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When managing asbestos means leaving it alone.

Asbestos-containing materials-from insulation on piping systems to fireproofing on structural steel-exist throughout structures built in the United States between the 1920s and early 1980s. Yet only over the past 10 years have building owners and managers, spurred by the public's reluctancy to live or work in buildings containing these materials, been inclined to view total removal as the most viable way to deal with asbestos. Even public policy requires removal of asbestos in certain instances. However, this situation has led to another fear: increased health risks due to improperly managed asbsetos abatement projects.

As a result, attitudes toward asbestos and its removal are changing. Building owners and managers are beginning to take notice of new scientific evidence that asbestos-containing materials (ACMs) rarely present a health risk to building occupants if the material retains its integrity and performs as designed.

In a controversial article in the January 1990 issue of Science, the authors suggest that incomplete data on asbestos has caused unnecessary and inadequately controlled asbestos removal projects. While this article, often referred to as "The Mossman Paper," after one of its authors, Brooke Mossman, fails to discuss the potential hazard to building maintenance workers, it does reinforce a more cautious approach-a control program that leads to the eventual removal of ACMs.

Few people question the scientific evidence that occupational exposure to asbestos can cause health problems. What is needed is a more practical way for building owners and managers to deal with ACMs other than total and immediate removal. The approach would address the removal of ACMs using techniques designed to safeguard the health and safety of building occupants and workers while protecting the interests of building owners.

In-Place ACM Management

The philosophy behind this approach is simple: Manage ACMs until the building is renovated, the condition of the material requires removal or the building is demolished. When ACMs cannot be repaired, have lost their effectiveness or have to be disturbed to make repairs, it may be more cost effective to abate all ACMs in one area than to deal with only the material in question. But when there is no urgent need to remove ACMs, effective, in-place management can protect occupants, maintenance workers and outside contractors from potential asbestos exposure.

The most prudent asbestos management approach is to work with an environmental consulting firm that has the expertise to guard against liabilities faced by owners and managers of commercial, industrial and educational facilities. The firm should be up-to-date on abatement standards as well as related regulations issued by the Environmental Protection Agency, Occupational Safety and Health Administration and state and local agencies (see sidebar about regulators on page 36). It should also have a track record in surveying, designing and managing asbestos projects and be well grounded in architecture, engineering and construction management as well as industrial hygiene.

Once a firm has been chosen, it should send inspectors accredited under the Asbestos Hazard Emergency Response Act to conduct a customized asbestos survey and assessment. The most comprehensive is a space-by-space survey in which the inspectors investigate every space on the property, from the boiler room to closets and from floors to crawl spaces, for materials that may contain asbestos. It is critical that this survey assess the accessibility and condition of the materials, since these are the most important factors in determining whether ACMs should be managed, repaired or removed.

Accessibility is determined by analyzing the location of the material relative to the typical activity patterns within a building. Generally, the greater the chance that people will disturb ACMs, the greater the need to remove the materials, since disturbing ACMs can cause asbestos fibers to be released. The condition of ACMs also affects fiber release, since intact material is less likely to present a problem than damaged material. Knowing the condition of the materials also helps determine what to do about them: Damaged material must be repaired or removed, while intact material may only require monitoring. No 'Surprise Discoveries'

A comprehensive survey should assure the building owner or manager that all accessible spaces have been surveyed and, therefore, there will be no "surprise discoveries" of ACMs. It should also provide a prioritized action plan with cost estimates that enable the building owner or manager to address immediate problems. In addition, it should outline all the information needed to develop and implement an effective asbestos operations and maintenance program and, finally, it should provide the information in document and electronic form to facilitate "real-time" access to data about ACMs in a facility.

The environmental consultant should provide software that sorts, analyzes, prioritizes, retrieves and updates data about asbestos and its location in facilities. The program will enable the building owner or manager to find out what types of ACMs exist, where they are located and which ones must be addressed immediately. This data should be continually updated as maintenance, renovation and abatement activities take place within the building, and removal priorities should be changed accordingly.

For example, before a maintenance crew is allowed to make repairs anywhere in a building, the asbestos program manager should access the computerized data to determine whether ACMs are present. Indeed, construction or maintenance workers who are inadequately informed about ACMs run the risk of repeatedly encountering these materials and releasing asbestos fibers into the air. The data can also be used to reassure the building's tenants when they question the presence of asbestos. By checking the data, the manager can inform tenants that either there is no asbestos in their areas or that the ACMs are in good condition.

The best way to deal with asbestos is to create an asbestos operations and maintenance program, which serves as a detailed road map of how to control ACMs during the life of the property. This written plan specifies the administrative procedures for controlling ACMs, including employee training and policies, program operations, procedures and forms for conducting and documenting asbestos-control activities. Supporting documents may include an annual asbestos abatement contract, relevant federal, state and local regulations, in-house work procedures and a personal protection program.

The plan is based on client comments, survey and assessment information and interviews with facility management on how maintenance operations are conducted and controlled. The client uses this information to designate an asbestos program manager who will be in charge of maintaining, cleaning and renovating the facility. Once in place, the program enables building owners and managers to deal with ACMs in a planned and rational manner by assuring them that trained workers are maintaining and inspecting these materials.

When Asbestos Must Be Removed

The approach to asbestos is different when the survey reveals ACMs that demand immediate attention. For example, if a heating pipe located 6 feet off the floor in a room frequented by children is found to have damaged asbestos-containing thermal insulation, the survey would identify the situation as a high priority. Clearly, abatement would be necessary.

The key to successful abatement is proper design and administration of the removal. Because the process disturbs asbestos, abatement requires a competent contractor and an environmental consultant who can provide effective design specifications and appropriate air monitoring and laboratory analysis, as well as ensure strict adherence to contracts and regulations. A consulting firm should be chosen based on its ability to develop an asbestos abatement design that protects the facility from contamination, without endangering occupants and workers, causing unnecessary delays and adding to costs.

The steps of a successful asbestos abatement project include: * review of facility drawings and asbestos survey data to determine requirements for the abatement project; * field investigation and asbestos bulk sampling/analysis as required to ensure the identification and location of suspect ACMs on a space-by-space basis; * development of a complete set of contracts, including technical specifications, drawings, general and supplementary conditions of the contract and bid documents; * submission of contracts and other forms to applicable regulatory agencies for approval as required by state law; * conducting pre-bid meetings with potential abatement contractors and assistance in contractor selection; and * review of contractor submittals for compliance with contract documents.

Once the abatement begins, the consultant's administrators should remain on-site for the duration of the project. Project administrators function as the owner's representative and, as such, are the owner's primary liability protection. Without this independent oversight, the owner has no way of knowing if the contractor is fulfilling his contractual obligations.

Risk managers should be wary of consultants who provide project administrators on a part-time basis or air sampling technicians with no background in abatement techniques or contract administration. While using less experienced project administrators may save the building owner money in the short run, it will greatly increase his or her liability if improper removal takes place.

Total asbestos removal projects are recommended in certain instances, such as when buyers or lenders concerned about liability will not commit to the building until asbestos have been removed or when it is deemed more cost effective to tackle all the asbestos at once. On the other hand, an in-place management approach that utilizes an asbestos operations and maintenance program is also useful because it treats asbestos management as a planned process that functions over the life of the building and ensures that those who have direct contact with asbestos are properly trained and adequately protected. Moreover, the approach provides the building owner or manager with a chart that steers clear of future liability. Henry Uhlig is manager of the engineering/architectural division and Douglas R. Whitaker is head of the environmental management division at Entek Environmental and Technical Services in Troy, NY.
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Title Annotation:includes related article on environmental laws
Author:Whitake, Douglas R.; Uhlig, Henry
Publication:Risk Management
Date:Aug 1, 1991
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