Document G9ke2V561QRYGjxmvO2n3g64

David R. Smith, M.D. Commissioner i PLAINTIFF'S EXHIBIT ASA-657 Texas Department of Health 1100 West 49th Street Austin, Texas 78756-3199 (512) 458-7111 Carol S. Daniels Deputy Commissioner for Programs Roy L. Hogan Deputy Commissioner for Administration February 13, 1995 RE: POLICY LETTER 295.36 - #1, REMOVAL OF RESILIENT FLOOR COVERING MATERIALS (This policy replaces all previous policies and/or guidelines) The intent of this policy is to clarify the regulations regarding the removal of asbestos-containing resilient floor, covering materials. Pertinent sections of House Bill 79 (HB79), the Asbestos Hazard Emergency Response Act (AHERA), the National Emissions Standards for Hazardous Air Pollutants (NESHAP), and the Texas Asbestos Health Protection .Rules (TAHPR) have been combined and interpreted. The following guidelines are not inclusive, but address aspects of the regulations which have proven to be confusing. All resilient floor covering material and their adhesive (mastic) must be inspected and analyzed for asbestos content prior to removal in a public building.^ The inspection and collection of bulk samples must be performed by an inspector licensed under the provisions of TAHPA. The samples collected from a public building must be analyzed by a laboratory licensed by the Texas Department of Health (TDH). A copy of the laboratory analysis must be kept available at the removal project site. Notification of the removal of floor covering must be submined to the TDH, if from a public building (according to TAHPR) or if floor covering is classified as regulated, asbestos-containing material (RACM, according to NESHAP). Notifications must be postmarked at least 10 working days (not calendar days) prior to the start of the abatement activities. Non-friable, asbestos-containing resilient floor covering may be removed by any of the methods described in the document titled, "Recommended Work Practices For The Removal Of Resilient Floor Coverings", published by the Resilient Floor Covering Institute (RFCI)(1992). If any other method is used for removal other than the approved RFCI methods, or if the floor material is friable, or if the floor material becomes friable during the removal process, then compliance with all regulations that address the abatement of friable asbestos-containing materials and RACM is required. This will include the establishment of containment, the use of negative air, air monitoring and, in public buildings, licensed persons. Workers engaged in the removal of non-friable resilient floor materials are not required to be licensed to work in public buildings if they receive training in an eight-hour course whicL teaches the methods described in the "Recommended Work Practices For The Removal Of ASARCO ELP 0000855 Page 2 Policy Letter 295.36 - #1 February 13, 1995 Resilient Floor Coverings" document. School employees must also complete the sixteen-hour custodial training in accordance with AHERA before they can engage in the removal of resilient floor material. ' When a project that is > 160 2 ft becomes friable, a licensed consultant must be obtained- if the removal work is in a public building. Removal work must stop in the event that the floor material unexpectedly becomes friable. The removal process must comply with all regulations that address the abatement of friable asbestos-containing material and RACM. An amended notification must be immediately submined to the Texas Department of Health (TDH). i A copy of the RFCI work practices manual must be on site. If your operation is covered by OSKA, a completed form for claiming an exemption from an initial exposure assessment must also be kept on site. To request information from the Resilient Floor Covering Institute, write to: Resilient Floor Covering Institute 966 Hungerford Drive, Suite 123 Rockville, MD 20850 . or call: (301) 340-8580 Should you have further questions concerning floor covering materials or any other matter concerning asbestoscontaining material, please direct your questions to the Division of Occupational Health, Asbestos Programs Branch. 1100 West 49th Street, Austin, Texas 78756-3199, (512) 834-6610 or 1-800-572-5548. Additional information and-support can be obtained by calling the TDH Regional offices in your area. Sincerely, -^)rr^ -T"' -- Todd F. Wingier, P.E., Chief Asbestos Programs Branch ASARCO ELP 0000856 :"nu.;i u i- i.ui State of TEXAS Regulations Governing Asbestos Abatement Projects #META 1 Corporate Offices P.O. Box 786 Lawrence, KS 66044 913.842.6382 1.800.444.6382 Fax 913.842.6993 ASARCO ELP 0000857 ........................... .. ,11 1 i ..... ............. ....................... I,..... _* Copyright 1994 Hayhew Environmental Training Associates, Inc. All rights reserved. No part of this manual may be copied by any means or for any reason without the written permission of META. META's training courses offered to fulfill regulatory training requirements have been approved by the appropriate federal, state, and/or local agencies for that purpose. Approval by any other regulatory authorities is not implied or guaranteed. META does not guarantee that the course content equips any individual to perform any particular job skill other than by serving to fulfill the regulatory requirements for training described above; nor is a passing grade on any examination required by law over the material presented in the course guaranteed. Printed in the United States of America i ASARCO ELP 0000858