Communicating Asbestos Locations, Hazards

The following article was first published in the CONN-OSHA Quarterly. It is reposted here with permission. 

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Asbestos is a naturally occurring fibrous mineral fiber. 

Once called the “Magic Mineral,” asbestos had many attractive properties for a building owner. 

It does not rust, rot, or decay. The fibers do not burn and are chemically inert. 

Products made with asbestos fibers have excellent insulation properties and are essentially fireproof.

However, asbestos fibers are carcinogenic and cause lung cancer, mesothelioma, and asbestosis. 

Asbestos Presence 

Although domestic manufacturing of asbestos building materials was phased out in the early 1980s, building owners of older public and commercial buildings may encounter asbestos products used as insulation in the boiler rooms/mechanical spaces and in the floor tiles and mastic used to cover the rooms and corridors of their facility. 

Employees engaged in housekeeping activities in public and commercial buildings with installed asbestos containing materials may be exposed to asbestos fibers. 

Most of these workers are covered by OSHA’s general industry standard, 29 CFR 1910.1001. 

Building owners are often the only and/or best source of information concerning the presence of previously installed asbestos containing building materials. 

Employees who perform construction work or housekeeping activities during and after construction activities are covered by the asbestos construction standard, 29 CFR 1926.1101. 

Building owners are often the only and/or best source of information concerning the presence of previously installed asbestos containing building materials. 

Therefore they, along with employers of potentially exposed employees, should communicate the presence, location, and hazards of asbestos in the building. 

Asbestos Identification 

Building owners are responsible for determining the presence, location, and quantity of asbestos containing material or presumed asbestos containing material at their facilities.  

Employers and building owners are required to treat installed thermal system insulation and sprayed-on and troweled-on surfacing materials as PACM in buildings constructed no later than 1980. 

Asphalt and vinyl flooring material installed no later than 1980 also must be treated as asbestos containing.

Asphalt and vinyl flooring material installed no later than 1980 also must be treated as asbestos containing.

 The employer or building owner may demonstrate that PACM and flooring material do not contain asbestos by having asbestos sampling performed by a licensed asbestos inspector. 

Building owners should maintain records of the presence, location and quantity of ACM and PACM in their buildings. 

The records should be kept for the duration of ownership and should be transferred to successive owners. 

Labelling Duties 

Building owners must inform employers of employees who will perform construction work or housekeeping activities in (or adjacent to) areas which contain ACM and/or PACM of the presence and location of ACM and/or PACM. 

For example, at the entrance to mechanical rooms/areas in which employees reasonably can be expected to enter and which contain ACM and/or PACM, the building owner shall post signs which identify the material which is present, its location, and appropriate work practices which, if followed, will ensure that ACM and/or PACM will not be disturbed. 

The employer shall ensure, to the extent feasible, that employees can comprehend these signs. 

Means to ensure employee comprehension may include translation of signs and warning labels for non-English speaking workers. 

Training for Employees 

OSHA’s asbestos standard for general industry at 29 CFR 1910.1001(j)(7)(iv) requires employers to provide an asbestos awareness training course for employees who perform housekeeping operations in areas where an ACM or PACM are present. 

Housekeeping activities include waxing and buffing vinyl asbestos floor tiles and cleaning any asbestos building materials. 

The elements of the training must include the health effects of asbestos; locations, signs of damage and deterioration of ACM and PACM; the proper response to asbestos fiber release episodes; and the standard’s requirements related to housekeeping. 

This training must be held annually and conducted so that all employees understand it. 

OSHA learned during its rulemaking process that there was evidence of asbestos disease among school custodians. 

In addition, general industry and construction employers should include asbestos in the programs they establish to comply with the Hazard Communication Standard, 29 CFR 1910.1200. 

The reason OSHA’s standard contains this training requirement for employees who perform housekeeping operations in facilities where ACM or PACM is present is because OSHA learned during its rulemaking process that there was evidence of asbestos disease among school custodians. 

OSHA believed that significant exposures to custodians resulted when they dry buffed floor tile and cleaned up accumulations of friable (damaged) material with no knowledge or concern about asbestos hazards, such as when insulation debris had fallen to the floor because it was so badly deteriorated.  

If your custodial workers are contract employees, their employers must provide the above asbestos awareness training to their employees. 

Information for Occupants and Tenants 

Building owners, in addition to informing building workers as required by OSHA, should also inform occupants and tenants about the location and physical condition of the ACM, and stress the need to avoid disturbing the material. 

Checklist. The information given to workers and building occupants should address the following points to the extent they reflect building conditions:

• ACM has been found in the building and is located in areas where the material could be disturbed (e.g., ceilings in Rooms 101 and 102, walls in the lobby, above suspended ceilings in the main corridor, on columns in the front entry, on pipes in the boiler room).
• The condition of the ACM, and the response that is appropriate for that condition.
• Asbestos only presents a health risk when fibers become airborne and are inhaled. The mere presence of intact ACM may not represent a health risk.
• Do not disturb the ACM (e.g., do not push furniture against the ACM, do not damage thermal system insulation). 
• Report any evidence of disturbance or damage of ACM to (name, location, and phone number). 
• Report any dust or debris that might come from the ACM or PACM, any change in the condition of the ACM, or any improper action (relative to ACM). 
• Cleaning and maintenance personnel are taking special precautions during their work to properly clean up any asbestos debris and to avoid disturbing ACM. 
• All ACM is inspected periodically, and additional measures will be taken if needed to protect the health of building occupants. 

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About the author: Mark Trotochaud is an occupational hygienist with the Connecticut Department of Labor. He has more than two decades of experience working as an industrial hygienist. OSHA and EPA materials were sourced for this article.