Revised MassDEP Asbestos Regulation

Welcome to the outreach present on therevised MassDEP asbestos regulation that came into force in june 2014. Im Mike Elliott, the Asbestos Program Coordinatorfor the Bureau of Air& Waste at the Massachusetts Department of Environmental Protection( alsoknown as MassDEP ). In the following lecture, I will guideyou through a high level overview of the regulatory revises that offers some revelation about howthese changes alter the regulated community such as property owners, contractors, andthe construction transactions. Eventually, I hope this information will helpeveryone to understand the requirements whenever they conduct renovation and defeat activitiesthat require the ruffle or removal of textile that contains asbestos. If after listening to this presentation, youhave further issue; my contact information is listed on the last slide. I welcome your comments and questions. After more than 10 times in the making, theMassDEP asbestos regulation has been revised. This represents the first major re-write in3 0 years or so. The basic Legal Structure hasnt reformed; there are two regulatory agencies in Massachusetts the MassDEP and the Department of LaborStandards( or DLS ), which together ensure the proper management of materials that containasbestos: MassDEP implements the nation and federal CleanAir Act ordinances to prevent liberations of asbestos into the air, as well as to protect publichealth, safety and the environment, and DLS enforces state acts with respect to: the licences of contractors qualified to work with asbestos, launching safe work practicesand worker qualification requirements, and certifying qualified laboratories that conductanalytical methods for asbestos.The overarching goals of the MassDEP AsbestosRegulation revisions promulgated in june 2014 were to clarify clarities and regulatoryrequirements; incorporate policies that were previously outside the existing regulations; and betteralign the territory curriculum with the EPA Asbestos National Emissions Standards for HazardousAir Pollutants( or NESHAPs ). It should be noted that the overlap withthe State Sanitary code opens an opportunity for inter-agency cooperation with neighbourhood Boardsof Health. State Sanitary Code involves owneds of residentialbuildings to repair or remove damaged asbestos containing cloths in accordance with MassDEPand DLS regulations.The MassDEP asbestos regulation focuses onrenovation and defeat work involving information that contain asbestos. The regulations two fundamental performancestandards for these activities have not changed. Whenever you need to disturb asbestos-containingmaterial, you will still need to: Prevent freeings of asbestos fibers to theair( the so-called visible release standard ); andProtect public health, safety and the environment. The essential elements of the program remainunchanged. These constituents show the typical life-cycleof an asbestos abatement job. Notify MassDEP and DLS before starting work. Notifications filed with MassDEP are sharedwith DLS so you only need to notify formerly Follow specified work practices when conductingthe abatement undertakings Manage asbestos containing waste materialproperly Please note: DLSs regulations have notchanged. In the next two slips, I will foreground afew of the brand-new elements of the revised regulation. Pre-Reno/ Demo Survey: While the requirement to conduct a pre-reno/ demo examine is new to the MassDEP regulation, itis not new to this type of work. Since 1990, EPAs Asbestos NESHAP regulationhas required a thorough inspection before starting any demolition or restoration activities.This inspection must identify all asbestos-containingmaterial in the area that will be disturbed by the projected drive. MassDEPs regulation describes which are capable of conductthe pre-reno/ demo surveys and what needs to be documented in a written canvas report. Notification Exemption for Small Jobs: The revised rules of procedure accommodates notification exemptions for a limited universe of smalljobs involving particular fabrics. Specific, the following points threshold quantitiesapply:< 100 sf of asbestos-cement shingles, placing, committees< 100 sf of asbestos floor tile and relatedmastics, or< 32 sf of gypsum wallboard and related jointcompound In addition, particular work on asbestos-containingmaterial at an owner-occupied single kinfolk palace does not have to be reported toMassDEP. This exemption only applies if the owner isworking exclusively on non-friable asbestos-containing material, does not cause it to become friable, and does the job himself/ herself( does not engage a contractor ). By non-friable, we represent substance thatwhen dry, cannot be deteriorated, crushed, pulverized or reduced to powder by hand-pressure. Aside from these limited notification exemptions, the notification requirements continue implementing as they always have in the past thatis - any activity that disrupts or removes any capacity of asbestos-containing materialrequires notification 10 -working days prior to starting the job. Irrespective of whether a chore prepares forone of the new notification exceptions, all asbestos abatement works must be performedin a manner that is consistent with the applicable work practices specified in the regulation.Generally speaking, applicable work practicesfor the materials that are now exempt from notification include the following: Wetting work surfaces with amended sea( which necessitates spray with soap/ surfactant added) toprevent generation of perceptible dust Carefully lowering roofing and placing shinglesto the ground Spreading tarp or plastic sheeting where debrismay sink and cleaning up at end of each shift Properly packaging waste material in leak-tight, closed and labeled consume receptacles Putting of waste material at a solid wastefacility that has a Special Waste permit to accept asbestos waste.Material Specific Work Practices: As I mentioned at the outset, one of the goals of the revised regulation was to provide greaterregulatory certainty by codifying fixed fabric specific work practices that werepreviously encountered either in plan or steering. Regarding this matter, brand-new parts were added tothe regulation to address the following material-specific work practices: Asphaltic roofing and backing fabrics Window glazing and/ or caulking compoundsCement shingles, surfacing and panels Floor tileGypsum wall-board and seam combination Non-Traditional Asbestos Abatement Work Practices: Non-Traditional Asbestos Abatement Work Practice were historically announced Alternative WorkPractices This now requires a formal permit employment( Application for Non-Traditional Asbestos Abatement Work Practice Approval BWP AQ-3 6) and fee of a $600 reward, if relevant. Post-Abatement Visual InspectionThe post-abatement visual inspection is a new requirement for all jobs that comes atthe end of the asbestos abatement activities.It ensures that no noticeable asbestos-containingdebris remains on any of the operate surfaces. Waste Shipment Record FormsThe Waste Shipment Record is another example where the revised regulation incorporatedan existing EPA NESHAP requirement. All shipments of Asbestos Containing WasteMaterial( or ACWM) must now be accompanied by a Waste Shipment Record that conforms toa template posted on the MassDEP Asbestos website.Record-keeping requirementsThe revised regulation will be required the owner/ operator deter copies of the pre-reno/ demo survey reportand Waste shipment record for at least 2 years. If MassDEP does a conformity inspection, theinspector is likely to ask to see these documents and will are dependent upon them, in part, to determinethat the asbestos-containing fabrics were properly managed. I will now accommodate a few more details abouteach of these new regulatory requirements in the following moves. The requirement for a pre-reno/ demo surveyapplies to ANY assignment with the possibility to disturb suppose asbestos-containing cloth. Before disturbing the material, a DLS-certifiedasbestos inspector must conduct a thorough inspection that is, to identify thepresence, point and capacity of any ACM or Suspect ACM that contains asbestos in anyamount. What elapses as a thorough inspectioncould be one thing for a constructed textile where product content is fairly consistent( for example VAT tile, asphalt roofing material, plaster shingles/ surfacing, etc .); but, it couldbe different for training materials with incoherent the different levels of asbestos content caused by contaminationwith naturally occurring asbestos minerals( such as vermiculite insulation) or hand-mixedcompounds( like plaster ). In the former occurrence: a very limited number of randomsamples may suffice, But in the latter instance: many more samplesmay be needed, particularly to target areas where asbestos is likely to have accumulated.Once enough samples ought to have obtained, theywill need to be analyzed by a qualified laboratory that follows an approved analytical method, to find out definitively whether information materials contains asbestos or not. The only analytical method recognized by MassDEPis the EPA Method for the Determination of Asbestos in Bulk Building Material whichgoes by the report number EPA/ 600/ R-9 3/116. Any Suspect ACM that is not sampled and analyzedMUST be presumed to be ACM, identified on the written examination report as ACM, and managedas ACM( i.e. it must be abated prior to demolition/ renovation ). The pre-demo/ reno overlook is the lynchpin ofcompliance for both the MassDEP and EPA regulations. The overlook supports valuable message :: It will determine whether notification toMassDEP is required; It will determine whether you will need tofollow the applicable work practices to remove asbestos-containing material safely ;; It will determine whether you will need to engage a licensed contractorIt will help with sequencing project chores( by identifying which cloths contain asbestosand need to be removed before your defeat or renovation can start ); It provides a basisfor developing a waste management plan that can help you minimize volume and cost of materialthat needs to be disposed of as ACWM; and, It provides the information you will needto comply with waste packaging, transportation and disposal requirements.To know whether you need to have a pre-reno/ demosurvey done, you will need to know what information are suspect ACM. Asbestos-containing materials are found inmost structures, even those improved after 1980 After successfully passing forbids on the use of asbestosin several individual products in the 1980 s, the U.S. EPA chose a regulation banningall asbestos-containing cloths from use in commerce in 1989. However, the present rule was affect down in 1991. While asbestos ores are no longer quarried orprocessed in the United Mood, thousands of concoctions containing asbestos continue tobe produced, imported, legally sold, and, commonly used in building construction and industrialapplications. All this is to say that there remain numerous, perhaps thousands, of believe materials on the market today. So contractors and homeowners doing renovationor demolition works need to be attentive to the likelihood of coming across suspectasbestos-containing textiles , no matter the age of the structure. Broadly speaking, the definition of suspectasbestos-containing material includes any product reasonably likely to contain asbestosbased on its appearance, constitution and use.This slither directories a few of the common typesof suspect ACM that can be found in builds. Work on asbestos-containing asphalt roofingor siding requires notification to the MassDEP 10 -working days before starting work. While roofing and placing proletarians need to betrained in accordance with OSHA requirements, there are no DLS asbestos license or certificationrequirements for the workers performing this work, as long as the material remains non-friable. The regulation specifies work practices formanaging asphalt roofing and placing that are in asbestos, to ensure that the asbestos isntreleased into the air. These work practices include: Isolating HVAC ventilation intakes Removing roofing material intact as much aspossible Note that roofers CAN cut roofs into slice, but where trimming machines are use: The machines must be equipped with HEP-Avacattachments the chipping skin-deep must be kept adequatelywet at all times and the reduction segments of roofing fabric mustbe carefully lowered to ground If ALL the specified work practices are strictlyfollowed, then: Waste roofing material can be bulk-loadedfor transport to the disposal facility without an N-T Work Practice Approval.Waste can be disposed at any landfill permittedto accept solid debris If, on the other hand, the piece causes thematerial to become friable, or causes the release of asbestos dust, then the undertaking becomesregulated by DLS, requiring the use of licensed contractors, workers taught and certifiedas asbestos foremen and workers, adherence to the full suite of asbestos work practicesspecified in the regulation, and container, transport and disposal of the waste roofingmaterial as an ACWM Special Waste. Either way, asbestos-containing asphalt roofingmaterial must never be sent to a C& D Processor for recycling, because these equipment grindmaterial they receive and the grinding action will almost surely secrete asbestos fibersinto the air. Non-traditional work practices are requiredwhen it is unsafe to follow prescribed work practices( for example it may be unsafe tobuild plastic containment near a fervor luck, or to keep facility ingredients around liveelectrical gear rain ). This approval is referred to as an NTapproval.The NT Approval now involves a formal permitapplication process( use the BWP AQ-3 6 form on MassDEPs web site) and a $600 reward( whereapplicable ). The work supported by a proposaldeveloped by a DLS-certified asbestos assignment designer. NT tolerates are available only for six particularcircumstances: 1. For defeat of a facility under ordering ofa district or local government agency because the facility is structurally unsound; 2. Where ACM or ACWM was discovered after demolitionbegan and , now cannot be safely removed with standard work practices; 3. For sure-fire disaster redevelopment runnings; 4. For cleaning process and decontamination as a resultof work that was not done properly or when there is a safety or public health hazard: 5. Where drying would damage equipment or presenta potential hazards; or 6. When it is necessary to bulk load ACMand/ or ACWM The post-abatement visual inspection is requiredfor ALL asbestos abatement pleasures. The one exception is for the owner of anowner-occupied single home palace who is working exclusively on non-friable asbestos-containingmaterial, does not cause the material to become friable, and does the exertion himself/ herself( In other commands the homeowner does not engage a contractor) The purpose of this requirement is to ensure the job has been exhaustively ended andthere is no observable debris left behind on any of the effort surfaces.The revised regulation had indicated that thefinal visual inspection must be performed by a DLS-certified asbestos campaign observe. Additionally, it must be performed beforeremoving any job neighborhood obstructions and ventilation systems( if they were used ). Keeping the barriers and ventilation systemsin place ensures that if any further cleaning is required, it can be done safely. The requirement to use a Waste Shipment Recordform is another example where MassDEP regulations have been modified to better align with EPAsNESHAP requirements. The consume of a WSR form that solely complieswith the template became effective January 1, 2015. A template for the WSR form can be found onthe MassDEP website at the URL link shown on the slide. MassDEP will not provide forms. Haulers and transportation companies can usethe online template or they can create their own form, but, at a minimum, it must containall the information found on the template.The purpose of the WSR is to ensure that proprietors/ operatorstrack the transportation and disposal of ACWM made at their jobsites. If a accomplished WSR confirming proper disposalof ACWM is not received within 35 days, the owner/ motorist must track down the shipmentand notify MassDEP within 45 dates if there are any incompatibilities. Fee increases for both the BWP AQ-0 4 AsbestosNotification form( ANF-0 01) and the BWP AQ-0 6 Notification Prior to Construction/ Demolitionthat started from $85 to $100 became effective in August 2013. In July 2014, three brand-new fees were added: A $35 reward for revising the initial ANF-0 01 or the AQ-0 6 formations( e.g. converting the projectstart or discontinue year) A $200 reward for the BWP AQ-0 5 Blanket NotificationApproval request, And a $600 fee for the NTWP Approval request.Asbestos abatement rackets at assets owned by certain types of entities are exempt fromMassDEP costs. These include: boroughs,( and municipalhousing officials ), districts, districts of the Commonwealth, Federally recognizedIndian tribe housing jurisdictions, the MBTA, and owner-occupied residential property with4 components or less. Please note that 501( c) 3 non-profit organizations, and private educational and health prisons are NOT exempt from MassDEP costs. Beginning in March 2015, MassDEP started toaudit notifications to ensure that all pertinent costs are paid. Anyone who claims fee-exempt status that doesnot appear to be eligible will be asked to provide supporting documentation or re-filewith proper payment. The Asbestos Project Look-Up tool is a usefulweb resource that anyone can use to see whether a notification has been entered for an abatementproject at any given address. Notifications registered through eDEP are addedto the look-up tool automatically. Notifications registered on paper patterns are addedto the database within one or two days of their acknowledgment by MassDEP.The look-up tool can be accessed from theMassDEP website at the links listed on the slide. In Massachusetts, substance that contains anyamount of asbestos( even< 1 %) is regulated. All substances that are in any sum of asbestosshould have been identified during the pre-reno/ demo inspect. ACM identified by the survey needs to be abatedbefore it is shook. Material containing less than 1% asbestosdoesnt need to be abated in accordance with work practices( and you dont needto notify MassDEP before the abatement starts ), but you will need to manage the waste materialcontaining less than 1% asbestos as ACWM.If you remove it carefully and keep it separatedfrom your other non-asbestos construction or demolition debris, you are eligible to forestalled contaminatingyour solid debris with asbestos, and can decrease the amount of material that has to be disposedof as ACWM. One of the main objectives of proper asbestosmanagement during a reno/ demo campaign is to prevent contamination of C& D debris by materialsthat contain any quantity of asbestos. This is because a C& D processing facilityusually grinds some of the material it receives, and can liberate asbestos fibers into the surroundingair and constitute a health risk to facility workers and perhaps to the general public as well. It is important to stress that C& D processors haveconditions in their operating permissions that prohibit them from acquiring ACM orsuspect ACM. If ACM or Suspect ACM shows up in a quantity, the cost of managing the load as ACWM will be passed on to the original generator, andthe MassDEP will be notified of the permit violation for further investigation. The MassDEP asbestos regulation requires thatALL ACWM is managed in accordance with the specified packaging, transportation, storageand jettison provisions.In simplest terms, fabric that containsasbestos in any extent( even< 1 %): Has to be segregated and properly managedduring reno/ demo campaign It has to be packaged and labeled as ACWMAnd, it has to be disposed as Special Waste at a permitted solid waste management facility. If you hope further detailed information, this slide stipulates links to relevant regulation and guidance documents. Or, you can always call one of us on the MassDEPprogram staff with specific questions by phone or email at the contact information listedon the slither; For information or help with filing asbestosforms, eDEP or the asbestos database, you can submit you question by email to the Bureauof Air& Waste eDEP mailbox, or you can call the Asbestos hotline. For a matter of grants or complianceat a specific jobsite, feel free to contact one of the regional staff in the appropriateMassDEP region for the town in which the project is located. If youre not sure which part of MassDEPyour town is located in, you can click on the Find Your Region link.Thank you for your attention during this overviewof the revised asbestos regulation. We hope this slip present was helpful, and we welcome your feedback ..

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