RBM Regulatory Understanding

Federal and state regulations require that employers and building owners identify, quantify, document, communicate, and mitigate any hazards in the workplace. When activities such as those that would disturb building materials like housekeeping/custodial, maintenance, renovation, or demolition activities are performed, federal and state regulations require that RBMs be properly identified and characterized prior to their disturbance.

For example, federal Environmental Protection Agency (EPA) National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations under the Clean Air Act require a thorough inspection for asbestos to be performed prior to any building or structure being renovated or demolished. Furthermore, Occupational Safety and Health Administration (OSHA) requires that prior to the initiation of any maintenance or custodial/housekeeping activities are performed, the building owner and/or employer is required to determine the presence of asbestos and take appropriate actions to adequately protect those employees working near or coming into contact with those asbestos-containing materials (ACMs). Another example is OSHA’s requirement for the employer to determine if any of their workforce would be potentially exposed to lead at or above the action level, and if so, take appropriate actions as required by their standards.

RBMs are heavily regulated at the federal (EPA and OSHA, primarily) and state level. Our RBM practice maintains appropriate federal and state accreditation, certification, and/or licensing to perform our RBM services. Langan has expert knowledge of federal and state RBM regulations and our Standard Operating Procedures (SOPs) and internal guidance instructions follow these regulatory requirements as well as industry-accepted standards developed by ASTM International, Inc. (ASTM).