Document 3Q69VzVdyZ6JqB0DLOKD1DxMy
CORPORATE INDUSTRIAL HYGIENE AND TOXICOLOGY MANUAL
SUBJECT: ASBESTOS DEMOLITION AND REMOVAL APPLIES TO: REYNOLDS METALS COMPANY AND SUBSIDIARIES
INDUSTRIAL HYGIENE DIRECTIVE
ASBESTOS DEMOLITION AND REMOVAL
It is the policy of Reynolds Metals Company that all employee ex posures to asbestos be kept as low as possible. Consequently, where feasible, all asbestos demolition/removal work should be performed by qualified outside contractors. A current list of qualified contractors 1 will be supplied by Corporate Industrial Hygiene and Toxicology, upon request. Attached is an Asbestos Abatement Contractor Performance Audit Form. (See Appendix A.) The Performance Audit Form should be returned to the attention of R. E. Benton, Industrial Hygiene, upon the comple tion of each job.
For small-scale asbestos demolition/removal jobs, where time is critical and a contractor cannot be obtained, properly trained RMC employees may perform the asbestos demolition/removal work. These employees must have successfully completed an EPA-accredited asbestos worker's course. See enclosed list of training centers in Appendix B.
I
At least one supervisor should attend an asbestos supervisor's
training course, if the plant anticipates using Reynolds' employees for
any asbestos demolition/removal work. Training courses are sponsored by
the Environmental Protection Agency (EPA) Asbestos Training Centers and
other groups. (See Appendix B.) The supervisor who attends the course
would then be responsible for ensuring that proper work practices are
used during all asbestos demolition/removal jobs. (See the glovebag procedure on Page 2, and Appendix C, for guidelines on small scale,
i
short duration jobs.)
Air sampling is also required on all asbestos demolition/removal jobs, to assure the effectiveness of the controls and work practices. This requirement may necessitate the purchase of air sampling equipment. (See Appendix D.) Should the plant wish to purchase equipment, please I contact R. E. Benton (Ext. 3795), regarding the type of equipment recom mended and its proper use.
From an environmental standpoint, EPA's National Emission Standard for Hazardous Air Pollutants (NESHAP) for asbestos dictates:
1) an asbestos inspection be performed in the facility or area prior to beginning the asbestos work;
2) agency notification of planned demolition and renovation activities;
3) adherence to specified procedures for asbestos emissions
I
APPROVED R-680-82 (Rev.2-91)
TX TINER RMC0043014
CORPORATE INDUSTRIAL HYGIENE AND TOXICOLOGY MANUAL
CIH&TM:
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SUBJECT: ASBESTOS DEMOLITION AND REMOVAL
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control during removal activities?
4) proper handling and disposal of the asbestos materials at the landfill site; and
5) a competent person is required on site during asbestos projects. The competent person must have successfullycompleted an EPA-approved supervisor's course or its equivalent. The competent person may be an RMC employee or an outside contractor hired by the company to oversee the asbestos project.
These standards are applicable to the renovation and/or demolition of friable asbestos. Please notify C. R. Bent (Extension 2918) of the Corporate Environmental Control Department, when asbestos removal ac tivities are planned, to determine the applicability of the NESHAP regu lations and/or to discuss the specifics of these requirements.
^ OVERVIEW OP THE GLOVEBAG PROCEDURE
A glovebag is a 6-12 mil bag fitted with long-sleeved gloves, a tool pouch, and a two-inch opening for water. Although glovebags can be fabricated by the user for each project, most contractors prefer to purchase readymade bags. The size, quality, style, and cost vary de pending on the manufacturer. In addition to the glovebag, several other tools and materials are commonly required to perform the project suc cessfully. These materials, listed below, are readily available from most asbestos abatement contractor suppliers.
MATERIALS
1. Glovebag (one or more, depending on project size) 2. Pump-up garden sprayer (2-3 gallon size) 3. Amended water (surfactant, availble from local garden shop or
safety supply company) 4. Duct tape (3-inch width) 5. Polyethylene disposal bags (6 mil) 6. Smoke tubes with aspirator bulb 7. HEPA-filtered vacuum cleaner 8. Bone saw 9. Utility knife with retractable blade 10. Wire cutters 11. Tin snips (if aluminum jacket is present) 12. Polyethylene plastic (roll of 4 or 6 mil) 1 13. Dual cartridge respirators with high efficiency cartridges
APPROVED R-830-62 (Rbv.2-91)
TX TINER RMC0043015
Ml VISION INDICATOR
CORPORATE INDUSTRIAL HYGIENE AND TOXICOLOGY MANUAL
ClH 4 TM:
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SUBJECT: ASBESTOS DEMOLITION AND REMOVAL
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APPLIES TO: REYNOLDS METALS COMPANY AND SUBSIDIARIES
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14. Disposable full-body suits with hood and feet covering 15. Small scrub brush
16. Stapler 17. Several rags 18. Wettable cloth 19. Asbestos caution signs and labels 20. Reinsulation materials, as necessary
BEFORE STARTING A GLOVEBAG PROJECT
Two persons are required to perform a glovebag removal project. Also, a third person is sometimes available, to assist with supplies, to keep unwanted visitors out of the area, and to conduct air monitor ing. Each of the team members should be trained on the use and limi tations of glovebags. They should also be included in the respiratory protection and medical surveillance programs.
Before any work begins, all necessary materials should be brought into the work area. The work area should be roped off, and warning signs should be posted on the perimeter to minimize the chance of visitors entering the area. Barrier tape (3-inch) with a preprinted asbestos warning is recommended. If applicable, the heating, venti lation and air conditioning (HVAC) system supplying the work area should be shut down.
Employees should also be trained about emergency procedures, in the event of a glovebag rupture. The emergency training should cover wet cleaning, High Efficiency Particulate Air (HEPA) filter vacuuming procedures, and shower use. The following guidelines may be used for most pipe lagging projects:
REMOVAL PROCEDURES
1. Follow the manufacturer's directions and mix the surfactant with water in the garden sprayer.
2. Each employee should wear a HEPA filter respirator and check the face-fit.
3. Each employee should wear a disposable full-body suit, being mindful that the hood goes over the respirator straps.
4. The pipe on which the work will be performed should be checked. REMEMBER...NEVER PERFORM GLOVEBAG REMOVAL ON HOT
APPROVES) R-880-62 (Rev.2-91)
TX TINER RMC0043016
RuVISlO* INDICATOR
CORPORATE INDUSTRIAL HYGIENE AND TOXICOLOGY MANUAL
CIH&TM:
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SUBJECT: ASBESTOS DEMOLITION AND REMOVAL
page
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PIPES OVER 150P. This may eauss the bag or gloves to melt over the workers' hands and arms. If the pipe is damaged (broken, lagging, hanging, etc.), the entire length of the pipe should be wrapped in polyethylene plastic and "candystriped" with duct tape. A common problem with glovebag work is that loose pipe lagging several yards from the glovebag may be jarred during the work, causing a release of asbestos into the air. Another problem is failure to clean up debris on the floor and other surfaces. If the pipe is undamaged, it is still necessary to place one layer of duct tape around the pipe at each location where the glovebag will be attached. This serves two purposes. First, it gives a good surface on which to seal the ends of the glovebag. Second, it minimizes the chance of releasing fibers when the tape at the ends of the glovebag is peeled off at the comple tion of the job.
5. Slit the top of the glovebag open (if necessary) and cut down the sides to accommodate the size of the pipe (about two inches longer than the pipe diameter). One brand has a zipper top and straps at each end facilitating installation of the bag on the pipe.
6. Place the necessary tools into the pouch located inside the glovebag. This will usually include the bone saw (flexisaw), utility knife, rags, scrub brush, wire cutters, tin snips, and wettable cloth. Note: It is easiest to pre-cut the wettable cloth at this point. Cut out a donut shape with the inner diameter 1/2-inch smaller than the diameter of the pipe beneath the insulation. The outer diameter of the donut should be three inches longer than the diameter of the pipe insulation being removed. Finally, cut a slit in each of the two donuts, so they can be slipped around the pipe.
7. Place one strip of duct tape along the edge of the open top slit of the glovebag for reinforcement.
8. Place the glovebag around the section of pipe to be worked on and staple the top together through the reinforcing duct tape. Staple at intervals of approximately one inch. This should provide an adequate seal along the top. Next, duct tape the ends of the glovebag to.the pipe itself, previously covered with plastic or duct tape (See Step 4).
APPROVED R48042 (Rev.2-91)
TX TINER RMC0043017
CORPORATE INDUSTRIAL HYGIENE AND TOXICOLOGY MANUAL
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SUBJECT ASBESTOS DEMOLITION AND REMOVAL
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A smoke tube and aspirator bulb are needed to test the glovebag. Place the tube into the water sleeve (two-inch opening to glovebag) . By squeezing the bulb, fill the bag with visible smoke. Remove the smoke tube and twist the water sleeve closed. While holding the water sleeve tightly, gently squeeze the glovebag and look for smoke leaking out, especially at the top and ends of the glovebag. If leaks are found, they should be taped closed, using duct tape, and the bag should be retested with smoke.
10 Insert the wand from the water sprayer through the water sleeve. Using duct tape, tape the water sleeve tightly around the wand, to prevent air leakage. The insulation should be pre-misted to minimize fiber release.
11. One person should place his hands into the long-sleeved gloves, while the second person directs the water spray at the work.
12 If the section of pipe is covered with an aluminum jacket, it should be removed by first using the wire cutters to cut any bands and then using the tin snips to remove the aluminum, it is impor tant to fold in the sharp edges to prevent cutting the bag when it is placed in the bottom. USE CAUTION TO PREVENT CUTS - THESE EDGES ARE SHARP! Once the aluminum jacket is removed, the exposed in sulation should be wetted with the amended water.
13 With the insulation exposed and wetted, use the bone saw to cut the insulation at each end of the section to be removed inside the glovebag. Note: A bone saw is a serrated heavy-gauge wire with ring-type handles at each end. Throughout this process, water is sprayed on the cutting area to keep dust to a minimum.
14 Once the ends are cut, the section of insulation should be slit
from end to end, using the utility knife. The cut should be made
along the bottom of the pipe and water continually supplied.
If possible, the cut should be along joints of preformed lagging
I
blocks. Again, care should be taken, when using the knife, not to
puncture the bag. Some insulation may have wire to be clipped, as
well.
15. Spray all tools with water inside the bag and place back into pouch.
16..... The insulation can now be.lifted off the .pipe..and gently placed in the bottom of the bag.
APPROVED (Rev.2-91)
1
TX TINER RMC0043018
H E V IS iv... INDICATOR
CORPORATE INDUSTRIAL HYGIENE
AND TOXICOLOGY MANUAL
CIH & TM:
SUBJECT: ASBESTOS DEMOLITION AND REMOVAL
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APPLIES TO: REYNOLDS METALS COMPANY AND SUBSIDIARIES
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17. Using the scrub brush, rags, and water, scrub and wipe down the exposed pipe inside the glovebag. Note: The inexpensive horse rub-down mittens work well for this.
18. Wet the donut-shaped pieces of wettable cloth and place over the exposed ends of insulation remaining on the pipe. Wettable cloth is a plaster impregnated fiberglass webbing available at many hardware and/or plumbing supply stores. A bridging encapsulant may be used I instead of the wettable cloth.
19. Remove the water wand from the water sleeve and attach the small nozzle from the HEPA-filtered vacuum. Turn on the vacuum only briefly to collapse the bag.
20. Remove the vacuum nozzle, twist the water sleeve closed, and seal it with duct tape.
21. From outside the bag, pull the tool pouch away from the bag and twist it to separate it from the bag. Place duct tape over the twisted portion and then cut the tool bag from the glovebag, cut ting through the twisted/taped section. This will allow the con taminated tools to be placed directly into the next glovebag with out cleaning. Alternatively, the tool pouch with the tools can be placed in a bucket of water, opened underwater, and the tools cleaned and dried without releasing asbestos into the air.
Note: Rags and the scrub brush cannot be cleaned in this manner and should be discarded with the asbestos waste. If more than one adjacent section of pipe is to be removed, the glovebag may be loosened at each end and slid along the pipe to the next section. In this case, the tools would remain in the bag for continued use.
22. With the removed isulation in the bottom of the bag, twist the bag several times and tape it to keep the material in the bottom during removal of the glovebag from the pipe.
23. Slip a 6 mil disposal bag over the glovebag (still attached to the pipe) . Remove the tape, open the top of the glovebag, and fold it down into the disposal bag.
24. After vacuuming the disposable suits, remove and place into the bag with the waste.
25. Twist the top of the bag closed, fold this over, and seal it with duct tape. Then put a warning label on the bag.
APPROVED R-880-82 (Rev.2-91)
TX TINER RMC0043019
TX TINER RMC0043020
TX TINER RMC0043021
APPEND^ A
ASBESTOS ABATEMENT CONTRACTOR PERFORMANCE AUDIT
The enclosed audit document is to be used only by properly trained personnel (i.e., have successfully completed an approved 5-day asbestos supervisor course) to audit the performance of asbestos abatement contractors. This
?ualified individual may be a Reynolds Metals Company n-plant person or an experienced outside person. The audit of the contractor's performance should be done daily and at random times. The appropriate sections of the audit document should be filled out at these times and copies forwarded to Corporate Industrial Hygiene on a weekly basis. For those projects where it is not possible to see clearly into the work area, it will be necessary to enter the work area to audit the contractor's performance.
Any work practice or situation which could result in the release of asbestos fibers into the workplace or environment (e.g. breach in containment barrier, inadequate worker decontamination, breakdown in negative air machines, etc.) must be stopped and corrected immediately. A report detailing this incident is to be prepared and sent to Corporate Industrial Hygiene in Richmond as soon as possible after the incident has been resolved. If there is any question concerning the need to stop a project, contact Corporate Industrial Hygiene immediately for guidance.
Once the asbestos project (and the final cleanup) has been completed, the trained individual must conduct a visual inspection of the work area prior to the beginning of the final clearance sampling. The inspection will require entrance into the work area. The individual inspecting the work area should look for visible contamination on all surfaces from which asbestos-containing material has been removed. In addition, he/she must look for material which might have been "caught" on equipment or other surfaces. A high intensity flashlight would be helpful for inspecting corners and other recessed areas.
Once the work area has passed the visual inspection, the final aggressive clearance sampling can be conducted. The project will be considered complete when the results of the aggressive air sampling indicate airborne asbestos levels are 0.01 f/cc or less.
Any questions concerning the use of this document should be directed to Corporate Industrial Hygiene.
TX TINER RMC0043022
TX TINER RMC0043023
1
ASBESTOS ABATEMENT CONTRACTOR PERFORMANCE AUDIT (All negative responses must be completely explained.)
I. Work Area Preparation
Y/N
Y/N
Y/N Y/N Y/N Y/N
Y/N Y/N
Is preparation of work area necessary? If yes, answer remaining questions. If no, proceed to Section II. Are caution signs posted and banner tape established in such a way to prevent accidental or unauthorized entrance? Are the electrical power and HVAC systems in the area shut down? Are sanitary facilities and eating areas being provided outside regulated areas? Are all movable objects being wet wiped or HEPA vacuumed prior to removal from work area? Are all nonmovable objects being wet wiped or HEPA vacuumed prior to being covered with a 4 mil. poly? Are all surfaces being wet wiped or HEPA vacuumed prior to covering with poly? Are all windows, doors, elevator openings, ducts, grill openings and any other openings between the work area and uncontaminated areas outside the work area being covered with 4 mil. poly?
TX TINER RMC0043024
2
II. Containment Room
V/N
V/N V/N V/N V/N V/N V/N V/N
V/N V/N
Is a containment room being used? If yes, answer the remaining questions. If no, proceed to Section III. Are floors covered with at least two layers of 6 mil. poly? Are walls covered with at least 2 layers of 4 mil. poly? Are seams located in such a fashion as to minimize the number and be no closer than six feet? Does floor poly extend at least 12" up the sidewalls? Does wall poly overlap floor poly by at least 12" beyond wall/floor joint? Is wall poly adequately secured to prevent pulling away from wall? Are walls constructed for the containment room (openings greater than 4* x 8'), will the framing consist of wood or metal? Is 3/8" plywood or sheathing being used on the work side of openings greater than 4' x 8`? Are checks being made to insure negative pressure is maintained inside the enclosure (smoke tubes or 0.01" water gauge difference between inside and outside)?
TX TXtiER KHC0043025
3
Y/N Y/N Y/N Y/N Y/N
Y/N Y/N
Are negative air machine(s) used to maintain negative pressure inside enclosure? Are the negative air machines of the centrifugal type? Do the negative air machines have an air-handling capacity of 1,000 - 2,000 ft.3/min. under clean
filter conditions? Are there at least 4 air changes per hour? Are the negative air machine(s) located so as to
insure that clean outside air is brought in through the decon unit and thru the work area before being exhausted to the outside? (This check should be performed using ventilation smoke tubes.) Are the negative air machines equipped with the necessary filters {prefilter, intermediate filter, and HEPA filter)? Are the filter(s) replaced as necessary or when the pressure drop reading exceeds 1" water gauge? Are the contaminated filters properly disposed of as asbestos-containing material?
III. Decontamination Facilitv/Area
Y/N
Is a decontamination (decon) facility necessary? If yes, answer remaining questions. If no, proceed to Section IV.
TX TINER RMC0043026
Y/N Y/N
Y/N Y/N Y/N Y/N Y/N Y/N Y/N Y/N
Y/N Y/N
4
Is decon facility a prefab unit? For a decon facility, is there an airlock between the equipment room and shower room and the shower room and clean room? Are the air locks formed by overlapping two sheets of poly at the exit and entrance ends? Are the air locks formed by overlapping two sheets of poly at the exit and entrance ends? Is there at least three feet of space between the entrance and exit? Are 2 layer 6 mil. opaque or white poly used for the decon unit walls? Is 1/4" - 1/2" plywood used for the decon unit walls? Are three layers of 6 mil. poly used for the decon floors? Is the water from the shower room filtered through a 0.5 - 1.0 micron filter prior to discharge? Is the decon facility designed so that entrance and egress to the work area is through the decon unit? Are emergency exits established and clearly marked? If decon area is used, are workers required to decontaminate themselves in that area before leaving?
TX TINER RMC0043027
5
IV. Waste Container Load Out
Y/N
Y/N Y/N
Is a waste container load-out necessary? If yes, answer remaining questions. If no, proceed to Section V. Is waste container load-out facility constructed with appropriate air locks? Is waste container load-out unit maintained under negative pressure?
V. Glove Bag
Y/N
Y/N Y/N Y/N Y/N Y/N Y/N Y/N
Are glove bag procedures being used? If yes, answer remaining questions. If no, proceed to Seciton VI. Are the glove bags at least 6 mil. poly? Are glove bags checked for tightness (smoke tube or squeeze test) prior to removed of ACM? Is amended water used to keep ACM wet? Is HEPA vacuum cleaner used to deflate bag after removal? Are the remaining surfaces cleaned at least twice after ACM removed? Is lock-down spray back material used to seal any remaining fibers? Is glove bag properly labeled for disposal?
TX TINER RMC0043028
6
VI. Open Air Removal
Y/N
Y/N Y/N Y/N Y/N Y/N Y/N
Is it necessary to utilize "open air" removal techniques? If yes, answer remaining questions. If no, proceed to Section VII. Has a regulated area been established based on valid air sampling data? Is ACM kept thoroughly wet during entire removal process? Is ACM allowed to drop from surface to floor or other surface? Is the ACM wrapped with mil. poly prior to removal? Are other procedures used to minimize release of fibers? If yes, please elaborate on back. Is 6 mil. poly placed underneath ACM being removed or repaired?
VII. Waste Disposal
Y/N Y/N Y/N
Y/N
Is all waste bagged vet? Is there any sweeping of AC waste? Is waste double bagged in labeled 6 mil. poly bags? Are drums used as a final storage container?
TX TINER RMC0043029
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y/n Y/N Y/N Y/N Y/N
Do drums have locking rims? If waste is not bagged or placed in drums, is it double wrapped and seams taped with duct tape? If not removed daily, is bagged/drummed waste stored in a secure location? Is the outside of bags/drums cleaned of all residue? Is any waste with sharp edges placed in plastic bags?
VIII. Air Sampling
Y/N Y/N Y/N Y/N Y/N Y/N
Y/N
Is sampling being conducted by an outside third party? Is sampling being conducted by trained personnel using required techniques? Are fiber counts performed by accredited laboratory? Are daily area samples being collected inside the containment enclosure? Are samples being collected using 25 mm filters at a flow rate of 0.5 - 2.5 liters per minute? Are the area samples at a collected frequency of 1 sample per 1000 ft.2 of enclosed area with a
maximum of 5 samples per work area? Is at least 1 daily area sample collected outside the enclosure, at the entrance to the clean room?
TX TINER RMC0043030
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Y/N Y/N Y/N Y/N
Is at least 1 daily area sample collected outside the enclosure, at the exhaust of the HEPA ventilation system? Are personal samples collected daily and in such a fashion as to adequately characterize the exposure of each worker? Is personal sampling being conducted for both the 8-hour time-weighted average and the 30-minute excursion limit. Are air sampling pumps calibrated before and after use with a representative filter?
IX. Respiratory Protection
Y/N Y/N Y/N Y/N Y/N
Are respirators selected on the basis of air sampling data? Is initial work being conducted with workers wearing atmosphere supplying respirators? Are all respirators used during the project NIOSH/MISHA approved for asbestos exposures? Does any employee wearing a respirator have a beard? Does any employee wearing a full facepiece respirator have on eyeglasses with temple bars?
TX TIMER RMC0043031
9
X. Clothing
Y/N Y/N
Y/N
Y/N
Is protective clothing necessary? Are disposable full body suits provided to workers? Are the suits to be removed prior to leaving the work area where there is no decon unit? Are the suits taped at cuffs and legs?
XIV. Site Security
Y/N Y/N Y/N Y/N Y/N Y/N Y/N
Is work area adequately cordoned off to prevent
accidental or unauthorized entrance?
Is daily log kept of all entrances into work area?
Is plant management notified immediately of any
unauthorized entries into work area?
During off work hours, will work area be secured
to prevent unauthorized entrance?
Are contractor personnel on site during off work
hours?
Are contractor personnel available during off work
hours?
For projects with decon units and containment
barriers, will entry be restricted to the decon
unit?
***
TX TINER RMC0043032
TX TINER RMC0043033
APPENDIX g ASBESTOS TRAINING CENTERS
INSTITUTION
Southeast Asbestos Info. Center GEORGIA INSTITUTE OF TECHNOLOGY Atlanta, GA 30332
Asbestos Information Center TUFTS UNIVERSITY Medford, MKA 02155
Natioal Asbestos Info. Center UNIVERSITY OF KANSAS Shawnee Mission, KS 66207-3398
MEDICAL COLLEGE OF VIRGINIA Dept, of Preventive Medicine Richmond, VA 23298-0212
PACIFIC ASBESTOS INFORMATION CENTER UNIVERSITY OF CALIFORNIA, EXTENSION DIV. 2223 Fulton St. Berkeley, CA 94720
MIDWEST ASBESTOS INFORMATION CENTER School of Public Health UNIVERSITY OF ILLINOIS 2035 West Taylor St. Chicago, IL 60612
TELEPHONE < 404/894-2400
617/381-3531
913/648-5790
804/786-9785 804/786-0494 415/643-7143
312/996-5762
TX TINER RMC0043034
TX TINER RMC0043035
appendix
WORK PRACTICES AND ENGINEERING CONTROLS FOR ASBESTOS REMOVAL/DEMOLITION ACTIVITIES
--Work Practical and Engineering Controls for Small-Scale borl-Duratio& Asbestoa Renovation and Maintenance Activities
Definition ofSmall-Stale. Short-Duration Activities
Fur the purposes of this appendix, smallscale. shurt-dgraiion renovation and maintenance activities are tasks such as. but not limited to:
Removal of asbestos-containing Insulation on pipes:
Removal of small quantities of asbestos* enntaininf insulation on beams or above ceilings:
Replacement of an asbestos-containing gasket on a valve;
Instillation or removal of a small section efdrywell:
Installation of electrical conduits through or proximate to asbestos-containing materials.
Evidence in the record (see the Summery nd Explanation section of the preamble for paragraph (g). Methods of Compliance, for specific citations] suggests that the use of certain engineering and work practice Controls is capable of reducing employee exposures to asbestos to levels below the final standard's action level (0.1 flee). Several controls and work practice!, used either singly or in combination, can be employed effectively to reduce asbestos exposures during small maintenance and renovation operations Dieae Include:
Wet methods: Removal methods
--Use of Clove begs --Removal of entire esbestos Insulated
pipes or structures --Use of mioi-enclosures
Enclosure of asbestos materials: and Maintenance programs. This appendix describes these controls and work practices in detail.
Preparation ofthe Area Before Renovation or Afointenonee Activities
The first step In preparing to perform a small-scale, short-duration asbestos renovation or maintenance teak, regardless of (he abatement method that will be used, is (he removal from the work area of all objects (hat are movable to protect them from asbestos contamination. Objects that cannot he removed must be covered completely with ^mil-thick polyethylene plastic sheeting before the task begins. If objects have already been contaminated, they should be thoroughly cleaned with a High Efficiency Particulate Air IMEPA] filtered vacuum or be wet wiped before they are removed from the work area or completely encased in the plastic.
It'c/ Methods
Whenever feasible, and regardless of the abatement method to be used (e g., removal, enclosure, use of glove bags], wet methods must be used during small-scale, short duration maintenance and renovetion activities that involve disturbing asbestoscontaining materials. Handling asbestos materials wet is one of the most reliable methods of ensuring that esbestos fibers do nut become airborne, and this practice should therefore be used whenever feasible. As discussed in the Summery and Explanation section of the preamble for paragraph (g). Methods of Compliance, wet methods can be used in the great majority of workplace situations. Only in cases where asbestos work must be performed on live electrical equipment, on live steam lines, or in other areas where wster will seriously damage materials or equipment may dry removal bo performed. Amended water or another wetting agent should be applied by means of on airless sprayer to minimise the extent to which the asbestos-containing materiel is disturbed.
Asbestcs-conteiniivg materials should be wetted from the initiation of the maintenance
Clow Bog Installation. Clove bags are approximately 40-inch-wide times Minchlong bags fitted with arms through which the work can be performed (see Figure G-l(A)). When properly installed and used, they permit workers to remain completely isolated from the aabesloa materiel removed or replaced intide the beg. Clove begs can thus provide flexibile. easily installed, end quickly dismantled temporary small work area enclosure that is idea) for amall-scale abcslos renovation or maintenance fobs.
or renovation operation and wetting agents should be used continually throughout the work period to ensure that any dry asbestoscontaining material exposed in the course of the work is wet and remains wet until final disposal.
Removal ofSmall Amount ofAsbestosContaining Materials
Several methods can be used to remove small amounts of asbestos-containing materials during small-scale, ahori-duralion renovation or maintenance teaks. These include the use of glove bags, the removal of an entire asbestos-covered pipe or structure, nd the construction of mini-enclosures. The procedures that employers must use for each of these operations if they wish to avail themselves of the final rule's exemptions are described in the following sections.
Clove Bogs
As discussed in the Summary and Explanation section of the preamble for paragraph (gk Methods of Compliance, evidence in the record indicate that the use of glove bags to enclose the work area daring smell-scale, short-duration maintenance or renovation activities will result in employee exposures to asbestos that are below the final standard's action level of o.l f/et.This appendix provides requirements for glovebag procedures to be followed by employers srishing to avail themeelves of the standard's exemptions for each activities. OSIiA has determined thst the use of these procedures wil) reduce the t hour time weighted average (TWA) exposures of employees involved ia ' these work operations to levels below the action level and will thus provide a degree of employee protection equivalent to that provided by compliance with all provisions of the final rule.
A-l
TX TINER RMC0043036
(A) (8)
(C) (0)
Rpn G-I. Disgmn Showing Fropur Um f Ctov* Bf bt SrasH-SeaU. Start-Duntrae Mualuoaacu and . Basovatios Oparatian*.
These bag* are tingle ue control device* that are disposed of at the end of each job. The bags are made of transparent 6-mil-lhick polyethylene plastic with arm* of Tyvek * material (the tame material used to make the disposable protective suit* used in major asbestos removal, renovation, and demolition operations and in protective gloves). Glove bags are readily available from safety supply stores or specialty asbestos removal supply houses. Clove bags eome pre-labeled with the asbestos warning label prescribed by OSHA and EPA for bags used to dispose of asbestos watte.
Clovt Bog Equipment endSupplies. Supplies and materials that are necessary to use glove bag* effectively Include:
0) Tape to seal the glove bag to the area from which absbettos is to be removed:
(2) Amended water or other wetting agents: (3] An airless sprayer for the application of the wetting agent;
* Mention of trade name* or commercial products doe* not constitute endorsement or recommendation for use.
(4) Bridging encapsulant (a paste-like
aubstance for coating asbestos) to set! the rough edges of any asbestos-containing materials that remain within the glove bag at the points or attachment after the rest of the asbestos hat be removed:
|S) Tools such at razor knives, nips, and wire brushes (or other tools suitable for cutting wire, ate.);
(6) A HEPA niter-equipped vacuum for evacuating the glove bag (to minimize the release of asbestos fibers) during removal of the bag from the work area and for cleaning
any material that may have escaped during the installation of the giovs bag: and
(7) HEPA-equipped dust cartridge respirators for use by the employees involved in the removal of asbestos with the glovk bag.*
Clove Beg Work Practices. The proper use ofglove bags requires the following steps:
(1) Glove bags must be installed ao that they completely cover the pipe or other etructure where asbestos work is to be done. Clove bags are installed by cutting the sides of the glove bag to fit the size cf the pipe from
which asbestos is to be removed. The glove
bap it attached to the pipe by folding >h open edges together and securely sealing them with tape. All openings in the glove bug must be sealed with duct tape or equivalent material. The bottom seam of the glove bag mutt also be sealed with duct tape or equivalent to prevent any leakage from the bag that may result from a defect in the bottom team (Figure G*l(8)).
(2) The employee who m performing the asbestos removsl with the glove bag must don a half mask dual-cartndge HF.PAequipped respirator respirators should be worn by employees who are in close contact with the glove bag and who may thus be exposed as a result of small gaps in the teams of the bag or holes punched through the bag by a razor knife or a piece of wire mesh.
(3) The removed asbestos materia! from the pipe or other surface that has fallen into the enclosed bag must be thoroughly wrtted with a wetting agent (applied with an airless sprayer through the pre-cut port provided m most gloves bags or applied through a smull hole cut in the bag) (Figure G--1(C)).
(4) Once the asbestos material has been thoroughly wetted, it can be removed from the pipe, beam or other surface The choice uf tool to use to remove the asbestos-containing material depends on the type of materiel to be removed. Asbestos-containing materials re generally covered with painted canvas and/or wire mesh. Painted canvas can be cut with a razor knife and peeled away from the asbestos-containing material underneath. Once the canvas has been peeled twav. the asbestos-containing material underneath may be dry. in which case it should be re-sprayed with a wetting agent to ensure that it generates as little dust as possible when removed. If the asbestos-containing material (a covered with wire mesh, the mesh should be cut with nips, tin snips, or other appropriate tool and removed.
A wetting agent must then be used to spray any layer of dry material that is exposed beneath the mesh, (he surface of the stripped underlying structure, and the inside of the glove bag.
(5) After removal of the layer of asbestoscontaining material, the pipe or surface from which asbestos hat been removed must be thoroughly cleaned with a wire brush and wet wiped with a wetting agent until no traces of the asbestos containing material can be seen.
(6) Any asbestos containing insulation edges that have been exposed ss a result of the removal or maintenance activity must be encapsulated with bridging eneapsuiant tu ensure that the edges do not release asbestos fibers to the atmosphere after the glove bag hat been removed.
(7) When the asbestos removsl and encapsulation have been completed, a Vacuunrhoie from a HEPA filtered vacuum mutt be inserted into the glove bag through the port to remove any sir in the bag that may contain asbestos fibers. When the sir has been removed from the bag. the bag should be squeezed tightly (as close to the top as possible), twitted, and staled with tape, to keep the asbestos materials safely in the bol.lom of the bag. The HEPA vacuum can
A-2
TX TINER RMC0043037
then be removed from the beg end Ihe glove
bag itself can be removed from the work area to be disposed of properly {Figure &-l(D]).
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v .fa loot instances. such as removal of asbestos from small ventilation system or from a short length of duct, s glove bog may not be either large enough or of the proper shape to enclose the work area. In such cases, c mini-enclosure can be built around the area where small-scale, short-duration asbestos maintenance or renovation work is to be performed (Figure G>2). Such an
enclosure shouiu oe constructed of 6-muthick polyethylene plastic sheeting and can be small enough to restrict entry to the asbestos work ares to one worker.
For example, a mini-enclosure can be built in a small utility closet when asbestoscontaining duct covering is to be removed. The enclosure is constructed by:
(1) Affixing plastic sheeting to the walls with spray adhesive and tape:
A-3
TX TINER RMC0043038
ft) C"'ir*S iKt Hoot *lih pUiilc *rvj reefing the plsttie wvtnn| the floor te the plastic on the walla.
(3) Sealing any penetration* such n pipes or ehetrical conduits with tape: and
(<1 Constructing a small change room (epproximafrly 3 fret square} mdr of (milMci polyethylene plastic supported by 2frvdi b) 4-inch lumber (the plastic should be (incited to (he lumber supports with staples 0* spray sdhesi'f and tope].
The change room should be contiguous to the mini enclosure, and it necessary to allow the worker to vacuum o(T hit protective ovei*Ils and remove them before leaving the work area While inaide the enclosure, the srerkar sltould urear Ty^rel' disposable coverall* and wre the appropriate MEPA filtered dual cartridge respiratory protection.
The adv*niges of mini-enclosure* are that they limn the tpread of asbestos contamination. reduce the potential exposure of bystanders and ether worked who may be working in adjaeenf areas. and are quick and asy to inttall The disadvantage of mininrlosures it that they may be loo small to contain the equipment newt ary to create a neg ative pressure within the endoture: however. the doable layer of plastic sheeting will ten-* ro restrict the releate of asbestot fibers to the area outside the enclosure.
firmonsf of Entire Structures
When pipes are Insulated with asbestos* containing materials. removal of the entire pipe may be more protective, easier, and more coti-efTeciive than t(rippin| the abettot insulation from the pipe. Before ouch a pipe la cut. the asbestos-containing Insulation mutt be wrapped with 6-mil polyethylene plastic and securely sealed with duct tape or equivalent. This plastic covering will prevent atbeslot fibers from becoming Clrbome at a result of the vibration created By the power saws used (o cut the pip*- if possible, the pipes should be cut at locations (hat are not imulsted to avoid disturbing the ' asbestos. If e pipe is completely Ineulared with asbestos-containing materials, until pections should be stripped using the glove* frog method described above before the pipe fc art at the stripped section*.
A*nrenu.ve frogrem
An asbestos maintenance prog'rm must Ih. initiated in all facilities that havr asbestoscontaining materials. Such a program should Include:
Development of an Inventory of sit sbestos-eonteining neterial* in the facility:
Periodic examination of all asbestoscontaining materials to delect deterioration:
Written procedures for handling asbestos materials during the performance of smallteale. shun-duration mjintenoArerond Innovation activities:
Written procedures for asbestos disposal: and
Written procedures for dealing with sbestos-related emergencies.
Members of the building s miintcrMm* engineering staff (electricians, heating/air conditioning engineers, plumbers, etc.) who may be required to handle asbestoscontaining materials should be trained in aafe procedures. Such training should include at a minimum:
Information retarding types of aalmatos nd its various uaet and forms:
Information on the health effects Moated with asbestoa exposure:
Descriptions of lbs proper methods of handling ssbesrioa-containing materials, and
Information on the use of HEPAquipped dual cartridge respirttory and other personal protection during maintenance ciivities.
Prohibited Activities
The tnhiinf program for ihe melntenamre engineering staff should describe methods of kandling asbetiot-contalning materials as well as routine maintenance activities that are prohibited when asbestos-containing materials are Involved For example, maintenance staff employees should be helmeted.
.Vut to drill holes in asbcstos-conUining materials:
A'ut to hang plants or pictures on structures covered with asbosttrt-cnntaining maleriuls;
.Wit to aand asbealns-eonUiniru; floor tile:
Sot to damage asbestos-containing aiatciials while moving lumiiure or other objects:
Set to install curtains, drapes, or dividers In such a way that they damage sbestns-containing materials:
Aor to dust Ifoors. ceilings, moldings ur other surfaces in atbestos-cnntuminated environment* with a dry brush or sweep with dry broom:
.Vor to use an ordinary vacvtim loclean p asbestos-containing debriv
.Vor to remove ceiling tiles Wo** Jtb<-slot-conluining materials without wearing the proper respirttory protection, clearing the ares of other people, and observing asbestos removal waste disposal procedures;
Sot lo remove ventilation system filters dry* and
Sot to shale ventilation ryatem Altars.
APPENDIX D
RECOMMENDED SAMPLING PROCEDURE FOR ASBESTOS
1. The preferred collection device shall be the 25mm mixed cellulose ester filter in a cassette with an open-faced 50mm extension cowl. The 37mm cassette may be used in those situations where dust loadings reduce the sampling time to less than one hour. (See Item 3, below.)
2. An airflow rate between 1.5 liter/min. and 2.5 liters/min. shall be used for either the 25mm or 37mm cassette.
3. If, during sampling, the filter darkens noticeably (i.e. changes color), or if loose dust is seen on the filter, a second sample shall be started.
4. All pumps should be calibrated with a bubble flow meter before and after each day's use. An inverted 500ml buret will suffice as the bubble meter.
5. Before starting the sampling, record the date, plant name, sample number (written on the white shrinkband), pump number, employee's name, work description, and controls used on the enclosed sampling data sheet. Also, note the type of protective clothing and respirator worn by the employees.
The tubing from the pump should be attached to the end of the cassette that has the "ribbed" appearance. The cassette should be sampled with an open face (i.e. entire cap removed from the end of the cassette, rather than the small plug) and attached to the worker's shirt collar.
7. After the pump is turned on, ensure that it is functioning properly and has an 8-hour charge. The time the pump is started is also recorded on the sampling data sheet.
8. Unless the filter darkens, as in Item 3, the sampling period should be a series of 4-hour samples until the project has been finished and clean-up completed. At the end of each sampling period, the cassette should be removed from the tubing, the end cap and bottom plug replaced, and the time pump stopped should be recorded on the sampling data sheet.
9. During sampling, any conditions which might affect the results should be noted on the sampling data sheet (e.g. glovebag rupture, insulation not kept wet, etc).
10. After sampling has been completed, each cassette should be taped around the ends, to prevent accidental opening during shipment, and returned to Corporate Industrial Hygiene in a rigid container, along with the completed sampling data sheets. (Note: One unused cassette should be returned as a blank, for every 6 filters used.)
***
TX TINER RMC0043040
TX TINER RMC0043041
