asbestos awareness

www.spin-safety.orgCreated by Felicia Thomason

ASBESTOS AWARENESS ASBESTOS AWARENESS TRAININGTRAINING

FORFORHAULERS, LANDFILL WORKERS, AND

MAINTENANCE EMPLOYEES

Created by Felicia Thomason

CHAPTER 1 - ASBESTOS AND ITS HEALTH EFFECTS

CHAPTER 2 - TRANSPORTATION, DISPOSAL, AND WORKER PROTECTION

REGULATIONS

CHAPTER 3 - DOCUMENTATION AND NOTIFICATION

CHAPTER 4 - PERSONAL PROTECTIVE EQUIPMENT

CHAPTER 5 - HAULING FRIABLE ASBESTOS WASTE

CHAPTER 6 - PROPER WORK PRACTICES FOR LANDFILL DISPOSAL

CHAPTER 7 - VEHICLE AND BUILDING MAINTENANCE

CHAPTER 8 - SPILL RESPONSE FOR FRIABLE ASBESTOS

DEFINITIONS

APPENDICES

CONTENTS

ASBESTOS AND ITS HEALTH EFFECTS

In this chapter you will learn:• What asbestos is• How asbestos is used in construction and motor vehicles• Why asbestos may cause health problems such as lung disease

In the upcoming chapters you will learn procedures used to prevent overexposure to asbestos. By following these procedures, you will comply with WMI policies. These policies are designed to comply with regulations created by government agencies for the handling of asbestos materials.

These regulations are designed to protect workers from the dangers of asbestos.

CHAPTER 1

Physical Characteristics of Asbestos

Asbestos is a naturally-occurring mineral. Even though it is a mineral, it breaks apart into fibers. It was often mixed with binders or other materials when used in construction. For example, some breaks and clutches contain asbestos in a binder. Asbestos is sometimes released during the braking operation and may be present inside the brake mechanism. Asbestos had thousands of other uses in construction and industry.

It is not possible to tell just by looking at a material weather it contains asbestos. Tests must be performed to determine the asbestos content. In the absence of test results, certain materials are presumed to contain asbestos (PACM). PACM includes thermal system insulation, sprayed and troweled on surfacing materials, and asphalt and vinyl flooring materials, found in buildings built prior to 1981.


Friable and nonfriable AsbestosAsbestos can be friable or nonfriable You can easily crush friable asbestos with hand pressure. Friable materials release small fibers as they crumble. Nonfriable materials normally release fibers only if cut, broken, damaged, or worked with power tools.

It is the released fibers that have the potential to cause disease.

Types of Asbestos-Containing MaterialAsbestos-containing materials are likely to be present in certain building materials and the debris from their demolition or renovation, certain industrial processes, and certain vehicle maintenance activities. Asbestos-containing materials are categorized as follows:

• Material that contains more than one percent asbestos is Asbestos Containing Material (ACM) and may or may not be friable.

• Thermal system insulation (TSI) and surfacing materials from buildings constructed prior to 1981 are Presumed Asbestos-Containing Material or PACM. PACM can be shown to be free of asbestos through testing and other methods. With respect to employee health and safety, PACM is treated as ACM unless it is shown to contain <1%.

• Regulated Asbestos-Containing Material or RACM is friable ACM present in regulated quantities.Normally, nonfriable ACM includes materials such as:

• Asbestos cement pipes• Transite (asbestos cement) boards• Other asbestos cement building materials• Roofing shingles

Hazards and regulatory requirements associated with these materials are generally minimal unless damaged (crushed, sanded, ground, cut, compacted, pulverized, or powdered). Undamaged nonfriable ACM can be handled as construction debris and is not covered in this training manual.

Friable ACMFriable ACM includes materials such as:

• Sprayed-on fireproofing• Thermal pipe insulation and boiler covering• Ceiling tiles• Damaged materials that were originally nonfriable

When friable ACM is removed above certain quantities, it is considered Regulated ACM (RACM). According to the Environmental Protection Agency (EPA), friable ACM becomes RACM when present in quantities greater than:

• Eighty linear meters (260 linear feet) on pipes; or • At least 15 square meters (160 square feet) on other

facility components; or• One cubic meter (35 cubic feet) on components where the

length or area could not be measured

This regulation is covered in 40 CFR Part 61.145.

In addition to the EPA, the Department of Transportation (DOT) and the Occupational Safety and Health Administration (OSHA) also have regulations for handling asbestos. These will be covered in Chapter 2.

Health Problems Related to AsbestosAsbestos fibers have the potential to cause disabling lung diseases and cancer.

Among the diseases linked to friable asbestos exposure are:• Asbestosis - a respiratory disease• Lung cancer• Mesothelioma - a deadly cancer of the lining of the

chest or abdominal cavity

How Does Asbestos Exposure Occur?Exposure to friable asbestos occurs when you inhale or swallow fibers. The fibers can become embedded in the tissues of the lungs and digestive system. The fibers cause scarring in the lungs, which makes breathing progressively more difficult.

You can inhale or swallow fibers from dust released by contaminated clothing or skin or when you consume food or drink in an area where asbestos is in the air.

Heavy or long term exposures to friable asbestos increase the likelihood of contracting a related disease. The less inhaled or ingested, the lower the risk of developing disease.

SMOKING INCREASES THE RISKCigarette smokers who are exposed to asbestos have a greatly increased risk of developing lung cancer compared to those who do not smoke. The harmful effects of smoking and asbestos exposure combine. The risk of lung cancer for a cigarette smoker not exposed to asbestos is nearly eleven times that of a nonsmoker; the risk of lung cancer for a cigarette smoker exposed to asbestos is over fifty-three times greater than that of a nonsmoker.

Quitting cigarette smoking dramatically reduces the excess lung cancer risk. Information on the effects of smoking appears in the Appendices.

TIME IS A FACTORAsbestos-related diseases develop slowly. They may take twenty years or more to show up. Mesothelioma may take forty years or more to develop.

The Role of WorkersYou play an important role in preventing exposure to asbestos fibers when you:

• Load, transport, unload, and dispose of friable asbestos materials

• Perform vehicle maintenance activities such as brake, clutch, and gasket replacement or repair

• Perform housekeeping functions in buildings with ACM or PACM

These activities have the potential to expose you to airborne asbestos fibers.

In order to prevent exposure, you must use the safe asbestos-handling practices described in this manual while hauling, landfilling, maintaining vehicles, and maintaining buildings with known or presumed asbestos containing materials.

CHAPTER 2

TRANSPORTATION, DISPOSAL, AND WORKER PROTECTION REGULATIONS

Federal Regulatory AgenciesSeveral federal agencies have established standards and regulations dealing with asbestos. Among these are the Environmental Protection Agency (EPA), the Occupational Safety and Health Administration (OSHA), and the Department of Transportation (DOT).

NESHAPs The EPA regulates asbestos management through the National Emission Standard for Hazardous Air Pollutants (NESHAPs) 40 CFR, Part 61, subpart M. According to this regulation, anyone planning to remove a regulated quantity (260 linear feet, 160 square feet, or 35 cubic feet) of friable asbestos (RACM) from a structure must notify the EPA at least ten days prior to removal.

NESHAPs continuedAccording to NESHAPs, when collecting asbestos-containing waste material for transport, generators must:

• Ensure that there are no visible emissions to the outside air during collection or packaging

• Wet the material thoroughly• Seal all material in leak-tight containers while it is wet• Label the containers with specified EPA or OSHA labels that include the appropriate

hazard warning, the name of the waste generator, and where the waste was generated.• Alternatively, process the material into nonfriable forms

When loading and unloading ACM, haulers must • Ensure that there are no visible emissions to the outside air• Properly mark the vehicle

During disposal, haulers and landfill operators must:• Eliminate visible emissions• Use barriers, warning signs, and fences to keep the general public out • Cover asbestos-containing waste within twenty four hours, or at the end of the operating

day• Maintain waste shipment records

Coverings can include six inches of compacted nonasbestos materials or an effective resinous or petroleum-based dust-suppressing agent. Check with your Group Environmental Manager for state requirements before using dust-suppressing agents. Do not apply used site or customer generated oil.


OSHA Standards

OSHA has two standards to regulate asbestos materials. The OSHA standard for controlling exposure to asbestos fibers in the construction industry is 29 CFR 1926.1101. Regulations for the disposal, storage, demolition, repair, installation, containment and emergency cleanup of asbestos is provided in that section.

A similar OSHA standard for industries involved in the manufacture and use of asbestos, including brake and clutch repair, and housekeeping in buildings with ACM or PACM is 29 CFR 1910.1001.

Medical monitoring, employee training, exposure monitoring assessments, respiratory and personal protection, record keeping, regulated work areas, engineering controls and work practices, hygiene, hazard communication, and housekeeping are key safety elements of these standards.


Air Monitoring

The OSHA standards establish a permissible exposure limit (PEL) for exposure to airborne asbestos fibers. Employers must ensure that no employee is exposed to more than 0.1 fibers of asbestos per cubic centimeter of air (0.1 f/cc) over the course of a shift. A personal monitoring device measures fiber levels.

Short- Term Excursion LimitOSHA also has a short-term exposure limit (STEL) for airborne asbestos. The STEL is also called an excursion limit. It limits exposure to one fiber per cubic centimeter in a thirty-minute period.

If the air sampled in an area contains asbestos at levels higher than the PEL or the excursion limit in a typical eight hour work day, then (1) workers must wear respiratory protection, (2) receive annual medical exams and training, (3) the area must be periodically monitored, and (4) special work practices and engineering controls must be followed.

PERMISSIBLE EXPOSURE LEVEL EXCURSION LIMIT

0.1 f / ccover 8 hours

1.0 f / ccover 30 min.

Exposure Assessments and MonitoringA qualified person must perform initial exposure assessments before work operations begin. He or she must obtain representative samples for both an eight hour shift and a thirty minute period. If samples show that exposure levels were not exceeded, a negative exposure assessment can be made. OSHA requires periodic monitoring where the PEL is expected to be exceeded.

Monitoring must also be performed whenever the process, control equipment, personnel, or work practices change. Affected employees or their representatives must be permitted to observe all monitoring activities. Employers must inform employees of monitoring results.

Worker ProtectionOSHA requires employers to provide respirators, protective clothing, and additional worker protection when exposure is above the PEL or the excursion limit. Employer must:

• Post warning signs to identify and restrict access to regulated areas• Communicate the presence of asbestos by labeling containers and products

containing asbestos (including containers of contaminated clothing and equipment)

• Provide a training program for workers on the health effects of asbestos, proper work practices, use of respirators, medical surveillance program, emergency and clean-up procedures and other aspects of the standard

• Provide an initial and an annual medical exam specific to asbestos

Medical Monitoring

OSHA requires employers to offer an annual medical exam to workers who are exposed above the PEL or excursion limit or who wear respirators at work.

The exam includes a medical and work history and a comprehensive exam. A test evaluates the employee’s lung function.

The exam determines weather an employee is physically able to tolerate wearing a respirator. It also determines whether any health problems may be aggravated by asbestos exposure.

The written opinion issued by the physician should address only asbestos related issues.

Employees receive a copy of the results of their medical exam. These results will determine whether an employee can perform the assigned work and whether any limitations exist on wearing respirators or other protective equipment.

Department of Transportation Requirements

The Department of Transportation (DOT) regulates the transportation of hazardous materials under 49 CFR 100-199. These rules establish marking, labeling, and performance requirements for hazardous materials packages that are transported. They also establish ways to identify the contents of vehicles hauling hazardous materials by using shipping papers and vehicle markings. DOT classifies friable asbestos as a class 9 (miscellaneous) hazardous material.

DOT requires the following: Mark individual packages (bags or drums) of friable asbestos with

Asbestos, NA 2212, RQ and label with class 9. Label roll-off, compactor boxes and other containers

carrying asbestos with class 9 on opposite sides near

the closure of the container and with 2212 in an orange

rectangular or white diamond on all four sides. NOTE:

Do not compact asbestos waste. Correctly fill out shipping papers (bills of lading and

waste shipment records).


CHAPTER THREE

DOCUMENTATION AND NOTIFICATION

WMI Policy on Management of Asbestos WasteThe accounts of customers generating asbestos waste are managed through the WMI Special Waste Program (ED-111 and Special Waste Guidance) typically as a Type B special waste stream.

WMI’s policy for management of asbestos waste complies with federal regulations as described in this chapter. Check with your Group Environmental Manager for applicable state, provincial, and local regulations.

The policy also provides for worker safety and protection of the environment. WMI’s policy outlines responsibilities for haulers (Chapter 5), landfill workers (Chapter 6), maintenance employees (Chapter 7). It also clarifies responsibilities for notification and cleanup of spills (Chapter 8).

Initial PaperworkBefore hauling can begin, you must identify and document the nature and the quantity of asbestos-containing wastes according to the WMI Special Waste Program. Next, a supervisor designates a disposal site and executes formal contracts to provide hauling services to the customer. These steps must follow the guidelines of the Special Waste Directives (ED-111) and the Special Waste Guidance. WMI policy requires the customer to:

• Provide information about the quantity and type of asbestos to be hauled

• Apply for hauling and disposal services • Adhere to any conditions imposed in the contract (see the current version

of the Special Waste Guidance Document)The paperwork is important for recordkeeping and for communicating the contents of the load. It lets those who come into contact with the waste know what precautions they need to take.

Necessary forms include:• WMI Generator’s Special Waste Profile Sheet (Appendix A)• WMI Service Agreement (Appendix B)• Waste shipment record (WSR) (Appendix C) or combination of waste

shipment record/bill of lading (see your technical manager for local requirements)

Only after you complete all forms can service begin.

DOCUMENT ASBESTOS WASTESA waste shipment record (WSR) or a DOT shipping paper (bill of lading) must accompany each shipment of friable asbestos waste (see your technical manager for local requirements). The disposal site must receive copies of the documents. Appendix D provides an example of a completed shipping paper.

The shipper / generator is responsible for properly completing the shipping papers. However, you must ensure that they do this correctly.

The shipping paper must list typical shipping information including:Shipping name: Asbestos

Hazard class: 9

Identification Number: NA 2212

Packing Group: III

Additional Description: RQ

Shipping papers must also include the total quantity of material being shipped and a certification by the shipper or generator that the material is packaged in accordance with DOT regulations.

Retain copies of the WSR and the bill of lading (as well as special waste paper work) for your files. Do not destroy records.


PERSONAL PROTECTIVE EQUIPMENT

Asbestos fibers are not harmful unless you ingest or inhale them. A respirator provides a barrier to airborne fibers in order to protect your mouth and lungs. Protective clothing prevents the spread of asbestos contamination. You must wear respirators and protective clothing whenever you handle or disturb asbestos-containing materials in ways that can release fibers.

Respiratory ProtectionYou must receive a physical exam to be sure you are physically capable of wearing a respirator. Your respirator must fit properly in order for it to protect you. You must undergo regular fit tests to be sure a leakproof seal is formed between the respirator’s facepiece and your skin. You must also receive annual training in the use and maintenance of the respirator.

CHAPTER FOUR

Respiratory RequirementsHaulers must wear respirators:

• When inspecting loads for transport• During unloading operations at the landfill• When cleaning up spills

Landfill workers must wear respirators during unloading operations and excavating.

Mechanics must wear respirators for break and clutch repair:• While engineering and work practice controls are being installed

• When it is not possible to use engineering and work practice controls

• When airborne asbestos levels are above the PEL or excursion limit

Building maintenance personnel must wear respirators when bulk sampling building materials for asbestos identification.

Types of RespiratorsThere are many types of respirators. The selected respirator must protect you from the potential exposure of your assigned task.

A half-mask, negative pressure, air-purifying respirator equipped with high-efficiency (HEPA) filters is the minimum protection required for asbestos exposure. This respirator is acceptable for most hauling and disposal tasks at WMI where you may encounter low levels of airborne asbestos fibers.

You may need full-facepiece respirators with an air supply source for higher exposures, such as the cleanup of large spills or friable asbestos.

Over 0.1f / cc

per 8 hours

REQUIRES

Limitations of Respirators Half- and full-face filter-type respirators:

• Do not supply oxygen• Must fit properly to provide protection • Must be cleaned and maintained properly to provide protection

For exposure levels above 1 fiber per cubic centimeter (the excursion limit) you must use full -face or air supplied respirators. For exposures above 5 fibers per cubic centimeters, you must use the air-supplied respirators.

Air-supplied respirators:• Are limited by the purity and integrity of their air supply systems • Must fit properly to provide protection

Selecting RespiratorsSelected respirators must be:

• Approved by the National Institute for Occupational Safety and Health (NIOSH)• Equipped with HEPA filters (air- purifying respirators)• Designed to provide the protection factor needed for the potential exposure

level

OSHA does not allow the use of disposable respirators for asbestos work.

Wearing, Maintaining, and Storing RespiratorsYou should inspect your respirator before each use to be sure all parts are present and in good condition. Review specific cleaning and maintenance instructions supplied by the manufacturer. In general, after each respirator use you should:

• Wash it with soap and water and let it air dry, wet wipe it with a soapy rag and rinse it, or clean it with disposable wipes

• Store it in a clean, resealable plastic storage bag

Never allow the inside of the filter cartridge to become wet. They do not provide adequate protection after getting wet.

Testing the Facepiece-To-Face SealIf you wear a negative pressure half-mask or full-facepiece respirator, you will undergo two types of qualitative fit tests to ensure that a tight seal is achieved between the respirator facepiece and your face and that no asbestos fibers can leak into the respirator.

These testes are:• The irritant smoke test (repeated every six months)• Positive and negative pressure checks (repeated each time you wear your respirator)

For other respirators and exposure conditions, you will perform quantitative fit tests.

FIELD TESTING OF THE FACEPIECE-TO-FACE SEALTo be sure that a respirator fits properly in the actual work situation, the seal

must be tested prior to each entry into the work site. Use the negative and positive pressure field tests recommended by the manufacturer to test the seal before entering the work site and anytime that you want the reassurance while wearing the respirator that the seal is intact.

Some additional factors can prevent a tight facepiece-to-face seal:• Beards and facial hair (prohibited by law for respirator wearers)• Facial scars• Changes in weight • Gum or tobacco chewing while wearing a respirator


Selection and Use of Protective ClothingWear protective clothing whenever you handle or disturb asbestos-containing materials in ways that could release fibers.

Protective clothing consists of disposable coveralls or similar whole body clothing, hood or hair bonnet, gloves, foot covering, and face shields, vented goggles, or other suitable eye protection. You must also wear the appropriate respirator.

When worn properly, protective clothing will prevent your work uniform, hair, hands, and feet from becoming contaminated and spreading contamination to other locations.


HAULING FRIABLE ASBESTOS WASTE

Requirements for WMI HaulersBefore transporting RACM, use the current version of the Special Waste Guidance Document to

identify the requirements that apply to asbestos. These are company requirements.

Hauling divisions must also comply with federal, state, provincial, and local regulations when transporting asbestos waste.

Before transporting RACM, WMI hauling divisions must receive written approval from the Group Vice-President of Environmental Management.

CHAPTER FIVE

WMI Hauling ProceduresFollow these practices for preparing friable asbestos waste containers:

• Use boxes designed for this purpose when they are available• Never compact waste containers• Handle nonfriable materials that have been made friable as friable

asbestos• Line and tape containers to prevent contamination• Provide closed or open top containers in good condition to the site.

(Closed boxes are preferred for ease of handling and safety.)• Cover open-top roll-off boxes with a nonporous tarp • Label container with signs as required by EPA during loading and

unloading• Label and mark containers as required by DOT (see next page)

Shipper/ Customer Responsibilities for Packaging ACM

Customers must handle and package friable, asbestos-containing material for transport as follows:• Wet ACM thoroughly or modify it with a bonding agent, coating, or binder before

bagging.• Bag ACM in two leak-tight, impermeable bags six ml thick.

(Goosenecking is preferred.)• Inspect to be sure containers are intact.• Place bagged asbestos in a roll-off box lined with plastic taped

over the sides of the open top, whenever this is practical• Label each bag, drum, or container with the EPA or OSHA danger

label, the name and address of the generator, the DOT description Asbestos, NA 2212, RQ, and the DOT category class 9.

• Mark roll-offs, compactor boxes, or other containers with the number 2212 in an orange rectangle or white diamond on all four container sides.

Display class 9 label on two opposite sides near the container’s closure.• Mark small packages, bags or containers (less than 640 cubic feet, 18 cubic meters or

23 cubic yards) with the number 2212, class 9 in a diamond shaped label, and Asbestos , RQ next to the label.

• Mark all four sides of freight and bulk roll-off containers larger than 640 cubic feet (188 cubic meters or 23 cubic yards) with the number 2212 in a white diamond or an orange rectangle. Also mark these containers with the generator’s name and address.

Inspect the Load Before PickupWhen you inspect loads, follow these guidelines:

• Wear a respirator to inspect and cover the load.• Inspect covered roll-off boxes through inspection plates (do not open the

door).• Check the load for:

• Visible dust • Integrity of the containers• Proper wetting of waste(to the extent possible, without opening containers or bags) • Double bags• Tight sealing of containers or bags• EPA or OSHA labels on bags or containers• DOT marks and labels

• Reject the load if any friable asbestos is exposed. The entire load must be properly packaged.

• Alert the dispatcher and the customer/ generator if the load shows visible dust or debris. Do not pick up the load.

• Ensure normally nonfriable materials that have been made friable are modified by the bonding agents or are safely packaged.

• Be certain that the shipping paper is filled out correctly and signed by all required parties.

Transporting the LoadYou may identify construction debris that is contaminated with asbestos but not labeled as asbestos. If you believe asbestos is in construction waste, contact your dispatcher immediately so the material can be identified. Do not disturb the waste material until it has been identified and properly characterized by the generator and determined to be acceptable to WMI.

If the load passes inspection, cover open top boxes with a nonporous tarp without walking on the load or compacting containers in any way. Mark and label the roll-off / compactor box container as described on page 5-3. Remove (Danger Asbestos Dust Hazard, Cancer and Lung Disease Hazard, Authorized Personnel Only) signs from the container before transporting. Then, transport directly to the landfill. Communicate by radio to the landfill that an asbestos load is coming. (Some landfills require twenty-four hours notice.)

When unloading friable asbestos waste at the landfill:• Wear a respirator and all required personal protective equipment• Place a NESHAPs sign (Danger Asbestos Dust Hazard, Cancer &

Lung Disease Hazard, Authorized Personnel Only) on container. Remove it when the container is empty• Dump the load carefully to avoid breaking the container• Dump the load with the cab of the truck headed upwind if possible• Do not back over waste material

Cleaning Containers

If there is evidence of asbestos in a container after a load is dumped, clean the container with water. Wear protective clothing and a respirator while cleaning. Use a mist spray to wet surfaces. High pressure water can carry asbestos into the air. Manage your cleaning water as required by local regulations.Note: Under federal regulations, you cannot let liquids enter an active landfill, so you cannot wash waste containers at the landfill.


PROPER WORK PRACTICES FOR LANDFILL DISPOSAL

Recordkeeping and Initial InspectionThe gate clerk or designated person reviews the DOT shipping paper (WSR or combination WSR/bill of lading). The clerk enters the name and address of the generator, the date, the quantity, the name and address of the transporter, and the disposal location coordinates in a receipt log.

Make certain that the Generator’s Special Waste Profile has been completed and that this and the service agreement have been approved.

The gate clerk or designated person inspects asbestos waste loads to be sure that:

• Waste is wetted (without opening bags or containers)• Waste is double-bagged or in leak-tight containers• Bags and containers are tightly sealed and in good condition • Bags and containers are correctly labeled • There is no loose debris

After the clerk inspects the load at the gate, he or she tells the driver where to take the load and alerts the landfill personnel of its presence.

CHAPTER SIX

Improperly Packaged LoadsIf gate inspection determines that unbagged or improperly packaged asbestos waste is present, it is sometimes preferable and potentially less dangerous to wet down the load, dispose of it properly, and document the incident rather than send the load back on the road. Alert landfill management to the arrival of these loads. This so they can complete the Special Waste Decision process if it has not already been completed. Landfill management will also notify the transporter and generator of the improperly packaged shipment.

Landfill Personal HygieneIn order to avoid potential exposure to asbestos, landfill spotters and heavy equipment operators must:

• Wear respirators when covering or unloading asbestos waste• Wear respirators and full protective clothing if unloading

asbestos waste by hand

Landfill Work PracticesAfter the waste is accepted, it is placed in a trench. Trenches are:

• Cut at the base of the working face (but not into the liner systems) or, preferably, in an area separate from the working face

• Cut perpendicularly to the prevailing wind if possible• Not within ten feet of the perimeter or the side slopes of any fill area or within ten feet of the base of any final cover, except in an asbestos monofill.

When asbestos waste is unloaded in the landfill:• Post the NESHAPs sign on the vehicle

(see page 2-2)• Assign a spotter to watch for spillage. The spotter

should stand upwind if possible and must wear full respiratory protection

• Cover asbestos waste by day’s end with six inches of nonasbestos- containing material or an approved, alternate daily cover

• Avoid compacting the waste until it is properly covered

Accepting and Managing Asbestos WastesSite management must:

• Post required signs at the entrance and around the perimeter of the facility• Ensure that all special waste paperwork is in order• Verify receipt of a WSR or bill of lading for each asbestos load• Develop a receipt log with:

• The name, address, and telephone number of the generator• The date of receipt• The volume in cubic yards• The name and address of the transporter• The disposal location coordinates

• Attempt to reconcile quantity discrepancies, if any, with the generator • Report discrepancies within fifteen days to the local, state, or regional EPA

office if they cannot be reconciled. If the offices responsible for regulating the generator and the disposal site are different submit a report to each office. Include a copy of the WSR with the report

• Report loads with improperly enclosed or uncovered waste or any asbestos material not in sealed, leak-tight containers to the local, state, or regional EPA by the next working day. Include a copy of the WSR with the report

• Send a copy of the completed WSR to the generator within thirty days.

Disturbing Landfilled Asbestos WasteLandfill management must notify the federal or state EPA administrator in writing forty-five days before excavating covered asbestos waste. Notify the administrator of date changes ten days before excavation begins. Include start and completion dates, the reason for disturbing the waste, emission control procedures to be used, and locations of temporary and final disposal sites.

• Retain WSRs and related documentation (including reports) for a minimum of two years

• Retain disposal location records until landfill closure

If a site closes, management must:• Submit asbestos disposal location and quantity records to the

federal or state EPA administrator• Notify the federal or state agency administrator forty-five days prior

to excavating asbestos-containing waste (for example, during construction or gas recovery at the landfill). Use the same procedures as for active sites

• Document that the land was used for asbestos - containing waste disposal, that the location and quantity records have been filed, and that the site is subject to 40 CFR 61, subpart M.


VEHICLE AND BUILDING MAINTENANCE

Vehicle MaintenanceYou may encounter asbestos-containing material during inspection, disassembly, repair, and assembly of brakes and clutches, and replacement of vehicle gaskets. Manufacturers must certify that new WMI vehicles have asbestos-free brake and clutch linings. Aftermarket suppliers should also verify that they provide asbestos-free products. Verification may not exist for certain vehicles or parts, such as acquisition vehicles. If this is the case, assume that break, clutch pads and gaskets contain asbestos and handle them accordingly.

CHAPTER SEVEN


Break and Clutch Repair

New OSHA regulations regarding break and clutch repair are effective July 10, 1995. These regulations require special handling procedures for break and clutch repair to prevent release of asbestos fibers. Required procedures include the following:

• Do not use compressed air or aerosol cans to clean any break or clutch assembly• Clean break and clutch assemblies using an approved cleaning method such as HEPA

vacuuming, or a wet washing system like the Safety Kleen system• Do not sand, grind, or drill any lining material• Use only approved methods for packaging and disposal of asbestos wastes


Building Maintenance

Some buildings occupied by WMI may contain asbestos. Facility managers must:• Have a Building Materials Survey conducted by a qualified industrial hygienist (or equivalent)

to identify ACM or PACM (see Building Material Survey form in appendix). Maintain all records of the presence, location, and quantity of asbestos

• Restrict access to thermal system insulation or surfacing ACM/PACM, where possible, and notify employees who may have access to the materials of their presence

• Train housekeeping and maintenance personnel on location, hazards and proper handling of ACM and PACM. Employeeswhose work requires direct contact that may disturb ACM or PACM must receive additional training. Training requirements vary depending on the type of asbestos-related work performed.


SPILL RESPONSE FOR FRIABLE ASBESTOS

Spill Reporting Procedure If a spill of friable asbestos above the reportable quantity (one pound or more) occurs, report the spill to the company dispatcher. The dispatcher must notify the appropriate company personnel for notification of the National Response Center (NRC).

Spills A spill of friable asbestos must also be

reported to the State Emergency Response Commission (SERC),& the Local Emergency Planning Committee (LEPC) if more than one pound of asbestos is released into

the environment.

CHAPTER EIGHT

Cleanup ActionsIf a spill occurs, workers should:

• Get upwind of the asbestos waste• Secure the area and keep others away until the

cleanup is complete • Notify the supervisor or dispatcher• Don the required respirator and protective

clothing • Summon the water truck, if at the landfill• Wet down the waste with a water mist ( a heavy

stream of water may agitate and release asbestos fibers)

• Make use of the spill kit or other equipment on hand.

Workers should put on an approved asbestos respirator with cartridges in place, disposable coveralls, shoe covers, gloves, & safety glasses or goggles before cleaning up spills. Fit test the respirator to be sure it will protect you.

Cleanup Actions Continued• Scoop up the waste into a properly marked and labeled bag or a

closed container (overpacking)• Wash any contaminated equipment or machinery• Dispose of gloves, coveralls, and shoe covers in a tightly-sealed six-

ml plastic bag as you would for any friable asbestos-containing material

• Wash all other personal protective equipment with soap and water

• Wash the respirator, refit it with new filter cartridges, and place it in a resealable, airtight container for future use• Wet down contaminated work clothes & uniforms & seal them in a six ml plastic bag• Inform the laundry service that clothing is

contaminated with asbestos in a letter accompanying it (Appendix E)


Large Spills of Asbestos-Containing materials

If a spill requires more than one spill kit:• Contact the supervisor immediately• Stay or assign someone to stay in the vicinity of

the spill to control access until it is cleaned up• Initiate the Emergency Response Plan (ERP).

Specially trained employees will come to the location & carry out the spill cleanup

• Notify the appropriate authorities as specified in the ERP

• Provide information to the supervisor as specified in the ERP

SUMMARYFederal, state, & local regulations, & WMI policies direct the transportation & disposal of friable asbestos.

Asbestos transport & disposal is carefully regulated because excessive exposure to asbestos fibers is hazardous to your health.

Using proper work practices when hauling & disposing of friable materials, wearing correctly fitted respirators and protective clothing, & knowing how to respond in an emergency lowers the risk of exposure to friable asbestos waste.

All people involved in hauling, landfilling, & those who perform certain vehicle maintenance & building housekeeping activities must know about the dangers of asbestos. To do this, proper signs & markings must always be in place, & all required paperwork must be completed.

If you follow these procedures, you will minimize or eliminate your exposure to asbestos fibers. Asbestos fibers will not be released into the air if you handle asbestos correctly. You will also do your part to protect yourself & the environment we live in.


APPENDICES

A Generator’s Waste Material Profile Sheet

B Service Agreement

C Waste Shipment Record(WSR)

D Shipping Papers

E Laundry Letter

F Smoking Cessation

G NESHAPs sign for loading and unloading vehicles

H Building Materials Survey


APPENDIX F

SMOKING CESSATION PROGRAM INFORMATION FOR ASBESTOS

The following organizations provide smoking cessation information and program materials.1. The National Cancer Institute operates toll-free Cancer Information Service (CIS) with

trained personnel to help you. Call 1-800-4-CANCER to reach the CIS office serving your area, or write: Office of Cancer Communications, National Cancer Institute, National Institutes of Health, Building 31, Room 10A24, Bethesda, Maryland 20892.

2. American Cancer Society, 3340 Peachtree Road, NE, Atlanta, Georgia 30062, (404)320-3333.-The American Cancer Society (acs) is a voluntary organization composed of 58 divisions and 3,100 local units. Through “The Great American Smokeout” in November, the annual Cancer Crusade in April, and numerous educational materials, ACS helps people learn more about the health hazards of smoking and become successful ex-smokers.


Smoking Cessation continued

3. American Heart Association, 7320 Greenville Avenue, Dallas, Texas 75231, (214)750-5300.-The American Heart Association (AHA) is a voluntary organization with 13,000 members (physicians, scientists, and layperson) in 55 state and regional groups. AHA produces a variety of publications and audiovisual materials about the effects of smoking on the heart. AHA also has developed a guidebook for incorporating a weight-control component into smoking cessation programs.

4. American Lung Association, 1740 Broadway, New York, New York 10019, (212)245-8000- A voluntary organization of 7,500 members (physicians, nurses, and laypersons), the American Lung Association (ALA) conducts numerous public information programs about the health effect of smoking. ALA has fifty-nine state and eighty-five local units. The organization actively supports legislation and information campaigns for smokers who want to quit, for example, through “Freedom From Smoking,” a self-help smoking cessation program.


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5. Office on Smoking and Health, US Department of Health and Human Services, 5600 Fishers Lane, Park Building, Room 110, Rockville, Maryland 20857.- The Off Office on Smoking and Health (OSH) is the Department of the Health and Human Services’ lead agency in smoking control. OSH has sponsored distribution of publications on smoking-related topics, such as free flyers on relapse after initial quitting, helping a friend or family member quit smoking, the healthhazards of smoking, and the effects of parental smoking on teenagers.

In Hawaii, on Oahu call 524-1234 (call collect from neighboring islands).

Spanish speaking staff members are available during the daytime hours to callers from the following areas: California, Florida, Georgia, Illinois, New Jersey (area code 210), New York, and Texas. Consult your local telephone for listings of local chapters.

asbestos awareness

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