Document vyB6djGaYmbgD6V3gG94DLxJE

The issue of what precautions to tjilte and why has been an evolving debate over the past several years. There are now several options to choose from and issues to consider. REGULATIONS There has been much confusion about whether asbestos-containing floor tile and mastic should be con sidered finable and subject to the same techniques and regulations as other finable asbestos-containing materials (ACM). Environmental ProtectionAgency (EPA) regulations define "friable asbestos* as any material containing more than 1 percent asbestosbyweightthathand pressure can crumble, pulverize or reduce to powder when dry. On July 9,1985, the EPA Region IV adopted the following position on non-friable ACM, which presuma bly includes floor tile and mastic: Without any type of disturbance (breaking, cutting) to this material, the material would not be considered friable and therefore the provisions of40 CFR.61. Subpart M (NESHAP) would not apply.... However, if this ^ containing floor tile and material is disturbed or broken up in the demolition process (including masticsfriable or non-Jtiable? Whatgov disposal) such that asbestos fibers ernmental regulations apply to their removal? Which are released, then the material is considered friable and then subject removal methods are most effective? Here's why totheNESHAPasbestosregulations. there aren't any uniform answers. In December 1985, the EPA Na tional Office issued a four-page memorandum addressing the sub By William H. Spain, CSP, Nicholas P. Wlckware, CSM, ject of NESHAP applicability to the and William M. Ewing, Jr., CIH removal of non-friable ACM. The following guidance was included in that memorandum: /// ultiple EPAreports have indi- high tensile strength and inherent Even though the (NESHAP) regu /// cated that there are 35,000 flexibility. These tiles are often lations address only material that is Iff schools and733,000private and adhered with a mastic that also presently friable, it does not limit commercial buildings in the United contains asbestos. itselfto material that isfriable at the States that contain asbestos. Addi When left in place, well- time ofnotification. Rather, ifat any tionally, many private residences maintained and undisturbed, these point during the renovation or demo contain certain asbestos products asbestos floor tile and mastic combi lition, additional friable asbestos such as floor tfle. There are millions of square feet of floor tile in these buildings, and a portion of that tile contains asbestos. Polyvinyl chloride/asbestos tile nations perform their function well without posing a significant asbes tos exposurehazard. However,ifthey are broken, cut, drilled or otherwise disturbed, as occurs during renova material is either discovered or cre ated from non-friable forms, then this additional friable material be comes subject to the regulationsfrom the timeofcreation ordiscovery. This has been manufactured since 1950. tion or demolition, they can release additional friable material will be Containing 18 to 25 percent asbes asbestos fibers into the air and pose come subject to all ofthe regulations, tos, the tile combines strength, a potential health hazard. Because including the notification require flexibility, fire resistance, imperme of this potential, asbestos floor tile ments. ability to water and excellent wear and mastic should be kept under an The memorandum also states: characteristics. Asphalt asbestos asbestos operations and mainte The owner or operator is not ex floor tile, which contains 26 to 33 nance (O&M)programwhile inplace. empt from the other requirements of percent asbestos, has been manu When it is intentionally or uninten the standard, such as wetting, dur factured since 1920. Chrysotile as tionally disturbed, more drastic ing the (notification) waitingperiod. bestos is used in tiles because of its precautions should be followed. When non-friable material is frac- -- OJ G9E004-S-- 1 I tured or otherwise becomes friable duringthe removal, the operatormust wet after the fracture occurs and follow all of the additional require ments in 40 CFR 61.147 and 61.152 (NESHAP). In some instances, these requirements may be burdensome. For example, when ragged edges result from the removal ofthe mate rial, such edges may be friable. In that same1985 time frame, the Environmental Protection Division of Georgia's Department ofNatural Resources suggested several steps to be taken during the removal and disposal of non-friable asbestos boards or other types of non-friable ACM. It suggested a variety ofsteps, including: isolating the removal area; posting EPA/OSHA warning signs; wetting the materials prior to removal; wrapping the materials in plastic or placing them in lined containers; having the workers wear respirators and protective clothing; disposing of the material in an approved sanitary landfill; checking on legal liabilities; preventing visible emissions; controlling airborne fiber exposures; and collecting and analyzing air samples. In spite of this and other govern mental guidance concerning the issues, the way in which floor tile and mastic removal projects are regulated and performed remains a matter of considerable local inter pretation. In some geographic areas, it is still considered to be a project involving basically non-friable material. In other areas it is treated and regulated as involving fully friable material. There is also reported to be vari ability in OSHA's enforcement of worker protection requirements for these projects. According to one ac count, a federal OSHA inspector re quired the use oftype C respirators forfloor tile removal projects inColo rado. These differences in regulatory interpretation have left building owners, consultants, contractors, inspectors and others somewhat confused about what is required and appropriate for floor tile and mastic removal projects. The trend defi nitely seems to be moving toward treating the projects as involving friable materials. However, those who take the opposite view argue stronglythatthe projectsdo notcause visible emissions (one NESHAP cri teria) and do not generate personal exposures above OJ. fibers per cubic centimeter of air (the OSHA action level). BULK SAMPLING ft ANALYSIS Tryingto figure out how the regu lations apply is not the only problem with asbestos floortile and mastic. It can also be difficult to determine if the tile and mastic contain asbestos. TheEPAAsbestos in SchoolsRule of1982 (and many early building in sert 1 here are still many questions regarding asbestoscontainingJloor tUe and masticfor which there are no generally accepted or uni form answers." r > spections) failed to address the issue of asbestos in floor tile and mastic. As a result, building owners, archi tects, contractors and consultants often have been surprised when they had to stop a demolition or renova tion project involving asbestos floor tile or mastic. In fact, floor tile and mastic are frequently the trigger is sue for `change orders" on renova tion and demolition projects. As of1987, EPA/AHERArequires schools to include floor tile and mas tic in their building inspections and asbestos management plans. All building owners are well-advised to do likewise. There is an alternative to the expensive and difficult proc ess ofcollecting and analyzing large numbers of bulk samples to deter mine if asbestos is present. All tile and mastic can be assumed to con tain asbestos (until proven other wise) and placed under a minimal asbestos operations and mainte nance program (O&M). This assump tion can be tested by collecting and analyzing a few samples from loca tions such as closets and corners. Erring on the side of safety', any positive results should cause the* assumed area to be treated as asbestos-containing material; how ever, a few negative results should be consideredinadequate to conclude that the area is asbestos-free. Before removal and replacement is scheduled for the assumed asbes tos materials, representative samples fromboth the tile andmastic should be collected and analyzed. Inexperienced inspectors often fail to sample the mastic. This sampling and analysis could help avoid an ex pensive removal and replacement project based upon a faulty assump tion. Unfortunately, it is often difficult to analyze the tile and mastic samples. There are no generally accepted or standard techniques for these multistep analyses. The prob lembecomes separatingthe collected sample so it can be analyzed by po larized light microscopy (PLM). The EPA recommends a process using solvents, but other highly qualified laboratories prefer other methods. Julian Gray,laboratory microscopist for Environmental Analytical Laboratories of Atlanta, comments thatit is easy for analysts to miss the asbestos in some floor tile. The aswbestos fibers are usually very finely milled and of fiber sizes near the resolution limit of PLM. Gray also says analysts have difficulty de termining the quantity (percentage) once they find asbestos in the tile. Most laboratory results fall in the range of 1 to 3 percent asbestos. About 25 percent of tested tile con tain more than 1 percent asbestos. Manufacturing information indi cates that tiles usually contain 2633 percent asbestos. The asbestos is essentially always of the chrysotfle variety. Shreds ofmica may be pres ent that interfere with the analysis. These analytical difficulties often lead to false negative results. According to Gray, analyzing the mastic is even more difficult. The mastic is smeared on a slide and then immersed in a refractive index liquid. Unfortunately, the mastic binder material is usually opaque and obscures the fibers. Thus the analyst must look for exposed ends of the fibers. Over half the mastic samples contain more than 1 per cent asbestos. Most positive results 72 ASUSTOS 8SUB S9--SEFTEMBB ST003TT9TJ ! ! \ fall in the range of 10 to 30 percent asbestos and,are essentially always ohrysotile. Only highly qualified analysts should be depended upon - for accurate mastic analysis. TILE REMOVAL METHODS Methods employed inthe removal ' of vinyl asbestos tile (VAT) and mastic tile adhesive (MTA) vary greatly, depending primarily on the existing conditions surrounding the subject facility and future or contin ued use ofthe involved space. Meth ods of choice also vary between contractors performing this work. However, the contractor's decision is usually based upon the factors mentioned above and previous expe- ' riences using the various available methods. One factor agreed upon by experienced contractors in asbestos ..abatement today is that no VAT removal job should be performed without utilizing proper personal protective equipment (PPE), decon- - tamination facilities and effective work area isolation and enclosure, including negative-pressure differ entials within the work area. Work area preparation may not be left up to the contractor's discre tion if he is working a project that . .has specified methods and proce dures. Still, contractors are often called on to fulfill a design/buildtype contract. Essentially, this will - allow the contractor--with the owner's consent--to use the meth ods he feels will adequately protect the work areas from a physical stand point, and all parties to the contract from a legal and liability standpoint. In these design/build situations, especially where work areas are within occupied buildings or adjacent to occupied spaces, experienced con tractors are not currently opting for - full work-area enclosure and isola tion before approaching VAT re moval. Studies are available showing elevated fiber levels during VAT re moval, and contractors nowconsider this data when making decisions .. toncemingmethods and procedures. Of course, limited or partial workarea isolation and enclosure is still very much in use today, especially in - pre-demolition projects in which all surfaces can be effectively washed and any residual fibers positively locked down* prior to the demoli- ~ 'tion. Partial isolation and enclosure is also still used in some occupied building projects, but only by opera tors who are willing to "throw the dice* from a legal/liability stand point, or by those who have not had data such as the study noted above made available to them. Once the degree ofwork-area iso lation and protectionis decided upon, the appropriate removal method must be addressed. When VAT re moval takes place on the ground floor of a facility that is "on slab* with no danger of water damage to floors below, or when working an multistory buildings scheduled for demolition, in which water damage to lower floors is not a consideration, the method of choice for VAT re moval is still controlled "flooding" of the work area with amended water Unfortunately, it is often difficult to analyze the tile and mastic samples. There are no generally accepted or standard techniques for these multistep analyses containinga surfactant. This method has been very effective in causing the VAT to release from the mastic material and virtually float to the top for ease in removal. Many abate ment contractors have discovered this method inadvertently, through past experiences working in areas in which existing floor tile has not been scheduled for removal. They found that once the floor enclosures were removed, undetected water leaks, or even collected moisture, left them facing a tile removal and replace ment job not anticipated in their original work estimate. This process sometimes can be accelerated by using a hot amended water mixture if an abundant sup ply of hot water is available on the site. The amendedwatermethodhas other advantages as well. Asbestos contractor Raymond McQueen, vice president of Safehouse, Inc., in At lanta, states, "The amended water method not only provides the most effective method of removal, but we have also had outstanding success in keeping airborne fiber levels within the work very low during removal, even when chipping and other mechanical methods must be utilized. The newer removal encap6ulants/suifactants have done a much better job in this respect" In some cases, no matter how much amended wateris used, orhow hot the water is, or what type or brand of surfactant is utilized, the VAT will not just "float to the top" and mechanical methods must be utilized to facilitate complete re moval of the tile materials. Several indicators are available to help the contractor determine the amount oflabor that will be needed for completion of a VAT removal project. Sunlight exposure and the amount of pedestrian traffic in an area are significant factors contrib uting to an increase in the difficulty ofVAT removal. The light/heat and constant downward pressure in heavy traffic areas such as corridors and other public-use areas help the tiles "set" in their base materials, adding to the difficulty of removal. Ron Amonds, vice president of Applied Asbestos Technology, Inc., based in Atlanta, Bays, "We know that areas which are heavily used and exposed to constant sunlight can cut production during removal by as much as 75 percent. These areas are estimated at 40-50 square feet per man hour as compared to 165-180 square feet per man hour in areas where these conditions are not present' The age ofthe installation, if determinable, should also be con sidered in coiyunction with these sunlight and traffic conditions. Another factor complicating VAT removal is the existence of multiple layers of flooring materials. Many older buildings are found to contain several floor coverings applied on top of one another. In one current prqject, Amonds has encountered this problem. "We are in a situation at the pres ent time where, after removing the top layer oftile and mastic, we found three additional layers of flooring materials and two layers of VAT with a layer oflinoleum sheet goods in between them. The owner's con sultant failed to identity these addi tional materials and the cost of the project has increased by approxi mately 50 percent.* Amonds goes on to say that, in 74 ASftESTOS BSUES W-XmMK* fr HiECOOl-S- I f \ i l I i ! this case, his additional workwill be compensated by way of a change order, a common occurrence in deal ing with the removal of flooring materials. However, the contractor should always make every effort to discover items such as this prior to bidding a project. He may find him* selfcaughtin a contractual language trapby wording such as 77k* contrac tor shall nmooe allflooring materi als. Or if working in a design/build capacity, the contractor may be held responsible for any additional work involving materials not considered to be part of the original scope of work. In any of these cases, unantici pated costs and schedule extensions are the result, andthey only serve to erodethe relationship ofthe involved parties.Amonds suggests, Tnasitu ation where we suspect multiple layers of floor coverings, we will always tty to ascertain the actual printing conditions, even if this means additionalbulk samplestobe analyzed at ourexpense. These bulk samples could provide information which will save ns significant sums. This ib also the time to find out what type ofMTAyou are dealing with. A closet or other isolated area is an excellent location to test the mastic for its reaction to different dissolv ing agents.* The point to remember in every situation is that all parties to the contract are better served by know ing as much detail as possible about the work facing them. This fosters an interdisciplinary approach to the project and helps the "team* to prop erly address tile project from the start, limiting surprises during the progress of the work. Contractors who perform a significant amount of work in schools should note that all ofthe complicating factors discussed here are prevalent in school build ings, and should always be consid ered when evaluating VAT projects performed there. When a VAT removal job moves up from the ground floor, a contrac tor faces a formidable challenge in effectively removing the materials while simultaneously using limited amounts of water to prevent poten tial damage to the spaces below. Two alternative methods are presently in use by contractors trying to find an acceptable solution to this di lemma: the application of heat and the application ofextreme cold. Both have received mixed reviews with regard to effectiveness and cost effi ciency. Heat, supplied from electric heat guns or electric heat machines, will eventuallycauseVATto release from its adhesive base materials. But this is a very time-consuming method. It hasbeen utilized on small-scale proj ects with success; but as the projects increase insize, thismethodbecomes less cost-efficient. Additionally, the same heat that causes the tile to release turns the mastic materials into a gummy mess that potentially can be tracked out ofthe work area and into other areas of the facility. The heat removal method will allow VAT to be removed in whole pieces. This helps to control the emission of airborne fibers, thru limiting the need for large amounts of water during the process. However, the VAT materials should always, at a minimum, be misted with amended water during handling and packag ing for disposal. New technology has been intro duced recently to the abatement industry in the form of an infrared ASSESTOS ISSUE W-SOTEMSB STO03G9 13 ii l 1 L neatmaehin .It is claimed that this floor tile* will amply break loose wmchin* is uble to automate VAT with a quick blow ofthe hammer at removal on large-scale projects. Un- the center of each tile. His remarks fortunately, data relating to the ef- remind us that sometimes we can fectiveness of this method is very forget the obvious when immersed limited at this time. in evaluating innovative or complex The removal of VAT utilizing removal options. As new technology extreme cold is presently being used catches up with the abatement on a limited bods in several areas of industry, more productive methods the country. The cold is supplied by for VAT removal will came to the either dry ice or liquid nitrogen forefront. Until that time, the appliedtothetopsurfaceoftheVAT. manual scrape or mechanically Extreme care must be used in the assisted scrape will continue to be application of these materials to the most utilized methods on these prevent damage to any adjacent projects. firnshingmatarinln Thigrnwfhnd nln will eventually cause the tiles to release from their adhesive base. But like the heat method, it is a long, time-consum:ng process. The cold method can ' e used on small-scale projects; how -ver, the cost ofthe ma terials relative to the amount ofVAT removal they provide is prohibitive for projects of any significant size. The cold method also has two notable side effects. First, the cold- source materials dissipate oxygen content in the ambient air as they evaporate. This oxygen depletion can reach a critical stage within an enclosed work area. It has been reported that on some projects utilizing the cold removal process, workers have lost consciousness.Ad ditionally, the application of these low temperatures to VAT makes the materials very brittle for bundling. The breakage increases the poten tial for elevated fiber levels within the work area and magnifies the need to use more amended water during the handling and packaging operations. An innovative floor tile removal method has been introduced by James Waite , of Walton Systems in Massachusetts. This method in volves laying a layer of foam (suds) approximately 12 inches deep. A power chipper is moved through the foam, breaking the floor tile loose from the substrate. The foam, simi lar to shaving cream in consistency, keeps the tiles wet and inhibits the release of airborne fibers. Walton reports that the foam dissolves in about 30 minutes, leaving a damp surface with little build-up of water that could cause damage. John Mayer, a contractor from Lake Oswego, Ore., suggests that contractors try a 316. sledgeham mer for removing old floor tile. He reminds contractors that many old TMa-Asuros nsws v* MASTIC REMOVAL Once the VAT materials an re moved, the abatement contractor ia faced with yet another task, often more challenging than the tile nmovaL He must now remove all traces Of the esheatne-wmitafaing mastic tile adhesive. The MIA ia found in two general categories: organic/petroleuxn-based or syn thetic-baaed. The synthetic-baaed MTAa will show a reddish tint and will seem almost brittle in consistency. Many solutions and compounds have been ST00 3 6 9 I 4 C experimented with to aid in removal ofsynthetic MTA. Success has been limited, and experiencedcontractors rely heavily on the manual scraping of these materials. The scraping process can be helped significantly by using a powered dripping ma chine. Amends utilizes the powered chipper almost exclusively on syn thetic MTA. He says, "An experi enced dripper operator can start at one side ofan area and roll the syn thetic material up like a newspaper. The friction generated by the me chanical motion produces just enough beat to allow the materials to be worked in this fashion." But Amonds reinforces the point that The time to ascertain whether you are dealing with a petroleumbased MTAor syntheticisbeforeyou bid or negotiate the project. The synthetic MTAs will not be affected by the various dissolving agents available. A simple test in some iso lated, unexposed area can give you the indication one way or another in less than five minutes.'* After the mechanical process removes the greater portion of the synthetic MTA, manual scraping is still required for removing residual material remaining in corners and other irregularly shaped areas not accessible with the powered ma chines. A new generation of dissolving agents arerapidlygainingwidepopu larity for the removal of the petro- tHe and mastic can be assumed to ! contain asbestos and \ therefore should be placed under a minimal asbestos operations and maintenance program (O&M). * leum-based MTAs. These solutions, based onnaturaltitricadd, arebeing marketed undermany trade names, includingLimi-sol,Target, Citridean and Maatic-Be-Gone, just to name a few. These products cause a natural reaction within the petroleum base to produce effective results. How ever, the process happens very fast and must be performed in a wellorganized manner to achieve thi desired level of cleanliness. "Our men utilize the citrus dean-^_ era on a predetermined area applying it in several stages al approximately three-minute inter- vals,"says McQueen.Thethiclmessofthemasticandthedegreeofdeanliness desired determine the numberofapplications.'' McQueen's workers provide agitation between-- stages with abroomto helpfacilitate thereaction. Whenthe desiredpene tration is achieved, McQueen adds _ an oil-sweep absorption material to" gather any liquid run-off Then the dissolved MTAcan be easily scooped into disposal bap. Amonds and bis crew use a simi lar technique, although they prefer a commercial floor machine with a stripping pad to the broom method.' ~ Amonds comments, The floor ma chine can cover a somewhat larger areathanthe broommethod. We can scrub the area with the floor machine after a heavy application of the dtrus cleaner and have the re sulting slurry ready for collection by . a HEPA vacuum in approximately GO O O CO CO CO five ninnies. This process has per' formed well for us thus far.' Both McQueen and Amonds agree that the citrua cleaners leave little residual materialwiththeexception ofoorners and other inaccessible lo cations. These hard-to-reach areas can be cleaned with minimal amounts of labor and spot applica tions ofthe citrus cleaner. This method may sound too good to be true, and in a way it is: the citrus deaners require some signifi cant precautions. They are based an natural citric add extracted from ritroa fruit rind and pulp; one Toad* of the rind/pulp material can be re processed toyield up to three runs of the dtric add base. Obviously, the first run of the base contains the strongest concentrations and is the purest product. As the reprocessing continues, subsequent runs become progressivelyweaker. Consequently, them* weaker base materials must be rejuvenated by the addition of solvent agents. Some of these sol vents have been found to contain components such aa methylene chloride, and in some cases poly chlorinated biphenyls (FCBs). The contractor can avoid those hazard ous compounds and the necessary extra precautions when they are present by specifying first-run ma terials when purchasing citrus cleaner products. But even the first-run cleaners can present problems, specifically new technol ogy catches up with the abatement Industry, more productive methods for VAT removal wOlcome to theforefront" those related to the high concentra tion of dtric add vapors within an enclosedworkarea. Negativeairmachines must remain in operation for ventilation, and special protective measures regarding worker health must be taken McQueen cautions, "We have found the dtric add va pors to be very irritating to the mucous membranes (eyes, nose and throat). We require our workers to wearfull-fece respirators foreye pro tection, and we utilize piggyback filter cartridges with asbestos/charcoal elements far protection to the respiratory tract" Speaking from past experience, McQueen adds, "Whan workers have attempted to work with these materials without the charcoal filter element, we have found them suffering from various symptoms induding severe head aches, mild intoxication and even lossofequilibrium.Wewill notallow anyone intheworkareas duringthis process without the added respira tory protection." From a performance standpoint citrus cleaners do an outstanding job inremovalofthe petroleum-based MTAa. The abatement contractor, when observing the precautions noted here, will have a safe, efficient system by which to accomplish the MTA removal. There are other ways to remove mastic. Jim Walton suggests that a high-pressure water system is more advisable than the chemical ap proach to mastic removal. This method uses a high-pressure (he ST003G9I 6 ST0036911. reporta 4,000 PSI) water jet to me chanically dislodge the mastic. Both water and mastic are then vacu umed from the surface by the same machine, leaving little opportunity forsignificantwaterdenude or fiber release. One contractor reports using a shot-blast machine coupled with a HEPA vacuum to remove both syn thetic and petroleum-basedmastics. Extremely hard beads are directed by the machine at the floor's surface. Upon impact, the beads mechani cally dislodge the mastic from the substrate and both the expelled beads and the masticare drawnback into the machine. The beads are recycled and the mastic is drawn into aHEPA vacuum forsubsequent disposal. PACKAGING AND DISPOSAL Because requirements for pack aging and disposal will vary from state to state and from locale to lo cale, each appropriate agencyshould be consulted before planning which methods to utilize for any particular project. Federal interpretation ofthe NESHAP regulations has remained fairly consistent Once non-friable VAT and MTA are removed and subsequently broken, or dislodged from their place ofinstallation, they should be packaged, handled and disposed of as friable asbestoscontaining materials. At a minimum, if more stringent requirements are not applicable, VAT and MTAshould be wetted with amended water and sealed in double 6 mil disposable bags with the statu torywarninglabels properly affixed. The VAT materials will, in most cases, require added protection in transport and disposal because of their relative weight and the rough, sharp edges that can potentially puncture even double layers of6 mil bags. Boxes and fiberormetal drums provide excellent containers for transport. Additionally, some landfills may requirethisrigid pack aging for deposition into their facili ties. AIR SAMPLING Typical asbestos removal projects often involve air samples being col lected and analyzed before, during andafterthe asbestos removal. Since airborne fiber counts tend to remain relatively low during tile and mastic removal, less air sampling is justifi able, although some sampling is required. Sample results are needed to assure appropriate respirator use and to "dear* the project. During most tile and mastic re moval projects, contractors seem to bevery efficientinkeepingthe phase contrast microscopy (PCM) fiber count for personal and area samples at or below 0.1 fibers percubic centi meters ofair {Gee). However, experi ence and reported data show that there is often difficulty gettingtrans mission electron microscopy (TEM) results below the typical clearance level of0.01 Gee, especiallywhen thei samples were collected under ag gressive clearance techniques. Such TEM clearance sample results are often found as high as 0.1 Gee. In one case, 3.0 Gee was reported. Analysisi "As oJ1987, 1 EPA/AHERA requires schools to includeJloor tile and mastic in their building inspections and asbestos man agement plans. " 'zearzsssaaZTBSi -- v. of the fiber sizes detected by TEM[ has shown that most ofthe fibers ares less than 5 microns in length. JohnM.Jenkins, anarchitectwithi Comprehensive Technical Consult ants, Inc., in Atlanta, presented the! following conclusions after conduct ing research on air counts associ ated with tile removal: 1. Asignificantamountofasbestos> fiberis released duringremoval1 of vinyl asbestos tile usingj conventional tile removal1 methods. 2. Fiber control methods such asi damp removal or isolation of areas by plasticizing, and use off appropriate respirators, shouldi be utilized for tile removal. 3. Areas subjected to contamin ation by tile removal usingg uncontrolled methods shouldbe thoroughly cleaned and testedd prior to being returned to use. WORKER PROTECTION Floor tile and mastic removatl projects pose many of the same worker hazards as do any other asbestos removal projects. Wile there should be major concert nr protecting workers against the nazard of airborne asbestos fibers that might cause disease in five tc 30 years, there are hazards uniqu to this type of removal that can cause injuries or illness in a matter-of seconds or days. As previously described, airbo.ue fiber counts in the tile and mastic removal area are usually below *le OSHA excursion level (1.0 f7cc for 0 minutes), permissibleexposurelimit (0.2 Bee for 8 hours) and action level (0.1 Gee for 8 hours). However, e levels do become elevated alx e background and clearance concen trations during routine removal ad may even exceed one or more of t OSHA limits while using sevue removal techniques. It is prudent to require employe ~i to wear respirators and protects clothing. In most cases, the respira tor choice will range from a half-fajs air purifier with appropriate cs fridges to a full-face, tight-fittu _ powered air-purifying respirator (PAPR) with appropriate cartridge*The most desirable minimum res; ratory protection is a respiratortha, reduces the exposure to 0.01 Gee insidethe respirator. And some locf jurisdictions may enforce even mot stringent requirements or interpretations. The protective clothing of choic is most frequently disposable covei alls. When a full decontamination setup is used, the employees shoulAremoveall`streetclothingand items in the clean area before donning the disposable coveralls, plus foot, hand, eye and head protection. Since thr~ purpose ofthia protective clothingii to prevent asbestos contamination from being carried outside the workareas and causing subsequent expo sure, the clothing requirement should be based upon several factors: airborne fiber concentration, - potential for contamination during tile and mastic removal, and poten tial for contamination during han dling, packaging and disposal, Special foot protection may be necessary. If heavy, long-handled scrapers are used for tile or mastic_ removal, or ifthere are other poten tial foot hazards such as handling drums or barrels of materials, employees should have safety-toe pro-- tection. Foot protectionagainst many 13 Macros issue w-wiboo hazards' often can be provided by be kept at the jobsite and readily saffty-t^ drabberr syntheticboots. available to supervisors, employees These can provide protection from and inspectors for review before the wetness and slipping, asbestos con chemicals are used. However,proper tamination andchemicals. Ofcourse, labeling procedures and making they become contaminated with the first trip intothe prqjectandmostbe stored in the dirty equipment area. Safety shoes or deck shoes will sometimes providethe levelofneeded MSDSs available are not adequate sources afinformationbythemselves. Employees also should receive on site training covering the chemicals on the list, the labels, the MSDSs, protection and may be acceptable the hazards and the required pre choices. Some foot protection over the booties is always necessary be cause they tear and rip quickly in these types ofprojects. Bootand shoe cautions. Fromidentification to government regulations to the many removal techniques, there are still many GIG9E001S selection can be even more critical if questions regarding asbestos-con they will be worn on surfaces cov tainingfloortile andmasticforwhich ered with solvents orcitric add solu there are no generally accepted or tions that may attack and dissolve uniform answers. But considering the materials or the glues used to the potential health and legal prob construct the footwear. lems associatedwith these asbestos- Hand protection is also a concern. containing materials, it is necessary Gloves should be worn to keep as to considerthe currentdata andtake bestos contamination off the hands appropriate actions based on that and protect against skin damage knowledge. As more research better from cuts, abrasions and the clarifies these issues, the removal | amended water and chemicals used in the project The contents of the solvents and citric adds used to techniques for asbestos floor tile and | mastic will accordinglybecome more j or less stringent j remove mastic may pose unexpected hazards. Actual glove selection William H. Spain, CSP, is presi- I should be made keeping these haz dent ofThe EnvironmentalManage- ! ards in mind. Styles range from short merit Group, Inc.,Atlanta. Spain was ; cotton gloves to longneoprene gloves previously the director of training j with moisture-absorbent linings Many of the removal techniques make eye protection necessary. The basic options for eye protection are full-face respirators orsafety glasses and goggles with half-face respira tors. The full-face respirator gives increased respiratory protection in addition to eye protection. A formal hazard communications program should be offered to inform employees about the potential haz ards of the chemicals used on the project. Such chemicals include wetting agents, solvents and ritric add mastic removal agents. The hazard communication program should indude, at a minimum, a list ofchemicals that will be used on the project, proper container labeling, material safety data sheets (MSDS) andpublications for the Georgia Institute of Technology. He is an accredited building inspector and < management planner under EPA- ' approved programs. William M. Ewing Jrn CIH, is the executive vice president of The Environmental Management Group, Inc., and the director ofthe Asbestos Management Consulting Division (AMCD). Ewing was previously group leader of the Asbestos Program of the Georgia Institute of Technology and was responsible for the development ofthe Transmission Electron Microscopy Laboratory. Nicolas P. Wickware, GSM, is senior project manager with Halliwell Engineering Associates, Inc. He waspreviously involvedwith The EnvironmentalManagement Group, and appropriate employee training. Inc., and has servedaspresident and If rite chemicals are kept in their operations manager for Asbestos original containers, they are usually Abatement Services, Inc. He was adequately labeled; but ifthe chemi cals are transferred to other con tainers,those containers shouldhave instrumental in creating a major EPA-approved asbestos training center in Boston and is a certified appropriate labels placed on them identifyingthe contents and precau tions. A copy of the MSDS for all chemicals used on the prqject should safety manager, building inspector, management planner, advanced asbestos abatement supervisor and abatement contractor.