This document provides an overview of regulations, requirements, and best practices for working with trace amounts of asbestos. It discusses definitions of trace asbestos in various regulations and standards. Requirements outlined include bulk sampling, personal exposure monitoring, training, use of personal protective equipment, work practices, waste handling, and recordkeeping. The goal is to ensure proper procedures are followed even when dealing with very small amounts of asbestos to limit potential hazardous exposures.

1. Trace Asbestos
“The Untold Story”
Presented by Ken Harenda & Dean Jacobsen
S.A. Herbst & Associates LLC
December 6, 2013
www.saherbst.com
(414) 727-7900

2. Trace Asbestos
• Regulations
• Bulk Sampling Requirements
• Personal Exposure Monitoring
• Training Requirements
• Personnel Protective Equipment (PPE)
• Work Practices
• Waste Handling
• Recordkeeping

3. Trace Asbestos
What is the definition of trace asbestos?

4. Regulations
•
NESHAP / NR 447
•
AHERA
•
OSHA Construction Standard
•
OSHA General Industry Standard
•
OSHA Hazard Communications
•
DHS 159

5. Regulations
• NESHAP 40CFR 61 Subpart M/NR 447
Definition
• “ACM” means asbestos−containing material,
containing more than 1% asbestos.
Sampling Requirements
•Thorough pre-inspection required prior to renovation or
demolition.
•PLM testing. Point Count if PLM less than <1% to
10%.

6. Regulations
AHERA 40 CFR 763
• Definition
ACM – Material that contains more than 1% asbestos.
• Sampling Requirements
Inspect school building to identify all locations of ACBM
If collecting bulk samples analyze by PLM.
Not ACM if 1% or less by PLM.
Requirements for re-inspections and response actions only if
proven or assumed ACBM.

7. Regulations
OSHA Construction Standard 1926.1101
• Regulates asbestos exposure in construction
• Definitions
Asbestos means any of the 6 asbestos minerals
ACM means contains more than 1% asbestos
• Sampling Requirements
(k)(5) Inspect and sample following AHERA to demonstrate
that PACM TSI & surfacing does not contain more than 1%
asbestos.
Drywall & Joint Compound are separate materials-must be
analyzed separately. OSHA Letter April 1997

8. Regulations
OSHA General Industry Standard 1910.1001
•
Definitions
Asbestos means any of the 6 asbestos minerals
ACM means material containing more than 1%
asbestos
•
Sampling Requirements
(j)(8) Inspect and sample following AHERA to
demonstrate that PACM TSI & surfacing does not
contain more than 1% asbestos.

9. Regulations
OSHA Hazard Communications 1910.1200
•
Definition
Chemical means any substance or mixture of
substances
•
Sampling Requirements
No sampling requirements

10. Regulations
DHS 159
•
Definition
ACM means material that contains more than 1%
asbestos
•
Sampling Requirements
Bulk sampling is an asbestos management activity
and must be done by certified inspector.
Exception for single family owner occupied housing
when done by owner

11. Personal Exposure Monitoring
OSHA General Industry Standard 1910.1001
•
Part (c) Comply with OSHA PEL 0.1 fibers/cc & EL 1.0
fibers/cc
•
Part (d) Initial Exposure Monitoring (PCM)
Breathing zone air samples
Employees who are, or may reasonably be expected to be,
exposed at or above PEL or EL
30 Minute Excursion - operations that are most likely to produce
exposures above the excursion limit
8 Hour Time Weighted Average - full-shift exposures representing
each shift for each employee in each job classification in each
work area.
Can also use objective data showing material won’t produce
asbestos above PEL or EL, or results from previous sampling

12. Personal Exposure Monitoring
OSHA Construction Standard 1926.1101
•
Parts (c) & (f) Comply with OSHA PEL 0.1 fibers/cc & EL 1.0
fibers/cc
Breathing zone air samples that are representative of exposures
Immediately before or at start of operation
30 Minute Excursion - operations that are most likely to produce
exposures above the excursion limit
8 Hour Time Weighted Average – representing each shift for each
employee in each work area.
Can also use objective data showing material won’t produce
asbestos above PEL or EL, or results from previous sampling

13. Personal Exposure Monitoring
•
Must be done by a competent person
•
Negative Exposure Assessment (PCM)
•
Required Reoccurrence of Monitoring
General Industry (d)(3) – at least every 6 months where exposure
do or may exceed PEL and EL and, often enough to represent
with reasonable accuracy the levels of exposure of the
employees.
General Industry (d)(4) – Can stop when exposures are below
PEL & EL
Construction (f)(2) – at least every 12 months
Whenever there has been a change in process, control
equipment, personnel or work practices that may result in new or
additional exposures above the PEL or EL

14. Training
• AHERA
• OSHA General Industry
• OSHA Construction Standard
• OSHA Respirator Protection
• OSHA Hazard Communications
• DHS Training

15. Training
• AHERA Training Requirement
Inspectors trained according to model accreditation
plan
Designated person training
Maintenance and custodial staff only if building
contains ACBM

16. Training
OSHA General Industry 1910.1001
• (j)(7) Training if exposure at or above PEL or EL
(A) The health effects associated with asbestos exposure;
(B) The relationship between smoking and exposure to asbestos producing lung cancer:
(C) The quantity, location, manner of use, release, and storage of asbestos, and the
specific nature of operations which could result in exposure to asbestos;
(D) The engineering controls and work practices associated with the employee's job
assignment;
(E) The specific procedures implemented to protect employees from exposure to
asbestos, such as appropriate work practices, emergency and clean-up procedures,
and personal protective equipment to be used;
(F) The purpose, proper use, and limitations of respirators and protective clothing, if
appropriate;
(G) The purpose and a description of the medical surveillance program
(H) The content of the standard, including appendices.

17. Training
OSHA Construction Standard 1926.1101
•
(k)(9)(viii) Training if exposure at or above PEL
(A) Methods of recognizing asbestos, including presumed building materials;
(B) The health effects associated with asbestos exposure;
(C) The relationship between smoking and asbestos in producing lung
cancer;
(D) The nature of operations that could result in exposure to asbestos, the
importance of controls to minimize exposure including, as applicable,
engineering controls, work practices, respirators, housekeeping
procedures, hygiene facilities, protective clothing, decontamination
procedures, emergency procedures, and waste disposal procedures,
and any necessary instruction in the use of these controls and
procedures;
(E) The purpose, proper use, fitting instructions, and limitations of
respirators;

18. Training
OSHA Construction Standard 1926.1101
•
(k)(9)(viii) Training if exposure at or above PEL
(F) The appropriate work practices for performing the asbestos job;
(G) Medical surveillance program requirements;
(H) The content of this standard including appendices;
(I) Smoking cessation information; and
(J) The requirements for posting signs and affixing labels and the
meaning of the required legends for such signs and labels.

19. Training
OSHA General Industry & Construction
•
Initial training before or at time of assignment
•
Annual training
•
Conducted in a manner that the employee is able to
understand
•
Employer maintains records for 1 year after last date of
employment

20. Training
OSHA Respirator Protection 1910.134 (k)
•
Initial and annual training for required and voluntary use of
respirators
(i) Why the respirator is necessary and how improper fit, usage, or
maintenance can compromise the protective effect of the respirator;
(ii) What the limitations and capabilities of the respirator are;
(iii) How to use the respirator effectively in emergency situations, including
situations in which the respirator malfunctions;
(iv) How to inspect, put on and remove, use, and check the seals of the
respirator;
(v) What the procedures are for maintenance and storage of the respirator;
(vi) How to recognize medical signs and symptoms that may limit or prevent
the effective use of respirators; and
(vii) The general requirements of the standard.

21. Training
OSHA Hazard Communication 1910.1200
•
Applies for General Industry if any amount of asbestos
•
Applies for Construction when installing new materials
•
Employers provide hazard communication program, labels and
other forms of warning, safety data sheets, and information and
training
•
(h)(3) Initial training at time of assignment
Methods and observations to detect the presence or release of a hazardous
chemical in the work area
Hazards of the chemical
Protective measures such as work practices & PPE
Company’s hazard communication program
Update training to reflect hazard communication regulation changes-labels and
safety data sheets plus new hazards

22. Training
•
DHS Training – Not Required

23. Personal Protective Equipment
•
OSHA General Industry
•
OSHA Construction Standard
•
OSHA Respiratory Standard
Respirators & protective clothing required if exposure
at or above PEL or EL
Hygiene facility if exposed at or above PEL or EL
General Industry (i) - Clean change area, shower
Construction (j) - Poly drop cloth, HEPA vacuum

24. Work Practices
OSHA General Industry Standard
•
(f) Minimal Requirements above the PEL / EL
Establish regulated area
Demarcate area and restrict access
Post warning sign
Local exhaust ventilation for tools
Wet methods
No compressed air without collection system
No sanding of flooring
No employee rotation to reduce exposure
Written program to reduce exposures below PEL & EL

25. Work Practices
OSHA General Industry Standard
(k) Minimal Requirements <1%
•
Spill clean up as soon as possible
•
HEPA vacuums
•
No dry sweeping unless wet methods and HEPA vacuums
are not feasible
•
Impermeable containers for waste. OSHA label not required
(j)(6)(ii)

26. Work Practices
OSHA Construction Standard 1926.1101 (g)
Minimal Requirements regardless of level of exposure
•
Wet methods for handling, removal, cleanup
•
Prompt clean up in leak tight containers
•
No high speed saws without point of cut ventilator or HEPA
enclosure
•
No compressed air without collection system
•
No employee rotation to reduce exposure

27. Work Practices
OSHA Construction Standard 1926.1101 (g)
Minimal Requirements regardless of level of exposure
•
No smoking in work area
•
(l)(1) When vacuuming use HEPA vacuums.
•
See also OSHA 11/24/03 letter

28. Work Practices
OSHA Construction Standard 1926.1101 (g)
Minimal Requirements above the PEL / EL
•
Establish regulated area
•
Demarcate work area and restrict access
•
Warning Sign
•
Local exhaust ventilation equipped with HEPA filter
•
Enclosure or isolation of processes producing asbestos dust

29. Work Practices
From DHHS (NIOSH) Publication Number 2003-141 Regarding Vermiculite
•
..”disturbing contaminated vermiculite with less than 1% asbestos can still result
in hazardous concentrations of airborne asbestos fibers.”
•
Recommended practices
Avoid handling or disturbing loose vermiculite
Isolate work areas with temporary barriers or enclosures to avoid spreading fibers
Use wet methods, if feasible, to reduce exposure
Never use compressed air for cleaning
Avoid dry sweeping, shoveling, or other dry clean-up methods
Use disposable protective clothing or clothing that is left in the workplace. Do not
launder work clothing with family clothing
Use proper respiratory protection.
Dispose of waste and debris contaminated with asbestos in leak-tight containers in
accordance with OSHA and EPA standards.

30. Work Practices
DHS 159
For renovations always assume vermiculite insulation
contains greater than 1% asbestos

31. Waste Handling Practices
• WDNR
Dispose at solid waste or C&D landfill
• OSHA Construction Standard 1926.1101(g)(1)(iii)
Prompt cleanup and disposal of wastes and debris
contaminated with asbestos in leak tight containers

32. Record Keeping
OSHA General Industry/ Construction Standards
•
Exposure Monitoring – 30 years
•
Training – at least 1 year
•
Medical Evaluations – 30 years after last date of
employment
•
Fit Testing – at least 1 year

33. Questions
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S.A. Herbst & Associates LLC
www.saherbst.com
(414) 727-7900