Asbestos heating pipe insulation in poor condition Asbestos Building Material Disposal Procedures
Advice & regulation for the disposal of asbestos floor tile, roofing, insulation, or other materials
     


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Asbestos disposal advice, guidelines, & regulations: this article describes the regulations for disposal of various types of asbestos-containing materials commonly found on or in buildings such as asbestos cement roofing & sididing, asbestos floor tiles, asbestos insulation found on heating pipes, boilers, furnaces, or plumbing, and cement asbestos sheet products.

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How to Dispose of Asbestos Containing Materials: asbestos floor tiles, asbestos sheet flooring, asbestos insulation, asbestos roofing etc.

Disposal of Asbestos Containing Flooring, Roofing or Siding Materials

Everlast Vinyl Asbestos Floor Tile (C) D Friedman D GrudzinskiFor handling and disposal guidance concerning old roofing material, siding material, vinyl-asbestos floor tiles, asbestos pipe or boiler or furnace insulation, or other asbestos containing or suspect asbestos containing materials at a job-site, contact the US EPA, your state Department of Environmental Protection/Conservation, or your local building and health departments.

[Click to enlarge any image]

At OSHA Asbestos Roof/Siding Regulations we discuss (briefly) the regulation of demolition & removal of cement asbestos or other asbestos containing roofing and siding materials.

At ASBESTOS ROOF MATERIALS we discuss environmental issues surrounding disposal of fiber cement roofing products that contain asbestos.

Asbestos regulations for Ontario are published under the Occupational Health and Safety Act and are in Ontario Regulation 278/05 also found at http://www.e-laws.gov.on.ca/html/regs/english/elaws_regs_050278_e.htm

How to Dispose of Vinyl-Asbestos or Asphalt Asbestos-Containing Floor Tiles

Red brick pattern sheet flooring (C) InspectAPedia.comAlthough not defined strictly as "PACM", both OSHA standards also require asphalt and vinyl flooring material installed no later than 1980 be "considered" and "treated" as asbestos-containing, until the building owner proves the flooring is not ACM.

This includes not only the flooring material, but associated mastics and backings.

See ASBESTOS FLOOR TILE IDENTIFICATION for details about vinyl-asbestos flooring including floor tiles and sheet flooring.

But this does not meant that asphatl asbestos floor tile, vinyl asbestos floor tile, or asbestos-conatining sheet flooring are necessarily hazardous nor friable materials. The hazard from asbestos floor tiles or sheet flooring, as we explain below, depends on the condition of the flooring and what is going to be done to it.

Three Options for Disposal of Asbestos-Containing Floor Tiles

Presumed asbestos containing floor tile (C) InspectApediaThe following advice for disposal of vinyl-asbestos or asphalt asbestos floor tiles is adapted from the Minnesota State Department of Health:

State health departments typically recommend that all asbestos debris and waste is disposed of in a landfill that accepts asbestos-containing waste. There are three methods of disposing of asbestos waste and they are:

  • Contact local waste hauler for special pick-up.
  • Contact licensed abatement contractor for pick-up and disposal.
  • Dispose of waste yourself.

Watch out: if you are disposing of asbestos-containing waste yourself, you should contact your local state health department for detailed instructions. For example, while a landfill may accept asbestos-containing-material (ACM) (as the material may be buried and thence non-hazardous, special requirements may apply to protect workers and buildings from asbestos dust during collection, bagging, removal, and transportation.

- Ref: MN DPH

US EPA Guidance on Disposal of Asbestos Floor Tiles

Kentile vinyl asbestos floor tile (C) InspectApediaReader Question: safe disposal of "new" old stock Kentile vinyl asbestos floor tiles

I recently bought some tile at a garage sale. It wasn’t until I was loading it and turned it over that I read the word asbestos. So now I have this tile. Is this tile safe to install? I’ve attached pics of the box and tile. It is Kentile Vinyl Asbestos Tile 12x12 sheets in Tan Portilla (716) color. The box also has 1K298C on it.

I just wanted to know if these should be disposed of or if they are safe. Thank you. - R.R. 9/6/2013

Reply: intact VAT is not normally friable - EPA guidance for disposal is here

The bottom line, in my opinion, is that you can dispose of intact Kentile or other vinyl-asbestos floor tiles as ordinary construction debris.

Kentile vinyl asbestos floor tile (C) InspectApediaI base this view on a review of detailed US EPA guidance on asbestos-containing floor tile disposal. The EPA explains that the concern for asbestos hazards focuses on *friable* asbestos - intact vinyl asbestos floor tiles are not friable, but old, installed flooring might *become* friable as a result of aging, exposure to environmental conditions, or damage during demolition of an existing, installed floor. It seems to me that such is *not* the case when you are disposing of "new" old stock vinyl asbestos flooring such as you described.

Below I quote from a letter from the US EPA to Richard A. Griffin, 11 June, 1987 in which the EPA explains this position. Quoting in excerpt form from a letter titled:

Re: Vinyl Asbestos Floor Tile Removal Prior to building Demolition.

EPA: Disposal of Intact Vinyl-Asbestos Floor Tiles

Kentile vinyl asbestos floor tile (C) InspectApediaVinyl Asbestos Floor Tile Removal Prior to building Demolition

Thank you for your May 1, 1987, letter to Charles Loomis of this office asking if vinyl asbestos floor tile should be removed prior to building demolition. Asbestos removal during building demolition is regulated by the asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP). 40 CFR Part 61, Subpart M. I have discussed your inquiry with the Stationary Source Compliance Division of the United States Environmental Protection Agency (U.S. EPA) in Washington, DC. The answer that follows is a coordinated U.S. EPA response.

Photo at left illustrates a common pattern of Kentile vinyl asbestos flooring.

The demolition and renovation standards in the asbestos NESHAP apply only to friable asbestos materials, and the waste disposal standards for demolition and renovation operations apply only to friable asbestos waste and asbestos waste from control devices. Friable asbestos includes material containing more than one percent asbestos by weight that can be crumbled, pulverized or reduced to powder when dry by hand pressure.

However, the scope of the regulation is not limited just to asbestos containing material that is friable prior to demolition. If vinyl asbestos floor tile becomes friable during demolition or associated waste disposal, then the asbestos NESHAP applies from the point where the tile becomes friable.

Vinyl asbestos floor tile that may become friable during demolition or waste disposal should be removed prior to demolition to preclude the possibility of releasing asbestos fibers and of violating the asbestos NESHAP. Again, the asbestos NESHAP would apply to the removed tile if it becomes friable, from the onset of friability through deposition at an acceptable waste disposal site. Since the liability extends through proper deposition, it would advisable to deposit all vinyl asbestos floor tile that can become friable at an acceptable site.

Region V has delegated its authority to implement and enforce the asbestos NESHAP to all six states in the region. By copy of this letter, I am distributing this response to the State asbestos NESHAP coordinators in Region V. If you have any questions on this matter, you may contact me at (312) 886-6793.

Sincerely yours, Bruce A. Varner NESHAP Coordinator Air Compliance Branch (5AC-26)

cc: Otto Klein Illinois Environmental Protection Agency

References
  • U.S. EPA, "Floor Tile Removal Prior to Demolition", Retrieved 9/7/2013, original source: http://www.epa.gov/oecaadix/pdf/adi-asbestos-c31.pdf

EPA Regulation of handling of firable asbestos materials created during demolition

If friable asbestos materials are created in the demolition process (using imploding), the owner and operator of the demolition operation would be responsible for complying with the notification, wetting, and disposal requirements of 40 CFR Part 61, Subpart M.

The regulations define "friable asbestos" material as any material that contains more than l percent
asbestos by weight that hand pressure can crumble, pulverize, or reduce to powder when dry. 40 CFR
61.141.

These regulations are designed to prevent the escape of asbestos fibers into the air. Therefore, if, at
any point during a renovation or demolition operation, friable asbestos materials are created from nonfriable
forms, this additional friable material becomes subject to the regulations from the time of
creation. The owner or operator must follow the notification, wetting and disposal requirements of 40
CFR Part 61, Subpart M in regard to this newly created material.

References

  • U.S. EPA, "Creation of Friable Tiles During Implosion", retrieved 9/7/2013, original source: http://www.epa.gov/oecaadix/pdf/adi-asbestos-c34.pdf, excerpted above, in a US EPA letter to Richard Miller, dated 4 December 1987, the EPA addressed friable asbestos that might be created during demolition of a building that contained vinyl asbestos floor tiles.

    Significant is that the title to the letter includes the following comment

    EPA believes that the demo. tech. of imploding a bldg doesnt render floor tile friable; therfore, NESHAP reg don't apply.

    While the body of the letter appears to contradict that comment by including the following text:

    This technique is unusual and could result in the creation of friable asbestos from the nonfriable vinyl floor tile. EPA is not in a position to determine whether friable asbestos will be created from the vinyl floor tile during the unique demolition process you plan to utilize. However, should friable asbestos materials be created in the demolition process, the owner and operator of the demolition operation would be responsible for complying with the notification, wetting, and disposal requirements of 40 CFR Part 61, Subpart M. The owner or operator would be subject to Federal enforcement procedures of Section 113 of the Clean Air Act, 42 U.S.C. 7413, for any violations of the Asbestos NESHAP which arise during the operation.

  • U.S. EPA, "Deconstruction - Building Disassembly and Material Salvage: The Riverdale Case Study", Prepared for: US Environmental Protection Agency The Urban and Economic Development Division By: NAHB Research Center, Inc. Upper Marlboro, Maryland Assistance Agreement Number: CX 8244809 June 1997, retrieved 9/7/2013, original source: http://www.epa.gov/wastes/conserve/imr/cdm/pubs/river.pdf

Government Advice on Disposal of Asbestos Containing Flooring, Roofing or Siding Materials in buildings

Asbestos in Roofing & Siding Materials

New and old fiber cement and asbestos cement shingles side by side (C) Daniel Friedman Cement asbestos roof shingles

The most common siding material containing asbestos fibers was cement-asbestos shingle siding popular from about 1940 to 1970.

See ASBESTOS CEMENT SIDING.

It is possible that other siding materials such as asphalt building siding may contain asbestos fibers as well, particularly if that material was produced during the same years that asbestos fibers appear in asphalt roof shingles.

For handling and disposal guidance concerning old roofing material, siding material, vinyl-asbestos floor tiles, asbestos pipe or boiler or furnace insulation, or other asbestos containing or suspect asbestos containing materials at a job-site, contact the US EPA, your state Department of Environmental Protection/Conservation, or your local building and health departments.

The US EPA points out in Adequately Wet Guidance, EPA340/1-90-019 that asbestos-containing floor tiles are considered non-friable materials but the materials can become friable with age or by grinding, sanding, demolition, etc. Also see ASBESTOS REMOVAL, Wetting Guidelines

Non-friable miscellaneous ACM includes floor tiles, asbestos cement sheet (transite board), siding shingles, asphalt roofing shingles, laboratory bench tops and even chalkboards. These materials may become friable with age, and under harsh conditions. Category I non-friable ACM must be carefully examined to determine if the material is in poor condition, that is, if the binding material is losing its integrity, exhibited by peeling, cracking or crumbling; and is also friable. When Category I non-friable ACM has become friable it is subject to the NESHAP.

If Category I or II ACM is sanded, ground, cut or abraded it is also covered by the NESHAP. Category II non-friable ACM which is damaged to the extent that it has or will become crumbled, pulverized or reduced to powder due to demolition/ renovation activities, is subject to the Asbestos NESHAP.

Miscellaneous materials are wetted in manners similar to those used to wet other categories of RACM. Coverings are saturated with a wetting agent before removal and the asbestos-containing portions fully penetrated with the agent prior to, during and after their removal, while stored in the removal area, and while being placed into disposal containers. Miscellaneous materials that don't absorb water readily (e.g., asbestos-concrete products, and floor tiles) are only required to have wetted surfaces. A misting sprayer may be used to diminish airborne asbestos fiber levels.

Asbestos Containing Materials: Regulations, Bans, Exposure Limits

Asbestos containing acoustic ceiling tiles

Photo above left: presumed-asbestos-containing material (PACM) acoustic ceiling tiles found above a suspended ceiling.

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