Wednesday, October 10, 2012

Difference Between Allied Trades and Operations & Maintenance.

Asbestos Handler Initial Class at IUOE
Asbestos Handler Initial Class at IUOE (Photo credit: angelogarciaiii)
Recently, we got a call from a client expressing an interest in asbestos training.  The client being a tradesperson (electrician, carpenter, plumber, etc.) was confused on which training and certificate they should get, either the Allied Trades or the Operations and Maintenance (O&M) Certificate.  Because this client was confused we figured others may be too.  So how do you determine which training/certificate is appropriate?  Well first we need to answer the question will the tradespeople disturb asbestos containing materials (ACM)?  What do we mean by disturb, well let's go the New York State Department of Labor Industrial Code Rule 56 (ICR56) to get the definition of disturb.  "Disturbance means any activities that disrupt the matrix of ACM or Presumed ACM (PACM), or generate debris, visible emissions, or airborne asbestos fibers from ACM or PACM.  This includes moving of friable asbestos containing material from one place to another."
So deciding whether the tradesperson will be disturbing ACM or PACM is the most important question.  The reason for this is that the primary difference between the two titles is that the O&M certificate allows disturbance (for repairs/maintenance that will fit into one glovebag or one tent, that does not exceed 10 square feer or 25 linear feet) and the Allied Trades certificate does not allow disturbance (see Guidance Document page 14, Q/A# 50).
Realize, one of critical points on the disturbance definition is the last sentence "This includes moving of friable asbestos containing material from one place to another."  So, if you have a tradesperson that enters a crawlspace where the dust is contaminated with asbestos, the tradesperson is considered to be disturbing asbestos.  Since the tradesperson is disturbing asbestos he must have an O&M certificate to enter the crawlspace.  This would also meet the training requirements for Class III workers (which are workers who are likely to disturb ACM/PACM in quantities that will fit into a maximum of a 60" waste bag) under the Occupational Safety and Health Administration (OSHA) 1926.1101 asbestos in the construction industry standard.
In addition, the meaning of the Allied Trades Certificate was originally for the purpose of tradesmen who worked with the asbestos abatement contractor to provide the contractor with water for the showers, shut down electric and provide temporary power, and construct the decontamination facility and isolation barriers, to name a few.  The purpose of this trainiing is to train the workers on the dangers of asbestos, respiratory protection, and how enter and exit the work area (another words how to decontaminate themselves in the shower).  The training does not include any abatement or disturbance training because they are not supposed to disturb asbestos.  This certificate/training requirement is not recognized by OSHA under 1926.1101.
For example, the recent violations issued to SMG at Nassau Coliseum included violations for not providing asbestos training for Class III work.  In addition, in a Newsday article on Wednesday, October 7, 2009, Carle Place School District admitted to erring in not hiring a specially licensed contractor to run conduit in their crawlspace.  That license (an asbestos abatement license) is required of the contractor/company performing the work and all the contractor's workers (working in the crawlspace) are required to have a minimum of the O&M certificate.
We hope this will clarify the difference between these two New York State Certificates and help tradespeople determine which certificate/training they should request. 
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1 comment:

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