Asbestos Containing Materials

FRIABLE ASBESTOS-CONTAINING MATERIALS:

Due to their high tensile strength, incombustibility, corrosion and friction resistance and other properties, such as acoustical and thermal insulation abilities, asbestos fibers have been incorporated into over thirty-six hundred (3600) commercial products. Thermal system, fireproofing and acoustical insulation materials have been used extensively in the construction industry.

Thermal system applications include steam or hot water pipe coverings and thermal block insulation found on boilers and hot water tanks. Fireproofing insulation may be found on building structural beams and decking. Acoustical insulation (soundproofing) commonly has been applied as a troweled-on plaster in school and office building stairwells and hallways. Unfortunately, with time and exposure to damaging forces (e.g., severe weather, chemicals, mechanical forces, etc.), many asbestos-containing materials may become crumbled, pulverized or reduced to powder, thereby releasing asbestos fibers, or may deteriorate to the extent that they may release fibers if disturbed. Since inhalation of asbestos fibers has been linked to the development of respiratory and other diseases, any material which is friable, or has a high probability of releasing fibers, must be handled in accordance with the Asbestos NESHAP.

The following work practice should be followed whenever demolition/renovation activities involving RACM occur:

Notify EPA of intention to demolish/renovate, remove all RACM from a facility being demolished or renovated before any disruptive activity begins or before access to the material is precluded, keep RACM adequately wet before, during, and after removal operations, conduct demolition/renovation activities in a manner which produces no visible emissions to the outside air, and handle and dispose of all RACM in an approved manner.

non-friable ASBESTOS-CONTAINING MATERIALS:

Because of the resilient nature of asbestos, it is used in materials exposed to a wide variety of stressful environments. These environments can cause the deterioration of binding materials and cause non-friable materials to become friable. For example, asbestos-containing packings and gaskets (Category I non-friable ACM) used in thermal systems may be found in poor condition as a result of the heat they have encountered. In petrochemical handling facilities, which may have miles of transfer pipes and fittings which contain asbestos gaskets and/or packings, profound degradation of the ACM may occur due to exposure to organic-based liquids and gases or to corrosive agents used to hemically clean these lines.

When non-friable ACM is subjected to intense mechanical forces, such as those encountered during demolition or renovation, it can be crumbled, pulverized, or reduced to powder, and thereby release asbestos fibers. When non-friable materials are damaged or are likely to become damaged during such activities, they must be handled in accordance with the Asbestos NESHAP.

There are two categories of non-friable materials: Category I non-friable ACM and Category II non-friable ACM.

CATEGORY I non-friable ACM

Category I non-friable ACM is any asbestos-containing packing, gasket, resilient floor covering or asphalt roofing product which contains more than one percent (1%) asbestos as determined using polarized light microscopy (PLM) according to the method specified in Appendix A, Subpart F, 40 CFR Part 763. (Sec. 61.141)

Category I non-friable ACM must be inspected and tested for friability if it is in poor condition before demolition to determine whether or not it is subject to the Asbestos NESHAP. If the ACM is friable, it must be handled in accordance with the NESHAP. Asbestos-containing packings, gaskets, resilient floor coverings and asphalt roofing materials must be removed before demolition only if they are in poor condition and are friable.

The Asbestos NESHAP further requires that if a facility is demolished by intentional burning, all of the facility’s ACM, including Category I and II non-friable ACM, be considered RACM and be removed prior to burning (Sec. 61.145(c)(10)). Additionally, if Category I or Category II non-friable ACM is to be sanded, ground, cut, or abraded, the material is considered RACM and the owner or operator must abide by the following (Sec. 61.145(c)(1)):

(i) Adequately wet the material during the sanding, grinding, cutting or abrading operations.

(ii) comply with the requirements of 61.145(c)(3)(i) if wetting would unavoidably damage equipment or present a safety hazard.

(iii) Handle asbestos material produced by the sanding, grinding, cutting, or abrading, as asbestos-containing waste material subject to the waste handling and collection provisions of Section 61.150.

CATEGORY II non-friable ACM

Category II non-friable ACM is any material, excluding Category I non-friable ACM, containing more than one percent (1%) asbestos as determined using polarized light microscopy according to the methods specified in Appendix A, Subpart F, 40 CFR Part 763 that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. (Sec. 61.141)

Category II non-friable ACMs (cement siding, transite board shingles, etc.) subjected to intense weather conditions such as thunderstorms, high winds or prolonged exposure to high heat and humidity may become “weathered” to a point where they become friable.

The following table lists examples and other relevant information about Category I and Category II non-friable ACM.

TABLE 1. non-friable ASBESTOS PRODUCTS

non-friable ASBESTOS PRODUCTS

From EPA Guidance entitled “Guidance for Controlling Asbestos- Containing Materials in Buildings” (Purple Book), appendix A, Page A-1; EPA 560/5-85-024.

Except for the following, Section 61.145(c) of the Asbestos NESHAP requires that each owner or operator of a demolition or renovation activity involving RACM remove all such material from a facility being demolished or renovated before any activity begins that would break up, dislodge, or similarly disturb the material or preclude access to the material for subsequent removal.

ACM need not be removed before demolition if it:

(i) Is a Category I non-friable ACM that is not friable.

(ii) Is on a facility component that is encased in concrete or other similarly hard material and is adequately wet whenever exposed during demolition.

(iii) Was not accessible for testing and therefore was not discovered until after demolition began and, as a result of the demolition, cannot be safely removed. If not removed for safety reasons, the exposed RACM and any asbestos-contaminated debris must be treated as asbestos-containing waste material and kept adequately wet at at all times until disposed of.

(iv) Is a Category II non-friable ACM and the probability is low that the material will become crumbled, pulverized, or reduced to powder during demolition.

INSPECTION PROCEDURES TO DETERMINE THE POTENTIAL FOR FIBER RELEASE FROM non-friable ASBESTOS-CONTAINING MATERIALS:

Members of the regulated community (i.e. abatement contractors, industrial hygienists, building owners & operators, etc.) should become familiar with these procedures as they are designed to enhance compliance with the Asbestos NESHAP.

GENERAL INSPECTION PROCEDURES

1. Identify all non-friable suspect ACM and determine whether it is Category I or II.

2. If it is Category I non-friable RACM:

Is it in “poor condition?” [Is the binding of the ACM losing its integrity? Is the ACM peeling, cracking, or crumbling? (Remember, friable ACM may not appear in poor condition.)]

Is it friable?

- Collect a piece of dry ACM and seal it in a transparent, reclosable sample bag.

- Apply hand pressure and observe if the ACM falls apart to the extent that it is crumbled, pulverized, or reduced to powder. Does it occur suddenly, all at once?

- Send representative samples of the RACM to an analytical laboratory which is able to test them for the presence of asbestos according to the methods specified in 40 CFR Part 763 Subpart F, Appendix A.

- Ask the owner/operator if any ACM or RACM has been sampled and analyzed. If so, determine where the samples were taken and ask if the methods of demolition/renovation were considered when assessing the fiber release potential of the material. Will it or has it been subjected to sanding, grinding, cutting or abrading?

3. If it is Category II non-friable ACM:

- Has the material been crumbled, pulverized or reduced to powder or is there a high probability that it will be crumbled, pulverized or reduced to powder during the demolition/renovation operations, thus rendering the material friable and subject to the Asbestos NESHAP?

- If Category II non-friable ACM has been or will be crumbled, pulverized, or reduced to powder by demolition or renovation forces, take representative samples and send them to a laboratory to test for the presence of asbestos according to the method specified in 40 CFR Part 763, Subpart F, Appendix A.

SPECIFIC INSPECTION PROCEDURES:

CATEGORY I non-friable ACM

Packings and Gaskets

These materials are often very difficult to find because they are usually placed inside ovens, doors, pipes, boilers, etc. Often a packing or gasket is discovered during a stripping or demolition activity. For example, some boilers have an asbestos containing paraffin wax packing between the steam lines that travel between the mud and fire boxes. The paraffin binding of the packing may decompose due to the high temperatures, and render the packing friable. Observe all of the packing and note areas that are in poor condition. Packings in poor condition appear dry and discolored, and fibers may be visible.

A representative piece of asbestos-containing packing material (in good or poor condition) should be removed with a utility knife and sealed in a transparent, reclosable bag. Apply hand pressure to the packing in the sample bag to determine if any portion is crumbled, pulverized or reduced to powder. If the material simply deforms, but does not crumble or reduces to a powder, then the material is considered non-friable.

Resilient Floor Covering

There is a wide variety of resilient floor covering applications that contain asbestos. The most common are linoleum flooring and vinyl asbestos tile (VAT). VAT is most commonly found in either a 9″x9″ or a 12″x12″ square size. The 9″x9″ VAT’s are normally found in older buildings because they were manufactured earlier than the 12″x12″ VAT’s; however, floor tile sizes and resilient floor covering applications vary greatly since many buildings have been re-tiled several times.

In order to determine if a resilient floor covering is in poor condition look for sections or tiles which are cracked or peeling to the extent that they are crumbled. Floor coverings in poor condition can often be found near doorways or loading/staging areas where the floor has sustained a lot of stress and traffic. If the floor covering is in poor condition, collect a small representative sample and seal it in a transparent, sample bag. Hand pressure should be applied to determine if the material can be crumbled, pulverized, or reduced to powder. If it can, the material is considered friable. Resilient floor covering that will be or has been sanded, ground or abraded is subject to the Asbestos NESHAP.

Asphalt Roofing Products

Asbestos-containing roofing felts have been widely used in “built-up” roofs. Built-up roofing was used on flat surfaces and consists of alternating layers of roofing felt and asphalt. The roofing felt consists of asbestos paper saturated and coated with asphalt. Asphalt-asbestos roofing products made from roofing felt coated with asphalt were reportedly used on residential structures for only a short time (1971-1974).

To determine if an asphalt roofing product is covered by the Asbestos NESHAP, examine the RACM to spot any areas where the material is in poor condition and friable.

If possible, sample areas where fibers can be seen protruding from the matrix of the asphalt. The sample should be sealed into a transparent, reclosable sample bag and hand pressure applied to see if the sample can be crumbled, pulverized, or reduced to powder.

CATEGORY II non-friable ACM

Asbestos Cement Pipe and Sheet Products

Asbestos-cement (A-C) pipe has been widely used for water and sewer mains and occasionally used as electrical conduits, drainage pipe, and vent pipes. A-C sheet, manufactured in flat or corrugated panels and shingles (transite board), has been used primarily for roofing and siding, but also for cooling tower fill sheets, canal bulkheads, laboratory tables, and electrical switching gear panels. If these ACM are crumbled, pulverized or reduced to a powder, they are friable and thus covered by the Asbestos NESHAP. Broken edges of these material typically are friable. The fractured surface should be rubbed to see if it produces powder.

If Category II non-friable ACM has not crumbled, been pulverized or reduced to powder and will not become so during the course of demolition/renovation operations, it is considered non-friable and therefore is not subject to Asbestos NESHAP. However, if during the demolition or renovation activity it €becomes crumbled, pulverized or reduced to powder, it is covered by the Asbestos NESHAP.

Source:

http://www.epa.gov/region4/air/asbestos/asbmatl.htm

EXAMPLES OF ASBESTOS CONTAINING MATERIALS

(This is not an exhaustive list)

A

Asbestos cement storm drain pipes

Asbestos cement water pipes (usually underground)

Air-conditioning ducts: exterior or interior acoustic and thermal insulation

Asbestos-containing laminates (e.g. formica) used where heat resistance is
required, e.g. ships

Arc shields in lift motor rooms or large electrical cabinets

Asbestos-based plastics products – as electrical insulates and acid-resistant
compositions or aircraft seat

Asbestos-containing pegboard

Asbestos felts

Asbestos ceiling tiles

Asbestos marine board (e.g. marinate)

Asbestos cement conduit

Asbestos mattresses used for covering hot equipment in power stations

Asbestos cement electrical fuse boards

Asbestos paper used variously for insulation, filtering and production of fire
resistant laminates

Asbestos cement external roofs and walls

Asbestos Cement in the use of form work when pouring concrete

Asbestos roof tiles

Asbestos cement internal flues and downpipes

Asbestos textiles

Asbestos textile gussets in air-conditioning ducting systems

Asbestos cement moulded products such as gutters, ridge cappings, gas meter
covers, cable troughs and covers

Asbestos yarn

Asbestos cement pieces for packing spaces between floor joists and piers

Autoclave / steriliser insulation

Asbestos cement render, plaster, mortar and coursework

Asbestos cement sheet

Asbestos cement sheet behind ceramic tiles

Asbestos cement sheet internal over exhaust canopies such as ovens, fume
cupboards, etc.

Asbestos cement (underground) pits, as used for traffic control wiring,
telecommunications cabling, etc

Asbestos cement sheet internal walls and ceilings

Asbestos cement sheet underlays for vinyl

B

Bitumen-based water proofing such as malthoid, typically on roofs and floors but
also in brickwork

Bituminous adhesives and sealants

Boiler gaskets

Boiler insulation, slabs and wet mix

Brake disc pads

Brake linings

C

Compressed asbestos fibres (CAF) used in brakes and gaskets for plant and
automobiles

Cable penetration insulation bags (typically Telecom)

Calorifier insulation

Car body filters (not common)

Caulking compounds, sealant and adhesives

Cement render

Chrysotile wicks in kerosene heaters

Clutch faces

Compressed asbestos cement panels for flooring, typically verandas, bathrooms
and steps for demountable buildings

G

GalbestosTM roofing materials (decorative coating on metal roof for sound
proofing)

Gaskets – chemicals, refineries

Gaskets – general

Gauze mats in laboratories / chemical refineries

Gloves – asbestos

D

Door seals on ovens

E

Electric heat banks – block insulation

Electric hot water services – normally not asbestos but some millboard could be
present

Electric light fittings, high wattage, insulation around fitting (and
bituminised)

Electrical switchboards – see Pitch-based

Exhausts on vehicles

F

Fire-resistant plaster board, typically on ships

Fire-retardant material on steel work supporting reactors on columns in
refineries in the chemical industry

Flexible hoses

Floor vinyl tiles

Floor vinyl sheets

Fuse blankets and ceramic fuses in switchboards

Filler in acetylene gas cylinders

Fire-rated wall rendering containing asbestos with mortar

Filters – beverage; wine filtration

Fire curtains

Fire door insulation

Fire blankets

H

Hairdryers – insulation around heating elements

Header (manifold) insulation

I

Insulation blocks

Insulation in electric reheat units for air-conditioner systems

L

Laboratory bench tops

Laboratory fume cupboard panels

Laboratory ovens – wall insulation

Lagged exhaust pipes on emergency power generators

Lagging in penetrations in fireproof walls

Lifts shafts – asbestos cement panels lining the shaft at the opening of each
floor, and asbestos packing around penetrations

Limpet asbestos spray insulation

Locomotives – steam; lagging on boilers, steam lines, steam dome and gaskets

M

Mastics

Millboard between heating unit and wall

Millboard lining of switchboxes

Mortar

P

Packing materials for gauges, valves, etc., can be square packing, rope or loose
fibre

Packing material on window anchorage points in high rise buildings

Paint, typically industrial epoxy paints

Penetrations through concrete slabs in high rise buildings

Pipe insulation including moulded sections, water-mix type, rope braid and sheet

Pitch-based (e.g. zelemite, ausbestos, lebah) electrical switchboard

Plaster and plaster cornice adhesives

R

Refractory linings

Refractory tiles

Rubber articles – extent of usage unknown

S

Sealant between floor slab and wall, usually in boiler rooms, risers or lift
shafts

Sealant or mastik on windows

Sealants and mastics in airconditioning ducting joints

Spackle or plasterboard wall jointing compounds

Sprayed insulation – acoustic wall and ceiling

Sprayed insulation – beams and ceiling slabs

Sprayed insulation – fire retardant sprayed on nut internally, for bolts holding
external building wall panels

Stoves – old domestic type; wall insulation

T

Tape and rope – lagging and jointing

Tapered ends of pipe lagging, where lagging is not necessarily asbestos

Tilux sheeting in place of ceramic tiles in bathrooms

Trailing cable under lift cabins

Trains – country – guards vans – millboard between heater and wall

Trains – Harris cars – sprayed asbestos between steel shell and laminex

V

Valve, pump, etc. insulation

W

Welding rods

Woven asbestos cable sheath