Dealing with asbestos is a reality for many demolition and construction projects. Because asbestos has been shown to cause a number of serious health problems, abatement or containment of asbestos must be addressed with the utmost seriousness. By developing contingency plans as well as following safety guidelines, it is possible to minimize the danger asbestos poses. A renovation or demolition plan must address the possibility of finding and having to deal with asbestos. This is for both health reasons and the need to comply with state, federal, and local regulations in relation to asbestos.
Asbestos was used in over 3,000 different products through the 1970s. As a result of this, it is encountered in many renovation and demolition projects. “Asbestos” is not a mineralogical definition; rather it is a generic term applied to the fibrous variety of six naturally occurring minerals used in commercial products. Asbestos is a commercial designation for mineral products that possess the following characteristics: high tensile strength, flexibility, resistance to chemical and thermal degradation, and high electrical resistance, and the ability to be woven. Asbestos is made up of fiber bundles. These bundles have splaying ends, are very flexible, and are made of long and thin fibers that can be easily separated from each other.
Asbestos can be found in many types of building material. This article addresses how it should be dealt with during renovations and demolitions.
Inspecting for Asbestos Before Renovation or Demolition
Before any renovation or demolition occurs, conduct an asbestos survey of the work area. You will be looking for ACM, or asbestos-containing material, which the EPA defines as any substance containing more than 1% asbestos. You will also look for presumed asbestos-containing material, or PACM. A PACM is any resilient floor covering, thermal system insulations, and spray-applied toweled-on surfacing material installed before 1981. You must presume that such materials contain asbestos, and treat them as such, until inspections and tests by accredited professionals prove otherwise.
If ACM or PACM is detected, appoint an asbestos program manager or an asbestos coordinator. This person will:
- Choose a consultant and laboratory
- Design the data management system
- Communicate with building occupants
- Coordinate all activities related to the inspection and management of asbestos
Ask knowledgeable building personnel to assist in the process. For instance, ask an engineer with drawings and original building specifications to accompany the surveyor during the physical inspection.
When and How to Notify the EPA About Renovation or Demolition
You must notify the EPA under certain circumstances. The NESHAP (National Emission Standards for Hazardous Air Pollutants) regulations state that the agency must be alerted to any renovation and demolition projects involving asbestos. Types of notification include:
- Routine maintenance blanket one-year notification: Each year, the asbestos coordinator must notify the EPA of all ACM to be abated through routine maintenance during that calendar year. The notice must include all individual, small-scale abatement actions that involve less than 260 linear feet or less than 160 square feet of ACM. This notification requirement will apply if the sum of all such small-scale abatements for the year is expected to exceed these limits. Not covered, however, is any single abatement action that exceeds 260 linear feet or 160 square feet or any demolition projects. Instead, a separate, individual notice must be submitted for these types of projects.
- Renovation projects: Notify the EPA if the amount of regulated ACM to be abated or otherwise disturbed in a facility being renovated is greater than 260 linear feet on pipes, 160 square feet on other facility components, or 35 cubic feet of facility components where the length or area could not be measured previously. Notifications must be postmarked or delivered at least ten working days before asbestos stripping or removal work or other activity begins (such as site preparation that would break up, dislodge, or similarly disturb asbestos material). In addition, notifications must be updated when the quantity of regulated ACM changes by at least 20 percent. Check with your state to determine applicable requirements.
- Demolition projects: Demolition is defined as the wrecking or taking out of any load-supporting structural part of a facility, together with any related handling operations or the intentional burning of any facility. Notify the EPA of all demolition projects involving ACM. Notifications must be postmarked or delivered at least twenty working days before work begins. In addition, notifications must be updated when the quantity of regulated ACM changes by at least 20 percent.
If the Planned Start Date of Renovation or Demolition Changes
If the planned start date of a renovation or demolition project changes after a notice has been submitted, notify the EPA according to the following schedule:
- If the new start date is later than the original, a notice must be provided by telephone as soon as possible before the original start date; a written notice must be postmarked or delivered as soon as possible before, and no later than, the original start date.
- If the new start date is earlier than the original, a written notice must be postmarked or delivered at least ten working days before any stripping or removal work begins.
The regulations state a renovation must begin on the new start date contained in the written notice.
Handling Asbestos Abatement Prior to Renovation or Demolition
Asbestos abatement is best handled separately before other contractors are allowed to perform renovation or demolition work. Whatever the project, an operations and maintenance program should be formulated to address training, cleaning, work practices, and surveillance to successfully manage the ACM or other hazardous substance. A good O&M program includes procedures for events such as water leaks that require asbestos abatement.
Project Design Specification
A project design specification outlines standard operating practices, the scope of work, and special requirements for abatement projects. A written specification enables effective bidding and provides long-term documentation of how the project was executed. Use standard, nationally recognized formats, such as those from the AIA (American Institute of Architects) or NIBS (the National Institute of Building Sciences) when preparing the specifications.
Develop full bid/contract specifications, or a technical specification only. Technical specifications should clearly define the responsibilities of all those involved with the project and be free of ambiguities and errors. A mandatory site walk-through is recommended to address the questions or concerns of all parties before bids are submitted and the project begins. Every contractor qualified and willing to bid should inspect the site thoroughly and analyze the project requirements. Whenever possible, contractors invited to bid should be prequalified using documentation including:
- Previous citations received
- Capacity to perform work in an allotted time frame
Asbestos-related work should be designed to ensure building occupant and public safety and to minimize disruption to construction or facility operations. Therefore, good project design should allow the process of asbestos removal to be entirely isolated and fully completed well before general contract work begins. In addition, coordinate with other personnel who may be working on the site.
Well-planned design specifications incorporated into the contract between owner and contractor attract qualified contractors, minimize contractor change orders, and provide solid criteria for satisfactory completion of the work. Written specification standards are often more stringent and comprehensive than asbestos regulations, using the industry’s current best practices that provide for long-term liability protection.
Specification costs will depend on project size, scope, and complexity. Specification costs may be 30 percent of the total for small-scale asbestos abatement projects (less than $3,000) and 5 percent or less of large-scale projects (more than $100,000). The owner should be cautious about using generic, boilerplate-type specifications that do not consider unique project requirements.
Dealing with Unexpected Asbestos Containing Materials During Renovation or Demolition
An important part of project management involves emergency contingency planning. If additional or unexpected asbestos containing material is encountered during a renovation or demolition, follow preplanned procedures to avoid problems. Qualified parties can respond promptly and efficiently to minimize the impact on the project. Other contingency elements are
- Evacuation procedures
- Building/property security
- A water control and fire plan
It is imperative that the abatement or containment of asbestos is addressed with the utmost seriousness. By developing contingency plans as well as following safety guidelines, it is possible to minimize the danger asbestos poses.
This article is adapted from BOMI International’s Contaminants Reference Guide. More information regarding this is available by calling 1-800-235-2664, or by visiting www.bomi.org.