Revised MassDEP Asbestos Regulation

Welcome to the outreach appearance on therevised MassDEP asbestos regulation that took effect in June 2014. Im Mike Elliott, the Asbestos Program Coordinatorfor the Bureau of Air& Waste at the Massachusetts Department of Environmental Protection( alsoknown as MassDEP ). In the following exhibition, I will guideyou through a high level overview of the regulatory revisions that offers some insight about howthese revisions alter the regulated community such as property owners, contractors, andthe construction transactions. Ultimately, I hope this information will helpeveryone to understand the requirements whenever they conduct renovation and demolition activitiesthat require the agitation or removal of substance that are in asbestos. If after listening to this presentation, youhave further issue; my contact information is listed on the last slide. I welcome your the remarks and questions. After more than 10 times in the making, theMassDEP asbestos regulation has been revised. This represents the first major re-write in3 0 years or so. The basic Legal Structure hasnt deepened; the report contains two regulatory agencies in Massachusetts the MassDEP and the Department of LaborStandards( or DLS ), which together ensure the proper management of materials that containasbestos: MassDEP implements the commonwealth and federal CleanAir Act ordinances to prevent freeings of asbestos into the air, as well as to protect publichealth, safety and the environment, and DLS enforces territory statutes with respect to: licensing of contractors qualified to work with asbestos, launching safe work practicesand worker qualification requirements, and showing able laboratories that conductanalytical methods for asbestos. The overarching the specific objectives of the MassDEP AsbestosRegulation revisions promulgated in june 2014 were to clarify interpretations and regulatoryrequirements; incorporate policies that were previously outside the regulation; and betteralign the nation platform with the EPA Asbestos National Emissions Standards for HazardousAir Pollutant( or NESHAPs ). It is also worth noting that the overlap withthe State Sanitary code opens an opportunity for inter-agency cooperation with neighbourhood Boardsof Health.State Sanitary Code necessitates owneds of residentialbuildings to repair or remove damaged asbestos containing cloths in accordance with MassDEPand DLS regulations. The MassDEP asbestos regulation focuses onrenovation and defeat work involving substances that are in asbestos. The regulations two fundamental performancestandards for these activities have not changed. Whenever you need to disturb asbestos-containingmaterial, you will still need to: Prevent secretes of asbestos fibers to theair( the so-called visible radiation standard ); andProtect public health, safety and the environment. The essential elements of the program remainunchanged. These constituents show the normal life-cycleof an asbestos abatement assignment. Notify MassDEP and DLS before starting work. Notifications filed with MassDEP are sharedwith DLS so you only need to notify formerly Follow specified work practices when conductingthe abatement pleasures Manage asbestos containing waste materialproperly Please note: DLSs regulations have notchanged. Within the next 2 moves, I will spotlight afew of the brand-new elements of the revised regulation. Pre-Reno/ Demo Survey: While the requirement to conduct a pre-reno/ demo cross-examine is new to the MassDEP regulation, itis not new to this type of work.Since 1990, EPAs Asbestos NESHAP regulationhas required a thorough inspection before starting any demolition or redevelopment undertakings. Such inspections must identify all asbestos-containingmaterial in the area that will be disturbed by the scheduled make. MassDEPs regulation describes who can conductthe pre-reno/ demo surveys and what needs to be documented in a written examine report. Notification Exemption for Small Jobs: The revised regulation offer notification exceptions for a limited universe of smalljobs involving particular substances. Precisely, the following threshold quantitiesapply:< 100 sf of asbestos-cement shingles, placing, boards< 100 sf of asbestos floor tile and relatedmastics, or< 32 sf of gypsum wallboard and related jointcompound In addition, specific work on asbestos-containingmaterial at an owner-occupied single clas residency does not have to be reported toMassDEP. This exemption only applies if the owner isworking alone on non-friable asbestos-containing material, does not cause it to become friable, and does the direct himself/ herself( does not engage a contractor ). By non-friable, we make substance thatwhen cool, cannot be crumbled, smashed, pulverized or reduced to powder by hand-pressure. Aside from these limited notification exceptions, the notification requirements continue to apply as they always have in the past thatis - any activity that distress or removes any length of asbestos-containing materialrequires notification 10 -working days prior to starting the job. Regardless of whether a undertaking prepares forone of the new notification exceptions, all asbestos abatement works must be performedin a manner that is consistent with the applicable work practices specified in the regulation. Generally speaking, applicable work practicesfor the materials that are now exempt from notification include the following: Wetting work faces with amended sea( which conveys spray with soap/ surfactant contributed) toprevent contemporary of conspicuous dust Carefully lowering roofing and surfacing shinglesto the ground Spreading tarp or plastic sheeting where debrismay autumn and cleaning up at demise of each shift Properly packaging waste material in leak-tight, closed and labeled garbage receptacles Disposing of waste material at a solid wastefacility that has a Special Waste permit to accept asbestos garbage. Substance Specific Work Practices: As I mentioned at the outset, one of the goals of the revised regulation was to provide greaterregulatory certainty by codifying proved substance specific work practices that werepreviously witnessed either in plan or guidance.In this respect, brand-new slice were added tothe regulation to address the following material-specific work practices: Asphaltic roofing and siding materials Window glazing and/ or caulking compoundsCement shingles, siding and panels Floor tileGypsum wall-board and seam combination Non-Traditional Asbestos Abatement Work Practices: Non-Traditional Asbestos Abatement Work Practices were historically called Alternative WorkPractices This now requires a formal grant application( Application for Non-Traditional Asbestos Abatement Work Practice Approval BWP AQ-3 6) and fee of a $600 cost, if relevant. Post-Abatement Visual InspectionThe post-abatement visual inspection is a new requirement for all jobs that comes atthe end of the asbestos abatement activities. It work towards ensuring that no evident asbestos-containingdebris remains on any of the wreak skin-deeps. Waste Shipment Record FormsThe Waste Shipment Record is another example where the revised regulation incorporatedan existing EPA NESHAP requirement.All shipments of Asbestos Containing WasteMaterial( or ACWM) must now be accompanied by a Waste Shipment Record that conforms toa template posted on the MassDEP Asbestos website. Record-keeping requirementsThe revised rules of procedure will be required the owner/ hustler save copies of these financial pre-reno/ demo canvas reportand Waste shipment record for at least 2 years. If MassDEP does a conformity inspection, theinspector is likely to ask to see these documents and will are dependent upon them, in part, to determinethat the asbestos-containing substances were properly managed.I will now furnish a few more details abouteach of these new regulatory requirements in the following moves. The requirement for a pre-reno/ demo surveyapplies to ANY project with its full potential to shake doubt asbestos-containing cloth. Before disturbing the material, a DLS-certifiedasbestos inspector must conduct a thorough inspection that is, to identify thepresence, locating and quantity of any ACM or Suspect ACM that contains asbestos in anyamount. What guides as a thorough inspectioncould be one thing for a fabricated substance where make material is fairly consistent( for example VAT tile, asphalt roofing cloth, plaster shingles/ siding, etc .); but, it couldbe different for training materials with inconsistent the different levels of asbestos content caused by contaminationwith quite natural asbestos minerals( such as vermiculite insulation) or hand-mixedcompounds( like plaster ). In the onetime client: a limited number of randomsamples may suffice, But in the latter occasion: many more samplesmay be needed, particularly to target areas where asbestos is likely to have accumulated.Once fairly samples ought to have collected, theywill need to be analyzed by a qualified laboratory that follows an approved analytical method, to be informed about definitively whether the material contains asbestos or not. The only analytical method recognized by MassDEPis the EPA Method for the Determination of Asbestos in Bulk Building Fabric whichgoes by the report number EPA/ 600/ R-9 3/116. Any Suspect ACM that is not sampled and analyzedMUST be presumed to be ACM, identified on the written examination report as ACM, and managedas ACM( i.e. it must be abated prior to demolition/ redevelopment ). The pre-demo/ reno overlook is the lynchpin ofcompliance for both the MassDEP and EPA regulations.The survey accommodates valuable info :: It will determine whether notification toMassDEP is required; It will determine whether you will need tofollow the applicable work practices to remove asbestos-containing material safely ;; It will determine whether you will need to engage a licensed contractorIt will help with sequencing project undertakings( by identify which fabrics contain asbestosand need to be removed before your demolition or restoration can start ); It provides a basisfor developing a waste management plan that can help you minimize volume and cost of materialthat needs to be disposed of as ACWM; and, It provides the information you will needto comply with waste packaging, transportation and disposal requirements. To know whether you need to have a pre-reno/ demosurvey done, you will need to know what textiles are suspect ACM. Asbestos-containing textiles are found inmost structures, even those improved after 1980 After successfully reenacting censors on the use of asbestosin various individual products in the 1980 s, the U.S.EPA accepted a regulation banningall asbestos-containing textiles from use in commerce in 1989. However, the present rule was struck down in 1991. While asbestos ores "re no longer" mined orprocessed in the United States, thousands of makes containing asbestos continue tobe produced, imported, legally sold, and, commonly used in building construction and industrialapplications. All this is to say that there remain many, perhaps thousands, of doubt materials on the market today. So contractors and homeowners doing renovationor demolition acts need to be attentive to the likelihood of coming across suspectasbestos-containing information , no matter the age of the structure. Broadly speaking, the definition of suspectasbestos-containing material includes any concoction reasonably likely to contain asbestosbased on its appearance, composition and use. This slither rosters a few cases of the common typesof doubt ACM that can be found in buildings.Work on asbestos-containing asphalt roofingor siding requires notification to the MassDEP 10 -working days before starting work. While roofing and siding works need to betrained in accordance with OSHA requirements, there are no DLS asbestos license or certificationrequirements for the workers performing this work, as long as the material remains non-friable. The regulation specifies work practices formanaging asphalt roofing and siding that are in asbestos, to ensure that the asbestos isntreleased into the air. These work practices include: Isolating HVAC ventilation uptakes Removing roofing material intact as much aspossible Note that roofers CAN cut roofs into sections, but where cutting machines are utilized: The machines must be equipped with HEP-Avacattachments the cutting face must be kept adequatelywet at all seasons and the reduction segments of roofing cloth mustbe carefully lowered to ground If ALL the specified work practices are strictlyfollowed, then: Waste roofing material can be bulk-loadedfor transport to the disposal facility without an N-T Work Practice Approval.Waste can be disposed at any landfill permittedto accept solid litter If, on the other hand, the cultivate causes thematerial to become friable, or causes the release of asbestos dust, then the project becomesregulated by DLS, involving the use of licensed contractors, laborers civilized and certifiedas asbestos directors and workers, adherence to the full suite of asbestos work practicesspecified in the regulation, and package, transport and disposal of the waste roofingmaterial as an ACWM Special Waste.Either way, asbestos-containing asphalt roofingmaterial must never be given to a C& D Processor for recycling, because these facilities grindmaterial they receive and the grind busines will almost surely exhaust asbestos fibersinto the air. Non-traditional work practices are requiredwhen it is unsafe to follow prescribed work practices( for example it may be unsafe tobuild plastic containment near a fire peril, or to keep facility ingredients around liveelectrical rig dry ). This approval is referred to as an NTapproval. The NT Approval now involves a formal permitapplication process( use the BWP AQ-3 6 form on MassDEPs web site) and a $600 cost( whereapplicable ). The application must be complemented by a proposaldeveloped by a DLS-certified asbestos campaign designer. NT lets are available only for six particularcircumstances: 1. For defeat of a equipment under prescribe ofa state or local government agency because the facility is structurally unsound; 2. Where ACM or ACWM was discovered after demolitionbegan and , now cannot be safely removed with standard work practices; 3. For sure-fire disaster renovation actions; 4. For cleaning process and decontamination as a resultof work that was not done properly or when there is a safety or public health hazard: 5. Where drying would damage equipment or presenta safety hazard; or 6. When it is necessary to bulk load ACMand/ or ACWM The post-abatement visual inspection is requiredfor ALL asbestos abatement pleasures. The one exception is for the owner of anowner-occupied single house mansion who is working alone on non-friable asbestos-containingmaterial, does not cause the material to become friable, and does the make himself/ herself( In other oaths the homeowner does not engage a contractor) The purpose of this requirement is to ensure the job has been fully ended andthere is no discernible debris left behind on any of the handiwork surfaces.The revised regulation had indicated that thefinal visual inspection must be performed by a DLS-certified asbestos projection check. Additionally, it must be performed beforeremoving any office sphere railings and ventilation systems( if they were used ). Keeping the barriers and ventilation systemsin place ensures that if any further cleaning is required, it can be done safely. The requirement to use a Waste Shipment Recordform is another example where MassDEP regulations have been modified to better align with EPAsNESHAP requirements. The consume of a WSR form that rigorously complieswith the template became effective January 1, 2015. A template for the WSR form can be found onthe MassDEP website at the URL link shown on the slide. MassDEP will not provide forms. Haulers and transportation companies can usethe online template or they can create their own form, but, at a minimum, it must containall the information found on the template. The purpose of the WSR is to ensure that owners/ operatorstrack the transportation and disposal of ACWM rendered at their jobsites.If a completed WSR confirming proper disposalof ACWM is not received within 35 periods, the owner/ operator must track down the shipmentand notify MassDEP within 45 dates if there are any inconsistencies. Fee increases for both the BWP AQ-0 4 AsbestosNotification form( ANF-0 01) and the BWP AQ-0 6 Notification Prior to Construction/ Demolitionthat exited from $85 to $100 became effective in August 2013. In July 2014, three new rewards were added: A $35 fee for revising the initial ANF-0 01 or the AQ-0 6 chassis( e.g. converting the projectstart or tip time) A $200 fee for the BWP AQ-0 5 Blanket NotificationApproval request, And a $600 fee for the NTWP Approval request. Asbestos abatement errands at assets owned by certain types of entities are exempt fromMassDEP costs. These include: districts,( and municipalhousing jurisdictions ), provinces, regions of the Commonwealth, Federally recognizedIndian tribe home governments, the MBTA, and owner-occupied suburban quality with4 measurements or less. Please note that 501( c) 3 non-profit companies, and private educational and health practices are NOT exempt from MassDEP rewards. Beginning in March 2015, MassDEP started toaudit notifications to ensure that all relevant costs are paid. Anyone who claims fee-exempt status that doesnot appear to be eligible will be asked to provide supporting documentation or re-filewith proper payment.The Asbestos Project Look-Up tool is a usefulweb resource that anyone can use to see whether a notification has been filed for an abatementproject at any given address. Notifications registered through eDEP are addedto the look-up tool automatically. Notifications registered on paper species are addedto the database within one or two days of their receipt by MassDEP. The look-up tool can be accessed from theMassDEP website at the links listed on the slide. In Massachusetts, substance that contains anyamount of asbestos( even< 1 %) is regulated. All substances that contain any extent of asbestosshould have been identified during the pre-reno/ demo inspection. ACM identified by the survey needs to be abatedbefore it is disturbed.Material containing less than 1% asbestosdoesnt need to be abated in accordance with work practices( and you dont needto notify MassDEP before the abatement starts ), but you will need to manage the waste materialcontaining less than 1% asbestos as ACWM. If you remove it carefully and keep it separatedfrom your other non-asbestos construction or demolition litter, you are eligible to evaded contaminatingyour solid squander with asbestos, and can downplay the amount of material that has to be disposedof as ACWM. One of the main objectives of proper asbestosmanagement during a reno/ demo job is to prevent contamination of C& D debris by materialsthat contain any quantity of asbestos.This is because a C& D processing facilityusually grinds some of the information that is it receives, and can release asbestos fibers into the surroundingair and pose a state jeopardy to equipment workers and perhaps to the general public as well. It should be noted C& D processors haveconditions in their operating admits that veto them from countenancing ACM orsuspect ACM. If ACM or Suspect ACM shows up in a quantity, the cost of managing the load as ACWM will be passed on to the original generator, andthe MassDEP will be notified of the permit violation for further investigation. The MassDEP asbestos regulation requires thatALL ACWM is managed in accordance with the specified carton, transportation, storageand disposal provisoes. In simplest terms, material that containsasbestos in any amount( even< 1 %): Has to be segregated and properly managedduring reno/ demo projection It has to be packaged and labeled as ACWMAnd, it has to be disposed as Special Waste at a permitted solid waste management facility.If you desire further detailed information, this slither plies links to relevant regulation and guidance documents. Or, you can always call one of us on the MassDEPprogram staff with specific questions by phone or email at the contact information listedon the slither; For information or help with filing asbestosforms, eDEP or the asbestos database, you can submit you question by email to the Bureauof Air& Waste eDEP mailbox, or you can call the Asbestos hotline. For a matter of permits or complianceat a specific jobsite, feel free to contact one of the regional staff in the appropriateMassDEP region for the town in which the project is located.If youre not sure which field of MassDEPyour town is located in, you can click on the Find Your Region link. Thank you for your attention during this overviewof the revised asbestos regulation. We hope this slither production was helpful, and we welcome your feedback ..

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