In our classes we have been watching it and discussing the various issues, here is a list:
- In the video you do not see one person wetting anything down. Wet methods are required by New York City Department of Environmental Protection (NYCDEP), New York State Department of Labor (NYSDOL), the Occupational Safety and Health Administration (OSHA), and the Environmental Protection Agency (EPA). Under EPA regulations not wetting asbestos or dry removal is a criminal violation.
- In the video you do not see a High Efficiency Particulate Air (HEPA) filtered vacuum anywhere. HEPA vacuuming is required by NYCDEP, NYSDOL, & OSHA.
- Workers in the video are hammering what looks like asbestos containing transite panels. These panels are considered non-friable and if intact they are not regulated by EPA. However, that changed as soon as the workers started hammering (crumbling & pulverizing) the materials. These materials are no longer intact and have become regulated asbestos containing materials (RACM). Meaning these materials must be placed in labeled asbestos bags or wrappings and sent to an EPA approved landfill for disposal. In addition, the crumbling & pulverizing of the materials probably means NYCDEP & NYSDOL would require a containment.
- Two workers inside the work area are not wearing suits and respirators, obviously a violation of the PPE requirements for this work.
- Under NYCDEP, NYSDOL, & OSHA materials are required to be bagged or wrapped immediately. Obviously, the hammering of the materials means they were not bagged or wrapped immediately.
- In the video we can see one air sample station in the work area. NYCDEP requires four (4) inside work area samples during the abatement. Since the one sample is located where they were hammering the panel with a crowbar it would be interesting to see the results of that air sample. Though it may be likely it will show nothing since it would depend on which way the wind was blowing.