Most local regulatory agencies are still not certain of their roles in the administration of asbestos-related regulation. It is often difficult for local inspectors to distinguish “friable” (in danger of crumbling) asbestos, from asbestos that is not friable. Many states that do not have licensing laws have set up guidelines for asbestos removal. The state of Virginia, for example, has the following guidelines as of July, 1988:
- NIOSH/MESA-Approved respiratory protection must be worn at all times.
- Full body coverings (i.e., disposable coveralls) must be worn at all times.
- Loose debris from the roof must be removed using a wet vacuum system and water, or other dustless methods.
- Area to be removed is to be sprayed continuously with “amended water” to control dust while removal is under way.
- All roofing debris must be collected and bagged or wrapped in six mil minimum thickness polyethylene, using dustless methods.
- All wrapped debris must be lowered to the ground, not dropped.
- Polyethylene sheeting, six mils thick, large enough to cover the ground in the loading area, should be used to store bags/ pallets of roofing waste until the waste can be disposed of properly.
- Air monitoring must be conducted by the contractor pursuant to the requirements of 29 CFR 196.58.
9. The Agency must procure the services of a consultant to monitor the project for the Agency to:
a. Conduct air monitoring to insure no contaminants are
being released due to poor work practice; and
b. To ensure all sections of the removal specifications are
- All applicable EPA and OSHA regulations are incorporated into the Virginia guidelines, including but not limited to 40 CFR, parts 53 to 80; 29 CFR 196.58; 29 CFR 1910,1001, and 29 CFR 1910.134.
- EPA-approved training and state licensing is required for all those involved in the removal process.
Researching and complying with the wide variety of applicable codes for roof installation and repair presents a challenge to every roofing contractor. For some types of work, such as asbestos removal, not only are the regulations complicated, but the cost is high, and a careful, organized approach is essential. All roofing contractors, designers, specifiers, consultants, and inspectors should have the latest editions of all applicable codes and standards. This information provides a reliable set of guidelines which, followed carefully, ensures the integrity of this aspect of their work.
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