Document R02LDnxD04gLyXreBppX6KEE

:r-S $>: ,.<T:: 2^ - UNTIL STUDIES INDICATE THAT ASBESTOS EXPOSURES DURING ROOFING PROJECTS ARE WITHIN ACCEPTABLE PARAMETERS. CONCERNS OVER THE PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT MUST REMAIN FOREMOST IN THE MINDS OF ROOFING PROFESSIONALS By Robert D. Schmitter and Mark L. Demyanek 56 ROOFING MATERIALS oncerns about the potential roofing worker cuts, saws or tears Chealth effects related to asbestos roofing material during removal or re exposures, as well as increased covering operations. liability, have led government andCurrently, there are no federal industry officials to closely scrutinize regulations that specifically address the renovation and demolition prac asbestos exposures during roofing tices that may disturb asbestos- projects, although the industry as a containing materials (ACM), Until whole falls under the U.S. Depart recently, little attention has been ment of Labor's Occupational Safety given to asbestos-containing roofing and Health Administration's (OSHA) materials (ACRM) and the potential asbestos standards for the construc worker exposures to elevated concen tion industry. Specifically, the OSHA trations of airborne asbestos fibers Asbestos Standard 20 CFR 1926.58 during roofing tear-off or re-covering applies to the removal, encapsulation, projects. " alteration, repair or maintenance of Although its use is gradually decreas structures, substrates or portions ing, and may be banned altogether if thereof that may contain asbestos.2 an Environmental Protection Agency Certainly, however, many roofing (EPA) proposal becomes law, asbestos projects may fall under at least one of has been used in a variety of roofing these categories. products. These products include While federal regulations have pre roofing felts, mastics, base flashings, viously forgotten, ignored or tokenly asbestos-cement shingles and asbestos- addressed asbestos in roofing, some cement tiles. The most commonly states are now taking a closer iook at used form of asbestos in roofing prod the potential for exposure to airborne ucts is chrysotile. Asbestos has been asbestos fibers during roofing tear-off used in roofing felts since the 1930s, and re-covering projects. As a result and constitutes as much as 86 percent of this policy re-evaluation, many of the dry felt weight.1 The potential states are beginning to require that for asbestos exposure occurs when a asbestos abatement contractors and Asetsios issues 99-APeii roofing contractors who become asbestos roofing contractors be fully licensed to perform work on ACRM. Fbr example, Georgia's Asbestos Safety Act was recently amended to include the licensing of asbestos contractors and the certification of asbestos roof ing forepersons. In order to become a licensed asbestos roofing contractor concentrations greater than OSHA's permissible exposure limit (PEL) of 0.2 f/cc.4 In addition, the latter group re-states the opinion of OSHA and the National Institute of Safety and Health (NIOSH) that there is no proven "safe'' level of asbestos exposure. In addressing the removal of roofing felts. OSHA acknowledges Contractors should keep in mind the lad that no two projects are identical and, therefore, interpretations of similar' projects may be subjective" in Georgia, a person must successfully complete either an EPA-approved con tractor supervisor course in asbestos abatement procedures (in addition to passing a 100-quesuon multiple-choice examination), or a state-approved three-day training program on pro cedures and practices for dealing with ACRM (plus passing a 50-question multiple-choice examination) based on the Georgia Model Curriculum.3 Persons successfully completing the five-day contractor/supervisor course and exam are eligible to perform asbestos abatement inside a building, as well as on a roof. In comparison, those who successfully complete the three-day course and exam specifically for handling ACRM are only licensed to perform abatement projects involv ing roofing materials.4 Currently, a controversy exists about whether airborne asbestos fiber con centrations become elevated enough to warrant concern over exposure levels during roofing operations. The two opposing sides argue whether personal protective equipment, includ ing respirators, should be required for roofing workers. The roofing industry itself is divided as to the hazard potential. Those who claim that no hazard exists have produced numer ous air monitoring studies indicating that airborne fiber concentrations fall below the OSHA action level of 0.1 fibers per cubic centimeter (f/cc) based on an eight-hour time-weighted sampling period. Those who charge that concern over asbestos exposure on roofing projects is legitimate have produced data showing airborne fiber that engineering controls will not reduce asbestos exposure below 0.2 f cc (the PEL) in all instances, and that respirators will be required in those situations.6 Additionally, OSHA states that evidence in the construc tion industry indicates that installa tion of asbestos roofing papers and felts causes difficulty in meeting an exposure level below the current PEL without the use of respirators.7 At the heart of the exposure contro versy lies the argument regarding the relative friability of roofing products such as felts, base flashings, asbestoscement shingles and asbestos-cement tiles that are considered non-friable. Yet. as a result of the weathering of these materials during the expected life-span, some of these products may not retain their original structural in tegrity and may even become brittle. Also, the question of friability be comes more of an issue when it comes to implementing those procedures necessary to tear off a roof, such as the use of roofing saws. The current National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations address only the release of asbestos fibers from friable materials. Although the definition of "friable'' m the regulations is relatively clear, a problem arises over the interpretation of whether nonfriabie materials have the potential to become friable through the implemen tation of various work practices. An EPA memorandum from the Of fice of Air Quality Planning and Stan dards dated Dec. 5, 1985. addresses the application of the NESHAP requirements to the removal of nnn- friable asbestos-containing materials. Basically, the interpretation given in the memorandum is that if any nonfriable asbestos-containing material becomes friable during a renovation or demolition project, the NESHAP requirements apply to that project. This includes the "no visible emis sions" provision, the use of wet methods to reduce fiber generation and the proper disposal techniques. Additionally, the notification require ments outlined tn the regulations would become applicable. Under the OSHA asbestos standards, initial employee exposure monitoring must be undertaken at the beginning of each project where asbestos materi als may be disturbed. The two excep tions to this requirement are: 1 it can be demonstrated that the asbestos fiber concentrations released will remain less than the action level (0.1 f cc); or 2. exposure monitoring results from similar projects with workplace conditions that resemble the processes, types of material, work practices and environmental condi tions of that project show exposure levels below 0.1 f/cc. However, con tractors should keep in mind the fact that no two projects are identical and. therefore, interpretations of `similar'' projects may be subjective. Most of the personal air samples col lected during roofing projects have been analyzed using phase contrast microscopy (PCM). Under the OSHA regulations, analysis of personal samples is required to be completed using the OSHA Reference Method, or an equivalent, which specifies PCM analysis The drawbacks of using PCM for the analysis of air samples for the presence of asbestos are well known-- the method is not specific for asbes tos nor can it detect fibers thinner than approximately 0.25 microns. To date, only a handful of detailed studies using transmission eiectron microscopy (TEM) for analysis of per sonal and area air samples on roofing projects have been completed, in the future it will be necessary to continue these research efforts in order to accomplish the goal of establishing an asbestos-specific index of worker exposures Until such studies indicate that exposures to asbestos during roofing projects are within universally acceptable parameters, concerns over the protection of human health and the environment must remain in the minds of roofing professionals. I 50 ASKSlOS ISSUES "9P-APWI. <: Robert D. Schmitter is an eninron- menial scientist with the Asbestos . programs Group of the Georgia Tech ! Research Institute. He was one of the \ developers of the "Asbestos Abatement j Projects in the Roofing Industry" ; course at Georgia Tech and has co- j directed this and other asbestos related courses : Mark L. Demyanek is the leader of ' the Asbestos Programs Group at Georgia Tbch Research Institute. He is . also the director of the PA-spon$ored .Asbestos Training and Information ' Center at Georgia Tech. Demyanek is core certified in the practice of in- . dustrial hygiene by the American . Board of Industrial Hygiene and in safety by the Board of Certified Safety ; Professionals of the Americas : REFERENCES 1 Information distributed by the Roofing In- , dustrv Educational Institute. Englewood. Colo 2 I'.S. Department of Labor Occupational : Safety and Health Administration. June : 20. 1986 29 CFR Parts 1910 and 1926. ; Occupational Exposure to Asbestos. Tremohte. Anthophylhte and Achvolile: ' Final Rules and Notice. Fed Reg. V'ol 51. Rules and Regulations, p. 22756 3 Georgia Asbestos Safety Act. .Amendments , to the Rules of the Asbestos Licensing Board Filed Sept 13 1988 Chapter -52-53. Licensing and Certification. Sect. 52-3- 04. 4 Bradford. M Program Manager Asbestos Licensing and Certification t nit. Environ mental Protection Division. Georgia Department of Natural Resources, per- Nonal communication 5 Health and Satety Facts. Questions and Answers Concerning .Asbestos Johns- Mam ille Corporation Denver. Colo. (I'n- daied circa 198! ) o V S Department of Labor i ><rupational Safety and Health Administration June 20 1986 29 CFR Parts 19H> and 1926 Occupational Exposure to Asbestos. ' Tremohte. Authophyllite and Actinutile: , Final Rules and Notice. Fed Reg VolSl. : Rules and Regulations, p. 22663. 7 C.S. Department of Labor. Occupational ! Safety and Health Administration. June j 20. 1986. 29 CFR Parts 1910 and 1926. ] Occupational Exposure to Asbestos. \ Tremohte. Anthophyllite and Axtinolite: : final Rules and Notice. Fed. Reg Vol 51. ' Rules and Regulations, p. 22708. 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