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Demolition debris from asbestos cement shingles (C) Daniel FriedmanOSHA Regulations Regarding Asbestos Building Siding or Roofing Materials

  • POST a QUESTION or COMMENT about rules, regulations, laws governing the demolition, removal, or repair of cement asbestos siding or roofing

Asbestos siding or roofing handling regulations:

Here we provide OSHA and other asbestos regulations regarding handling of asbestos-containing-materials (ACM) such as asbestos cement siding and asbestos cement roofing or asbestos-containing shingles.

This document series assists building buyers, owners or inspectors who need to identify asbestos materials (or probable-asbestos) in buildings by simple visual inspection. In the website sections listed below, we provide photographs and descriptive text of asbestos insulation and other asbestos-containing products to permit identification of definite, probable, or possible asbestos materials in buildings.

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OSHA Regulations for roof demolition where asbestos containing roofing materials ACRM are present

Corrugated cement asbestos roofingThese OSHA regulations may also pertain to wall siding demolition where asbestos containing materials are present.

Sources for OSHA regulations address removal and disposition of asbestos cement materials in some circumstances are given here. What is the allowable exposure to debris or fibers from cement asbestos building materials?

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

We note that the association would 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.

OSHA asbestos regulations

Question: reader warns about amateur cement-asbestos shingle siding or roofing removal

To all those reading this comment feed, know that most of what these people are saying is incorrect.

If you are a contractor know that 29 CFR 1926.1101 OSHA asbestos standards apply and you need to remove the material properly.

A dust mask (N95) will not protect you or your employees. Contact an asbestos abatement company to remove the asbestos and DO NOT ATTEMPT TO REMOVE THE MATERIAL YOURSELF. Your just asking for mesothelioma (lung cancer) if you do. - Inspector 5/11/12

Reply: be careful, understand voluntary asbestos standards, be reasonable

Thanks Inspector.

We agree that there are both health and legal hazards in removing asbestos-containing materials, even cementious ones. In our experience there are often local regulations or ordinances that describe the level of site and dust control required when demolishing cement-asbestos materials (roof shingles or siding usually) outdoors.

But it's also fair to point out that the standard you cite is "...a non-mandatory appendix to the asbestos standards for construction and for shipyards." Details about asbestos removal and handling regulations including the actual standards and recommendations are discussed in the article above and further quoted just below.

In our OPINION, even non-mandatory standards involving health and safety ought to be followed, though it is reasonable to guess that some adjustments may be needed for the variation in individual cases and environments.

For example, we seriously doubt that a homeowner or even a small contractor is going to set up a tent, containment, negative air, air monitoring and testing, and expert trained supervision simply to pull two nails and replace one cracked asbestos-cement wall shingle with a new fiber-cement shingle that fits into the same space.

CFR 1926.1101 OSHA asbestos standards refers to the U.S. OSHA regulations and standards PART 1926 Safety and Health Regulations for Construction - retrieved 8/10/12, original source: http://www.osha.gov/pls/oshaweb/owasrch.search_form p_doc_type=STANDARDS&p_toc_level=1&p_keyvalue=1926

Within that OSHA standard, 1926 Subpart Z - Toxic and Hazardous Substances contains subsection 1926.1101 - Asbestos which in turn contains quite a few sections and a bit of advice. We quote from the introduction to the standard here

This is a non-mandatory appendix to the asbestos standards for construction and for shipyards. It describes criteria and procedures for erecting and using negative pressure enclosures for Class I Asbestos Work, when NPEs are used as an allowable control method to comply with paragraph (g)(5)(i) of this section.

Many small and variable details are involved in the erection of a negative pressure enclosure. OSHA and most participants in the rulemaking agreed that only the major, more performance oriented criteria should be made mandatory. These criteria are set out in paragraph (g) of this section.

In addition, this appendix includes these mandatory specifications and procedures in its guidelines in order to make this appendix coherent and helpful. The mandatory nature of the criteria which appear in the regulatory text is not changed because they are included in this "non-mandatory" appendix. Similarly, the additional criteria and procedures included as guidelines in the appendix, do not become mandatory because mandatory criteria are also included in these comprehensive guidelines.

In addition, none of the criteria, both mandatory and recommended, are meant to specify or imply the need for use of patented or licensed methods or equipment.

Recommended specifications included in this attachment should not discourage the use of creative alternatives which can be shown to reliably achieve the objectives of negative-pressure enclosures.

Requirements included in this appendix, cover general provisions to be followed in all asbestos jobs, provisions which must be followed for all Class I asbestos jobs, and provisions governing the construction and testing of negative pressure enclosures.

The first category includes the requirement for use of wet methods, HEPA vacuums, and immediate bagging of waste; Class I work must conform to [additional detailed provisions that describe supervision, dust control, air monitoring, worker safety]. - retrieved 8/10/12, original source http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10868

ASBESTOS MATERIAL REGULATIONS and also ASBESTOS REGULATION Update address the handling of asbestos containing building materials, including ACM (asbestos containing materials), PACM (presumed asbestos containing materials), SACM (suspect asbestos containing materials), and ACRM (asbestos containing roofing materials).

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 atReferences or Citations

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.

 

 

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Reader Comments, Questions & Answers About The Article Above

Below you will find questions and answers previously posted on this page at its page bottom reader comment box.

Reader Q&A - also see RECOMMENDED ARTICLES & FAQs

On 2016-03-17 - by (mod) -

That's correct, Dab. You'll need to examine close-up photos, or more likely you'll need to identify the manufacturer's brand and shingle model, then read its specifications.

On 2016-03-17 by dabboussi

I searching for fiberglass roof blue color but I can't know from pictures if it fiberglass or another material

Hope you contact me on my email

Mas.dabboussi@hotmail.com

Question: how to demolish & dispose of an old barn sided with asbestos cement shingles

(Oct 7, 2014) Anonymous said:
How do you dispose of an old barn with this type of asbestos cement siding

Reply:

Anon

Demolition requirements for cement asbestos siding vary by where you live. In some locations a costly and arduous asbestos air monitoring as well as special demolition methods may be required (wetting for example) and the material is disposed-of in a hazmat waste sit. In other communities the material is removed and hauled to a landfill.

Even if your country, state, or province or community does not impose regulations on demolition of a building sided with cement asbestos shingles or having that material on its roof, basic precautions to minimize dust production (choice of removal method for example) and to protect workers should be followed. Since I don't know where in the world you are it doesn't make much sense to outline a program that may not apply.

Have you asked your local government or building department what regulations apply in your area?


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