Roofers
A common-sense approach to asbestos in roofing.
Plant Engineering | March 1, 1996 | Steinmetz, William R., Jr.
Revisions were made concerning the regulations over the removal of asbestos on roofing materials, following claims by the National Roofing Contractors Association that the low asbestos content in most roofing materials pose minimal health risks. The revised agreement provides relief on roofing jobs involving felt, shingles and transite panels, as well as jobs involving intact materials, such as roof coatings, mastics and cements. These rules were set to protect workers from occupational diseases and reduce liability claims for asbestos removal works in roofings.
A look at the regulations, concerns, considerations, and procedures for dealing with the problem
The word asbestos carries an ominous connotation to many plant engineers and building owners. Many are caught up in the hype surrounding asbestos abatement. Others are confused about how to face the questions surrounding this mysterious, dangerous, and often misunderstood substance.
Asbestos issues cast a particularly perplexing spell over decisions about how to deal with the material in the removal of roofing systems. The product is an excellent roofing choice because it is fire-resistant, durable, and nonrotting. And most significantly on the other hand, asbestos causes three deadly diseases: lung cancer, asbestosis, and mesothelioma (cancer of the lung lining and always fatal).
Asbestos particles are tiny and stay airborne for long periods, making them easily inhaled by humans. The substance is an accumulative, dose-response hazard. Once in the lungs, it is there for life.
This danger prompted enactment of the Asbestos Hazard Emergency Response Act (AHERA) in the early 1980s. The regulation required every K-12 school in the U.S. to develop a management plan for dealing with asbestos. Since then, much has been done to raise awareness of the issues surrounding this material.
Revising Regulations... Again
Removal of roofing material containing asbestos has been regulated for many years by OSHA's asbestos standard for construction. The standard's earliest form based removal requirements primarily on exposure levels. A 1994 revision, however, extended stringent removal requirements to all roof removal work involving asbestos, regardless of exposure level.
This revision was challenged in the courts by the National Roofing Contractors Association (NRCA) and other groups. These organizations contended that the low levels of asbestos present in most roofing materials posed little or no health hazard. In April 1995, OSHA and NRCA reached an agreement that provides regulatory relief on roofing jobs involving felt, shingles, and transite panels (so-called Class II work subject to a prescribed set of procedures). These materials may be made friable if not properly removed.
Relief is also provided for jobs involving intact materials such as roof coatings, mastics, cements, and flashings (so-called incidental work subject to a less stringent set of procedures than Class II work). Intact is an OSHA term meaning that the material is not friable under ordinary circumstances.
The agreement benefits the contractor and building owner because it exempts many roof removal jobs from requirements for air monitoring, protective clothing, and other burdensome practices. In contrast to previous standards, which were often vague and nebulous, the 1995 version clearly sets out what is required of both parties when asbestos is present.
Yet, while the new agreement takes a more reasonable approach to the problem of asbestos removal, it is unlikely to allay plant personnel's deep-seated anxieties.
Numerous Concerns
Hype and trepidation surrounding asbestos is rooted in several factors: fear of liability, stringent government regulations for workplace and environmental safety, and greed on the part of contractors qualified to remove the material.
While much of the hype is actually unfounded due to the low levels present in roofing, all owners should have at least a minimal concern about asbestos. In addition to potential liability, two new obligations have been placed on them by the 1995 agreement.
* If a building owner is aware of asbestos anywhere in the facility, he is obligated under the standard to notify contractors that come onsite. If the plant contains thermo system insulation and surfacing materials installed prior to 1981, these products are presumed to contain asbestos, unless sampling of the area proves otherwise.
* If the building owner installs asbestos products, he is obligated, to label them as such.
However, dealing with asbestos does not need to be panic-driven. A common-sense approach helps the company discern the best method of sorting through the questions regarding the presence of this troubling substance in its roofs.
No one tears off a roof solely because it contains asbestos. Roof removal is necessitated by deterioration and leaks. But if removal is necessary, special steps must be taken to minimize liability and stay within government regulations.
Selecting a Contractor
According to the new agreement, the presence of any asbestos makes the material asbestos-containing. Since regulations covering the handling of asbestos-containing roofing material (ACRM) are complex, selecting a roofing contractor familiar with and experienced in documenting asbestos-removing activities that comply with local, state, and federal regulations is very important.
The roofing professional is critical, because he must be capable of dealing with the multiple government agencies involved in asbestos removal regulation. For example, OSHA sets its standards with a focus on worker safety, while EPA concentrates on regulating levels to protect the environment. DOT further complicates matters with regulations involving the hauling of asbestos-containing materials.
Many states require licensing of asbestos contractors. If your state does, make sure your contractor is.
Testing the Roof
In taking a common-sense approach to dealing with asbestos in a leaky roof, first determine the presence of the material in the system. Contact a National Institute of Occupational Safety and Health (NIOSH)-accredited asbestos testing laboratory to determine if the material is asbestos-bearing, and whether or not it is friable.
Friability in roofing is determined by visually examining its condition. An asbestos roofing system in an advanced state of deterioration with the potential for fiber release could be considered friable.
Another test involves cutting an 18-in.-square piece of the material and bending it in a horseshoe configuration. In some states, the person making the cut must have special training. The roofing contractor is likely to have a trained person who can do the job. If the sample does not fracture, it is considered nonfriable. This test is obviously very dependent on the temperature of the sample. A material is also made friable if the removal process uses a roof cutter.
EPA regulations are structured according to a material's friability. In designing its regulation, EPA recognized that not all asbestos-containing material has the same potential for releasing fibers into the air, so it drew up the rules accordingly.
Under the EPA regulation governing ACRM, the only requirements for friable material removal are proper training and notification to EPA. It is not necessary to follow the more stringent work practices and activities mandated for Class II asbestos work. The new OSHA agreement, however, automatically mandates Class II treatment for asbestos roofing felts, shingles, and transite panels. This treatment includes air sampling, protective clothing, hygiene facilities, and respiratory protection.
However, requirements are relaxed if an exposure assessment determines that the amount will be below the permissible exposure limit. This is called a negative exposure assessment. It exempts the job from Class II mandated practices.
The exposure assessment must be made on the jobsite by a "Competent Person," which is OSHA's term for an individual with the required training and authority. Under the new agreement, the assessment is based on one of the following: air sampling data collected by the contractor on previous jobs within the last 12 months, air sampling data assembled by the NRCA, or air sampling conducted on the current job. If the third method is used, Class II requirements apply until the results of the air sampling come back.
Based on air sampling data collected by NRCA over the past several years, chances are extremely good that the exposure assessment will be negative. Therefore, air sampling, protective clothing, and other burdensome practices will not be required.
Asbestos roof coatings, cements, mastics, and flashings are not subject to Class II treatment under the OSHA agreement, as long as they remain intact, or nonfriable.
However, the friability test is very subjective. Just because an inspector deems it nonfriable does not mean the plant should turn the other cheek and do nothing. The judgment is simply a valuable determination that may help in the future if there is a lawsuit.
If no traceable level of asbestos is found, that discovery must also be documented for proof. If asbestos is present, there are three options.
First, the plant can elect not to remove the material immediately, and simply maintain the roof until removal is scheduled. Care should be taken, however, that maintenance activities do not disturb the material and create a Class II situation. Some repairs require specially trained personnel.
Second, the plant can recover the roof. Again, this approach forestalls the removal of asbestos.
Third, the plant can completely or partially remove the asbestos-containing roof.
Removing the Roof
Before removal begins, remember that EPA, most states, and many municipalities require notification in advance of the work being performed. Time periods and reporting thresholds for notification vary among the various agencies.
It is advisable for owners to notify all authorities, regardless of the requirements, as a courtesy. A little effort is required, but the good-faith practice goes a long way in building amicable relations with government officials.
Determine whether roofers should use power tools (specifically a roof cutter) before beginning the process of removing a roof containing asbestos materials. These tools impact the friability issue.
A roof cutter makes a material friable along the line of the cut. Axing the material by hand does not. Since stringent regulations apply to friable materials, use hand-removal of asbestos with spades and axes when possible. However, this approach is only feasible on flashings and smaller roof areas. A roof cutter is more economical on larger surfaces.
In order to maintain the exemption from Class II requirements, the new OSHA agreement prohibits power tools when removing intact asbestos roof coatings, cements, mastics, and flashings. If power tools are used for the sake of economy, the job becomes subject to Class II requirements.
Ensure that the contractor is protecting all personnel - both inside and out - during the removal of friable asbestos. Several safeguards are necessary to properly guard employees, and protect against liability claims and OSHA citations.
First, all air intakes near the asbestos removal site must be isolated during Class II work to prevent the material from entering the plant and affecting employees.
Second, all roofers must be trained in asbestos removal. Training requirements are spelled out in AHERA for EPA compliance, and in the new NRCA agreement for OSHA compliance.
If the state has a contractor licensing regulation and yours participates in this program, he has demonstrated to the agency which regulates asbestos that he meets existing requirements. This program will include training. Ask to see current (less than 12 months old) training class certificates for employees involved with the asbestos removal process.
Third, all personnel doing Class II work more than 30 days/yr must be under medical surveillance. This protection determines their suitability to wear a respirator and monitors the prognosis of any asbestos-related medical condition.
Finally, even when a negative assessment is made, it is still a good idea to monitor the jobsite in order to have documentation in case of a lawsuit.
Depending on the comfort level desired, consider taking area samples inside the plant before work begins, while work is underway, and after the job is finished to document the airborne levels at these times.
A common use for asbestos in the past was to spray it on the underside of roof decks as a fireproofing agent. The roof removal process easily dislodges this material into the building interior. If you suspect the plant may have an interior airborne asbestos problem, it is best to find out before work starts.
If a negative assessment can't be made, or the company chooses to do voluntary monitoring, two factors should be kept in mind.
* Air monitoring should continue for a representative number of days, depending on job size and conditions, to determine the asbestos levels in a variety of conditions and locations on the roof. If levels of airborne asbestos exposure are below the permissible exposure level of 0.1 fiber/cc/8-hr TWA, the wearing of personal protective equipment by workers is optional.
* Until air monitoring results are in, or a negative exposure assessment is made, all workers should wear appropriate respiratory protection and disposable protective clothing that is discarded each time they leave the jobsite.
Special Considerations
The area cut by the saw is the only part of the material considered friable. As a result, it is necessary to keep the material damp to avoid creating a dust. The new OSHA agreement requires that the roof cutter have a water mist inside the blade shroud. This shroud should have a rubber gasket around the bottom so it fits closely to the roof surface to help prevent visible emissions.
Debris generated by the cutter must be removed directly from the shroud by powered, high-efficiency, particulate air filters (HEPA) or a HEPA vacuum along the finished saw cut. It is permissible on smooth-surface roofs to wet-wipe any debris from the finished saw cut in lieu of using a HEPA vacuum.
Dry removal is possible if there is concern about water getting into the plant as a result of wetting the work area. However, EPA approval must be obtained prior to starting this approach.
While removing the roof, it is vitally important to document every step to prove that the amount of asbestos is under the permissible exposure level.
Perhaps the greatest potential liability on the owner is disposal of materials from the tearoff. Roofing material belongs to the building owner forever. Therefore, it is important to dispose of it in a manner that will not come back to haunt you in the future.
The concept of joint and several liability may force the company to help pay cleanup costs, even if limited materials of a nontoxic nature were deposited into the landfill. Deal with a licensed, insured, and well-capitalized waste hauler, and a landfill that is familiar with the proper disposal of ACRM, to minimize the problem.
Most states have little or no requirements for hauling or disposing of non-friable ACRM. However, many haulers and landfills, recognizing their potential liability and opportunity for increased revenue, have requirements of their own for handling this material. These requirements include double-bagging all roofing tearoff material, lined dumpsters, 24-hr advance notification to the landfill, use of EPA-approved landfills for all asbestos (friable and nonfriable), and use of a manifest.
Actually, a manifest is a good idea whether required or not. The manifest allows the owner to document in writing who hauled the asbestos, how it was hauled, when it was hauled, where it was hauled, and how it was land-filled.
The bottom line on asbestos in roofing is that there are generally small levels to contend with, but a plan must be followed to confirm the absence of asbestos, or to safely remove those materials containing asbestos. Asbestos and related liability must be taken seriously. The potential problem is successfully handled by those willing to take a safe, common-sense approach and document every step along the way.