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1851 Full Text OSHA MEMORANDUM ON PROPOSED ASBESTOS RULEMAKING AND DRAFT REGULATORY TEXT OF PROPOSED STANDARDS [Editor's Note: This memorandum, outlining proposed changes to OSHA's asbestos starulards, which was distribut ed to the Advisory Committee on Construction Safety and Health, is in the draft stage only and the agency says it should not be cited as official policy.] MEMORANDUM FOR; ADVISORY COMMITTEE ON CON STRUCTION SAFETY AND HEALTH /s/John F. Martonik FROM- HEALTH STANDARDS PROGRAMS, OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION rator requirements will result in employee risk being re duced below that remaining at the PEL; 3) adding a require ment that employers assure that employees work in or contiguous to regulated areas comprehend required warning signs and requiring that training programs specifically in struct employees about the content and presence of signs and labels. All of the resolved issues were resolved on the basis of the 1986 record. SUBJECT: EXPLANATORY INFORMATION ON ASBESTOS REMAND ISSUES FOR NO TICE OF PROPOSED RULEMAKING (NPRM) PURPOSE: The purpose of this memo is to transmit the explanatory information which the Construction Advisory Committee needs in order to review the draft proposal for asbestos. OSHA will discuss the draft proposal at the Committee's March 13-14, 1990 meeting and obtain the Committee's recommendations at that time. BACKGROUND: On 20 June 1986, OSHA published a revised asbestos standard which reduced the permissible exposure limit (PEL) to 0.2 fibers per cubic centimeter of air (f/cc) as an 8 hour time-weighted average (TWA) from a previous PEL of 2.0 f/cc. On 22 February 1988, the US Court of Appeals of DC upheld the standard in most respects, but remanded the case to OSHA on several issues. In partial response, on 14 September 1989, OSHA issued a short-term exposure limit of 1 f/cc averaged over a 30 minute sampling period. On 30 October 1989, at the request of the AFLCIO and others, the Court ordered OSHA to resolve the remaining remand is sues, as outlined in the enclosed letter from the Court of the same date. REMAND ISSUES RESOLVED ON 1986 RECORD: On 14 December 1989, OSHA responded to the first three issues. These included: 1) removing the ban on the spraying of asbestos-containing materials; 2) changing the regulatory text to clarify when construction employers must resume periodic monitoring; and 3) explaining that the clarification of the exemption for "small-scale, short-duration oper ations" in the construction industry standard will require OSHA to Institute rulemaking. OSHA's January 1990 response to the next 3 issues were: 1) expanding its ban on workplace smoking and adding training requirements covering the availability of smoking controls programs; 2) explaining how and why OSHA's respi ISSUES IN PROPOSED RULEMAKING: The final group of issues are to be addressed in a notice and comments rulemaking procedure. OSHA has asked the Court to postpone the completion of the proposal until 13 April 1990 to allow time for consultation with the Advisory Committee on Construction Safety and Health. It is the draft of this proposal that OSHA is requesting you to consider. Briefly, the remanded issues covered in this document in clude: 1) clarification of the exemption of small-scale, shortduration operations mentioned above; 2) expansion of the competent person requirement to all employers in construc tion work; 3) extension of reporting and information transfer requirements; 4) establishment of operation-specific PELs to reduce residual risk. DEFINITION OF "SMALL-SCALE, SHORT DURATION OPERATIONS": In the February 1988 decision, the Court found the scope of the small-scale, short-duration operation exemption to the negative pressure enclosure requirement was such that it "seemed to erase the rule." The Court ordered OSHA to clarify the exception by limiting it to operations where it is impractical to contract a negative-pressue enclosure be cause of the configuration of the work environment. Rather than making the suggested alternations to the regulatory text, which may not lead to reduced risk, OSHA believes that rulemaking should be instituted on the matter. It is antici pated that additional information concerning the benefits and potential hazards associated with negative-pressure en closures and alternatives will be developed in the rulemak ing. The issue of establishment of a negative-pressure enclo sure is closely related to two of the remanded issues -- the exemption for small-scale, short-duration operations and the requirement that a competent person be designated to over see the establishment and operation of the enclosure. The 1986 rulemaking record contains no data to quantitate the exposure of workers within such enclosures, or the potential for increased risks from other hazards such as that of heat stress within the enclosure. The present rulemaking will allow OSHA to examine the experience with negative-pres sure enclosures and alternative methods made possible by 3-14-90 Occupational Safety & Health Reporter 1852 OCCUPATIONAL SAFETY & HEALTH REPORTER new technologies unavailable in 1986 which might provide qual or better worker protection. OSHA continues to believe that negative-pressure enclo sures are required in these operations since asbestos dis turbed during abatement and renovation would spread be yond the actual point of asbestos handling posing a risk to bystanders. In this proposal OSHA clarifies that employers engaged in demolition, renovation or removal of asbestoscontaining material must establish a full negative-pressure enclosure before engaging in these operations-repardiess of the level of employee exposure to asbestos. The enclosure requirement is triggered by the work activity, not by the PEL. This clarification will enhance the Agency's ability to enforce the standard, particularly in instances in which the abatement job is completed prior to compliance inspections by OSHA. There are three exemptions proposed to the negativepressure enclosure requirement. The first of these, [con tained] in the 1986 standard, is the exemption of small-scale, short-duration operations. Hie Court indicated that the defi nition of these operations in the 1986 standard lacked speci ficity. This proposal defines the exemption both in terms of its objectives and by setting specific maximum parameters of specific jobs in terms of their size and length of time for completion. The proposed provision for small-scale, short duration operations would specifically require the use of glove bags, mini-enclosures or wet methods to reduce work er and bystander exposure. OSHA is also considering requiring the use of negativepressure glove bags (boxes) in lieu of glove bap, if sufficient information is developed during the rulemaking concerning seir feasibility and effectiveness. Ihe Agency requests comments on its definition of smallscale, short-duration operations and specifically requests comment on individual elements of the definition, as well as information on the exposures potentially associated with these operations and any effective alternate measures to control asbestos exposure in them. Recommendations for other jobs which may also fall within the definition are requested. The second exemption to the negative-pressure enclosure requirement is proposed for roofing operations. The 1986 standard was unclear on whether roofing should be required to use negative-pressure enclosures. OSHA seeks comment on the practicality and effectiveness of the use of negativepressure enclosures on roofs. In extending this exemption to roofing operations, OSHA would require these employers reduce employee and bystander exposure by requiring the use of airtight chutes to lower debris from the roof and the use of wet methods to reduce the spread of asbestos con tamination. Comments on the effectiveness of these specific control methods and others are requested. The third proposed explicit exemption to the negativepressure enclosure requirement is that of infeasibility. That is, an employer is not required to establish a negativepressure enclosure when such a measure is infeasible be cause of the configuration of the work environment. OSHA's feasibility analysis indicate that very few activities will qualify for this exemption. This exemption was implicit in the 1986 standard. OSHA requests comments on whether additional circumstances would render enclosures "infeasible". PANSION OF THE COMPETENT PERSON REQUIRE MENT: As mentioned above, OSHA is proposing that competent persons be designated to oversee small-scale, short-duration operations involving asbestos. The current standard requires such persons in large-scale removal, demolition and renova tion operations where establishment of negative-pressure enclosures is required. Such competent persons must super vise the implementation of most requirements including setting up the enclosure, respirator use, and measurement. Competency is earned only after training in an EPA-sponsored course lasting one week. In addition to this special requirement in the asbestos standard, the General Safety and Health Provisions for Construction (29 CFR 1926.20) require employers to designate a competent person to insure compliance with general safety and health requirements at the job site. OSHA has determined that the general provi sions governing a '"competent person" apply to all job sites where exposure to asbestos occurs. The proposed standard will clarify this. Under the 1986 standard, small-scale, short-term oper ations were not required to be supervised by a specially trained "competent person". Although small-scale, shortduration operations are exempted from the- negative-pres sure enclosure requirement, they still pose a risk to workers. In addition, it is likely that many different types of jobs will be classified small-scale, short-duration and the protection measures will be varied, necessitating oversight by a knowledgable competent person specifically trained to deal with these operations. Therefore, OSHA is proposing that a spe cially trained competent person also supervise these operations. The training period for the competent person involved in small-scale, short-duration operations will consist of an EPA-accredited course of at least 2 days' duration, whereas that of the competent person in other asbestos operations is approximately one week in length. OSHA requests comments on the training requirements for the competent person in small-scale, short-duration as bestos work, including course availability, content and certification. EXTENSION OF REPORTING AND NOTIFICATION REQUIREMENTS: OSHA's response to the issue of extension of reporting and information transfer is two-pronged. First, OSHA is propos ing to include a requirement that employers communicate to persons who own buildings in which demolition, renova tion and/or removal of asbestos-containing materials oc curs, information concerning the asbestos hazard and steps being taken to reduce exposure. Building owners will then be required to communicate this information to other employ ers in the building, to employees of the building owners, and to building occupants. The proposed requirement to notify building owners in addition to the present requirement of notification of other employers is a simple extension of provisions and will lead to more effective and complete communication of important information further reducing bystander exposure to asbestos during these operations. OSHA is also proposing that building owners communi cate their knowledge of the location of asbestos containing material in the building to all employers and employees who may enter such areas. Secondly, in its further response to the Court, OSHA is proposing to add a new provision to the standard requiring employers undertaking asbestos removal, demolition or ren ovation operations, other than small-scale, short-duration, to 3-14-90 Published by THE BUREAU OF NATIONAL AFFAIRS. INC.. Washington. D.C. 20037 CURRENT REPORT provide OSHA with written notification 10 days prior to engaging in any such operation. OSHA considers that notifi cation will act as an incentive for employer compliance with the worker protection standards. Additionally, notification assists OSHA in setting priorities for compliance inspec tions. No overlap with EPA reporting requirements is envi sioned, since employers can satisfy OSHA's requirements simply by complying with those of EPA's NESHAP. The requirements of EPA mandate that employers in all build ing demolition operations involving asbestos and renovation operations involving amounts of asbestos at least 260 linear feet on pipes of 160 square feet on other facility components must provide notice of these operations to EPA. Since smallscale, short-term operations are exempted from the notifi cation requirements, most notification reported to OSHA is anticipated to involve those operations whose size falls between the OSHA-defined small-scale, short-duration oper ations and EPA's minimum for notification. OSHA seeks comments on the usefulness of notification as a stimulus for employer compliance and as an enforcement tool. OSHA also is interested in receiving comments on the specific information being requested in the notification, including the proposal to' model OSHA data requests upon EPA-NESHAP requirements. PROPOSED LOWERING OF PEL IN PREFERENCE TO OPERATION-SPECIFIC PELS: In responding to the Court's request that OSHA consider the establishment of operation-specific permissible exposure limits, OSHA prefers to address this issue by proposing to lower the PEL to 0.1 f/cc (TWA) across the board. OSHA believes the new PEL may be feasible in many construction operations through use of engineering controls and specified work practices. Due to the difficulty in achieving valid, reproducible measurements below the newly proposed PEL of 0.1 f/cc, an action level is not specified in this proposal. Traditional ly, in its standards, OSHA has set the action level which triggers various activities, at one-half the PEL. The sam pling variability at 0.05 f/cc renders this measurement of little use. Due to the significant risk remaining at 0.2 f/cc, lowering the PEL to 0.1 f/cc will contribute to worker safety. Thus, establishment of operation-specific exposure limits will not be necessary since a PEL of 0.1 f/cc (TWA) will be required in all operations. OSHA also believes that the additional specified work practices and controls pro posed in the exemptions to the negative-pressure require ment will also help to reduce exposures and thus risk. OSHA is seeking comment on the reduction of the PEL to 0.1 f/cc in all industries and the concept of omitting the action level from the requirements. TIME SCHEDULE: Due to the need to complete the proposed rule by 13 April 1990, we ask that you consider the asbestos remand proposal at the March 1990 meeting, and make recommendations at that time. ENCLOSURES: Letter from Court of Appeals, 30 October 1989. Draft regulatory text New docket list for remand issues (H033-e) Regulatory text and appendices f and g, 1986 Asbestos Standard 1853 OSHA response Federal Register 20 December 1989 OSHA response Federal Register 5 February 1990 1910.1001 asbestos, tremolite anthophyllite, and actinolite. (c) Permissible exposure limits (PELS). (1) Timeweighted average limit (TWA). The employer shall ensure that no employee is exposed to an airborne concentration of asbestos, temolite, anthophyllite, actinolite, or a combina tion of these minerals in excess of 0.1 fiber per cubic centimeter of air as an eight (8)-hour time-weighted average (TWA) as determined by the method prescribed in Appendix A of this section, or by an equivalent method. (f) Work Practices * (lXx) Engineering controls and work practices for brake and clutch repair and service. During automotive brake and clutch repair operations, the employer shall institute engineering controls and work practices to reduce employee exposure to materials containing asbestos, tremo lite, anthophyllite, or actinolite using an enclosed cylinder/ HEPA vacuum system method or a solvent system method, following the detailed requirements set out in Appendix (F). The employer may also comply using an equivalent method, which follows written procedures, which the employer dem onstrates is as effective as the methods described above in reducing employee exposure. Such demonstration must in clude monitoring data conducted under workplace conditionsclosely resembling the process, type of asbestos con taining materials, control method, work practices and environmental conditions when the equivalent method will be used or objective data which documents that under all foreseeable conditions of brake and clutch repair applica tions, the method results in exposure reductions equivalent to those achieved by applying methods specified in Appendix F. * (k) Housekeeping -* * (kX8) In primary and secondary manufacturing oper ations, floors and surfaces shall be cleaned at least once per shift with a vacuum containing a HEPA-filler, and, where feasible, combined with wet methods. Appendix [] to Section 1910.1001 -- Work Practices and Engineering Controls for Automotive Brake and Clutch Re pair and Assembly -- Mandatory This mandatory appendix specifies engineering controls and work practices that must be implemented by the em ployer during automotive brake and clutch repair and as sembly operations. Proper use of these engineering controls and work practices will reduce employees' asbestos expo sure below the permissible exposure level during clutch and brake repair and assembly operations. The employer shall institute engineering controls and work practices using ei ther the method set forth in paragraph [A] or paragraph [BJ, or any other method which the employer can demonstrate to be equivalent in terms of reducing employee exposure to asbestos as defined and which meets the requirements de scribed in paragraph [C]: 3-14-90 Occupational Safety & Health Reporter 1854 [A] Enclosed Cylinder/HEPA Vacuum System Method. T) The brake and clutch assembly and repair work shall . _ enclosed in a cylinder designed to cover and enclose the wheel/brake assembly and repair to prevent the release of asbestos fibers into the worker's breathing zone. (2) The cylinder shall be sealed tightly and thoroughly inspected for leaks before work begins on brake and clutch repair and assembly. (3) The cylinder shall have viewing ports to provide visibility and impermeable sleeves through which the work er can handle the brake and clutch assembly and repair. The integrity of the sleeves and ports shall be examined before work begins. (4) A HEPA-filtered vacuum with a compressed-air hose and nozzle that fits into a connection on the cylinder shall be used to remove asbestos fibers or particles from the cylinder. (5) The vacuum cleaner shall be used first to loosen the asbestos containing residue from the brake and clutch parts and then to evacuate the loosened asbestos containing mate rial from the cylinder and capture the material in the vacuum filter. (6) The vacuum's filter, when full, shall be first wetted with a fine mist of water, then removed and placed immedi ately in an impermeable container, labeled according to paragraph (jX2X>i)of the standard and disposed of according to paragraph (k) of the standard. (7) Any spills or releases of asbestos containing waste material from inside of the cylinder or vacuum hose or vacuum filter shall be immediately cleaned up and disposed of according to paragraph (k) of the standard. (8) During the process of removing, containing and disposg of the filter, respirator protection as described in para graph (g) of the standard, shall be used so as not to expose workers to airborne asbestos in excess of 0.1 fiber per cubic centimeter of air. [B] Spray Can/Solvent System Method. (1) The spray can/solvent system shall be used to first wet the brake and clutch parts. Then, the brake and clutch parts shall be wiped clean with a cloth. (2) The cloth shall be placed in an impermeable container, labelled according to paragraph (jX2Xii) of the standard and then disposed of according to paragraph (k) of the standard, or the cloth shall be laundered in a way to prevent the release of asbestos fibers in excess of 0.1 fiber per cubic centimeter of air. (3) Any spills of solvent or any asbestos containing waste material shall be cleaned up immediately according to paragraph (k) of the standard. (4) The use of dry brushing during solvent spray oper ations is prohibited. [C] Equivalent Methods If an equivalent method of engineering controls and work practices is used, the employer shall follow written proce dures which have been shown to provide exposure reduction equivalent to the methods described in paragraphs (A) or (B) above. 1926.58 Asbestos, tremolite, anthophyllite, and actinolite * (a) Scope and Application. Coverage under this standard -nail be based on the nature of the work operation involving asbestos exposure, not on the primary activity of the employer. OCCUPATIONAL SAFETY & HEALTH REPORTER (b) Definitions. "Small-scale, short-duration operations" means only those demolition, renovation, repair, and remov al operations which affect small surfaces or volumes of material containing asbestos, tremolite, anthophyllite, or actinolite, and which are to be completed within short time spans, and which are not expected to expose bystanders to significant amounts of asbestos. The following operations are included within the definition of small-scale, shortduration: pipe repair of asbestos on piping that is less than 21 linear feet; repair or removal of asbestos panel that is less than 9 square feet; pipe valve repair or replacement of pipe valves containing asbestos gaskets, or electrical work that disturbs asbestos that is completed by one worker in less than four hours; removal of drywall which is completed for the facility within an eight-hour workday; renovation projects involving endcapping of pipes and tile removal that can be completed in less than four hours; and installation of conduits that can be completed within an eight hour work shift * (c) Permissible exposure limits (PELs). (1) Timeweighted average limit (TWA). The employer shall en sure that no employee is exposed to an airborne concentra tion of asbestos, tremolite, anthophyllite, actinolite, or a combination of these minerals in excess of 0.1 fiber per cubic centimeter of air an eight (8)-hour time-weighted average (TWA) as determined by the method prescribed in Appendix A of this section, or by an equivalent method. * (d) Communication among employers. (1) General. On multi-employer worksites, an employer performing asbes tos, tremolite, anthophyllite, or actinolite work requiring the establishment of a regulated area shall inform all other employers on the site of the operation resulting in asbestos, tremolite, anthophyllite, or actinolite exposure and of the contents of the requirements pertaining to regulated areas contained in this standard. (2) Notification to building owners. Any employer per forming asbestos, tremolite, anthophyllite, or actinolite work requiring the establishment of a regulated area shall inform the building owner in writing of the nature of oper ations reasonably expected to result in asbestos, tremolite, anthophyllite, or actinolite exposure, the contents of the requirements pertaining to regulated areas contained in the standard, and the measures taken by the employer to pro tect other employees and building occupants from exposure to asbestos, tremolite, anthophyllite, or actinolite. (3) Notification by building owners. Upon receipt of notification from employers pursuant to paragraph (dX2) of this section, or having knowledge of work covered by these requirements, building owners shall immediately provide notice of the contents of the notification to the following: (A) Other employers working in the building, such as construction, maintenance, and security contractors, whose employees can reasonably be expected to work in or contiguous to the regulated area; (B) Employees of the building owner who work in or contiguous to the regulated area; and (C) Building occupants who can reasonably be expected to work in or contiguous to the regulated area. ** 3-14-90 Published by THE BUREAU OF NATIONAL AFFAIRS, INC., Washington. D.C. 20037 CURRENT REPORT (e) Regulated areas. (1) General, (i) Except for absestos removal, demolition and removal, the employer shall estab lish a regulated area in work areas where airborne concen trations of asbestos, tremolite, anthophyllite, actinolite, or a combination of these minerals exceed or can reasonably be expected to exceed the permissible exposure limit pre scribed in paragraph (c) of this section. (6) Regulated areas for asbestos removal, demolition, and renovation operations. (1) All asbestos removal, de molition and renovation operations shall be treated as regu lated areas. (1) The employer shall establish negative-pressure enclo sure before commencing any removal, demolition, and ren ovation operation. (ii) Exceptions to negative-pressure enclosure re quirements. The employer is not required to install nega tive-pressure enclosures in the following work situations: (A) Where establishing a negative-pressure enclosure is not feasible, because of the configuration of the work area and where the employer shall institute all feasible addition al controls to reduce the exposure to asbestos of workers engaged in the removal, demolition, or renovation operation and minimize the spread of contamination to workers not engaged in the removal, demolition, or renovation. (B) In roofing, where the employer shall institute all feasible additional controls to reduce employee exposure, such as using wet methods to the extent feasible, immediate ly bagging all asbestos containing materials, and lowering asbestos containing materials to the ground level using airtight chutes. (C) In small-scale, short-duration operations, as defined in paragraph (b), where the employer uses alternative feasible containment or enclosures, such as glove bags or minienclosures, and uses feasible wet methods to handle, install, disturb, and/or remove asbestos-containing material. (New) Competent person -- (1) General. On all con struction worksites covered by this standard, the employer shall designate a competent person, having the qualifica tions and authorities for ensuring worker safety and health required by Subpart C, General Safety and Health Provi sions for Construction (29 CFR 1926.20 et seq.). (2) Requirements for asbestos removal, demolition, and renovation operations, (i) On all worksites where employees are engaged in removal, demolition, and renova tion of asbestos, tremolite, anthophyllite, and actinolite, the competent person designated in accordance with paragraph (gXl) of this section shall also perform or supervise the following duties: (A) Set up the regulated area, enclosure, or containment; (B) Ensure the integrity of the enclosure or containment; (C) Control entry to and exit from the enclosure and/or area; (D) All employee exposure monitoring required by this section is conducted as required by paragraph (f); (E) Ensure that employees working within the enclosure and/or using glove bags wear protective clothing and 1855 respirators as required by paragraphs (h) and (i) of this section; (F) Ensure that employees are trained in the use of engineering controls, work practices, and personal protec tive equipment; (G) Ensure that employees use the hygiene facilities and observe the decontamination procedures specified in paragraph (j) of this section; (H) Ensure that engineering controls are functioning properly, and; (l) Ensure that notification requirement in paragraph (fX6) are met. (iiXA) The competent person shall be trained in all aspects of asbestos, tremolite, anthophyllite, or actinolite handling relevant to the specific work involved, including abatement, installation, removal and handling, the con tents of this standard, the identification of asbestos, tre molite, anthophyllite, or actinolite, removal procedures, where appropriate, and other practices for reducing the hazard. Such training shall be obtained in a comprehen sive course, such as a course conducted by an EPA Asbestos Training Center, certified by the EPA or a State, or an equivalent course. (iiXB) For small-scale, short-duration operations, the com petent person shall be trained in aspects of asbestos removal appropriate for small-scale, short-duration work, to include procedures for setting up glove bags and mini-enclosures, practices for reducing asbestos exposures, use of wet meth ods, the contents of this standard, and the identification of asbestos, anthophyllite, or actinolite. Such training shall be obtained in an appropriate course, such as a course conduct ed by an EPA Asbestos Training Center for supervisors of small-scale, short-duration work, or an equivalent course. (h) Methods of Compliance 900 (2Xiv) Floor tile containing asbestos, tremolite, anthophyl lite, and actinolite may be sanded only with low-abrasion pads at speeds of 190 rpm or less. Sanding of such tile or material at speeds greater than 190 rpm or using high abrasive pads is prohibited. * (1) Notification to OSHA -- (1) General. Before engag ing in demolition, renovation, or removal of materials con taining asbestos, tremolite, anthophyllite, or actinolite which do not meet the definition of small-scale, shortduration operations, the employer shall provide the OSHA Area Office with written notices of intention to demolish, renovate, or remove asbestos. (2) Method of notification. The employer shall ensure that OSHA receives written notices at least 10 working days before removal, demolition, or renovation, or other related activities such as site preparation which would disturb asbestos will begin. (3) Content. The employer shall include the following in the notice: (A) Name, address, and telephone number of employer, (B) Type of operation: demolition, renovation, or removal; (C) Description of the facility including the size (square 3-14-90 Occupational Safety & Health Reporter 1856 feet) and number of floors, age, and present or prior use of the facility, (D) Procedure employed to the detect the presence of materials containing asbestos, tremolite, anthophyllite, or actinolite; (E) Estimate of the amount of materials containing asbestos, tremolite, anthophyllite, or actinolite, including separately identified non-friable material, to be affected by the demolition, renovation, or removal, in linear feet or area (square feet); (F) Location and address of the facility where demoli tion, renovation, or removal will occur; (G) Scheduled starting and completion date; (H) Description of planned demolition, renovation, or removal work to be performed and methods to be em ployed including demolition, renovation, or removal tech niques to be used and description of affected facility components; OCCUPATIONAL SAFETY & HEALTH REPORTER (I) Description of work practices and engineering con trols to be used to comply with the requirements of this standard; (J) Name and location of waste disposal site where the asbestos containing material will be deposited; (K) A certification that only a competent person trained as required by paragraph (newXiiXA) of this section will supervise the demolition, renovation, or removal activity described in this notification; and (L) Description of procedures to be followed in the event that unexpected asbestos is found. (4) Compliance with EPA reporting. An employer re porting to the Environmental Protection Agency's National Emissions Standards for Hazardous Air Pollutants for As bestos (40 CFR Part 61.146) may satisfy the notification requirements contained in this paragraph by demonstrating full compliance with applicable EPA reporting requirements. BNA OCCUPATIONAL SAFETY AND HEALTH CONFERENCE New developments in occupational safety and health--ranging from the challenges presented by emerging workplace hazards to enforcement priorities aimed at meeting those challenges-- will be addressed by some two dozen prominent speakers at an April 26-27 conference in Washington, D.C., sponsored by The Bureau of National Affairs, Inc. The two-day meeting, "Occupational Safety & Health: The New Decade," is designed to provide safety and health specialists, attorneys, physicians, insurers, loss-control managers, and labor-relations practitioners with up-to-the-minute information on critical current issues in this important public policy area. The conference will highlight the Occupational Safety and Health Administration's regula tory response to the growing concern over ergonomic hazards in the workplace. An update on er gonomic policy and compliance efforts will be paired with a nuts-and-bolts review of how to spot--and prevent--potential problems in the workplace. Also spotlighted will be OSHA's evolving enforcement policy, particularly the role of egregious violations and corporatewide settlements in the agency's enforcement scheme. In addition, state and federal officials will report on activities involving the prosecution of companies and corporate executives under criminal statutes for health and safety violations, and a distinguished panel of state officials will examine the challenges to state plan programs. Another session will offer a look at what the '90s hold for the agency and the Occupational Safe ty and Health Act. Gerard F. Scannell, assistant secretary of labor for occupational safety and health, will deliver the keynote address. Other OSHA speakers include Deputy Assistant Secretary of Labor Alan C. McMillan; Charles Adkins, the agency's director of health standards; and OSHA industrial engineer Roger Stephens. Rep. Paul B. Henry (R-Mich) is the invited speaker at a mid-morning brunch on the second day of the conference. Representatives from management, labor, and state enforcement agencies will also address the group. Space is limited for the conference. Registrants are urged to sign up early to avoid being placed on a waiting list. The conference registration fee is $645 ($545 for BNA subscribers and government employees). For additional information or to register, call BNA PLUS Conferences at 800-452-7773 or (202) 452-4323 in Washington, D.C. 3-14-90 Published by THE BUREAU OF NATIONAL AFFAIRS. INC., Washington. D.C. 20037