Sample Protocol for Inspection of Asbestos Containing Material
Date: Wednesday, December 30, 2009
Subject: (Short Form) Protocol for Inspection of Asbestos Containing Material (Residential Structure)
The removal of asbestos containing material from a residential structure can be regulated by numerous federal and local regulations. For example, a home in the 91748 zip code would be governed by regulations promulgated by the U.S. EPA, U.S. OSHA, Cal/OSHA, Cal/EPA, NESHAPS, and SCAQMD. This protocol outlines the proper procedures for an asbestos inspection in a home within the 91748 zip code. In other cases, local regulations will differ depending on where the home in need of inspection is located.
The South Coast Air Quality Management District (“SCAQMD”) has jurisdiction over the potential emission of stationary source asbestos containing material. Generally, a SCAQMD Notification form and associated filing fee must be filed with the SCAQMD fourteen calendar days before the potential release of asbestos containing material within its jurisdiction so that the SCAQMD can perform an inspection of the residence. The proposed inspection would fall within an exception, and should not require notification and filing fee, so long as less than a few square feet of asbestos containing material is removed and the removed asbestos containing waste not be replaced with non-asbestos containing joint compound and drywall.
Within SCAQMD jurisdiction the person engaged in the inspection and removal of asbestos containing material from a residence such as the Camwood rental property must be certified by Cal/OSHA pursuant to regulations required by subdivision (b) of Section 9021.5 of the Labor Code, and shall have taken and passed an EPA-approved Building Inspector Course. Before the inspection and removal of asbestos containing material, the following must be supplied: (a) his/her Cal/OSHA Registration number, (b) verification of his/her passing an EPA-approved Building Inspector Course, (c) the name and location address of off-site storage area for the asbestos containing waste material, (d) the name, address and telephone number of the transporters used to transport the asbestos containing waste material off-site, and (e) a signed certification that Georgia-Pacific will adhere to the terms of the protocol and indemnify the property owner, his counsel and consultants should there be resulting liability associated with the release of asbestos containing materials related to the inspection at the Camwood rental property.
A Clean Room shall be established in an area of the house adjacent to the asbestos removal work area. Before entering the asbestos removal work area each individual will put on a respirator and clean protective clothing in the Clean Room. Respirators will be either Powered Air Purifying Respiratory with HEPA Filtration, or Type “C” air supplied respirators. Protective clothing will be disposable full body coveralls, disposable foot covers, disposable head gear, and eye protection. When leaving the work area, all individuals must remove gross contamination clothing before leaving the work area except for respirators which must remain on and only removed in the Clean Room. No individual shall eat, drink, smoke, or chew gum while in the work area. Prior to commencement of work, all individuals shall be instructed on emergency evacuation and evacuation procedures to be followed in the event of compressor failure.
The SCAQMD recommended HEPA Filtration removal procedure requires:
(1) All stationary objects and surfaces not intended for removal or stripping of asbestos-containing materials shall be covered with plastic sheeting;
(2) All air passageways, such as doors, windows, vents and registers in the work
area, shall be covered and rendered air tight with plastic sheeting or hard wooden
barriers with studded support. Air passageways used to provide makeup air for
the isolated work space need not be covered;
(3) All sources of air movement, including the air-handling system, shall be shut off or temporarily modified to restrict air movement into the work zone;
(4) The barriers used for the construction of the isolated work area shall be equipped with transparent viewing ports which allow outside observation of all stripping and removal of asbestos containing materials;
(5) The isolated work area shall be vented, with negative air pressure to a HEPA filtration system, which shall be operated continuously from the commencement of removal activities through the final clean-up of the work area;
(6) The HEPA filter shall be free of tears, fractures, holes or other types of damage and shall be securely latched and properly situated in the holding frame to prevent air leakage from the filtration system;
(7) Asbestos containing materials shall be adequately wet during the removal process;
(8) Asbestos containing materials shall be carefully lowered to the ground or a lower floor without dropping, throwing, sliding, or otherwise damaging or disturbing them;
(9) Asbestos containing waste materials shall be collected, and sealed in transparent leak-tight containers. They shall be adequately wet prior to and during collection and packaging.
(10) All surfaces in the isolated work area shall be cleaned, with a vacuum system utilizing HEPA filtration, wet mopping and wipe down with water, or by an equivalent methods, prior to the dismantling of plastic barriers or sealed openings within the work area.
The asbestos containing waste material must be placed in transparent leak-tight containers. The transparent leak-tight containers must be labeled in accordance with Cal/OSHA requirements as follows:
DANGER
CONTAINS ASBESTOS FIBERS
AVOID CREATING DUST
CANCER AND LUNG DISEASE HAZARD
The leak-tight containers must also contain the name of the waste generator and the Camwood address as the location at which the waste was generated. The leak-tight containers containing the asbestos containing waste materials must be enclosed in a locked area.
The vehicle that will transport the asbestos containing waste material must be marked with 20 x 14 inch upright signs, displayed in a location and manner that is easily readable, that sate:
DANGER
[2.5 cm (1 inch) Sans Serif, Gothic or Block]
ASBESTOS DUST HAZARD
[2.5 cm (1 inch) Sans Serif, Gothic or Block]
CANCER AND LUNG DISEASE HAZARD
[1.9 cm (3/4 inch) Sans Serif, Gothic or Block]
Authorized Personnel Only
[14 Point Gothic]
[With spacing between any two lines at least equal to the height of the upper of the two lines.]
Records shall be kept containing at least this information relating to the transport of the asbestos containing material:
(i) The name, address, and telephone number of the waste generator;
(ii) The name, address, and telephone number of the South Coast Air Quality Management District;
(iii) The quantity of asbestos containing waste;
(iv) The name and telephone number of the storage site owner and operator;
(v) The name and physical site location of the storage site;
(vi) The date transported;
(vii) The name, address, and telephone number of the
transporter; and
(viii) A signed certification that the contents of this consignment are fully and accurately described by proper shipping name and are classified, packed, marked, and labeled, and in proper condition for highway transport according to applicable federal, state, and local regulations.
Georgia-Pacific or its agents must maintain records for not less than three years, and make them available to the SCAQMD, Camwood tenants, or property owner upon request, of (A) a copy of all survey-related documents, (B) records containing an estimate of the amount of asbestos containing material removed, (C) the type of removal controls used, and (D) a copy of all asbestos containing waste shipment records.
The inspection and removal should be monitored by a Cal/OSHA certified consultant representative of the tenant or property owner to monitor and verify compliance with the above procedures. Attorneys for the respective parties should agree upon doubling of asbestos contaminated waste samples, amount of sampling, etc.
