Document n9dJmZMNBvvYqjKKLrMwpgDY8

STATE OF MICHIGAN s JAMES J BLANCHARD. Governor DEPARTMENT OF PUBLIC HEALTH .1423 N. LOGAN P O. BOX 30195. LANSING, MICHIGAN 48909 Raj M Wiener, Director February 15, 1990 ST0072030 TO: FROM: SUBJECT: Michigan Licensed Asbestos Abatement Contractors, Consultants, and Other Interested Parties Bill DeLiefde, Asbestos Coordinator Division of Occupational Health Bureau of Environmental and Occupational Michigan Department of Public Health Health Amendments of the Asbestos Abatement Contractors Licensing Act (Act 135, Public Acts of 1986) Please be advised that on February 9, 1990, the state of Michigan passed Public Acts 2 through 6 (copies enclosed) which have a significant impact on contractors allowed to perform asbestos abatement work within the state of Michigan and the procedures they must follow before undertaking a project. These acts became effective February 12, 1990. Act 2, P. A. of 1990 Act 2 amends section 207 and adds section 220 to Act 135 of the Public Acts of 1986, which is entitled the "Asbestos Abatement Contractors Licensing Act." Previously, section 207 required that any contractor involved in demolition, renovation, or encapsulation activities involving friable asbestos had to become licensed through the Michigan Department of Public Health (MDPH) as an asbestos abatement contractor. This included plumbers, electricians, mechanical contractors, residential builders, and alteration contractors involved in these types of activities. As a result of Act 2, "licensed" plumbers, electricians, mechanical contractors, residential builders, and alteration contractors are now exempt from the asbestos abatement contractors licensing requirements of Act 135, provided that the asbestos abatement work they perform is incidental to their primary licensed trade and the project Involves no more than 160 square feet or 260 linear feet of friable asbestos containing materials. An example of this type of work would include a plumber who must repair/replace valves or pipes that are insulated with asbestos. 377997 ST007203 I < I V February IS, 1990 Page 2 It must be emphasized that although these licensed trade groups are now exempt from the asbestos abatement contractor licensing requirements as specified by Act 135, they have many other legal obligations under the newly amended Act 135 and Michigan's Occupational Safety and Health Act (MIOSHA) which is referred to as Act 154 of the Public Acts of 1974, as amended. Ir. essence, these groups of contractors must comply with the same legal requirements applicable to licensed asbestos abatement contractors. They must provide project notification and the newly established project fees that will be discussed subsequently in this letter; their workers and project supervisors must be fully trained through Michigan approved/recognized worker (24 hour) or supervisor (32 hour) training courses; the individual workers or supervisors must be accredited through MDFH; they must comply with all applicable requirements under the MIOSHA, NESHAP, and E.P.A. asbestos regulations; and they must assure that clearance air monitoring is performed by a neutral party at the completion of every asbestos abatement project they undertake. Project Notification and Project Fee Requirements Sec. 220 (1) of Act 135, P.A. 1986, as amended, revises the project notification requirements. Licensed asbestos abatement contractors must now. notify MDPH in writing "10 days" before beginning an asbestos abatement project that exceeds 10 linear feet or 15 square feet, or both, of friable asbestos containing materials. Also, written project notifications must include the following information: a). The name and address of the owner of the building or structure. b). The location of the building or structure where the asbestos abatement project will be performed. c). The schedule for the starting and completion of the asbestos abatement project which may not exceed one year in length. d). The amount of friable asbestos materials that will be removed or encapsulated (linear or square feet). With these more specific project notification requirements, MDPH will "mandate" that any changes in the starting or ending date of a project will require immediate notification to the Asbestos Program by phone of these changes followed by a written amended project notification form. Sec. 220 (3) of Act 135, P.A. 1986, as amended, specifies that all projects requiring notification must include a "project fee" equal to one percent (12) of the price of the contract for the asbestos abatement project ar.d shall make available upon request by MDPH, a copy of the contract for the asbestos abatement project. To address both the new project notification and fee requirements, MDPH/DNR have revised the asbestos project notification form (see enclosed copy). c 377998 41 ST007 2032 February 15, 1990 Page 3 The total cost of the asbestos abatement project includes the cost of abatement area preparation, decontamination, installations, enclosures, alterations, removal abatement, and repairs. Examples of total cost may include: wages, materials, waste disposal, associated environmental monitoring, profit, performance bond, insurance, and administrative overhead. The total cost of the asbestos abatement project does not include the cost of re ir.sulat ion. If me final invoice amount charged to the contracting entity for the asbestos related work exceeds the total costs of the asbestos project previously reported on the notification form, additional fee payment in the amount of one percent (II) of that difference must be submitted to MDPH. Within five working days after submission of the final invoice to the contracting entity, the asbestos abatement contractor must submit the additional fee and an amended notification form. MDPH shall issue a refund in the event of an overpayment of the project fee. Emergency Project Notification Procedures Sec. 220 (8) of Act 135, P.A. 1986, as amended, now specifically addresses emergency project notification procedures. As a result, the Asbestos Program will no longer issue nor recognize past emergency "blanket notification" waivers granted to licensed asbestos abatement contractors for asbestos abatement work associated with emergency maintenance and repair operations at specific businesses or corporations in Michigan. Sec. 220 (8) of Act 135 now specifies that emergency asbestos abatement projects (exceeding 10 linear feet or 15 square feet, or both) resulting from equipment failure or malfunctions are now exempt from the 10-day written advance notice required by Sec. 220 (1) of Act 135. However, contractors or the business entity involved, must contact MDPH by phone immediately or as soon as possible after the discovery of the emergency situation. Within 48 hours after commencement of the asbestos abatement project, the contractor must then submit their standard written project notification form and project fee. Obviously, MDPH recognizes that emergency projects of this nature often are initiated during non-standard business hours and therefore, will accept telephone notification during the next day that state offices are open. When projects of this nature are on a "time and materials basis" and the project cost cannot be calculated within 48 hours of commencing the project, the contractor will be required to submit the one percent (II)'project fee and amended notification form to MDPH within five working days after submission of the final invoice to the contracting entity. As specified by Sec. 307 (1) of Act 135, P.A. 1986, as amended, any asbestos abatement contractor that fails to provide the proper project notification or fee specified by this act is subject to a monetary civil penalty not to exceed more than-$10,000 for each violation or day that the violation continues. Project notification forms and fees must be submitted for all asbestos abatement projects initiated after March 5, 1990. 377999 42 ST0072033 * February 15, 1990 Page 4 Acts 3 through 6, P.A. of 1990 Acts 3 through 6 were tie-barred and passed with Act 2 on February 9, 1990. These individual acts grant the authority to the licensing boards of the plumbers, electricians, mechanical contractors, residential builders, and alteration contractors to revoke or suspend these trade licenses for violations of the Asbestos Abatement Contractors Licensing Act, Act 135, P.A. of 1986, as amended. In conclusion, licensed plumbers, electricians, mechanical contractors, residential builders, and alteration contractors wishing to perform asbestos abatement work under the exemption granted in section 207 (2)(A-D) of Act 135, P.A. 1986, as amended, have many legal rules and obligations with which to comply. Failure on their part to understand these obligations not only exposes them to stiff civil penalties and the potential loss of their primary license, but it can also expose them to substantial liability. If you have any questions regarding this letter, please contact the Asbestos Program at (517) 335-8246. JVD:mjb c 378000 43 STATE OF MICHIGAN ST0072050 JAMES J. BLANCHARD. Governor DEPARTMENT OF PUBLIC HEALTH 3500 N. LOGAN P.O. BOX 30035. LANSING, MICHIGAN 48909 Raj M Wiener, Director November 6, 1989 TO: FROM: SUBJECT: Michigan Asbestos Abatement Contractors, Consultants, and Other Interested Parties Bill DeLiefde, Asbestos Coordinator Asbestos Program, Division of Occupational Health Limitation on Glove Bag Usage Within the State of Michigan As many of you are aware, there has been considerable controversy over the past several months regarding the usage and limitations of glove bags for asbestos removal operations under the requirements of the Federal Occupational Safety and Health Administration (OSHA) Asbestos Construction Standard (i.e., 20 CFR 1926.58). The discussions and concerns were prompted by the issuance of citations by Federal OSHA to contractors in Chicago (Region 5) and Seattle (Region 10) for the usage of glove bags on projects exceeding small-scale, short-duration asbestos renovation and maintenance activities as defined in Appendix G of 1926.58. These were also projects where negative pressure enclosures were deemed feasible by Federal OSHA. Michigan's Occupational Safety and Health Act (MI0SHA) program policy on glove bag usage has been that there are no 1imitations jon the usage of glove bags provided that employee exposure levels to asbestos are maintained below the action level (i.e., 0.1 fibers/cubic centimeter). Since the MI0SHA program is mandated by Federal OSHA to implement and enforce occupational health and safety regulations "at least as stringent" as OSHA's, this divergence on glove bag limitations and enforcement policies between the state of Michigan and the Federal government has caused us all great concern. On March 17, and September 20, 1989, the Michigan Department of Public Health received correspondence letters from Mr. Michael G. Connors, OSHA Regional V Administrator, which addressed OSHA's interpretations and enforcement policies pertaining to the usage of glove bags in lieu of a full negative pressure enclosure as specified by 29 CFR 1926.58 (e)(6). 378017 Si mrnt*tp ST007205 I \ November 6, 1989 Page 2 Mr. Connor's March 17, 1989, letter confirmed that standard glove bags could only be utilized on small-scale, short-duration asbestos renovation and maintenance activities as specified in 29 CFR 1926.58 (e)(6)(iv) and Appendix G. Further clarification on the definition of small-scale, short-duration operations was provided in OSHA's instruction directive CPL-2-2.40, dated September 1, 1987. This directive stated that for purposes of the OSHA Asbestos Construction Standard, a small-scale, short-duration operation defined as: 1. Maintenance or renovation tasks, where the removal of asbestos-containing materials is not the primary goal of the job (e.g., repairing a valve which entails the removal of asbestos, installing electrical conduit which must be fastened to asbestos-cement siding, etc.). 2. Activities where employees' exposures to asbestos can be kept below the action level via worker isolation techniques, such as glove bags or other methods described in Appendix G. 3. An operation which has been included in the employer's asbestos maintenance program (as required in Appendix - G) of all employers who are claiming an exemption from the requirements of 29 CFR 1926.58 (e)(6). 4. Nonrepetitive operations (viz.: not a series of sma^l- -- scale jobs, which if performed at one time would have resulted in a large-scale removal). The most recent correspondence from Mr. Connors dated September 12, 1989, included a copy of a letter written to the Brand Companies, Inc., from Mr. Alan C. McMillan, OSHA's Acting Assistant Secretary. Mr. McMillan's letter addressed the usage of a "negative air glove baR" in lieu of the conventional full negative pressure enclosure with decontamination facilities attached. Brand's specific procedures for utilizing a negative air glove bag to remove asbestos pipe insulation were as follows: 1. The poly bag is modified so as to allow make-up air to enter the bag but not leave the bag. This is done with the addition of a poly flap which is taped inside the bag over an opening cut into the bag. 378018 / STATE OF MICHIGAN '1G02L001S C JAMES J. BLANCHARD. Governor DEPARTMENT OF PUBLIC HEALTH 3423 N. LOGAN P.O. BOX 30195. LANSING. MICHIGAN 48909 Raj M Wiener, Director February 15, 1990 TO: FROM: SUBJECT: Michigan Licenaed Plumbers, Electricians, Mechanical Contractors, Residential Builders, Residential Alteration Contractors, and Other Interested Parties Bill DeLiefde, Asbestos Coordinator^)^ Division of Occupational Health Bureau of Environmental and Occupational Health Michigan Department of Public Health Amendments of the Asbestos Abatement Contractors Licensing Act (Act 135, Public Acts of 1986) Please be advised that on February 9, 1990, the state of, Michigan passed Public Acts 2 through 6 which have a significant impact on contractors allowed to perform asbestos abatement work within the state of Michigan and the procedures they must follow before undertaking a project. These acts became effective February 12, 1990. Act 2, P. A. of 1990 Act 2 amends section 207 and adds section 220 to Act 135 of the Public Acts of 1986, which is entitled the "Asbestos Abatement Contractors Licensing Act." Previously, section 207 required that any contractor involved in demolition, renovation or encapsulation activities involving friable asbestos had to become licensed through the Michigan Department of Public Health (MDPH) as an asbestos abatement contractor. This included plumbers, electricians, mechanical contractors, residential builders, and alteration contractors involved in these types of activities. As a result of Act 2, "licensed" plumbers, electricians, mechanical contractors, residential builders, and alteration contractors are now exempt from the asbestos abatement contractors licensing requirements of Act 135, provided that the asbestos abatement work they perform Is incidental to their primary licensed trade and the project involves no more than 160 square feet or 260 linear feet of friable asbestos containing materials. An example of this type of work would include a plumber who must repair/replace valves or pipes that are insulated with asbestos. c 378001 2 25 4/88 Ct f < February 15, 1990 Page 2 C It must be emphasized that although these licensed trade groups are now exempt from the asbestos abatenient contractor licensing requirements as specified by Act 135, they have many other legal obligations under the newly amended Act 135 and Michigan's Occupational Safety and Health Act (MIOSHA) which is referred to as Act 154 of the Public Acts of 1974, as amended. An overview of some of these obligations are as follows: Training and Worker Accreditation Rule 408.1058, Sec. 58, of Act 154, P.A. of 1974, as amended, requires that persons performing asbestos abatement work on the property of someone else, must be trained and accredited as specified by Act 440, P.A. of 1988. This requires that workers receive no less than 24 hours of training and supervisors receive no less than 32 hours of training through a "Michigan approved* asbestos training course. MDPH will also recognize worker or supervisor training courses provided by out-of-state companies that have been approved by the Environmental Protection Agency (EEA) under the authority of the Asbestos Hazard Emergency Response Act's (AHERA's) Model Contractors Accreditation Program. Once the individual worker or supervisor has successfully completed a recognized training course, he/she must then file for individual accreditation as an asbestos worker or supervisor with MDPH before any actual asbestos abatement work is undertaken. Please be advised that under the authority of Act 440, Sec. 17., P.A. of 1988, any ^ individual, partnership, association, corporation, public or private agency, or other legal entity that violates these training or accreditation requirements is subject to civil penalties for each violation or each day that a violation continues in accordance with the following schedule: a). First Violation $ 2,000 b). Second Violation 5,000 c). Third or Subsequent Violation 10,000 Work Practices and Procedures All contractors involved in asbestos removal, demolition, or renovation operations have many potential legal obligations under the MIOSHA Act 154, rule 408.1057 through 408.1060d, and the Federal OSHA Asbestos Construction Standard, 29 CFR 1926.58. These obligations and requirements are covered in the asbestos worker and supervisor courses and include the following subjects: 1). Establishing Regulated Areas 2). Employee Air Exposure Monitoring 3). Required Engineering Controls 4). 'Respiratory Protection Programs 5). Protective Clothing 6). Hygiene Facilities and Decontamination 7). Communication of Hazards to Employees 8). Housekeeping and Waste Disposal 9) . Medical Surveillance 10). Recordkeeping 378002 ST0072035 ST0072036 V, February 15, 1990 Page 3 Project Notification and Project Fee Requirements Sec. 220 (2) of Act 135, P.A. 1986, as amended, specifies that all licensed plumbers, electricians, mechanical contractors, residential builders, and alteration contractors performing friable asbestos removal or encapsulation in an amount exceeding 10 linear feet or 15 square feet, or both, shall notify the MDPH of the asbestos abatement project "before* it begins. Contact by telephone will suffice these requirements. Certain emergency asbestos abatement vork may initiate in non standard business hours and therefore, must be reported during the next day state offices are open. Not more than 10 days after the discovery, the contractor must then provide written notification to MDPH providing the following information: a). The name and address of the owner of the building or structure. b). The location of the building or structure where the asbestos abatement project will be performed. c). The schedule for the starting and completion of the asbestos abatement project which may not exceed one year in length. d). The amount of friable asbestos materials that will be removed or encapsulated (linear or square feet). Sec. 220 (4) of Act 135, P.A. 1986, as amended, specifies that all licensed plumbers, electricians, mechanical contractors, residential builders and alteration contractors providing a written project notification as specified above must also include a "project fee" of one percent (1Z) of the asbestos abatement portion of the contract price. In addition, the contractor must make available upon request by MDPH a copy of that portion of the contract covering the asbestos abatement work. The total cost of the asbestos abatement project includes the cost of abatement area preparation, decontamination, installations, enclosures, alterations, removal abatement, and repairs. Examples of total cost may include: wages, materials, waste disposal, associated environmental monitoring, profit, performance bond, insurance, and administrative overhead. The total cost of the asbestos abatement project does not include the cost of reinsulation. If the final invoice amount charged to the contracting entity for the asbestos related work exceeds the total costs of the asbestos project previously reported on the notification form, additional fee payment in the amount of one percent (1Z) of that difference must be submitted to MDPH. Within five working days after submission of the final invoice to the contracting entity, the asbestos abatement contractor must submit the additional fee and an amended notification form. MDPH shall issue a refund in the event of an overpayment of the project fee. As specified by Sec. 307 (1) of Act 135, P.A. 1986, as amended, any contractor that fails to provide the proper project notification or project fee specified above, is subject to a monetary civil penalty not to exceed more than $10,000 for each violation or day that the violation continues. Project notification forms and fees required for projects exceeding 10 linear feet or 15 square feet, or both, of friable asbestos containing materials must be submitted for all asbestos abatement projects initiated after March 5, 1990. 378003 February 15, 1990 Page 4 c Clearance Air Monitoring As specified by rule 408.1060b, Sec. 60b. of Act 154, P.A. 1974, as amended, all contractors performing asbestos abatement work (i.e., friable asbestos removal or encapsulation) on the premises of another person oust assure that a post abatement air monitoring check is taken at the completion of the asbestos abatement project by a neutral party. These projects cannot be declared complete until the level of asbestos fibers per cubic centimeter of air (f/cc) is confirmed to be no greater than 0.05. In addition, clearance air monitoring results must be submitted to MDPH for all projects exceeding 10 linear feet or 15 square feet. Air monitoring results should be clearly labeled so they can be united with the written notification previously submitted. Acts 3 through 6, P.A. of 1990 Finally, Acts 3 through 6 were tie-barred and passed with Act 2 on February 9, 1990. These individual acts grant the authority to the licensing boards of the plumbers, electricians, mechanical contractors, residential builders, and alteration contractors to revoke or suspend these trade licenses for violations of the Asbestos Abatement Contractors Licensing Act, Act 135, P.A. of 1986, as amended. In conclusion, licensed plumbers, electricians, mechanical contractors, residential builders, and alteration contractors wishing to perform asbestos abatement work under the exemption granted in section 207 (2)(A-D) of Act 135, P.A. 1986, as amended, have many legal rules and obligations with which to comply. Failure on a contractor's part to understand these obligations not only exposes them to stiff civil penalties and the potential loss of their primary license, but it can also expose them to substantial liability. If you haveany questions regarding this letter or would like copies of our rules, worker accreditation applications, project notification forms, or lists of worker/supervisor training courses in Michigan, please contact the Asbestos Program at (517) 335-8246. JVD:mj b ST0072037 378004 ucmgui strumerr of turuRM. resources NOTIFICATION mcmgm otruman of wax icatm AW QUALITY DIVISION OF INTENT TO RENOVATE/DEMOUSH ASBESTOS PROGRAM \ (PleasO Type or Print In In*. Insaucdons on the Reverse Side) DNR/UDPH USE ONLY n Sant Pursuant to: NESHAP, 40 CFR. Part 61, Subpart M Xerox to:______________ Fax to: MAH. TO: ASBESTOS NOT1F1C. COOfl. AND U.S. EPA REG. V Postmark Oats:________ . Rac'd Oats:. c DNR. AIR QUALITY DIV. P.O.Box 30028 5AO-2S-1 Asb. Coof. 230S. Oeartom Confrlnsp. TNs FY____ NodfSc. Ravld: OK . Dot Latter Sene _______ _Rasp. Duo: _____ Sand Oaf. Latter ________ AM: Lming. Ml 48909 CNca0O.L 80604 Entarsd on Oof. Log:___ .Entered on Rac'd Log: For Projects In Wayne County Sand Nobca To: FOLLOW UP Oats:____ _Rev. Due: .AM: Wayne Co. HaaBi Dept. Air Poludon ConM OMNon 6________ Transcacdon# 2211 E. Jeftarson, Detroit U 48207 If Sent Pursuant to: Sac. 220 (1-4) or (I). Public Act 139 (X1966, aa Comments: Spoke wf MAIL TO: MDPH, OOH - Asbestos Program 3423 N. Logan SL, P.O. Box 30195 Lansing. Ml 48909 IIDPH Asbastoa Project Fee (To obtain IX Project Fee rrxidpty Total Project Cost by 0.01) Total Project Cost IX Project Fee: x0.01 Ucsnaad Asbastoa Abatement Contractors Plumber Lie.# Electrical Lie.#. Licensing Authority: Lie.# Bidders Lie.# 1. Assiranrr Cownucroa: _ fcteiing Address;_______ CJty/Stata/Zp;. Conact Dtaounoa Cotmucrort: Maiing Address:______ . Phone: ( )_ PLEASE CHECK ALL THAT APPLY I 1 MPOH> 10 day nodes (>10 ktftor IS sq It) I I DNR/EPA Renovedan (at least 2G0 In ft or 160 sq ft) I I DNR/EPA Demeidon-10 day nodes (at toast 260 In ft or 160 sqft) DNR/EPA Demoition* 20 day nodoe (<260 In ft or 160 sq ft) Ctty/Ststa/Zjp:. Conact______ Name of Facility Owner_ ^ Maiing Address:_______ Cdy/sas/Zip:_ Contact: :( -< ). Dado of Nodfiesdon Date of Revision (V appicabie). For Ouasdons Regandng trdormadon Piwtded. Contact, Phone: ( 3. FacStyNama^. Street Address (or description oflocadon): ________________ City/State/Zip;_______________ 4. Estimate oI Amount of Friable Asbestos to be Removed: On Pipe:___________________________________________ Surface Area:. -- inoar toot .square feet 5. Fadrty Size (sq ft): FacOtyAge:-------Facfity Use:____ 6. If demoiton involving toss Son 260 inear teat or 160 squats feet, exptain tecriniquee of esdmadon:. CO --I CD CD ro CD GO CO 7. Nature at Removal (example: ceSng. boter, piptng^te.): Mediod(s) of Removte (example: cut andtor scrape hand toote, glove bag. efe):. Methods of DemoWon (example: wrecking bad, buddozer, etc.):. 8. Dates of Asbestos Remarml/Renaradon: Start End: . 9. Emission Control Procedures Dutina Removal: AND Dates of Demotion: (V appicabie) Start End: 10. Emission Control Procedures Dutina Handina: -C- 'iLDisoosaf Site Nanw- Street Address (or description orv^j. Cify/Stata/Zjp- tn S4*l. steeM^ CZTtO) _ 378005 12.If ordered demolition, name and authority of state or local gevommont representative wtio ordered it Phone: ( ) Oil 142 <2/*0> Instructions for Completing the Notification of Intent to Renovate/Demolish Form / The following are only guidelines for completing the notice. The regulations contain other requirements that may apply to your project. For more detailed information in completing the form, please see the `'Guidance for Preparing Asbestos Demolition/ Renovation Notices" pursuant to NESHAP, 40 CFR 61, Subpart M. You may obtain this information from the Department of Natural Resources (DNR) or Michigan Department of Public Health (MDPH). For information regarding Federal and State regulations, please contact the appropriate agency on the front side of this form.' Notification All information pertinent to the removal, encapsulation, renovation, and/or demolition of asbestos containing material must be completed. Please send the completed form to the specified address of MDPH. DNR, Environmental Protection Agency (EPA) or Wayne county as indicated oa the font side of this form. MDPH requires project notification forms and fees for projects exceeding 10 linear feet or 15 square feet, or both, of friable asbestos containing materials. Failure to notify is a violation of NESHAP, 40 CFR, Part 6i, Subpart M and/or Sec. 220 (1-4) or (8) of Public Act 135 of 1986, as amended. DNR and MDPH will accept this form or a facsimile which includes all required information. Abatement Contractor An asbestos abatement contractor is a person, partnership, firm, association, corporation, sole proprietorship, public or private agency, or other legal entity, which carries on the business of asbestos abatement on the premises of another business entity as defined by Section 103(d) of Act 135, PA. i486. This definition is applicable to plumbers, electricians, mechanical contractors, residential builders, maintenance and alteration contractors, as well as Licensed Asbestos Abatement Contractors. Other categories All other categories listed on the front side of this form (1-12) should be self explanatory. However, if additional information is needed, please consult the "Guidance for Preparing Asbestos Demolition/Renovation Notices." MDPH Asbestos Project Fees Submit protect fees to MDPH onto. Project fees are only required for projects that exceed 10 linear feet or 15 square feet, or both. One-percent (1.0%) of the total cost of a project most be submitted by all asbestos abatement contractors (as defined in the Abatement Contractor paragraph above). The total cost of an asbestos abatement project includes the cost of abatement area preparation, decontamination, installations, enclosures, alterations, removal abatement, and repairs. The total cost of the asbestos abatement project does not include the cost of reinstallatioa nor does it include non-asbestos related costs, (i.e. cost to repair a boiler, or string electrical cable). Any questions or information regarding fees should be addressed to MDPH only. Please remit the fee in the form of a check or mooey order payable to the Stale of Michigan. Attach the check to the notification form so it will not become separated. Please, do not send cash! Should you have questions or need additional information, please contact: Asbestos Notification Coordinator DNR, Air Quality Division P.O. Box 30028 Lansing, MI 48909 (517) 373-7064 378006 Michigan Depatment of Public Health DOH - Asbestos Program 3423 North Logan. P.O. Box 30195 Lansing. MI 48909 (517) 335-8246 ST0072039 STATE OF MICHIGAN \ ST 1)072040 C JAMES J. BLANCHARD. Governor DEPARTMENT OF PUBLIC HEALTH 3423 N. LOGAN P.O. BOX 30195. LANSING. MICHIGAN 48909 Raj M Wiener, Director February 13, 1990 TO: FROM: SUBJECT: Trade Associations and State and Municipal Licensing Programs for Plumbers, Electricians, Mechanical Contractors, Residential Builders, and Alteration Contractors James V. DeLiefde, Asbestos Coordinator Division of Occupational Health Bureau of Environmental and Occupational Health Michigan Department of Public Health Changes in Michigan's Asbestos Abatement Contractor Licensing Requirements The attached letter summarizes some very important changes to Michigan's asbestos abatement contractor licensing requirements as a result of the passage of Acts 2 - 6 of the Public Acts of 1990 (copies enclosed). These legislative changes will have a significant impact on future work that Michigan licensed plumbers, electricians, mechanical contractors, residential builders, and alteration contractors perform that involves asbestos removal or encapsulation work associated vith their primary licensed trade. Obviously, it is extremely difficult for the Michigan Department of Public Health to assure that all affected parties receive notification of these new legislative changes. Ve would greatly appreciate any assistance that your organization can provide us in circulating the attached information to affected trade groups you represent. If you have any questions regarding this information, please contact us at (517) 335-6246. Thank you for your cooperation regarding these matters. JVD:mj b Attachment - c Z-25 4/88 378007 Si V 4 / STATE OF MICHIGAN 'IS02L001S JAMES J. BLANCHARD. Governor DEPARTMENT OT PUBLIC HEALTH 3423 N. LOGAN P.O. BOX 30195. LANSING. MICHIGAN 48909 Raj U. Wiener, Acting Director TO: TRAINING COURSE SPONSORS RE: TRAINING OF CONTRACTOR/SUPERVISORS This memo Is to clarify the State's position on the Issue of training an approved worker who successfully completed a 24-hour EPA/State approved course and then allowing that worker to take the last day of the contractor supervisor course within a six month period to become a contractor/supervisor. It Is the Michigan Department of Public Health's (UDPH) position that this practice will not be accepted In the State. The reasoning behind this position are several. First, a student who Initially takes the worker course to become a worker may not view the material In the same context as If he was going to be a supervisor of other workers. Second, the training course sponsor will most likely differ their approach and Intent of each subject taught In the contractor/supervlsor course (l.e. more emphasis will be placed on supervising rather than workIng). Third, although the specific content of each course Is addressed, each Individual trainer has the latitude In determining when and how each subject Is taught. This situation allows for a considerable degree of uncertainty as to the content of the last day of any contractor/supervlsor course. It Is for these reasons that a certified worker wishing to become a certified contractor/supervlsor oust attend and successfully complete an entire 32-hour EPA/State approved course. If you have any further questions regarding this or other course accreditation concerns please contact : Ulch(gan-Department of Public Health DOH - Asbestos Program 3423 North Logan P.O. Box 30195 Lansing. Michigan 48909 (517) 335-9280 378021 72 ASBESTDS TRAINING REQUIREMENTS IN MICHIGAN ST0072055 'ASBESTOS ABATEMENT CONTRACTOR' means an employer who carries on the business of asbestos abatenent on the prenises of another individual (includes homeowner) or employer and not on the Asbestos Abatement Contractors prenises. Projects subject to 29 CfR 1926.58 CeX6> requirements shall be supervised by a 'conpetant person' 32 hours training required/reconnended. Or successfully complete the 32 hour Contractor/Supervisor course. 378022 CJDG-IEC 89) ! 75 ST0072056 Instructions for Completing The Michigan Asbestos Abatement Accreditation Application Public Act (P.A_) 154 of 1974 and P, A. 440 of 1988 require that any individual engaged is asbestos abatement activity in Michiga; apply for and receive a '`certificate of accreditation" from the Michigan Department of Public Health (MDPK) before performing thi activity. The following information must be provided with a completed application for the approval process to begin. Reciprocity Information Sections 10 (7) and 14 of PA. 440 of 1988 require a peraoa properly accredited in a "reciprocal agreement state" to submit a certificati of successful compleaoa of training from the other sates and the appropriate fee for consideration. Please attach the neeessar documentation. Training Sections 4 (1). <Z) and (3) of PA. 440 of 1988 require that applicants seeking accreditation successfully complete appoprine initial and/or refresher training requirements. Please submit poof (Le. copy of training cetificate) indicating that you have successfully completed the required Environmental Protection Agency (EPA) or Michigan appoved training eoune(s). Expgisacc Sections 2 (j) and 7 of PA. 440 of 1988 require (he following experience, where *yearfs) of experience in asbestos-related work* means at least rwenry-Gve percent (25%) of the individual's working dxoe was spent on asbestos-related work, or an equivalent amount of work over mere than one (I) year's time if the work was conducted after January 1,1983: 1) Asbestos inspectors Shall possess at least one (1) year of experience in asbestos-related workor at least five (5) years of supervisory experience in school building operations and maintenance. 2) Asbestos management planners and asbestos project designers shall possess so less than two (2) years of experiencr asbestos related work or at least five (5) years of experience in school building operations and maintenance. 3) . No experience requirements have been designated for asbestos abatement workers or supervisors. Please submit a resume addressing the appropriate experience requiremeres. Fss Schedules Sections 14 (I) and (2) of PA. 440 of 1988 require that an applicant submit to the department the appropriate fee for each area of accreditation or reaccredisuoo. Failure to submit (he appropriate fee constitutes just cause to deny issuance of a certificate. ~ General Information Failure to submit any applicable information will result in the denial of jour application. Upoa approval a certificate of accreditation will be issued to cover a period ofone (1) year. An application for renewal of this heeny must be recaved by the Department no sooner than 90 dars nor later than 30 da vs prior to the eipiratioo date or it wig be considered an initial application. Should this application not be approved, the applicant wdfbe so notified. Please be advised that accreditation fces.wiH not-bejefunded for rejected applications. The accreditation fee is considered by MDPH to be a processing fee. Should you have questions or need additional applications, please contact the Department at: Michigan Department of Public Health DOH - Asbestos Program 3423 North Logan P.O.Box 30195 Lansing, Michigan 48909 (517)335-8229 74 378023 Departmou PubSU Heaivh Qiwmim mi Oca>p*wo*i Utftlih Michigan Asbestos Abatement Accreditation Application (Please type or prim in ink. instructions are on the reverse side.) Applicant Information Hr* Not. M*odic buuM hw Sue Koan.ii iNuaoer ana Oirau) JjpCotc <-*T Social 5eeity Nfirwr Umc t tyino Are you currently, or have you ever been, certified by the State of Michigan in one of the following categories? Please Check the appropriate box(es) and anach a copy of the certificate. Inspector II CootracJot/Supervisor M Management Planner j | Project Designer I 1 Abatement Worker | [ RcoprocrtT Informatiofl Are yoo currently, or have you ever been, certified by a sate other than Michigan to perform asbestos abatement activities? If yes, please specify and attach documentation. . Yes f j No j | ST0072057 Training ' Attach proof of successful completion of EPA or Michigan approved training coursefs) arspecified in the license application in structions fue. copy of training certificates). These certificates most be included to begin the approval process. FeeSchcdnle Check the appropriate box(es) below to indicate the type of wccrcditaaoc and whether this is an initial or a renewal application. Cateporr Inspector Management Planner Projea Designer Contraaoc/5 upervisor Abatement Worker Initial S 150.00 S 150.00 S 150.00 5 25.00 S 25.00 Renew*! 575.00 S75JOO S75J00 525.00 525.00 Total Remittance = Total Initial Total Renewal S : J00 Total Remittance Make check or money order payable to: Return completed application, documentation and remittance to: State of Michigan Please, do not send cash! Michigan Department of Public Health DOH - Asbestos Program 3423 North Logan, P.O. Box 30195 Lansing. MI 48909 I certify that I am the person named above and that all statements arc true. Should I become'accredited. I will comply with all applicable Federal and State regulations. , ` gnuurc rfNM.H.rt W 378024 Date: 73 W ficjno fm