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Asbestos

Introduction

Environmental regulations can be complicated and overlapping, often proving difficult to identify all requirements that apply to an operation. In each Related Program Index (RPI) this task is simplified by identifying implications one program applicably often has on others. This RPI uses the J.J. Keller & Associations, Inc. broad regulatory knowledge to recommend regulations and compliance programs that may also apply when asbestos air program regulations (40 CFR 61 subpart M) cover an operation.

If asbestos air regulations apply, you should also consider ...

Toxic Substances Control Act (TSCA)

Under TSCA, pursuant to the Asbestos Hazard Emergency Response Act (AHERA), the Asbestos-Containing Materials in Schools rule requires local education agencies to inspect their school buildings for asbestos-containing building material. This is similar in how Asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP), requires that during demolitions and renovations inspections are carried out to minimize health effects. In addition to school inspections, there is a requirement to prepare asbestos management plans and perform asbestos response actions to prevent or reduce asbestos hazards. Public school districts and non-profit private schools, including charter schools and schools affiliated with religious institutions are all among those subject to the rule’s requirements.

Also under TSCA, is EPA’s Asbestos Worker Protection Rule. EPA extended worker protection requirements to state and local government employees involved in asbestos work who were not previously covered by the Occupational Safety and Health Administration’s (OSHA) asbestos regulations.

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Effluent standards

For those that work in manufacturing related to asbestos there are certain effluent standards and guidelines for source categories. Specifically, there are effluent limitations for the subcategory manufacturing of asbestos: cement pipes, cement sheets, paper, paper (elastomeric binder), millboard, roofing products, floor tile, coating or finishing of textiles, the process of solvent recovery, vapor absorption, and wet dust collection. The limitations establish the quantity or quality of pollutants or pollutants properties which may be discharged by a point source subject to the provisions of this subpart after application of the best available technology economically achievable. There can no discharge of process wastewater pollutants to navigable waters.

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OSHA Safety and Health Standards

OSHA oversees U.S. working conditions by implementing and managing occupational safety and health standards. The Asbestos General Standard covers work in general industry. This includes exposure during brake and clutch repair, maintenance work, and manufacture of asbestos-containing products.

In 1986, this standard established the current permissible exposure limit (PEL) for asbestos in the workplace: (0.1 fibers/cc of air as a time weighed average). PELs are allowable exposure levels in workplace air averaged over an 8-hour shift of a 40-hour workweek. Those exposed to asbestos above the PEL in certain industries must be given proper PPE, undergo medical surveillance to identify signs of asbestos-associated disease, comply with regulations for documentation of work-related injury claims, and be given information on where to go to find help for trying to quit smoking. The Asbestos Construction Standard covers construction, alteration, repair, maintenance, or renovation and demolition of structures containing asbestos.

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MSHA Miner Protection

The Mine Safety and Health Administration (MSHA) has mandatory safety and health standards for each mine subject to the Federal Mine Safety and Health Act of 1977. MSHA oversees the safety and health of miners and has specific regulations regarding asbestos. Just how OSHA’s Asbestos General Standard sets PELs for asbestos, MSHA, sets PELs for miners. There is a standard for exposure limits, engineering controls, and respiratory protection measures for workers in underground mines and another for those in surface mines. Both types of miners have the same PELs set for them.

The standards outline a full-shift limit that states that a miner’s personal exposure to asbestos shall not exceed an 8-hour time-weighted average full-shift airborne concentration of 0.1 fiber per cubic centimeter of air (f/cc). Additionally, there are excursion limits that state that no miner shall be exposed at any time to airborne concentrations of asbestos more than 1 fiber per cubic centimeter of air (f/cc) as averaged over a sampling period of 30 minutes.

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Waste transportation

The Department of Transportation (DOT) regulates the transportation of asbestos-containing waste material. Asbestos waste may be a hazardous material according to DOT regulations if it is friable. This means it can be reduced to a powder when dried by hand pressure. Non-friable asbestos is not subject to hazardous waste DOT regulations when transported. Friable asbestos can be transported in non-rigid packaging if they are dust and sift proof and are placed inside rigid leak tight packaging and are not loaded or unloaded by anyone other than the shipper and its destination.

EPA requires shippers (generators) and carriers (transporters) of hazardous wastes to have identification numbers which must be displayed on hazardous waste manifests. Hazardous wastes must also have a shipping paper and package markings that include the word “waste” immediately after the proper shipping name. The shipping papers must be retained by the shipper for three years after the material is accepted. Standards also outline the requirement of labels and emergency information on the shipping paper when it comes to hazardous material transportation.

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