Sunday, July 28, 2013

New? NYS Education Department Asbestos Clearance Air Sampling Requirements

On July 12, 2013, New York State Education Department (NYSED) released a table regarding the various asbestos clearance air sampling requirements.  The table compares the Environmental Protection Agency's (EPA) Asbestos Hazard Emergency Response Act (AHERA) regulation to the New York State Department of Labor's (NYSDOL) Industrial Code Rule 56 (ICR56) and the table has a center column designating what we assume to be NYSED's requirement for schools.  It is interesting to note that New York State Department of Health (NYSDOH) noted these items were a problem in 2009, when they were doing AHERA audits for EPA.  Visit Future Environment Design's Resource Page for the Asbestos Clearance Table Requirements from NYSED.

What's wrong with this picture?
There is some very interesting information on this table.  An example of this is the requirement of 5 inside samples for asbestos projects that range from three (3) linear feet (LF) or square feet (SF) to < 160 SF or < 260 LF.  These samples are analyzed using the phase contrast microscope methodology (National Institute of Occupational Safety and Health (NIOSH) method 7400).   We wonder how many schools are actually doing five (5) samples inside the work area for small projects (> 10 SF or 25 LF but < 160 SF or 260 LF) or the minor projects (> 3 LF or SF to < 10 SF or 25 LF)?  

In actuality to comply with both AHERA and ICR56 for small projects (> 10 SF or 25 LF but < 160 SF or 260 LF), a school should also run a minimum of three (3) outside samples.  So, for a small project in a school in NYS the project air sampling technician should run five (5) samples inside each work area, three (3) samples outside each work area, and two (2) blanks.  This current table, with the adjustment mentioned above, provides Asbestos Air Sample Technicians with the total number of samples, based on the size of the project, necessary to clear an asbestos abatement work area located in a school that will comply with AHERA, NYSED, & ICR56.  
Enhanced by Zemanta

No comments: