Document Jv7NbEq1DVpkm0OvJayOgORoe

straus systems me interoffice memorandum TO: Belov; Distribution FROM: Earl Warner SUBJECT: Asbestos Removal DATE: May 1, 1986 In the future any jobs pertaining to the cutting or removal of asbestos, or asbestos related mterials must be performed by a state approved asbestos removal contractor. Earl Warner Asbestos; menace in the boiler room To avoid the tragedies from asbestos related diseases, HVAC workers should have a full understanding of asbestos and how to deal with it By DANIEL CULBERG, President, Brand Asbestos Control Co., Park Ridge, III Since the mid 1970s, concern for asbestos related health problems has focused on those who worked directly with asbestos. More re cently, however, the focus has shifted to people who work in any environment where asbestos may be present. HVAC workers fall into both categories. The Environmental Protection Agency has reported that while can cer risk from asbestos for people in an urban environment is one in 10,000, the risk for highly exposed construction workers is one in 10. The accuracy of such risk projec tions and what constitutes "high ex posure" can ofcourse be questioned, particularly since experts are far from agreement on what consti tutes a dangerous level of exposure. There are documented cases of death resulting from only inci dental exposure to asbestos. At the other end of the spectrum, research in an asbestos mining town where the air is laden with asbestos part icles showed that this posed no sig nificant health problem. However, what is indisputable is the fact that workers continue to die lia, and South Africa. There are five from asbestos related diseases. Cur major types of asbestos: rently, more than 8000 die each Chrysotile (white asbestos). year, and by the year 2000, sci Crocidolite (blue asbestos). entists believe that figure will reach Amosite (brown asbestos). 10,000 a year. Anthrophyllite. Unfortunately, HVAC workers TVemolite. find themselves full-square in the Historians trace the first use of middle of this controversy. It has asbestos back to the 5th century BC been over a decade since workers when it was used as lamp wick. Tou installed asbestos insulation on and ted as the miracle fiber of the 20th around HVAC systems. But most of century, its mechanical strength, what they did install remains in fire resistance, flexibility, and good ^>lace, endangering the health of wear characteristics made asbestos those who now must repair and the mineral of choice in a wide vari maintain those systems. ety of products from construction To avoid a repeat of the tragedy materials to clothing. that befell those who installed as Asbestos was used commercially bestos containing materials, today's as fireproofing as early as the 1890s. HVAC worker should have a full un The use of asbestos in insulation derstanding of the issues sur materials began in England early in rounding asbestos, what it is, where the 1900s and continued through it's found, when it is dangerous, and the mid 1970s in the United States. how it should be dealt with. At the height of its popularity, What is asbestos? more than 3000 commercial appli cations of asbestos were in use. Its Asbestos is a generic term for a low cost and the ease with which it group ofnaturally occurring fibrous can be mixed with binders and minerals. Asbestos is virtually inde spray applied created applications structible. When separated or bro for millions and millions of tons of ken down, even to its molecular the mineral. level, asbestos remains an extremely Asbestos' ability to be woven into tough fiber. This characteristic is thread or cloth made asbestos pop asbestos' greatest attribute--and ular in fire resistant clothing, cur its tragic flaw. tains, and draperies. Its fire and Asbestos is mined all over t}ie heat resistant properties provided world and is found primarily in innumerable uses for asbestos as an Canada, the Soviet Union, Austra extremely versatile building mate- Heating/Piping/Air Conditioning* February 1987 33 * Asbestos menace rial. It is believed that at least one asbestos containing product can be found in virtually every building constructed from 1900 to the mid 1970s. Promise turns to disaster The promise of this "miracle fi ber" turned to disaster after nearly 100 years of modern use when in the between asbestos and disease was also established by medical re searchers in the United States. But again, the problem was considered an occupational hazard that could be controlled by controlling the lev els of dust in the manufacturing en vironment. "' This assessment of the problem was supported in a 1945 study of Table 1 --Types of asbestos most commonly used. Chrysotk Amosite White asbestos 901 of usage High tensile strength Good overaH workability Used in fireproofing and insulating materials Brown asbestos Coarse, good Good acid resistance Less flexible and workable than chrysotile Used principally in high temperature products Croddolta Blue asbestos High tensile strength Acid resistant Low resistance to heat Good flexibility and fair workability - mid 1970s asbestos was proved to be a cancer causing agent. While the useful properties of as bestos were known for centuries, it was not until the early 1900s that asbestos became suspect as a poten tial health hazard. Early warnings ofasbestos related health hazards in the workplace focused on the Brit ish textile industry where heavy concentrations of asbestos-laden airborne dust were common. The first connection between as bestos dust and disease was pub lished in a British medicaljournal in 1906, and in 1924 the first known case of asbestosis (a lung disease) was documented. In 1930, Dr. E. R. A. Merewether, a British govern ment factory inspector, published a study that solidified the re lationship between disease and heavy concentrations of asbestos dust in textile plants. Heavy concentrations of dust, as opposed to asbestos itself, seemed to be the culprit. As a result, in 1931 regulations were put in place to in crease ventilation and thereby de crease visually obvious dust in the environment. As yet, no direct con nection between asbestos and can cer was made. By the late 1930s, a correlation pipe insulation/covering operations that concluded that this operation was relatively safe. However, sub jects of the study had been at their jobs less than 10 years whereas as bestosis symptoms take 10 to 20 years to become apparent. . It was not until 1965 that a true link between asbestos and cancer was established. In *that year, Dr. Irving Selikoff studied over 1500 in sulation workers who had been at the trade for a significant length of time. Selikoff found that of workers with more than 40 years in the in dustry, more than 90 percent had asbestosis related medical prob lems. The real scope and magnitude of the problem were beginning to be recognized. Since that time, asbestos has Table 2--Categories of asbestos containing materials. Friable materials are those that can be crumbled, pulverized, or reduced to powder in the hand, readily releasing fibers with minimal mechanical disturbance. friable__________ NontriaWe Sprayed-on Cementitious fireproofing products Thermal insulation Paper products Textiles______________ Roofing felts been identified as one of only eight known naturally occurring cancer causing agents. All five types of as bestos can cause cancer. There is no "safe" type of asbestos. The regulatory environment By 1973, the government moved to ban asbestos containing materi als from new construction. In that year, the EPA Clean Air Act pro hibited spraying of asbestos con taining materials. In 1975, all asbes tos was banned from use in pipe, boiler, and other types of thermal insulation. In 1976,.Occupational Safety and Health Administration (OSHA) standards mandated removal for applications where asbestos fibers 5jt or longer were present in the at mosphere with a density of two fi bers per cu cm or greater. Recently, allowable limits were reduced to 0.2 fibers per cu cm. These two agencies, OSHA and the EPA, are in the forefront of reg ulation regarding asbestos control. OSHA regulates exposure to asbes tos in the workplace, and the EPA regulates the use, removal, and dis posal of materials containing asbes tos under authority of the Clean Air Act and Toxic Substarices Control Act. EPA regulations focus primarily on applying and removing asbestoscontaining materials in new or re modeled buildings and on identi fying friable asbestos in schools. There are no federal require ments mandating tests to deter mine asbestos levels in commercial buildings unless building reno vation or asbestos removal is planned. When renovation or removal is planned, EPA regulations call for filing notice with the agency's re gional office and sometimes the state if more than 260 ft of asbestos pipe insulation or 160 sq ft of asbes tos surfacing material will be re moved. The notice must name the building's owners, location, and de scription; how the removal will be done; and where the asbestos will be disposed. 34 Heating/Piping/Air Conditioning February 1987 When problematic asbestos is identified in a building or reno vation is planned, the federal stan dards governing asbestos control are lengthy, detailed, and quite spe cific. Also, many states are estab lishing or strengthening existing training and enforcement programs for asbestos removal. Fourteen states have certification programs, and 15 others have bills pending in their legislatures. A dozen states al ready have licensing and training requirements for asbestos removal contractors, although only four of these have been in force for over a year. When it is dangerous Asbestos is virtually everywhere: in auto brake linings, in electric hair dryers, and in nearly every building constructed from 1900 to the mid 1970s. Asbestos-containing materials are found on ceilings, walls, and structural beams where they were sprayed or trowled on. Asbestos is also common as insulation around hot or cold pipes, ducts, boilers, and tanks. It is also found in many building materials such as tile and wallboard. Sprayed-on asbestos and asbes tos in pipe insulation are of greatest concern to the owners of commer cial/industrial buildings and the people who service their HVAC sys tems. It is in these applications that asbestos is most often in a danger ous state. Asbestos is dangerous only when it is "friable," that is, old and crum bling. In its friable state, asbestos can be crumbled, pulverized, and reduced to powder in the hand. Fri able asbestos does not have to be visible as airborne dust to be dan gerous. Minimal disturbance re leases microscopic asbestos part icles into the air that are so light they may take days to settle. Asbestos-containing materials that are usually considered nonfriable include cementitious prod ucts, paper products, and roofing felts. Categories of materials that are likely to become friable with Asbestos insulation on piping and ductwork is hazardous in a triable condition when it can be crumbled or reduced to powder by hand pressure alone. time include sprayed-on fire proofing, textiles, and all types of asbestos-containing insulation. Experts agree conservatively that 1 million tons of friable asbestos materials are in schools, shops, of fices,'and industrial buildings as thermal and acoustic insulation. It has been estimated that 21 million living Americans have been exposed to asbestos in the workplace. Routine activity, including the installation of phone lines, HVAC system work, and general mainte nance, can free asbestos into the air, endangering workers and building occupants. Dangerous amounts of asbestos can also be freed into the. atmosphere in and around a build ing during renovation and related construction. ~ ' ' Asbestos fibers have the tensile strength of steel and are sharper than fine needles. Asbestos part icles are microscopic in size; it would take as many as 1 million fibers laid side-by-side to measure just 1 in. When these fibrils escape into the air, they are easily inhaled or swal lowed. Asbestos fibers that are in haled and enter the lungs stay there for life. They may also enter the blood stream or the lymphatic sys tem where they are transported throughout the body. Asbestos has been linked to as- bestosis; cancers of the lung, es ophagus, stomach, colon, and other organs; and mesothelioma, a cancer of the chest and abdominal lining that is extremely rare except when asbestos is involved. Asbestos ranks second as the leading cause of cancer. Only ci garettes rank higher. Asbestos re Respiratory protection is standard equip ment for workers to prevent the inhalation or ingestion of hazardous asbestos fibers. lated cancer is usually inoperable as1 cancer cells cluster around micro scopic asbestos fibers that lodge throughout the system. As a result, it is almost always incurable. More than 100,000 workers have died as a result of installing asbestos years ago. Leading experts on the subject project at least an additional 300,000 deaths from asbestos re lated cancer in the next 25 years. The dilemma The asbestos abatement industry is headed for increasing attention because of strict state and federal legislation on the books and in the wings. In addition, record court awarded settlements of asbestos re- Heating/Piping/Air Conditioning February 1987 35 Asbestos menace lated lawsuits and the documented health hazards of asbestos are cre ating greater public awareness of the problem. Commercial buildings built be fore 1973 suffer an added penalty. Mortgage lenders, investors, insur ers, and potential tenants are grow ing hesitant to become involved in buildings that contain asbestos. The result is potential economic lia bilities for owners and managers of these buildings. For commercial building owners and managers, the asbestos di lemma assumes two dimensions, safety and economics, both com pounded by the lackvof qualified people who can help. Up to 75 per cent of all asbestos related projects are done improperly, according to estimates of industry experts and federal agencies. Federal and state agencies cited more than 1300 vio lations last year. Most industry observers agree that the high incidence of poor workmanship in asbestos abate ment stems from several factors. Among them are the lack of train ing, the "quick buck" artists who entered the business, and the ten dency of building owners to accept the lowest bid for removal. This ob viously has serious implications for the health and safety of the work crews but also for those surrounding the work area. With large asbestos control con tracts at stake for renovation of commercial and industrial build ings, many contracting firms are vying for success in asbestos abate ment. While there are many reputa ble, experienced, and qualified firms in the business, the concern over asbestos related issues has spa wned numerous "opportunistic" newcomers. Many of these firms are under capitalized, staffed with untrained people, uninsured or underinsured, and generally ill-equipped to do a safe, competent job of asbestos con- trol or abatement. For some of them, the path to contracts is the low bid. But for their clients, that path could lead to health dangers, lawsuits, and eco nomic disaster. It's easy to take shortcuts on an asbestos removal project. Since health effects of shoddy practices may not show up for decades, it is sometimes difficult to know exactly when or how the poor work was done when it is less than obvious. The work of unqualified con tractors has given rise to many hor ror stories about inept and danger ous practices. For example, workers have been seen gathering up asbes tos debris with brooms "the way you clean up your garage," an EPA offi cial told the Wall Street Journal. In another example, asbestoscoated workers-tramped into a building cafeteria for lunch, ex posing the diners, cafeteria person nel, and the food to significant haz ard, not to mention the danger the asbestos workers themselves were courting. The insurance environment The hesitancy shown by many owners of older buildings to reno vate, by lending institutions to fi nance, and by insurers to cover the work is due in no small part to the ever present possibility that some How to identify asbestos I All sprayed-on firoproofing and insulation materials used p-ior to the early 1970s have a good chance of containing some type of asbestos. Sprayed-on ! fireproofing is usually found on j ceilings and/or above suspended j ceilings in all types of buildings. Thermal insulation products i such as steam and cold water j piping and boiler insulation are | found in many commercial and I industrial buildings. day liability claims for asbestos re lated illnesses may be filed. Adding to that concern is the way all insurers are now writing liability policies. Major changes in the in dustry in recent years have been triggered by the hundreds of mil lions of dollars paid to settle asbes tos related claims on policies 30 or 40 years old. By one estimate, asbes tos related settlements could cost insurance companies up to $87 bil lion in payouts over the next several decades. This has led to a big difference in the types of policies insurers are now writing. The insurance indus try is shifting from the long-term liability coverages of "occurrence" type policies to short-term "claims Well protected, well trained technician ap plying wetting agent to asbestos prior to removal. 36 Heating/Piping/Air Conditioning February 1987 made" type policies. The claims made policy has be come the policy of choice for insur ance companies because the insur ers are responsible only for defense and payment of claims Hied during the short-term period while the pol icy is in force. A claims made policy will not cover claims for injuries or damages filed after the policy has expired--even if the injury or dam age took place during the policy pe riod. Under the terms of an occurrence policy, the insurer pays claims for all injuries and property damage oc curring during the policy period. The big advantage to policy holders is that once the policy is written, claims can be made at any time af terward. These policies cover acts, errors, and omissions that occur during the policy period. The in surer is responsible for paying claims at any time in the future fol lowing an "occurrence"--even after the policy is no longer in force. The difference between the two types of insurance coverage is of par ticular significance considering that asbestos related illnesses typically take up to 40 years or more to man ifest themselves. Simply put, insurance experts agree that occurrence type insur ance affords adequate protection while claims made insurance does not. As this whole issue becomes more volatile, additional changes will oc cur in the types and amounts of in surance available. The insurance in dustry will continue to minimize its long-term liability by decreasing coverages in policies. This will in crease the asbestos removal con tractors' (and their customers') fu ture business related risks. It is, therefore, of paramount im portance for the customer to deal with large, well managed, finan cially stable asbestos abatement contractors. When there are only a few companies left who can obtain occurrence type insurance coverage, it will be this kind of firm that will have it. Abatement, the first step The first step in an asbestos abatement program is risk analysis. Whether the asbestos in a given building is contaminating the envi ronment and posing a real danger can be determined only by an on site audit. While most HVAC workers can probably recognize and identify as bestos, this work is best performed by an experienced and qualified registered industrial hygienist or abatement professional. These peo ple will collect samples of suspected asbestos in a manner that will not disturb surrounding materials and send them to an independent labo ratory for analysis. While any HVAC worker can col lect samples, the danger of the worker being exposed or unneces sarily releasing asbestos fibers into the air while collecting samples is great. Also, a hygienist or other competent professional will know of the best independent laboratories for testing. Once it has been determined that asbestos is present, four factors should be considered prior to decid ing what, if anything, should be done about it. These four factors are damage, friability, location, and air movement. Asbestos causes little concern if it is in perfect condition. If asbestos is found in good condition, leave it alone! However, if the asbestos has been frayed or damaged, it should be either removed or contained. Asbestos also poses a problem when it is located where it may be disturbed by building occupants, maintenance personnel, or the vi bration of machinery or building ac tivity. Air movement around friable asbestos is extremely problematic. Microscopic particles of asbestos are easily transported by the slight est draft or air movement. Considering that significant amounts of asbestos were originally installed as insulation for HVAC components, the danger of friable asbestos entering the HVAC system and circulating throughout an en tire building is great. When asbestos is determined to be problematic by virtue of damage, friability, location, or air movement, an abatement program is in order. Asbestos abatement can constitute one or more of three basic abatement methods: removal, en closure, or encapsulation. The choice among all three tech niques depends on the condition of the asbestos-containing material; i.e., whether is is rated as good, showing minor damage, or poor. Re moval is generally perceived to be the most desirable choice since the other alternatives are considered temporary. Removal can cost anywhere from $10 to $25 per sq ft, a high price in a multi-million sq ft building. Two somewhat lower priced alternatives for asbestos abatement are en- Heating/Piping/Air Conditioning February 1987 37 Asbestos menace closure and encapsulation. Enclosure involves construction of airtight drywalls around the ma terial. Encapsulation is achieved by spraying the material with a seal ant. Neither is recommended when dealing with highly friable asbestos. In this case, proper and safe re moval is the preferred method for eliminating this imminent health hazard. Selecting an abatement firm Once a decision is reached that asbestos abatement--removal, en closure, or encapsulation -- is needed, the next step is to select a qualified firm to do the work. That is not as simple as it may seem. It's not just a matter of looking in the Yellow Pages, asking a few firms for bids, and then choosing the low est. In fact, that may be the worst way. There are, unfortunately, some firms that will low ball ajob, bidding their work at break even or below, merely to gain experience and to train people. Too often, however, they find the project quickly be comes unprofitable. So they seek additional contracts, again low ball ing their bids. Then, to make up for unsatisfactory profit margins, the shortcuts and slipshod and unsafe work begin. To avoid this scenario, an ap proach in pricing asbestos abate ment projects that is growing in popularity is price negotiation as opposed to contract bidding. Larger, more reputable firms are willing to work at a negotiated price. The privacy of negotiations also preserves the confidentiality of a project if necessary. Letting out bids, on the other hand, is a good way to tell the world that a building may have an asbestos related prob lem. The key is to identify a competent organization with a successful track record in asbestos abatement--one that has mastered practices ap proved by regulatory agencies to en sure the safety of tenants, the work ers on the job site, and the surrounding environment. Cleanup of asbestos debris. All work is carried out within containment to prevent the release of asbestos fibers to the surrounding environment. Preliminary packaging of asbestos debris prior to final packaging and shipment to PA approved waste sites. The movement toward in creasingly sophisticated and ex pensive asbestos abatement equip ment is expected to knock smaller, less reputable firms out of the busi ness. OSHA and industry leaders, for example, are backing more rou tine use of Type C equipment, which through a remote air system con tinually creates a negative air pres sure in the containment area, thereby preventing breaches and providing maximum protection to workers inside. Compared to half-masks and per sonal battery powered air packs, this type of equipment is the cream of the crop and an expensive in vestment. Asbestos control firms must be well capitalized and intend to stay in the business to purchase this equipment. And operators must be extremely well trained to use it. Weeding out the less than com petent contractors can still be tricky business. There are several screening criteria that can be ap plied to find the good ones. Insurance -- With the changes taking place in the insur ance industry concerning liability 38 Heating/Piping/Ar Conditioning February 1987 coverage (i.e., the trend toward writing short-term claims made vs. long-term occurrence policies), a copy of the contractor's certificate of insurance should be part of the bid package. Sharp building owners and managers have also begun ask ing for a notarized letter from the contractor's insurance broker stat ing that the contents of the insur ance certificate are in fact authentic and current. The client should ask how much and what kind of insurance the con tractor carries. Since occurrence type policies offer the best protec tion and since they are hard to get, only the large, well managed, and financially stable companies can qualify. Performance bonding--Be cause of the enormous risk that as bestos lawsuits pose, asbestos abatement firms should be bondable for large projects, and the bond should be backed by the U.S. Trea sury. Large, well capitalized, stable firms with a minimum net worth of at least $5 million are the safest partners when undertaking an as bestos abatement program. These are the companies that will remain solvent arid continue in business should liabilities arise. Training--The contractor's asbestos removal personnel must be thoroughly trained, with dangers clearly outlined to them, protective and safety measures presented and explained, and workers tested as to how well they learned. Moreover, on-the-job training and retraining should take place as well as class room instruction. Safety of contractor employ ees-- In addition, the responsible firm does not employ smokers or permit bearded workers on asbestos jobs. Studies have proved that a smoker's chances of developing lung cancer are many times greater than a nonsmoker's. Beards prevent proper respirator fit. Respirators should be approved by the National Institute of Occupational Safety and Health, and full body protec tive clothing, eye protection, head gear, and footwear should also be Wetdown procedures and ven used. tilation methods can be attempted Referrals-- References should to comply with the limit. Ifthese fail be checked for all prospective con to reduce the exposure level to tractors. Some things to ask: How within the standard, respirators big a job was it? Was it done profes must be worn. Employees must also sionally, on time, and within bud be provided with protective cloth get? What kind ofair and bulk sam ing and a changing room. pling were done? Were proper OSHA also stipulates that warn authorities involved as required? ing signs and labels must be used in Were project management and asbestos work areas and on waste worker safety and training satis disposal containers. In addition, factory? employers must monitor the expo Other criteria include the use of sure level and maintain records. insured waste haulers and EPA ap proved dump sites, the ability to Protecting yourself render 24 hr emergency services, Asbestos abatement is serious third party verification of compli and dangerous work--too serious ance with federal and other guide and too dangerous to ever be consid lines, and the contractor's ability to ered as part of HVAC work. Once perform confidentially. asbestos enters the lungs, it stays The hitch there forever. While no minimum dangerous exposure to asbestos has Where problematic asbestos is been established, once may be identified, it must be dealt with; enough. that's the law. However, there is as HVAC workers who smoke should yet no federal directive requiring as never work around asbestos. Smok bestos audits, monitoring, or test ing and asbestos have a synergistic ing in commercial or industrial effect on increasing the risk of can buildings unless renovation is , cer. Experienced asbestos abate planned. For that matter, it is not ment contractors have a policy of even required that owners deter not hiring smokers because it has mine whether a building has aisbes- been shown'that smokers are 50 to tos-containing materials. 90 times more susceptible to asbes How then can HVAC workers, or tos related lung cancer than non any employee, protect themselves smokers. The message to others from this menace? The answer is who work in areas where asbestos found in OSHA's Occupational may be present is clear. Safety and Health Act. In addition, HVAC workers with OSHA's Occupational Safety beards should not attempt to work and Health Act includes a general near asbestos even while wearing clause that mandates that employ respirators. Beards prevent proper ers must provide a safe workplace fitting of respirators. for all employees. In addition to this As a final caution, it is an unfortu general clause, OSHA has a number nate fact that many years ago of specific standards for particular HVAC workers installed asbestos, toxic substances, including asbes worked near the installation of as tos. bestos, or handled asbestos in the An employee may not be exposed course of routine work and thus to over 0.2 fibers of asbestos per cu were exposed to its dangerous ef cm of air averaged over an 8 hr day. fects. Do not repeat this exposure In addition, OSHA has specified an by working on or around asbestos "action level" of 0.1 fibers per cu cm removal. of air averaged over 8 hr. If this level is exceeded, employers must begin First line of defense air monitoring, employee training, The first line of defense in pre and medical surveillance. venting asbestos related health Heating/Piping/Air Conditioning February 1987 39 How To Specify Quiet, Good Looking, YearRound Comfort Start With Mitsubishi Ductless Air Conditioners & Heat Pumps. You'll end up with an installation that is easy, efficient and fast; a SEER rating that will please everyone . . and best of all a satisfied client! A MITSUBISHI ELECTRIC AIR CONOITIONINQ PRODUCTS The new answer to economical, quiet air conditioning featuring Mr. Slim Ductless Split-Type Heat Pumps & Air Conditioners. 5757 Plaza Drive, Cypress, CA 90630-0007 Let us put you in touch. -- . . with the people who really understand the "world" B of design/build and ductless air conditioning and how to get Plus Business with it . . your local 8 Mitsubishi Distributor: B Name Firm_ | Address City.___ _State_________________________ Zip___ I'd also like your latest full line catalog of Heat Pumps and Air Conditioners. n Circle 349 on Reader Service Card 40 Asbestos menace > problems is awareness--awareness of the issues, of what asbestos is, where it's found, when it is danger ous, and how it should be dealt with. Other than building owners and managers themselves, HVAC engi neers, supervisors, and workers are in the forefront of asbestos de tection. While building owners and managers have a moral, ethical, and legal obligation to protect employ ees, it is HVAC engineers, super visors, and workers who are coming into contact with asbestos in the course of day-to-day operations. It therefore rests to a great extent upon these people to develop aware ness and bring potentially prob lematic asbestos situations to the attention of management. HVAC engineers and supervisors in particular should seek the knowl edge and information necessary to become well educated on all issues related to asbestos. Building owners and managers must take the ini tiative to protect employees, but they depend on their HVAC engi neers and supervisors to recognize that a problem may exist that must be dealt with. Where obviously problematic as bestos exists, HVAC engineers and supervisors must work with man agement to find competent people to bring the situation under control. Where asbestos is identified but ap parently in a good nonfriable state, HVAC engineers should work with management to develop a system atic program of monitoring the situ ation. In either case, any and all phys ical contact with asbestos should be performed only by competent pro I fessionals in the asbestos control in dustry. The asbestos problem did not de velop overnight, and it is likely to be B with us for generations to come. Whether the future of the asbestos B problem is to be defined in terms of B sensible, clear headed action or by more needless human tragedy de pends on how willing we are to edu cate ourselves and act responsibly based on that knowledge. fl Heating/Piping/Air Conditioning February 1987 RECEIVED SEP 6 1&5 SPECIAL NOTICE ALERT New Penalty for Asbestos Violation As of September 1, 1D85 TO: All AGC General Contractors and Affected Associate Members Gentlemen: This is a reminder that effective September 1/ 1985, the maximum penalty for violation of the EPA Asbestos Standards will increase from $1000 per day to $25,000 per day! This increase was authorized by the state legislature witJrpacsage of SB 725. Mr. Dallas Evans, Chief of the Air Quality Control Bureau in Houston, said recently an automatic fine will be issued in every case, which appears to be consistent with the firm approach the Bureau has taken in all cases to date. General Contractors who have experience in dealing with Asbestos have found the following steps to be helpful. We offer them as general guidelines only. Attempt to determine early in any job involving demolition or remodeling whether there is any asbestos in the structure {attached is a list of common areas where asbestos can be found). Take samples of suspicious materials to a commercial lab for testing. Normally results can be obtained from these lab,s in 24 hours. ' If there is asbestos, notify the building owner immediately. It is preferable that the owner then make arrangements directly with a competent "asbestos abatement contractor". However, if he insists that you handle it, the key is to select a qualified asbestos abatement contractor who is thoroughly familiar with the EPA requirements. The AGC can assist you with a list of such contractors that you can provide to the building owner or use yourself. M0USI0N CHAPTER/ASSOCIATED GENERAL CONTRACTORS Of AMERICA. INC. P0 BOX 662. HOUSTON. TEXAS 77001 0662 (713) 659-4846 2- - The asbestos abatement contractor will need to notify Hr. Evans' office (645-5316) at Air Quality Control Bureau, describing the amount of asbestos and what they need to do with it (remove or capsulate). The Bureau requires at least 10 days notice before abatement work can begin in the case of large amounts and 20 days notice in the case of routine or small amounts.. Hence the importance of determining early in the job if you are dealing with asbestos. Along with all the standard documents involved in subcon tracting it is recommended that both the owner and the general contractor also receive fxom the asbestos abatement contractor the following: a. Copies of the results of air sample tests that show the number of fibers, taken immediately before the abatement process begins. - b. Copies of the results of air sample tests that show the number of fibers, taken during the job. c. Copies of the results of air sample tests that show the number of fibers, taken immediately after the joo is completed, and d. In the case of removal, copies of the certificate of disposal from a dump site approved by the EPA. These should be kept as permanent job records. If superintendents or foremen open up a suspicious area during demolition or remodeling, they should cease work immediately until the materials can be analyzed. The Chapter Safety Committee is planning a seminar with Hr. Evans and abatement experts for early October. The purpose will be to help superintendents, foremen and field engineers avoid the potentially staggering penalities of the law. . Again, the purpose of this bulletin is only as an alert, and these suggestions are as guidelines only, not as advice in any sense. As this is a new area and the potential consequences are so severe we recommend you check directly with Mr. Evans' office at the Air Quality Bureau (645-5316). Best regards, DL: jg Diqk\l,ewis Executive Director  COMMON AREAS WHERE ASBESTOS CAN BE FOUND A) Fireproofing 1. Steel columns 2. Steel beams 3. Steel decking (underside) B) Lagging & Insulation 1. Boiler breeching & flue 2. Domestic hot water heater 3. Domestic hot water storage tank 4. Hot water piping C) Acoustical tile & wallboard D) Cement asbestos panels E) Transit roofing F) Transite pipe, primarily water & sewer G) Asbestos siding H) Vinyl asbestos tile I) Asphalt asbestos tile - J) Chemical laboratory tops (usually black) K) Roofing felts L) Auditorium curtains