Standard Practice for Comprehensive Building Asbestos Surveys

Importancia y uso:

4.1 Management of asbestos-containing materials in buildings and facilities requires knowledge of the location, type, quantity, and condition of the material. The more complete and accurate the information available, the more appropriate and cost-effective are the control measures used to reduce possible exposure to airborne asbestos fibers. This is true whether the asbestos-containing materials remain undisturbed and completely intact, are selectively removed for maintenance or prior to renovation, or are removed to the greatest extent feasible before demolishing the building or facility.

4.2 This practice describes three types of surveys that support different objectives. These are the Baseline Survey, the Project Design Survey, and the Pre-Construction Survey.

4.2.1 The Baseline Survey is a building-wide or facility-wide inspection that provides a general sense of the overall location, type, quantity, and condition of asbestos-containing materials present. It is thorough in that most accessible functional spaces are inspected and bulk samples taken of suspect materials observed. The baseline survey provides information for long-term management of asbestos-containing materials and prioritization of response actions. The presence of asbestos in suspect materials may be assumed or presumed in some cases without bulk samples being taken or analyzed. However, the baseline survey is unobtrusive in that samples are not taken where doing so would result in objectionable damage to surfaces or where institutional barriers preclude access. In a baseline survey, destructive testing is avoided. Posting of signs and labels required for compliance with OSHA regulations would use the information generated during a Baseline Survey.

Note 1: A Baseline Survey is sometimes called an “AHERA” survey because it provides the type of information used for management of asbestos-containing materials in schools. However, the baseline survey described in this practice requires inspection, bulk sampling, quantification, and assessment of suspect materials that are excluded by virtue of their type and location from the AHERA regulations for schools.

Note 2: Suspect material subject to disturbance by planned or emergency maintenance may not always be identified as to asbestos content in a Baseline Survey. Collecting a single bulk sample, or a small number of samples, to determine if the material contains asbestos does not constitute a survey within the meaning of this practice. Nonetheless, the sample(s) should be collected in accordance with the methods described in Appendix X1 (this must be done by a properly-credentialed individual) and analyzed as set forth in 6.5.

4.2.2 The Project Design Survey is more focused than a Baseline Survey and is used to provide information to the Project Designer for preparing abatement plans and specifications. The locations inspected are limited to the areas that will be affected by the abatement project. If the project is being done prior to renovation or demolition, the construction plans or at least a clear statement of the scope of the renovation or demolition work are required for a proper Project Design Survey. Destructive testing is often required for a Project Design Survey. The presence of asbestos in suspect materials is always confirmed in a Project Design Survey rather than being assumed or presumed. Other information required for the Project Design is collected during the survey.

4.2.3 The Pre-Construction Survey is performed in anticipation of renovation or demolition where a Baseline Survey has not been conducted and there is no information, or insufficient information, as to the existence of asbestos-containing materials within the planned limits of construction. The Pre-Construction Survey requires destructive testing if concealed spaces are to be breached during construction. If asbestos-containing materials are found, a Project Design Survey is conducted to provide information for preparing the plans and specifications. The Pre-Construction Survey satisfies the EPA NESHAP requirements for renovation or demolition to “thoroughly inspect the affected facility.”

Note 3: On August 7, 2015, the EPA published a clarification letter allowing for the use of the Pre-Construction Survey for compliance for the asbestos NESHAP requirements to “…thoroughly inspect the affected facility…” [40 CFR Part 61.145(a)] . This clarification letter can be found on the EPA’s Applicability Determination Index (ADI) as item number A150001. The clarification letter explains what sections of this practice must be used for compliance.

4.3 The inter-relationships among the three types of surveys and with other ASTM asbestos control standards is shown in Fig. 1.

FIG. 1 Relationship Between E2356 Surveys and Other Standards

4.4 This practice emphasizes the concept that a Comprehensive Building Asbestos Survey consists of more than the collection and analysis of samples, and the report is more than a compilation of laboratory results. It is important to inspect as many functional spaces as possible and to document the reasons why certain functional spaces were not inspected and locations where no suspect materials were observed and, consequently, no samples were taken. Reasons might include access limitations, the absence of materials to sample, the existence of information from previous surveys, or the availability of reliable documentation such product data sheets or Safety Data Sheets (previously known as Material Safety Data Sheets, MSDS) where the content of that document specifically details the absence of added asbestos. It is worthy to note that it can be difficult to find MSDS or product data sheets for installed materials or in older buildings or structures. It is also known that asbestos content was not always disclosed in these documents. In other cases there may be a material descriptions (as with asphaltic roofing products) where the term “encapsulated asbestos” is used. Terms of this nature do not do not constitute the absence of asbestos. If the absence of asbestos is not clearly noted on these documents they should not be used to eliminate an installed material from a survey.

4.5 A Comprehensive Building Asbestos Survey is not limited to the class of materials commonly referred to as asbestos-containing building materials (ACBM), defined in the AHERA regulations as “... found in or on interior structural members or other parts of a building.” Items that are difficult to distinguish as such may include cooling towers, laboratory hoods, gaskets, chalkboards, and other articles. These may be installed in, attached to, or adjacent to the building or facility but are not as clearly a part of the building or facility as fireproofing or floor tile. Nonetheless, such items still fall within the scope of an asbestos management program and therefore are addressed in this practice. Locations outside the building, in particular equipment in industrial facilities and power plants, and crawl spaces underneath the building are within the scope of a Comprehensive Building Asbestos Survey.

4.6 This practice is intended to be used by individuals who are conducting a Comprehensive Building Asbestos Survey for the owner or manager of a building or facility under a contractual arrangement for services as well as by employees of the owner or manager. If the individual is conducting the survey under a contractual arrangement (which may be with the firm employing the individual), the owner or manager of the building is still responsible for certain activities as described in this practice.

Subcomité:

D22.07

Referida por:

D7390-18E01, E1494-18, D7390-18E01, E1494-18, E2394-11R20E01, E1368-23, E2394-11R20E01, E1368-23, D7886-14R19E01, D7886-14R19E01, E2247-23

Volúmen:

11.07

Número ICS:

91.100.40 (Products in fibre-reinforced cement)

Palabras clave:

AHERA; baseline survey; bulk sample; EPA; inspection; NESHAP; OSHA; polarized light microscopy (PLM); pre-construction survey; project design survey;