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Building Owners When is Asbestos a Concern
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There are no health threats when asbestos containing building materials remain undisturbed and do not become airborne.   Asbestos containing floor tile is a good example of a building material that is not a health hazard when in good condition.  Normal wear will not release fibers, in fact you would have to burn, grind, or use extreme mechanical methods to release enough fibers to be a health concern.  On the other hand, popcorn ceiling texture can easily become airborne.  If you simply rub your hand over the surface you will cause a release of fibers.

The EPA has placed asbestos containing materials into two basic groups:

  • Friable
  • Non-Friable

Friable asbestos is the worst of the two and is defined by the EPA as follows: “Friable asbestos material is any material containing more than 1 percent asbestos as determined using Polarized Light Microscopy (PLM), that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.”   As you can imagine floor tile would be difficult to make friable, but popcorn ceiling texture would be relatively easy.

Non-Friable asbestos is defined by the EPA as follows: “Non-friable asbestos containing material is any material containing more than 1 percent asbestos as determined by Polarized Light Microscopy (PLM) that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.”  
But this grouping only describes materials that are in place and undisturbed. 

The EPA further warns that if a non-friable material such as floor tile is very dry or in poor condition or gets run over by an excavator, loader, or other vehicle, it may become converted to a friable material.  The EPA only recognizes certain persons to legally make this determination, a certified building inspector, and an ADHERA Contractor/Supervisor, be aware that the local regulators that administer the NESHAP regulations have all the proper certifications as well.
  
Asbestos materials become a concern for Building Owners when you hire a General Contractor, or other contractors that may disturb asbestos materials through demolition or renovation activities.

Asbestos is also a concern when routine maintenance activities will disturb asbestos or asbestos in poor condition might release fibers, like old pipe insulation that starts breaking off and falling on the floor.   The building owner is ultimately responsible for being certain that the regulations are being followed. 

Charter Schools

All schools K thru 12 whether public or private that are organized as “not for profit” under the IRS Code are subject to the AHERA (Asbestos Hazard Emergency Response Act) regulations.  This means church schools, charter schools and any other schools.  The only exceptions are universities, colleges, and schools which are organized for profit, like Nevry Institute and ITT Tech.

            The Federal AHERA regulations 40 CFR 763, Subpart E require that schools:

  • Assume the presence of asbestos in building materials
  • Conduct an inspection to prove the absence of asbestos  
  • Develop, implement and follow an asbestos management plan
  • Maintain records as required

Schools must have an Asbestos Management Plan and a trained “Designated Person” must manage the asbestos program.
 
All maintenance and custodial personnel that merely work in a building that contains asbestos must be trained in a 2-hour Awareness class.  All those who may disturb asbestos must have an additional 14 hours of training (16 hours total - Operations and Maintenance). Both OSHA and EPA compliance depend on these training requirements. 

Go to the Other Links page and there are links to training providers like The Asbestos Institute which can provide the necessary training.

 

Building Owners

When is Asbestos a Concern