4.1 Work practices, engineering controls, personal protective equipment and other precautions to minimize exposure to airborne asbestos fibers have been extensively documented in regulations, training manuals and other publications. The work described in these publications ranges from large-scale abatement projects to minor disturbances and clean-up. Practices E1368 and E2394 address these issues within the context of their subject matter.
4.2 This practice applies to specific types of asbestos work where the same task is performed by various persons without substantial deviation from a documented procedure and with material containing the same type and similar content of asbestos fiber. The exposure from such operations can be expected to remain fairly consistent as long as these parameters do not vary substantially and the workers have received the required training to perform the task.
4.3 Because of the variability in field conditions under which large-scale work such as asbestos abatement is performed, the opportunity to collect sufficient personal air samples under conditions similar enough to establish statistical confidence can be questioned. For this reason, this practice does not address the collection of such samples and their use for determining exposure data to apply on other projects. Users with such requirements are referred to the applicable regulations for guidance.
4.4 There are many tasks, however, that are of short duration and amenable to testing under controlled conditions for assessing worker exposure. These tasks are performed by equipment installers and other tradesmen in the course of their ordinary duties in what this practice refers to as the current job. The following list of potential tasks where ACMs can be disturbed is by no means inclusive and the feasibility of conducting an Exposure Assessment is the responsibility of the user:
4.4.1 Drilling holes through asbestos floor tile and sheet vinyl flooring,
4.4.2 Removing small pieces of floor tile and sheet vinyl flooring to expose the substrate,
4.4.3 Drilling holes through asbestos-cement roofing, siding, ceiling panels, ducts and pipes,
4.4.4 Drilling and cutting holes in wallboard,
4.4.5 Drilling holes in ceiling tiles,
4.4.6 Removing and replacing ceiling tiles,
4.4.7 Patching roofing materials,
4.4.8 Removing window putty and caulking,
4.4.9 Cleaning asbestos-lined or contaminated ducts,
4.4.10 Removing gaskets and packing,
4.4.11 Removing and installing locksets in fire doors,
4.4.12 Taking bulk samples of suspect ACM,
4.4.13 Removing and patching acoustical ceiling texture and fireproofing, and
4.4.14 Removing and replacing insulation on pipes, tanks, boilers, ducts, etc.
4.5 The Exposure Assessment is based on personal air samples taken over a full or partial shift to determine an 8-h TWA exposure and a short-term Excursion Limit exposure, which requires that two sampling pumps be worn.
4.6 Samples are taken for comparison with criteria determined by the user, including but not limited to the following:
4.6.1 Permissible Exposure Limits (PELs), including the 8-h TWA of 0.1 f/cc and the 30-min EL of 1.0 f/cc, or to establish engineering controls, respiratory and personal protection, and other requirements in accordance with 29 CFR 1926.1101;
Note 1: These OSHA PELs will be used for illustration purposes in this practice.
4.6.2 National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure Limit of 0.1 f/cc;
4.6.3 American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value (TLV) of 0.1 f/cc for respirable fibers;
4.6.4 Employee exposure limits imposed by other governmental jurisdictions;
4.6.5 Employee exposure limits to establish engineering controls, respiratory and personal protection, and other requirements of an employer's policy or the requirements of a specification or procedure that applies to the current job; and
4.6.6 Non-occupational exposure limits for building occupants and other affected persons.
4.7 Compliance with the PELs and other criteria is typically determined by analyzing the air samples using NIOSH Method 7400 for Phase Contrast Microscopy, which reports all fibers meeting the counting criteria and does not distinguish between asbestos and non-asbestos fibers. The Exposure Assessment can be based on analysis using NIOSH Method 7402 for Transmission Electron Microscopy, which identifies asbestos fibers and adjusts the fiber count from a NIOSH Method 7400 analysis.
4.8 An important aspect of an Exposure Assessment is determining a margin of safety between the exposures measured during the test and criteria for respiratory protection, regulatory compliance or other purposes. This practice therefore includes a statistical test (Confidence Factor) for the exposure based on the air sample results from a test as described in Section 7.
4.9 The responsibility for comparing the results of the test performed for the Exposure Assessment is given to the competent person, usually but not necessarily someone in a supervisory capacity, who compares the conditions under which the test was performed to those for the current job to which a worker has been assigned. If the work practices and asbestos-containing materials are sufficiently similar in the judgment of the competent person, and the worker has been trained on the work practice using simulated asbestos-containing materials, the competent person certifies that the Exposure Assessment applies to the current job for purposes of respiratory protection and other precautions. A form is provided in Appendix X1 for this purpose.
Note 2: OSHA regulations in 29 CFR 1926.1101 permit an employer to dispense with respiratory protection and other precautions on the basis of an Exposure Assessment (sometimes called a Negative Exposure Assessment) or on the basis of “objective data.” This practice does not use the terms “Negative Exposure Assessment” and “objective data,” and the responsibility for elimination of protective measures based on an Exposure Assessment remains with the competent person. 29 CFR 1926.1101 requires a “high degree of certainty” that the PELs will not be exceeded, but does not define this parameter.