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Corrugated cement asbestos roofingWorld Guide to Asbestos Building Material Regulations, Bans, Rules & Laws
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urrent & historic asbestos regulations & laws around the world

InspectAPedia tolerates no conflicts of interest. We have no relationship with advertisers, products, or services discussed at this website.

Asbestos Bans, Rules, Regulations Guide: this article describes current asbestos exposure & handling regulations and lists the history of asbestos law and regulations for most countries.

We include a list of countries where asbestos containing materials or products (ACM) are banned in various forms. We provide a summary of OSHA regulations for asbestos containing building materials, including assumed asbestos containing building materials (roofing, flooring, insulation, drywall, etc), suspected asbestos containing materials, and assumed asbestos containing materials.

We address the handling of asbestos containing building materials, including the permissible exposure limits for asbestos particles or fibers in buildings (Asbestos PELs), ACM (asbestos containing materials), PACM (presumed asbestos containing materials), SACM (suspect asbestos containing materials), and ACRM (asbestos containing roofing materials).



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Asbestos Containing Materials: Regulations, Bans, Exposure Limits

Asbestos containing acoustic ceiling tilesIn the U.S. and other countries, using the U.S. EPA guidelines, if either TEM or PLM analysis yields a result that the asbestos-suspect material contains greater than 1 percent asbestos, then the material must be considered ACM - "Asbestos-Containing-Material" and thus would merit appropriate protective measures depending on the material's friability, condition and location. - U.S. EPA, "Asbestos Frequently Asked Questions" cited in the REFERENCES section of this article.

Really? In the U.S. OSHA regulations and letters clarifying them also state that items or materials that do not contain >1% asbestos are covered to at least some extent by the Construction Asbestos Standard.

That is, in the workplace, OSHA 29 CFR 1926.1101 would apply even if neither asbestos permissible exposure limit (PEL) is exceeded 1. The standard contains numerous work practice requirements and prohibitions which apply, regardless of the exposure levels.

However, only two of the requirements and three of the prohibitions must be observed in the case of work activities involving installed construction materials that do not contain >1% asbestos. Details from OSHA are given later in this article.

That same US EPA reference and many others also remark that

Asbestos that is in good condition and left undisturbed is unlikely to present a health risk. The risks from asbestos occur when it is damaged or disturbed where asbestos fibers become airborne and can be inhaled. Managing asbestos in place and maintaining it in good repair is often the best approach.

Article Contents

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

History & Dates of Asbestos Containing Material Bans & Regulations & Related Occupational Safety Regulatory History

Australian, New Zealand, & Japan Regulation of Asbestos Containing Products

According to the Government of South Australia SafeWork SA,

According to Australian contractor Bill Bradley, referring to Fibro asbestos-cement roofing, "Only cement sheet products made before 1987 contain the deadly stuff.  In NSW, for example, the use of it was discontinued in cement sheets by 1982, in corrugated sheets by 1984 and in all other products by 1986. Products containing it have been totally banned in Australia since 2004."

In Japan asbestos production peaked in 1974 but did not significantly drop before 1990. - citation needed beyond Wikipedia

New Zealand banned the import of amphibole asbestos in 1984, and banned chrysotile asbestos in 2002

Complete List of Countries that Ban or Regulate the Use or Production of Asbestos

List of Countries Banning All Asbestos Use & Production as of 2005

List of Countries Banning Asbestos Use but Permitting Small Production or Trade in ACM

List of Countries that Ratified the 1986 ILO 162 Rules on Asbestos Safety in the Workplace

Definition of & Handling Rules for Suspect Asbestos Containing Materials (SACM) & Presumed Asbestos Containing Materials (PACM)

The term suspect ACM or SACM (Suspected Asbestos Containing Material) does not appear in either of the OSHA standards. The term, however, has long been used by the asbestos industry to refer to any building material that is suspected of being asbestos-containing (based on appearance, usage, age of building, etc.), but has not been proven conclusively to be ACM (asbestos containing material) (based on sampling and analysis, documentation, building records, etc).

For OSHA’s purposes, suspect material would include any material (including TSI, surfacing, and flooring) that a building owner suspects of containing asbestos and is found in a building constructed after 1980, or any material (excepting TSI, surfacing, and flooring) found in a building constructed prior to 1981. See:

Other typical suspect building materials would include ceiling tiles, asbestos-cement products (Transite®), and joint compound. The exercise of due diligence (as noted in the OSHA asbestos standards) requires that, where a building owner knows or should have known that materials other than PACM (presumed asbestos containing material) are asbestos-containing, these materials must be treated as ACM until proven otherwise.

This makes sense especially for building products for which a non-asbestos-containing-form was not ever produced, or was not produced during certain years. It is on this basis that we assert that it is possible to identify some asbestos-containing materials with confidence, even before any asbestos lab tests.

For examples of PACM (presumed asbestos containing materials), see:

A building constructed prior to 1981, therefore, could contain both PACM and suspect ACM. Newer buildings (constructed after 1980) would contain only suspect ACM.

Asbestos regulations for Ontario are published under the Occupational Health and Safety Act and are in Ontario Regulation 278/05 and provide a clearly-written and comprehensive guide to cleaning up and disposing of asbestos containing materials in or on buildings.

What is the Permissible Exposure Limit (PELs) for Asbestos in or at Buildings?

Photograph of asbestos pipe insulation in poor conditionBeginning in 1986 OSHA set a permissible exposure limit (PEL) of 0.2 fibers per cubic centimeter (f/cc) of air over an 8-hour time-weighted average exposure period. OSHA also set an action level of 0.1 f/cc of asbestos for an 8-hour TWA average, and (the highest permitted short term asbestos fiber exposure) 1.0 f/cc "excursion limit" for a 30-minute time period.

Thanks to reader Thomas Sukeforth for pointing out a 1994 summary of changes made to the OSHA Asbestos Construction standard and for suggesting a discussion of PACM (below).

The time-weighted average (TWA) permissible exposure limit has been reduced to 0.1 fibers per cubic centimeter. The Excursion Limit remains at 1.0 fibers per cubic centimeter averaged over 30 minutes. Both of these values are considered PELs. (permissible exposure limits).

There is no established
action level in the new asbestos exposure standard because the sampling and analytical method is not reliable below the time-weighted average limit of 0.1 fibers per cubic centimeter.

Definition of & Handling Rules for Presumed Asbestos Containing Material (PACM)

Presumed Asbestos Containing Material (PACM) as OSHA defines it refers to thermal insulation and surfacing materials prior to 1980 but within the regulation they also mention that flooring (tile & sheet) and roofing materials shall also be deemed as asbestos containing unless sampled and shown otherwise.

For presumed asbestos-containing materials, there are two courses of action (under OSHA's standards):

  1. Rebut or disprove the Presumed Asbestos Containing Material (PACM )designation for a particular material or environment being addressed
  2. Treat the PACM as Asbestos Containing Material (ACM) and follow the OSHA requirements for protecting worker and building occupant safety and health

According to CIH Kindley,

In both the OSHA Construction Asbestos Standard (29 CFR 1926.1101) and the General Industry Asbestos Standard (29 CFR 1910.1001) PACM is defined as thermal system insulation (TSI) and surfacing material found in a building constructed no later than 1980.

TSI is the material applied to pipes, fittings (joints, "Ts", elbows, valves, etc.), boilers, breechings, tanks, ducts or other structural components, generally to prevent heat loss or gain. Surfacing material refers to materials sprayed, troweled-on or otherwise applied to surfaces generally for acoustical, fireproofing, or other purposes.

Examples of surfacing materials include decorative finishes on ceilings and walls, fireproofing on structural members, and acoustical plasters. OSHA requires that building owners identify PACM in their buildings and treat the PACM as asbestos-containing materials (ACM) until the materials are proven not to contain asbestos.

Occurrence of Asbestos in Common Building Materials

For our complete guide to recognizing asbestos-containing materials in buildings see the individual asbestos-containing products described at ASBESTOS IDENTIFICATION IN BUILDINGS. Two other articles provide longer lists of asbestos-containing products used on or in buildings and in other products as well:

Following are references to or examples of some common asbestos-containing building materials discussed in that article series.

Asbestos in Joint Compound, Bondex example:

Bondex manufactured a joint compound that was commonly used on construction sites during the installation of drywall. From 1961 to 1977, Bondex joint compound contained asbestos. - retrieved 15 June 2015 original source: www.courts.mo.gov/file.jsp?id=54841 [LOIS J. WAGNER, ROBIN G. ) WAGNER and WENDE L. WAGNER, ) Individually and as Wrongful Death ) Beneficiaries of ROBERT WAGNER, ) ) Appellant-Respondent, ) ) WD72474 (Consolidated with WD72482 v. ) and WD72619) ) BONDEX INTERNATIONAL, INC., and ) Opinion filed: June 19, 2012 SIMPSON TIMBER COMPANY, ) ) Respondent-Appellant, ) ) CONWED CORPORATION, ) ) Defendant. ) APPEAL FROM THE CIRCUIT COURT OF CLAY COUNTY, MISSOURI The Honorable Kathryn E. Davis, Judge Before Division Four: Lisa White Hardwick, Chief Judge, Presiding, Joseph M. Ellis, Judge and Victor C. Howard, Judge]

Asbestos in Flooring Materials

Everlast Vinyl Asbestos Floor Tile (C) D Friedman D Grudzinski

Although 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.

Asbestos in Roofing Materials

Cement asbestos roof shingles

The risk of high levels of airborne asbestos from cementious roofing products is probably very low unless the workers are using power equipment like sanders and saws on these substances.

See  ASBESTOS ROOF MATERIALS.

According to NRCA, the National Roofing Contractors' Association, their studies up to February 1992 had not found a single roofing job at which these limits were exceeded, and NRCA reported that in some cases no fiber release was detected.

But it appears that the association may have been referring only to asphalt-based roofing materials, not jobs involving the demolition of other ACRM such as cement-asbestos roof shingles (or "asbestos roof tiles" as some consumers refer to them) which might produce different statistics.

Asbestos in Heating Systems

Asbestos heating pipe insulation in poor condition

The use of corrugated asbestos paper and asbestos cement on heating and some water pipes and pipe elbows has been widely recognized. Because in poor condition this material is more friable than cementious or vinyl-based building products it has received plenty of attention.

See  these key articles on heating system and plumbing system asbestos insulation products and locations:

Asbestos in Siding Materials

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

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.

Disposal of Asbestos Containing Flooring, Roofing or Siding Materials

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.

Detailed advice & regulations citations for disposing of asbestos containing materials or presumed asbestos containing materials are
at ASBESTOS DISPOSAL REGULATIONS

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

Asbestos Regulations in the E.U.

Quoting from EU regulations and data

Asbestos - Training and permits are mandatory

There are common EU rules determining provisions concerning asbestos. The provisions apply to all activities where there is a risk that an employee will be exposed to the dust which contains asbestos.

To work with asbestos, you need a special permit from the Swedish Work Environment Authority, you also need training as well as a medical examination certificate.

A company that conducts demolition work on materials that contain asbestos without permission from the Swedish Work Environment Authority risks having to pay a penalty of SEK 50,000. Questions regarding products that contain asbestos are covered by the Chemicals Agency’s regulations.

This is where you can read the entire provision on asbestos www.av.se/dokument/inenglish/legislations/eng0601.pdf

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

Three Options for Disposal of Asbestos-Containing Floor Tiles

The 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:

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

Reader Question:

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:

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

Vinyl 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.

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

EPA Regulation of handling of friable asbestos materials created during demolition: Definition of action percentage level for friable asbestos.

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

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

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.

OSHA Clarifications on Asbestos Handling & Exposure Regulations in Schools depending on the percentage of asbestos in a tested sample

Source: "Questions concerning the OSHA requirements covering the renovation of school buildings that have hard plaster containing some asbestos, but the amount is not more than 1%", [PDF], OSHA Clarification, (2003) cited at REFERENCES

Question 1: Are the OSHA letters dated April 17, 1997; August 7, 1998; and August 13, 1999 correct? They all say that items that do not contain >1% asbestos are covered to at least some extent by the Construction Asbestos Standard.

Reply: Yes, those letters are correct although some requirements of the Construction Asbestos Standard, 29 CFR 1926.1101 were not addressed. 29 CFR 1926.1101 would apply even if neither asbestos permissible exposure limit (PEL) is exceeded1.

The standard contains numerous work practice requirements and prohibitions which apply, regardless of the exposure levels. However, only two of the requirements and three of the prohibitions must be observed in the case of work activities involving installed construction materials that do not contain >1% asbestos.

Those work practice requirements and prohibitions that must be observed regardless of the exposure levels and of the percentage of asbestos in the installed construction materials are:

29 CFR 1926.1101(g)(1)(ii), which requires: wet methods, or wetting agents, to control employee exposures during asbestos handling, mixing, removal, cutting, application, and cleanup, except where employers demonstrate that the use of wet methods is infeasible due to, for example, the creation of electrical hazards, equipment malfunction, and, in roofing, except as provided in paragraph (g)(8)(ii)2 of this section;

29 CFR 1926.1101(g)(1)(iii), which requires: prompt clean-up and disposal of wastes and debris contaminated with asbestos in leak-tight containers except in roofing operations, where the procedures specified in paragraph (g)(8)(ii)3 of this section apply;

29 CFR 1926.1101(g)(3)(i), which prohibits: high-speed abrasive disc saws that are not equipped with point-of-cut ventilator or enclosures with HEPA filtered exhaust air;

29 CFR 1926.1101(g)(3)(ii), which prohibits: compressed air used to remove asbestos, or materials containing asbestos, unless the compressed air is used in conjunction with an enclosed ventilation system designed to capture the dust cloud created by the compressed air; and

29 CFR 1926.1101(g)(3)(iv), which prohibits: employee rotation as a means of reducing employee exposure to asbestos.

There are also some other provisions that apply to work activities involving installed construction materials even where the material does not contain >1% asbestos. However, if neither asbestos PEL is exceeded, only the following few provisions apply:

29 CFR 1926.1101(f)(2)(i), the provision for establishing that neither asbestos PEL is exceeded:

Each employer who has a workplace or work operation covered by this standard shall ensure that a "competent person" conducts an exposure assessment immediately before or at the initiation of the operation to ascertain expected exposures during that operation or workplace. The assessment must be completed in time to comply with requirements which are triggered by exposure data or the lack of a "negative exposure assessment," and to provide information necessary to assure that all control systems planned are appropriate for that operation and will work properly;

29 CFR 1926.1101(f)(6)(i), a provision covering the observation of monitoring:

The employer shall provide affected employees and their designated representatives an opportunity to observe any monitoring of employee exposure to asbestos conducted in accordance with this section;

29 CFR 1926.1101(f)(5)(i), a provision covering employee notification of monitoring results:

The employer shall notify affected employees of the monitoring results that represent that employee's exposure as soon as possible following receipt of monitoring results;

29 CFR 1926.1101(f)(5)(ii), another provision covering employee notification of monitoring results:

he employer shall notify affected employees of the results of monitoring representing the employee's exposure in writing either individually or by posting at a centrally located place that is accessible to affected employees; and

29 CFR 1926.1101(n)(2)(i)-(iii), a set of provisions covering recordkeeping for measurements of exposures to airborne asbestos.

There are numerous additional provisions of the standard that apply to work activities involving installed construction materials even where the material does not contain >1% asbestos if at least one of the asbestos PELs is exceeded.

...


Continue reading at ASBESTOS REGULATION UPDATE includes more recent asbestos regulations for the U.S. and other countries. That article clarifies just what products are currently permitted or not permitted to contain asbestos. - or select a topic from closely-related articles below, or see our complete INDEX to RELATED ARTICLES below.

Or see ASBESTOS DISPOSAL REGULATIONS

EPA ASBESTOS MATERIALS BANS CLARIFICATION - 2003

EPA ASBESTOS MATERIAL REGULATIONS - 1999 Update

EPA ASBESTOS MATERIAL BANS -1989

ASBESTOS MATERIAL REGULATIONS, OSHA

ASBESTOS REGULATIONS for ONTARIO CANADA - Ontario Regulation 278/05

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ASBESTOS MATERIAL REGULATIONS at InspectApedia.com - online encyclopedia of building & environmental inspection, testing, diagnosis, repair, & problem prevention advice.

INDEX to RELATED ARTICLES: ARTICLE INDEX to ASBESTOS HAZARDS

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