Document XJk8nZ8QXRygokJpggRJ9rRG

a Clayton Environmental Consultants No. 23, July 1996 OSHA Issues New Asbestos Standards newsletter by Michael A. Coffman, C.LH Manager, Industrial Hygiene Services Since it was first proposed in April 1984, the revised OSHA asbestos standard has been the subject of much debate. On June 20,1986. in the latest round of that debate, OSHA issued two final rules forasbestos: 29 CFR 1910.1001 forgeneral industry, and 29 CFR 192658 forthe construction industry. In issuing two separate rules, OSHA recognized the difficulties most employers have faced in trying to apply the existing standard (which was intended for fixed places of employment) to construction, renovation, demoli tion, and maintenance work involving asbestos-containing building products. The new OSHA regulations reduce the permissible exposure Emit (PEL) for asbestos from 2 libers (longer than 5 micrometers) per cubic centimeter of air (libers/cc) to 0.2 fibers/cc and establish an 'action level "of 0.1 fibers/cc. In This Issue OSHA Issues Comprehensive Asbestos Standard. ...1 Odor Testing...................... 1 Breakfast Seminar Schedule..........................3 Profile of Vic Hanson.......... 4 Ouantit/ing VOC Emissions....................... 9 PCB Removal....................11 Clayton News Briefs.........12 OSHA has also specified a mandatory reference method for air samping and analysis in both versions of the standard. The sampling and analytical method is essentially the same as the 7400 method proposed by NIOSH in February 1984 (see Clayton Newsletter 16). The principal difference between the NIOSH 7400 method and the OSHA reference method (ORM) is the sampling flowrate. Under the ORM, the sampling rate is restricted to 0.5 to 2.5 Lpm, while the NIOSH method permits air sampling at any flowrate above 0.5 (Continuedon Page 6) Dr. Shekar Viswanathancharacterizes odors using organoleptic (sensory) andgas chromatographic techniques. Ah Environmental Dilemma Industrial Odors by S.VIswanathan, Ph.D., P.Eng. and A.W. Gnyp, Ph.D., P.Eng. Windsor Office ...the gas chromatograph/mass spectrometer, has in generalneither the sensitivity nor the discriminative ability ofthe bloodhound...-Carl Sagan. The Dragons of Eden. Even with the considerable advances in environmental analytical techniques, identification and control of industrial odors remains elusive and poses a dilemma. In many instances, success depends more on the investigator's ingenuity, intuition, and experience than on established engineering and scientific principles. Ot the various categories ot air pollutants, odors are the most immediately noticeable in a neighborhood. They generally are (Continuod on Page 2) A Marsh & McLennan Company UCC 006385 S O f t= ;rw 0 ^ie *i OSHA Issues New Asbestos Standards (Continued (mm Page 1j Lpm, with no maximum specified. By standardzing the sampling procedure used. OSHA hopes to reduce the relatively targe inter* laboratory variabilitywhich may partly result Irom different laboratories followingdifferent procedures. r OSHAalso requires that persons performing asbestos analysis attendthe NIOSH course " forsampfing and evaluating airborne asbestos fiber ooncentra- lions, or equivalent. From a practical standpoint, this may turn out to be a formidable task. Although no accurate figures are available, a ratherlarge numberof people are currently engaged in asbestos sampfing and analysis, particularly at asbestos removal jobs. Imparting NIOSH training to all those persons could be a lengthy process. It should be emphasized that C participation in a course alone does not ensure competency in asbestos analysis. Only successful participation in an ongoing rigorous quality control program, such as the AIHA PAT program, can ensure maintenance of proficiency. White OSHA mandates partidpationin such a program, it does not specify V. any performance requirement. Forgeneral industry, OSHA requires that initial air monitoring be conducted prior to October 1986 to evaluate employee exposures. II an employer has already conducted such monitoring after December20.1985, OSHA will acceptthat data. It the initial or subsequent monitoring indicates 8hour, lime-weighted average (TWA) exposures exceeding the action level, monitoring must be repeated every six months. For the construction industry, OSHA requires lhat initial monitoring be conducted at the beginning of each job involving asbestos unless monitoring data from an earlier bul similar project can be presented or it the employer can demonstrate with objective data that employee exposures win not exceed 0.1 fibers/cc. If initial monitoring Indcates 8-hour, TWA exposures above the action level (0.1 fibers/cc), the employer must conduct representative daily monitoring unless all employees are provided with supplied air respirators. Forgeneral industry, when exposures are found to be above the PEL, OSHA requires employers to estabEsh regulated areas and change rooms (including showers), and provide employees with respiratory protection, coveralls, gloves, head and foot coverings, and eye protection, and to develop a written compliance program. The employer is also responsible to ensure that employees showerat the end of thework shift. For employees exposed at or above the action level; OSHA requires annual training of employees and preplacement, annual, and termination-oFemployment physical examinations. Forthe construction industry standard, when exposures are found to be above the EL. OSHA requires the establishment of a regulated area and use of respiratory protection and protective dothing. Forprojects involving removal of asbestoscontaining materials. OSHA (Continuedon Page 7) TABLE 1 s Measured 8-Hour, TWA Exposure Not in excess of 2 fibers/cc (1 OX PEL) pFfimi S / ^ CiT" /w > r'- Not in excess of 10 Ibers/bc (SOX PEL) V Not In excess of 20 fibers/cc .(100XPEL) Not in excess ol 200 tibers/cc (1.000 X PEL) Greater than 200 fibers/cc . (>1,000 X PEL) or unknown Type of Respirator Halt-mask air-purifying respirator equipped with highefficiency fitters Full facepiece air-purifying respirator equipped with high-efficiency filters Any powered air-purifying respirator equipped with high-efficiency filters Any supplied-air respirator operated in continuous flow mode Full facepiece supplied-air respirator operated in pressure demand mode Full facepiece supplied-air respirator operated in pressure demand mode equipped with an auxiliary positive pressure selfcontained breathing apparatus -fi- UCC 006384 Asbestos (Continued Itom Pago 6) requires construction of a decontamination room, clean room, showerarea, and equipment room. Preemployment and annual medical surveillance is required for all employees who may be exposed to asbestos at or above the action level for more than 30 days per year orwho are required to wear respirators. Both standards mandate the selection of respiratory protection basedon measured employee exposures and the criteria outined in Table 1. The standards also require that the employerprovide powered air purifying (PAP) respirators whenever employees request them (provided measured exposures are at or below 20 libers/cc). OSHA requires respirator tit-testing every six months of alt negative pressure respirators. Although OSHA accepts qualitative fit-testing For half-mask respirators, the standards require quantitative fit- testing for other negative pressure respirators. Table 2 contains a summary of the compliance schedule for these regulations.. Forfurther information or assistance, please call our Industrial Hygiene Department. MichaelA Coffman, is Manager ofthe IndustrialHygiene Department in Southfield, Michigan. He hasperformed literally hundreds of asbestos management projects. Mr. Coffman was one of the principal participants in a study on the technologicalfeasibility ofproposed OSHA standards lorthe construction industry, an OSHA subcontract Clayton performed with CONSAD of Pittsburgh, Table 2 Requirement Initial Monitoring Regulated Areas Respiratory Protection Exposures >2 (fee Exposures between 0.2and2f/oc Powered airpurifying Hygiene/Lunchroom Areas Construction plans In use Employee Training Medical Surveillance Written Program Engineering Controls All Other Requirements General Industry 10-20-86 11-17-86 07-21-86 11-17-86 01-16-87 01-16-87 07-20-87 10-20-86 11-17-86 07-20-87 07-20-88 07-20-86 Construction Industry 01-17-87 01-17-87 01-17-87 01-17-87 01-17-87 01-17-87 01-17-87 01-17-87 01-17-87 01-17-87 01-17-87 07-20-86 With asbestos removalprojects on the rise across the country, more and more states are requiring removalcontractors to be certified. 7- - UCC 006386