Asbestos Management Plan

“Asbestos” describes six naturally occurring fibrous minerals found in certain types of rock formations. When mined and processed, asbestos is typically separated into very thin fibers that are normally invisible to the naked eye. They may remain in the air for many hours if released from asbestos – containing material (ACM) and may be inhaled during this time. Three specific diseases – asbestos (a fibrous scarring of the lungs), lung cancer and mesothelioma (a cancer of the lining of the chest or abdominal cavity) – have been linked to asbestos exposure. It may be 20 years or more after exposure before symptoms of these diseases appear; however, high levels of exposure can result in respiratory disease within a shorter period of time.

Most of the health problems resulting from asbestos exposure have been experienced by workers whose jobs exposed them to asbestos in the air over a prolonged period without the worker protection that is now required. Asbestos fibers can be found nearly everywhere in our environment, usually at very low levels. While the risk to occupants is likely to be small, health concerns remain, particularly for the custodial and maintenance workers in a building. Their jobs are likely to bring them into proximity to ACM and may sometimes require them to disturb the ACM in the performance of maintenance activities.

EPA estimates that “friable” (easily crumbled” ACM can be found in an estimated 700,000 public and commercial buildings. About 500,000 of those buildings are believed to contain at least some damaged asbestos. Significantly damaged ACM is found primarily in building areas not generally accessible to the public, such as boiler and mechanical rooms, where asbestos exposures generally would be limited to service and maintenance workers. However, if friable ACM is present in air plenums, it can be distributed throughout the building, thereby possibly exposing building occupants.

When is asbestos a problem? Intact and undisturbed asbestos materials do not pose a health risk. The mere presence of asbestos in a building does not mean that the health of building occupants is endangered. ACM which is in good condition, and is not damaged or disturbed, is not likely to release asbestos fibers into the air. When ACM is properly managed, release of asbestos fibers into the air is reduced, and the risk of asbestos – related disease is thereby correspondingly reduced.

There are a number of guidelines and regulations that govern asbestos exposure. Occupational standards for preventing asbestos-related diseases are recommended by NIOSH and promulgated by OSHA. NIOSH guidance contains Recommended Exposure Limits (RELs) and OSHA standards set Permissible Exposure limits (PELs). The standards also contain many other measures, such as surveillance, medical screening, analytical methods, and methods of control. OSHA regulations and the EPA Worker Protection Rule also provide guidance on day-to-day activities that bring workers in contact with ACM. EPA National Emission Standards for Hazardous Air Pollutants (NESHAP) define acceptable practices for renovation and demolition activities that involve asbestos-containing materials. In addition, many State have set exposure standards and other regulations concerning asbestos.

EPA and NIOSH recommend a practical approach that protects public health by emphasizing that ACM on buildings should be identified and appropriately managed, and that those workers who might disturb it should be properly trained and protected.

EPA AND NIOSH POSITIONS ON ASBESTOS

In an effort to calm unwarranted fears that a number of people seem to have about the mere presence of asbestos in their buildings and to discourage the decisions by some building owners to remove all ACM regardless of it’s condition, the EPA Administrator issued an Advisory to the Public on Asbestos in Buildings in 1991 . This advisory summarized EPA’s policies for asbestos control in the presentation of the following ” five facts”:

Although asbestos is hazardous, the risk of asbestos-related disease depends upon exposure to airborne asbestos fibers. Based upon available data, the average airborne asbestos levels in buildings seem to be very low. Accordingly, the health to most building occupants also appears to be very low. Removal is often not a building owner’s best course o action to reduce asbestos exposure. In fact, an improper removal can create a dangerous situation where none previously existed. EPA only requires asbestos removal in order to prevent significant public exposure to airborne asbestos fibers during building demolition or renovation activities. EPA does recommend a pro-active, in place management program whenever asbestos-containing material is discovered.

NIOSH’s position on asbestos exposure has been expressed in NIOSH policy statements and Internal reports and at OSHA public hearings:

NIOSH recommends the goal of eliminating asbestos exposure in the workplace. Where exposures cannot be eliminated, exposures should be limited to the lowest concentration possible. NIOSH contends that there is not safe airborne fiber concentration for asbestos. NIOSH therefore believes that any detectable concentration of asbestos in the workplace warrants further evaluation and, if necessary, the implementation of measures to to reduce exposures. NIOSH contends that there is no scientific basis to support differentiating health risks between types of asbestos fibers for regulatory purposes.

Copies of EPA and NIOSH policy statements and public advisors are available, respectively, from
those agencies. See the last section in this appendix and Appendix G for information on how to obtain them.

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