Where do we go from here?

Where do we go from here?

Exposure to elevated levels of asbestos fibers has been documented to cause a variety of diseases including asbestosis and cancer.  Consequently, the application, removal, and disposal of asbestos-containing materials are regulated by several agencies, including state health and environmental resource departments. 

To date two federal agencies have been principally responsible for generating regulations for asbestos control. These two agencies are the United States Environmental Protection Agency (EPA) and the United States Occupational Safety and Health Administration (OSHA).

 

Primary regulations concerning asbestos related issues are found in:

EPA   AsbestosSchoolHazard Reauthorization Act (ASHRA)

EPA    National Standard for Hazardous Air Pollutants (NESHAP)

EPA    Asbestos Hazard Emergency Response Act (AHERA)

EPA    Asbestos Ban and Phase Out Rule

EPA    Worker Protection Rule

OSHA 29 CFR 1910.1001     General Industry

OSHA             29 CFR 1926.1101     Construction Industry

OSHA             29 CFR 1919.134       General Industry

 

EPA, state and local air program inspectors may inspect renovation and demolition sites to determine compliance with the Asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP), 40 CFR sections 61.140 through 61.157.

A building owner is required to inspect the structure to be demolished or the area to be renovated prior to the commencement of work.

The inspection requirements of NESHAP are as follows:

  • Thorough inspection by a certified inspector for friable and non-friable ACM within a building or facility prior to any demolition activity or renovation that may involve demolition aspects.
  • Prior to any renovation activity a thorough inspection for friable and non-friable ACM must be conducted by a certified inspector within that portion of the building or facility being renovated.

An EPA NESHAP Inspectors may:

  • review notification documents
  • inspect job sites and building locations
  • collect physical evidence necessary to document compliance or      noncompliance

The Asbestos NESHAP program focuses on renovation and demolition activities and waste disposal sites. It applies to asbestos generation during mining, manufacturing/fabricating, renovation and demolition and waste disposal.

Depending upon the type of operation, owners and may be required to:

  • notify the appropriate state or local air program authority
  • conduct a thorough inspection
  • use renovation and/or demolition techniques that do not cause visible emissions and in certain cases utilize certified workers and contractors

Regulated material removed during a renovation or demolition must be managed and buried in an approved landfill.

Whether asbestos is present or not, the owner or operator of a facility that will be demolished must submit a NESHAP notification to the appropriate agencies 10 days prior to any demolition (certain exceptions may apply depending on jurisdiction). The owner or operator means any person who owns, leases, operates, controls, or supervises the facility being demolished or renovated or any person who owns, leases, operates, controls, or supervises the demolition or renovation operation, or both.

Before you begin your next demolition or renovation project contact GPAC for assistance in the planning process.

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