re-occupied by meeting a specified control level (e.g.. 0.01 fiber/cc). Recordkeeping and Reporting Procedures It is the responsibility of the ACPM to develop and maintain accurate and complete recordkeeping and reporting proce dures. which encompass the following types of information: Environmental Recordkeeping 1) Building survey information including the locations of all asbestos-containing materials(asbestos inventory): 2) Background environmental monitoring and hazard assessment data and results; 3) Episodic monitoring data and results: 4) Periodic monitoring and surveillance data and re sults: and 5) Clearance (post-abatement) monitoring data and results. All environmental reports should describe air monitoring in detail, showing sketches of floor areas or photographs, results of all sample analyses, and analytical methods used. Administrative Recordkeeping 1) Employee education and training records: 2) Employee medical surveillance program referrals and medical records: 3) Maintenance permit applications, notifications and approvals: 4) Reports of exposed or damaged friable materials, and actions taken: 5) Prioritization scheme for scheduling of areas lor abatement: and 10003257 sot 6) Abatement cor, tract or reports and evaluations. Administrative reports should include complete descrip tions of all incidents, and any instances ol non-compliance with Asbestos Risk Management Program procedures, or applicable EPA and OSHA regulations. Both environmental and administrative records should be stored in a format that will permit them to be readily accessed. Environmental data should be maintained for the duration of the long-term management program. Medical, training and education records should be maintained for at least 40 years. Summary The basic framework of an Asbestos Risk Management Program lor buildings has been presented, the primary objective of which is to minimize employee and public expo sure to asbestos in air. The program utilizes a decision framework for assessing the degree of hazard, determining appropriate action, assigning priorities for asbestos abate ment and incorporating specific guidelines for the control of potential asbcsios-rvlated hazards in non-occupational environments. Acknowledgments The Asbestos Risk Management Program described is derived from programs developed by the authors, cither singly or in combination for the U.S. General Accounting Office, the Library of Congress, the General Services Administration and the IBM Corporation. We gratefully acknowledge the support ot asbestos control program development by these sponsors. References 1. U.S. Environmental Protection Agency: Asbestos in Build ings: A National Survey ol Asbestos-Containing Friable Materials (EPA 56015-84-006). Washington, D.C.: Environ mental Protection Agency. 1984. 2. U.S. Environmental Protection Agency: National Emission Standards lor Haza'dous Air Pollutants: Asbestos (38 CFR 8826). Washington. D C.: Government Printing Ollice, 1973. 3. U.S. Environmental Protection Agency: Friable AsbestosContaining Materials in Schools. Identilication and Notifi cation Rule (47 FR 23360). Washington, D C.: Government Printing Office 4. Occupational Safety and Health Administration: Standard lor Occupational Etoosure to Asbestos (29 CFR 1910.1001) Washington, D C. Government Printing Office. 1972 5 National Research Council: Asbeslilorm Fibers. Nonoccupational Health Risks. Washington. D C.: National Academy Press. 1984. 6. Ollice ol Carcinogen Identilication and Classilication: Pre liminary Risk Assessment lor Asbestos. Occupational Safety and Health AdmimstrSTion by H.K. Kang and K. Chu Washington, D.C.. Government Printing Office. 1981. 7. Ontario Ministry ol Government Services: Report of the Royal Commission on Matters ot Health and Safety Arising From the Use of Asbestos in Ontario by J.S. Dupre et al. Toronto. Canada: 1984. 8. Irving, K.F., R.G. Alexander and H. Bavley: Asbestos Expo sures in Massachusetts Public Schools. Am. Ind. Hyg. Assoc. J. 41:270-276 (1980). 9. Baldwin, C.A., H.J. Beaulieu, R.M. Buchan and H.H. John son: Asbestos in Colorado Schools. Prevention 97:325-330 (1982). 10 U.S. Department ot Health Education and Wellare: Asbes tos Detection and Control. Local Educational Agencies. Asbestos Detection and State Plan (FR 61950 - 61954). 1980 11. U.S. Navy: Procedure for Risk Evaluation: Asbestos Hazard Index. In Management Procedure for Assessment of Friable Insulating Materials (Report R883). Port Hueneme, Calif.: Civil Engineering Laboratory. Naval Construction Battalion Center. 1979. 12. Findley, M.E., V.E. Rose, G.R. Cutter and R.A. Windsor An Assessment of the Environmental Protection Agency's . Asbestos Hazard Evaluation Algorithm. Am. J. Pub. Health 73 1179-1181 (1983). 13. U.S. Environmental Protection Agency: Provisional Metho dology for Transmission Electron Microscopic Analyses of Asbestos Fibers (EPA-600/2-77-178). Washington. D.C.: 1978 14. Middleton, A.P. and E.A. Jackson: A Procedure for the Estimation of Asbestos Collected on Membrane Filters Using Transmission Electron Microscopy (TEM). Ann. Occup. Hyg. 25:381-391 (1982) 15 Asbestos International Association: Method tor the Deter mination of Airborne Asbestos Fibers and Other Inorganic Fibers by Scanning Electron Microscopy. London. Eng land: 29 February 1984. 16 Corn, M.: "Asbestos Control Management Document for U.S. Library of Congress." Johns Hopkins University School of Hygiene and Public Health Div. Environmental Health Engineering. Typescript 9 August 1985. 17. Maryland Department of Health and Mental Hygiene: Recom mended Guidelines tor Asbestos Abatement Contractor Licensing Programs. Baltimore, Md.: Office of Environmental Programs/Science and Health Advisory Group. April 1985. 18. Maryland Department ol Health and Mental Hygiene: Recom mended Contract Specifications lor Asbestos Abatement Protects. Baltimore. Md.: Office of Environmental Programs/ Science and Health Advisory Group, April 1985. 19 Ewing, W.M. and W.H. Spain: Getting to the Very Fiber of Industrial Asbestos Removal. Occupational Safety 6 Health 53(6) 29-33. 60, 68 (1984). 2 IX'ixmhci IVK5. Ri-mmJ 14 Ma\ IVkf. 10003258 *04 uni H.t -j>0t J (J/;