by Robert Campbell
Instructor/Industrial Hygienist

Although there are very specific guidelines and regulations from the EPA which govern the management of asbestos in public school systems, typically within the AHERA regulations; these regulations do not apply to commercial and industrial buildings. However, OSHA has provisions in the construction asbestos standard, 1926.1101(k)(2)(ii)(D), which requires property owners to notify tenants; occupants and employees of the location and quantity of asbestos containing materials (ACMs) in occupied or leased space.

Ensuring the development and proper use of an asbestos operations and maintenance (O&M) plan allows Facility owners to safely manage asbestos materials onsite.

ACMs are only truly dangerous if they are damaged or disturbed which can occur through routine maintenance or building renovation activities involving damaged, friable asbestos containing materials. Friable asbestos materials can be crushed or pulverized by hand, posing the most significant potential for asbestos to be released and become airborne. Friable asbestos building materials were typically used as insulation to wrap HVAC ductwork, hot water pipe runs as well as piping elbows. It was also employed in spray-on coating materials, which were routinely applied to surfaces for the insulation of firewalls and to add “texture” to ceilings for visual effects. Although non-friable asbestos can also become airborne, it is typically embedded in a matrix, thus making the release of airborne asbestos unlikely. Non-friable asbestos was routinely used in the manufacture of 9 x 9 inch floor tiles (although multiple sizes of floor tile were found to contain asbestos), as well as the glue or “mastic” used to adhere the floor tile to the floor surface. Non-friable asbestos products were manufactured for fireproofing; to increase tensile strength and flexibility, it increased chemical resistance and is some cases helped with waterproofing.

The relative cost to conduct a building asbestos re-inspection, is SIGNIFICANTLY less than the cost to identify ACMs during the original asbestos survey.

Facility owners can safely manage asbestos through the development and proper use of an asbestos operations and maintenance plan (O&M). An Operations and Maintenance (O&M) program is a formulated plan of training, cleaning, work practices, and surveillance to maintain asbestos-containing materials (ACM) within buildings in good condition. The goal is to minimize exposure of all building occupants to asbestos fibers. An asbestos O&M plan typically identifies the location, classification, and condition of asbestos building materials. An asbestos O&M plan is referenced by building maintenance and construction renovation contractors to determine if their activities will impact or disturb building materials which contain asbestos. If the contractor reviews the asbestos O&M plan and determines that their activities will potentially come into contact and disturb asbestos containing building materials, they should take the proper precautions and engage licensed asbestos professionals to minimize the possibility that airborne asbestos fibers will be released.

Additionally, prudent owners of buildings which contain asbestos and who have developed asbestos O&M plans (typically buildings constructed before the early 1980s), should perform an asbestos re-inspection every few years. Since asbestos building re-inspection efforts focus on the “condition of asbestos” which was outlined in the original asbestos O&M plan, the relative cost to conduct a building asbestos re-inspection, is SIGNIFICANTLY less than the cost to identify ACMs during the original asbestos survey. This “extra precautionary measure” is used to document that the asbestos identified previously and documented in the original asbestos O&M plan has not been damaged. Damaged friable asbestos should be evaluated by a professional and should either be removed or encapsulated/repaired to minimize the release of airborne asbestos fibers.