Asbestos-Containing Material Surveys
The presence of asbestos in buildings must always be a consideration when building materials are disturbed, whether planned or by accident. Asbestos has not been 100% banned in the United States, therefore the EPA NESHAP regulations that require a “thorough inspection” do not specify a date of when this requirement is no longer required. Thus, any structure falling under the EPA NESHAP regulation is required to be inspected for asbestos, regardless of age. OSHA’s requirements of building owners and employers to identify the presence, quantity, and location of ACM in the workplace are similarly not restricted to just “older buildings”. Obviously, with the diminishing use of asbestos in the U.S. through the last 70 years, the more recent a building has been constructed, the less likelihood of the presence of asbestos, but we cannot definitively determine the absence of asbestos merely based upon age of the structure.
For all buildings and structures that do not fall under the EPA AHERA regulations (i.e. public schools), there are no federal regulations specifying the methods or procedures for conducting asbestos inspections to determine the presence or absence of ACM, even though these inspections are required to be performed prior to any renovation or demolition work. However, certain states have their own asbestos regulations stipulating their own expectations for how an asbestos inspection is to be performed to be compliant with their regulations. In addition, certain municipalities such as City of Philadelphia and New York City even have their own asbestos regulations and licensing requirements in addition to their state regulations and the federal regulations.
To manage the ambiguity of the federal asbestos inspection expectations and divergent state asbestos survey requirements, Langan’s Standard Operating Procedures (SOPs) are based upon the American Society for Testing and Materials (ASTM) standard E2356 – Standard Practice for Comprehensive Building Asbestos Surveys. ASTM E2356 meets the applicable requirements of almost all states, as well as EPA NESHAP Standard 40 CFR 61, Subpart M (Asbestos), EPA AHERA Standard 40 CFR 763, Subpart E, and Occupational Safety and Health Administration (OSHA) asbestos survey and/or sampling regulations. Where state and/or local municipality regulations differ from the ASTM standard, Langan follows the state and/or local municipality requirements. This ensures that when performing asbestos inspections, regardless of the type of building or location of building, Langan’s inspections comply with the current industry standards as well as federal regulations requiring “thorough inspection” and any applicable state asbestos regulations.
For all asbestos surveys, it is vitally important for inspectors to inspect as many functional spaces as possible, and document the reasons why certain functional spaces were not inspected, and locations where no suspect materials were observed and, consequently, no samples were taken. Reasons might include access limitations, the absence of materials to sample, the existence of information from previous surveys, or the availability of reliable documentation such as Safety Data Sheets. This information helps provide lines of evidence supporting:
• Confirmation of the presence or absence of ACM through bulk sampling and analytical analyses or reliable, field verified historical data;
• Confirmation of the presence of assumed ACM through observation of suspected ACM, but sampling not performed;
• Confirmation of the presence of Presumed to be Present ACM through observation of building materials, functional areas, building systems, etc. that are known to historically have suspect ACM, but such suspected ACM are not directly observed or visible to the inspector within the limitations of the amount of destructive or intrusiveness allowed by the client (e.g., inside boilers, inside wet walls of restrooms, under mirrors [adhesives] or other decorative items on walls); or
• Confirmation of absence of suspected ACM in areas through visual observations (e.g., fiberglass, rubber, plastic, wood, metal) and/or reliable, field verified historical data or objective data supporting that the observed materials were not manufactured with asbestos.