Revised MassDEP Asbestos Regulation

Welcome to the outreach introduction 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 demonstration, I will guideyou through a high level overview of the regulatory revises that offers some revelation about howthese revises change 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 dislocation or removal of fabric that contains asbestos. If after listening to this presentation, youhave further questions; my contact information is listed on the last slide.I welcome your comments and questions. After more than 10 years 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 converted; there are 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 regime and federal CleanAir Act statutes to prevent handouts of asbestos into the air, as well as to protect publichealth, safety and the environment, and DLS enforces territory statutes with regards to: licensing of contractors qualified to work with asbestos, establishing safe work practicesand worker qualification requirements, and guaranteeing skilled laboratories that conductanalytical methods for asbestos.The overarching goals of the MassDEP AsbestosRegulation revisions enacted in June 2014 were to clarify interpretations and regulatoryrequirements; incorporate policies that were previously outside the existing regulations; and betteralign the mood curriculum with the EPA Asbestos National Emissions Standards for HazardousAir Pollutants( or NESHAPs ). It is also worth pointing out that the overlap withthe State Sanitary code renders an opportunity for inter-agency cooperation with neighbourhood Boardsof Health. State Sanitary Code asks owneds of residentialbuildings to amend or remove damaged asbestos containing textiles in accordance with MassDEPand DLS regulations. The MassDEP asbestos regulation focuses onrenovation and defeat work involving information 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 conspicuous release standard ); andProtect public health, safety and the environment. The essential elements of the program remainunchanged. These parts show the usual life-cycleof an asbestos abatement project.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 tasks Manage asbestos containing waste materialproperly Please note: DLSs regulations have notchanged. Within the next 2 slips, I will spotlight afew of the new elements of the revised regulation. Pre-Reno/ Demo Survey: While the requirement to conduct a pre-reno/ demo overlook 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 defeat or renovation activities.This inspection is to determine all asbestos-containingmaterial in the area that will be disturbed by the projected task. MassDEPs regulation describes which are capable of conductthe pre-reno/ demo the investigations and what needs to be documented in a written examination report. Notification Exemption for Small Jobs: The revised rules of procedure supports notification exceptions for a limited universe of smalljobs involving specific substances. Solely, the following entry threshold quantitiesapply:< 100 sf of asbestos-cement shingles, surfacing, committees< 100 sf of asbestos flooring tile and relatedmastics, or< 32 sf of gypsum wallboard and related jointcompound In addition, sure-fire work on asbestos-containingmaterial at an owner-occupied single clas mansion does not have to be reported toMassDEP. This exception only applies if the owner isworking alone on non-friable asbestos-containing material, does not cause it to become friable, and does the project himself/ herself( does not engage a contractor ). By non-friable, we convey substance thatwhen bone-dry, cannot be disintegrated, shattered, pulverized or reduced to powder by hand-pressure. Aside from these limited notification exemptions, the notification requirements continue implementing as they always have in the past thatis - any activity that disrupts or removes any capacity of asbestos-containing materialrequires notification 10 -working days prior to starting the job.Regardless of whether a enterprise qualifies forone of the brand-new notification exceptions, all asbestos abatement activities 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 water( which represents water with soap/ surfactant supplemented) toprevent contemporary of discernible junk Carefully lowering roofing and surfacing shinglesto the ground Spreading tarp or plastic sheeting where debrismay drop and cleaning up at boundary of each shift Properly packaging waste material in leak-tight, closed and labeled debris receptacles Jettisoning of waste material at a solid wastefacility that has a Special Waste permit to accept asbestos garbage. Material 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 cloth specific work practices that werepreviously experienced either in plan or advice. Regarding this matter, brand-new divisions were added tothe regulation to address the following material-specific work practices: Asphaltic roofing and surfacing fabrics Window glazing and/ or caulking compoundsCement shingles, surfacing and bodies Floor tileGypsum wall-board and joint complex Non-Traditional Asbestos Abatement Work Practices: Non-Traditional Asbestos Abatement Work Pattern were historically called Alternative WorkPractices This now requires a formal tolerate lotion( Application for Non-Traditional Asbestos Abatement Work Practice Approval BWP AQ-3 6) and fee of a $600 cost, if applicable. Post-Abatement Visual InspectionThe post-abatement visual inspection is a new requirement for all jobs that comes atthe end of the asbestos abatement tasks. It ensures that no perceptible asbestos-containingdebris remains on any of the operate 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 regulation will be required the owner/ hustler remain copies of the pre-reno/ demo overlook 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 stipulate a few more details abouteach of these new regulatory requirements in the following moves. The requirement for a pre-reno/ demo surveyapplies to ANY job with its full potential to shake suspect asbestos-containing cloth. Before disturbing the material, a DLS-certifiedasbestos inspector must conduct a thorough inspection that is, to identify thepresence, spot and quantity of any ACM or Suspect ACM that contains asbestos in anyamount.What overtakes as a thorough inspectioncould be one thing for a manufactured information where product content is fairly consistent( for example VAT tile, asphalt roofing material, cement shingles/ siding, etc .); but, it couldbe different for a material with incompatible levels of asbestos content caused by contaminationwith quite natural asbestos minerals( such as vermiculite insulation) or hand-mixedcompounds( like plaster ). In the onetime dispute: a very limited number of randomsamples may suffice, But in the latter dispute: many more samplesmay be needed, particularly to target areas where asbestos is likely to have accumulated. Once fairly samples ought to have obtained, theywill need to be analyzed by a qualified laboratory that follows an approved analytical method, to find out 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 Material 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 under the written cross-examine report as ACM, and managedas ACM( i.e. it must be abated prior to demolition/ renovation ). The pre-demo/ reno investigation is the lynchpin ofcompliance for both the MassDEP and EPA regulations. The inspection caters 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 assignments( by identifying which fabrics contain asbestosand need to be removed before your defeat or redevelopment 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 information are suspect ACM. Asbestos-containing information are found inmost houses, even those improved after 1980 After successfully ordaining forbiddings on the use of asbestosin several 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 Government, hundreds and concoctions 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 suppose materials on the market today. So contractors and homeowners doing renovationor demolition activities need to be attentive to the likelihood of coming across suspectasbestos-containing cloths , 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, form and use.This slide inventories a few of the common typesof believe ACM that can be found in houses. Work on asbestos-containing asphalt roofingor siding requires notification to the MassDEP 10 -working days before starting work. While roofing and backing works need to betrained in accordance with OSHA requirements, there are no DLS asbestos license or certificationrequirements for the workers performing the present working, as long as the material remains non-friable. The regulation specifies work practices formanaging asphalt roofing and siding that are in asbestos, are responsible for ensuring that the asbestos isntreleased into the air. These work practices include: Isolating HVAC ventilation intakes Removing roofing material intact as much aspossible Note that roofers CAN cut roofs into segments, but where cutting machines are utilized: The machines must be equipped with HEP-Avacattachments the trimming skin-deep must be kept adequatelywet at all times and the slashed cases of roofing material 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 consume If, on the other hand, the employment causes thematerial to become friable, or causes the release of asbestos dust, then the undertaking becomesregulated by DLS, requiring the use of licensed contractors, works learnt and certifiedas asbestos managers and workers, adherence to the full suite of asbestos work practicesspecified in the regulation, and parcel, 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 grinding action will almost surely liberate 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 fervor hazard, or to keep facility constituents around liveelectrical rig moisture ). 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 reward( whereapplicable ). The application must be complemented by a proposaldeveloped by a DLS-certified asbestos campaign designer. NT permits are available only for six particularcircumstances: 1. For defeat of a equipment under ordering ofa nation 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 emergency redevelopment activities; 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 potential hazards; or 6. When it is necessary to bulk load ACMand/ or ACWM The post-abatement visual inspection is requiredfor ALL asbestos abatement acts. The sole exception is for the owner of anowner-occupied single genealogy residency "whos working" alone on non-friable asbestos-containingmaterial, does not cause the material to become friable, and does the study himself/ herself( In other words the homeowner does not engage a contractor) The purpose of this requirement is to ensure the job has been thoroughly accomplished andthere is no visible debris left behind on any of the act surfaces.The revised regulation specifies that thefinal visual inspection must be performed by a DLS-certified asbestos assignment monitor. Additionally, it must be performed beforeremoving any toil neighborhood hurdles 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 apply 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 is the subject of the WSR is to ensure that proprietors/ operatorstrack the transportation and disposal of ACWM produced at their jobsites. If a completed WSR confirming proper disposalof ACWM is not received within 35 periods, the owner/ motorist must track down the shipmentand notify MassDEP within 45 epoches if there are any contradictions. 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 extended from $85 to $100 became effective in August 2013. In July 2014, three new costs were added: A $35 cost for revising the initial ANF-0 01 or the AQ-0 6 kinds( e.g. varying the projectstart or dissolve time) A $200 reward for the BWP AQ-0 5 Blanket NotificationApproval request, And a $600 cost for the NTWP Approval request.Asbestos abatement tasks at qualities owned by certain groups of entities are exempt fromMassDEP rewards. These include: districts,( and municipalhousing sovereignties ), counties, territories of the Commonwealth, Federally recognizedIndian tribe dwelling authorities, the MBTA, and owner-occupied residential dimension with4 legions or less. Please be advised that 501( c) 3 non-profit makings, and private educational and health organizations are NOT exempt from MassDEP fees. Beginning in March 2015, MassDEP started toaudit notifications to ensure that all pertinent fees 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 filed through eDEP are addedto the look-up tool automatically. Notifications registered on paper shapes are addedto the database within one or two days of their acknowledgment by MassDEP. The look-up tool can be accessed from theMassDEP website at the links listed on the slip. In Massachusetts, material that contains anyamount of asbestos( even< 1 %) is regulated. All substances that contain any quantity of asbestosshould have been identified during the pre-reno/ demo questionnaire. ACM identified by the survey needs to be abatedbefore it is perturbed. Substance 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 defeat squander, you are eligible to avoided contaminatingyour solid trash with asbestos, and can understate the amount of cloth that has to be disposedof as ACWM. One of the main objectives of proper asbestosmanagement during a reno/ demo assignment is to prevent contamination of C& D debris by materialsthat contain any amount of asbestos. This is because a C& D processing facilityusually grinds some of the material it receives, and can exhaust asbestos fibers into the surroundingair and pose a health risk to facility workers and perhaps to the general public as well.It is worth noting that C& D processors haveconditions in their operating admits that prohibit them from admitting ACM orsuspect ACM. If ACM or Suspect ACM shows up in a load, 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 packaging, transportation, storageand disposal funds. In simplest terms, information that containsasbestos in any extent( even< 1 %): Has to be segregated and properly managedduring reno/ demo campaign 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 hope further detailed information, this move offer 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 move; 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 questions about grants 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 sphere 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 move show was helpful, and we welcome your feedback ..

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