Asbestos containing materials (ACM) are found in thousands of building products making up homes, commercial buildings and industrial work places. Having ACM within a building does not mean that there is an immediate risk. While asbestos can cause a variety of serious health problems, it is only a problem when the fibers become airborne and are breathed into the lungs. In order to determine whether asbestos may be a problem in any given building, there are different services that may be helpful:
Asbestos Monitoring & Project Management
Going hand and hand with the surveys, facility owners and operators are also required to insure that employees or occupants of their buildings are not exposed to unsafe levels of airborne asbestos. Allowable fiber levels as defined by the regulatory agencies and various standards exist for different facilities. Possible asbestos air monitoring services include:
Provides the basic daily level of fibers in the air. Useful for insuring that employee exposures are below regulated levels and that asbestos has not been improperly disturbed within the building.
This sampling is conducted daily while asbestos abatement operations are being conducted. Additionally, ETC verifies that the contractor is complying with the project specifications and all applicable regulatory requirements. This allows the building owner to provide documentation to occupants and / or employees that the asbestos removal operation is not exposing them to asbestos fibers.
For these projects, ETC provides a comprehensive report detailing all on-site activities and sampling results. Daily sampling includes performing clearance sampling.
Clearance (Post Abatement) Air Sampling – This is sampling conducted after asbestos has been removed. These samples taken in the area of removal insure that the area / building in safe to reoccupy.
Although usually reserved for other types of exposure (lead, cadmium, etc.), some types of asbestos removal operations (of non-friable asbestos only) allow the contractor to perform initial sampling over two (2) days and demonstrate that the removal employee’s exposure is very low. If the results are acceptably low, the contractor may then discontinue monitoring for the duration of the project.
ETC also provides a variety of other types of asbestos monitoring including TEM sampling, SEM sampling, personnel sampling, etc. for unique and special projects.
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ETC can help identify and quantify environmental issues, liabilities, and costs associated with acquisitions and projects, and lead our clients to better business decisions.
Lead & Cadmium Monitoring
As with asbestos, OSHA has recently been conducting heavy enforcement of the lead and cadmium rules. Most OSHA enforcement officers conducting a field audit are requesting information to insure that the contractor is complying with current requirements for lead and cadmium. The three questions asked by a compliance officer are:
- Are those surfaces covered with lead or cadmium paint?
(Has your company had the paints and coatings you are working on tested?)
- Have you given your employees the required awareness training to be working on lead and / or cadmium?
- Are your employees being exposed above the action level of PEL?
(Have you conducted monitoring showing that the airborne levels are below the required OSHA action level or PEL?)
Given the recent increase in lead / cadmium enforcement actions, it is important that contractors, employers and trade groups have documentation of their compliance with these OSHA requirements including: training, sampling, respirator selection, engineering controls, administrative controls, etc.
Negative Exposure Assessments
Negative Exposure Assessments (NEAs) are situations where the contractor believes that the potential exposure levels are very low and will never exceed the OSHA – Action Level (AL) or the Permissible Exposure Level (PEL). In cases like these, if the contractor can demonstrate that even under “worst case” scenarios the AL nor the PEL will be exceeded they may often discontinue monitoring, PPE and other OSHA requirements.
ETC is often contacted and requested to conduct a negative exposure assessment for a variety of different possible exposures. Some exposures that are being looked at closely by OSHA currently include: mercury, formaldehyde, welding fumes, silica, total particulates, respirable particulates, and many others.
Unfortunately when ETC is requested to perform an NEA, we have to explain to the requestor that we can initially only provide “exposure monitoring”. Only if the documented levels are low enough can this exposure monitoring be converted in to a Negative Exposure Assessment. In order for this to work, the contractor has to develop a “worst case” situation.
In general some of the requirements to try and develop an NEA include:
- The NEA is good for 12 months at which point additional monitoring would be required.
- Each NEA requires two days of monitoring a full 8 hour shift.
- Work activities must represent the “worst case” as compared to work that will be done after NEA is developed. Each different type of work activity must be monitored (i.e. – sandblasting, scrapping, encapsulating, inc.).
- The NEA is only valid for workplace conditions “closely resembling” those demonstrated during the NEA development. It the contractor’s responsibility to insure that the activities that were used during the NEA development are “representative” of the activities to be used for the rest of the project.
- Employees who perform work using this NEA must have both equivalent training and experience as those employees who were tested during the NEA development.
Lastly, even if ETC is able to develop an NEA, there are still some activities that will be required on that project for OSHA compliance. Some of these might be (not a complete list):
- Workers must still use HEPA equipped vacuum cleaners for all clean-up work.
- Workers must still use wet methods for all work to reduce producing contaminated dust and keep the area properly cleaned.
- Workers must comply with the OSHA – HAZCOM standard any contaminants in question.
- All workers must practice good hygiene by washing their face and hands at the end of each work period.