Future Environment Designs Training Center specializes in asbestos, indoor air quality, industrial hygiene, and occupational safety training programs. We offer New York State asbestos and mold certification courses. We design, develop, and maintain the various indoor air quality, asbestos, and safety programs that are Keeping Your Employees Safe.
The Occupational Safety and Health Administration (OSHA) annually posts the top ten frequently violated standards. The purpose of this posting is to give employers the opportunity to fix these violations before OSHA inspects your project site. When we discuss these with our clients and students we call these violations the low-hanging fruit for OSHA.
OSHA in a sense is providing you with fair warning that during an OSHA inspection these are the first thing they will be looking at. Many of these items can be easily resolved before OSHA arrives, such as respiratory protection, hazard communication, ladders, fall protection training, scaffolding, and powered industrial trucks. Remember these items must be documented and this can be easily done, also.
Future Environment Designs together with SiteDocs can handle the documentation and training requirements for the above safety hazards and have this information easily documented. With SiteDocs this documentation is readily available on multiple devices allowing inspections in the field to be documented, stored, and made available upon request. Future Environment Designs can not only provide your staff the training and documentation required either in-person, virtual, or through e-learning, but we can also create the written programs and inspections required under the various standards. So visit our website and click on Contact to start discussing how we can help you be better prepared for an OSHA inspection.
Mr. Dan Crothers demonstrated the features of the AirBox pumps in our courses. Those who attended the courses were introduced to the equipment, and how it operates. We discussed the various features, advantages, and disadvantages of using this new pump. Two of our clients who attend our courses The LIRO Group and New York Environmental Consultants & Laboratories ended up walking away with an Airbox sampling pump to try in the field. While Mr. Dan Crothers was here he recorded a video discussing asbestos air sampling pumps with Angelo Garcia, III, and what makes this pump a game changer. The video will be shown in our future asbestos classes or you can see it below: If you are interested in more information feel free to contact us.
We attended the Environmental Information Association (EIA) 2022 National Conference and Exhibition in Phoenix, Arizona from March 20, through March 23, 2022. We attended several sessions regarding asbestos where we discussed with some attendees asbestos clearance air sampling and what are the Federal requirements. Based on those discussions we figured it was time to write an article on this topic. To make sure we wrote this article based on general industry practice, versus what we are used to in New York State and New York City, we consulted with Mr. Tom Laubenthal, of TGL Consulting, Inc., and Mr. Dana Brown, of Time's Dark Captains. Since everything else seems to start with the Environmental Protection Agency's (EPA's)Asbestos-Containing Materials in Schools Rule (40 CFR Part 763, Subpart E, known in the industry as the Asbestos Hazard Emergency Response Act (AHERA))why don't we start there? The AHERA regulation remember applies to schools from Kindergarten to 12th grade (K-12), both public and private schools. The requirements are found in two sections of the rule:
Response Actions; §763.90 (i)
Appendix A (to Subpart E) -Interim Transmission Electron Microscopy Analytical Methods - Mandatory and NonMandatory - and Mandatory Section to Determine Completion of Response Actions
For all intents and purposes, these methods serve as the industry standard when final clearance is performed for most asbestos abatement projects, especially when areas are to be re-occupied. We’ll discuss applicability issues as we go.
TEM Analysis
First, let's discuss the requirement for aggressive clearance sampling. In the AHERA regulation, aggressive sampling means floors, ceilings, and walls shall be swept with the exhaust of a minimum one (1) horsepower leaf blower. Some states and specifications may also require the use of fans as described in the non-mandatory section of Appendix A. The non-mandatory section states, that stationary fans shall be placed in locations that will not interfere with the air monitoring equipment. Fan air is directed toward the ceiling. One fan shall be used for every 10,000 cubic feet (CF) of a worksite. This is required in the New York State Department of Labor's Asbestos Regulation Industrial Code Rule 56 (NYSDOL ICR56) and the New York City Department of Environmental Protection Asbestos Regulation Title 15 (NYCDEP Title 15). However, NYSDOL ICR56 also requires one fan per room in addition to the one fan per 10,000 CF.
This is not in the spirit of the AHERA/NYSDOL ICR56/NYCDEP Title 15 requirements for aggressive clearance sampling. Thank you Greg Mance for the photo.
As defined by the AHERA rules, final clearance air sampling can be done by phase contrast microscopy (PCM) methodology for projects less than or equal to 160 square feet (SF) or 260 linear feet (LF) by the National Institute for Occupational Safety and Health (NIOSH)7400 methodology (Issue 3: 14 June 2019 is the current issue). For projects greater than 160 SF or 260 LF clearance shall be done by the AHERAtransmission electron microscopy (TEM) method (requirements at 763.90 (i) (4) and Appendix A).
Graphic courtesy Tom Laubenthal
There are some similarities between the AHERA TEM and NIOSH 7400 methods. For example, the AHERA TEM method (Appendix A) allows for the use of either a 25-millimeter (mm) filter cassette or a 37-mm filter cassette. We haven't used a 37-mm cassette since the industry switched from the old asbestos sampling method NIOSH P&CAM 239 to the NIOSH 7400 method that was formally adopted into AHERA. For sampling, whether it is the AHERA TEM method or the NIOSH 7400 method, we use a 25-mm 3-piece cassette with 50-mm electrically conductive extension cowl cassettes. The two methods require the filter cassette to face 45 degrees downward from the horizontal. The filter material used is mixed cellulose ester (MCE). AHERA TEM methoddoes allow for the use of polycarbonate (PC) filters as well. The PC filters fell out of favor because post-sampling handling was more problematic than the MCE filters. With PC filters, if samples sent to the lab are not handled carefully, the sampled fibers can move significantly from the filter surface. This was widely discussed in the industry in the 1980s. Since then, only MCE filters are used outside of specialty applications.
The filter cassette is to face 45 degrees downward from the horizontal.
Both methods require blanks, however, that is where the similarities end. The AHERA TEM method requires three blanks two field blanks and one laboratory (sealed) blank. While the NIOSH 7400 method requires a minimum of two blanks or 10% of samples collected with a maximum of 10 blanks. How the blanks are handled is different as well. The AHERA TEM method laboratory (sealed) blank is not opened and kept sealed, while the field blanks are opened for 30 seconds at the entrance to each abatement area and one at an ambient area. While the NIOSH 7400 method requires the blanks to be opened at the same time as the other cassettes just prior to sampling and stored with the top covers of the cassettes that are running and remain open for the duration of sampling (here is an interesting difference, in some places the cassettes are stored in the box with the lid closed or, the way we were taught, they are placed in a Ziploc bag that is used to deliver the samples to the laboratory).
A typical box of air sampling cassettes
Another difference is that with the AHERA TEM method we use a 0.45-micron (µm) MCE filter and the NIOSH 7400 method uses a 0.8 µm MCE filter. This refers to the size of the air passages in the filter material. Filter manufacturers will color code or mark the label so that the type of filter within the cassette assembly is known to the user and the laboratory.
TEM filter is 0.45-micron. PCM filter is 0.8-micron.
Let's get to some of the interesting items such as how the samples are taken and how many are required. The AHERA TEM method is straightforward, it requires 5 samples inside the work area and 5 samples outside the work area that represent air entering the abatement site plus the blanks (as mentioned above) for a total of 13 samples. These samples should run from 1 to less than 10 liters per minute (LPM) for a total volume of air greater than 1199 liters or greater (see Table 1 below for the recommended sampling volume range for this method, typically the volume range is between 1200 liters and 1800 liters). It is interesting that the maximum flow rate is less than 10 LPM. It would be interesting to find out how many in the industry actually sample at less than 10 LPM (i.e., 9.9 LPM versus 10 LPM). Likely most of the industry merely samples at 10 LPM. The statistical difference between 10 and 9.9 LPM, some regulators insist upon, is statistically insignificant and will affect method performance in no discernable manner. Either way, this means your clearance samples will take a little over 2 hours to collect.
In speaking with Mr. Tom Laubenthal, we learned at the time this method was developed it became known through the research involved that flow rates higher than 10 LPM could cause fibers to impact the MCE filters vertically and not horizontally to the filter surface. This makes the sample analysis, counting, and identification, difficult and likely biased. This is also the reason the method specifies a second MCE filter under the 0.45 µm sampling filter and the 5 µm diffuser. This additional filter is placed in this manner to attempt to create an even flow across the filter surface so that fibers impact the filter uniformly. Since the fibers are lying flat on the filter this is the reason for turning the sample upright before interrupting the pump flow to ensure the fibers remain on the filter.
Sampling Cassette Configuration
In the AHERA TEM method, the clearance samples pass when the average concentration of the five samples inside the work area does not exceed 70 structures per square millimeter (s/mm2). See AHERA at 763.90 (i) (3) for an optional clearance test based on the z-test which compares the outside and inside air samples. This is rarely necessary. But cases have occurred when contamination can exist in the air outside the work area that could cause a failure in the work area.
The NIOSH 7400 method for final clearance is also interesting when it comes to how the sample is taken and how many are based on the project. For schools, when PCM is allowed, it's 5 samples inside the work area. What's interesting is that the clearance is based on each sample and each sample must be less than or equal to a limit of quantitation (LOQ) for PCM of 0.01 fibers per cubic centimeter (f/cc). Well according to the NIOSH 7400 method how do you achieve clearance at that LOQ? This concept of LOQ is not a concept understood by many that use the NIOSH 7400 method for all its purposes. In the NIOSH7400 method, this issue is addressed as follows in the section "Sampling", number 4 on page 4. It utilizes the formula below to determine the amount of time needed to achieve the fiber density, E, for optimum filter loading. So, the minimum density the method allows is 100 fibers per square millimeter (mm2). The Ac is the collection area for a 25-mm cassette which is 385 mm2. The Q is the sampling flow rate in LPM, so let's say that is 16 (the maximum flow rate allowed by the method). The L is the concentration of fibers in the air, we are looking to achieve clearance at 0.01 fibers/cubic centimeters (f/cc). So if you plug these numbers into the formula you get a time of 240.6 minutes, which means the sample would have to run for a little over 4 hours at 16 liters per minute (total volume of air of 3,850 liters).
Realize that is running the sample at 16 LPM. If your pump/flowmeter can only go to 15 LPM then you would have to run the sample for 256.7 minutes which is just short of 4 hours and 15 minutes. The lower the flow rate, the longer time it will take to meet sample volume requirements.
Many believe or have been misled to believe that PCM sampling is the same as TEM sampling in terms of sampling volume. This is not the case. A PCM sample volume meeting AHERA clearance requirements are not at 1200 liters. To do so is outside of the NIOSH 7400 method requirements for this purpose. In the NIOSH7400 method, the issue regarding "relatively clean" environments" is addressed on page 4, number 4, note number 1 which states "In relatively clean atmospheres, where targeted fiber concentrations are much less than 0.1 f/cc, use larger sample volumes (3000 to 10,000 liters) to achieve quantifiable loadings." Even though the formula calculates that 3,850 liters of air should be collected, many people use note 1 to collect 3,000 liters of air for clearance. Either way clearance samples should be collected using no less than 3,000 liters of air as the minimum allowed for the NIOSH7400 method requirements and AHERA compliance.
PCM image of fibers
The true problem is the NIOSH 7400 was never designed as a clearance tool, it was designed as a personal air sampling method. NIOSH and the Occupational Health and Safety Administration (OSHA) still view the method in that manner officially. The other problem with PCM is that all fibers meeting method criteria are counted, not just asbestos fibers. The AHERA TEM method is the only procedure that was designed as a final clearance air sampling method. Only asbestos fibers/structures are counted in the analysis meeting method criteria for size, and those much smaller than can be determined by the PCM.
EPA's Silver Book
Realize this is not something out of the ordinary the EPA's publication "Measuring Airborne Asbestos Following An Abatement Action" (otherwise known as the Silver Book) written in November 1985 on page 2-6 recommends the sample volume for the PCM analysis should be a minimum of 3,000 liters of air (though at the time of this publication it was describing the NIOSH P&CAM 239 PCM methodology). In addition, in March 2015 the EIA published a revision to the EPA's1985 document "Guidance for Controlling Asbestos-Containing Materials in Buildings"(EPA 560/5-85-024, known as the Purple Book). This nationally peer-reviewed document was re-titled "Managing Asbestos in Buildings: A Guide for Owners and Managers." Chapter 5 (on page 88) says the minimum sampling volume of 3,000 liters of air for samples taken to meet the NIOSH 7400 method requirements for LOQ sampling. Mr. Dana Brown did a video regarding the LOQ issue and why NIOSH7400 method is not the best choice for clearance, you can see it below.
This doesn't count that we have called for the AHERATEM method to be utilized for asbestos-containing floor tiles and mastic removals based on our previous blog post "Asbestos Floor Tile Debate", published in the August 2017 issue of Healthy Indoors Magazine, which found that the NIOSH7400 method is not able to analyze the type of fibers (Grade 7-Shorts and Floats that are known to be less than 5 microns) found in these materials because of the known small fiber sizes generated by floor tile work. Whether AHERA-based work or asbestos abatement where re-occupancy will occur, the surest way to make sure an area is ready to be given back to the public to be free of asbestos as practicable by current methods, and the fastest method for clearance would be the AHERATEM method.
NYSDOL ICR56 Definition of an Asbestos Project
Of course, those of you who work in New York State or New York City realize these requirements only apply to public and private K-12 schools. So they don't apply to other buildings, or do they? First, let's take the NYSDOL ICR56Subpart 56-4, page 35 is the air sampling requirements. 56-4.6 "Test Methods" on page 36 says "the same NIOSH approved methodology for project air sampling and for analysis of the air samples shall be used at all phases of an asbestos project that require area air sampling and analysis, with the possible exception of clearance air sampling." This means that the NIOSH7400 method must be followed for all phases except clearance (Phase IIC of the asbestos project) this allows you to use either the NIOSH 7400 method or the AHERA TEM method instead for clearance. So this means you have to follow the NIOSH 7400 method's LOQ requirements for all phases (Phase I B and Phase II A, B, & C) of the asbestos project. In addition, the NYSDOL ICR56 regulation for clearance is less than 0.01 f/cc so that changes the formula again. Let's use 0.009 f/cc for the L instead and still use 16 liters per minute, well that means the sample has to run for 267 minutes, almost 4 hours, and 30 minutes (a total volume of air of 4,278 liters).
The consummate leader cultivates the moral law, and strictly adheres to method and discipline; thus it is in his power to control success. ~ Sun Tzu
So why does everyone sample 1,200 liters of air for all samples? On April 8, 2011, the New York State Department of Health (NYSDOH)Wadsworth Center issued frequently asked questions (FAQs) regarding asbestos/fibers analysis that were developed through the collaboration of the NYSDOH Environmental Laboratory Approval Program (ELAP) and the Bureau of Occupational Health and the NYSDOL. In this FAQ is FAQ#13: What is the minimum sampling volume to be collected for air sampling associated with (a) post-abatement (clearance) air monitoring and (b) post-abatement area monitoring for PCM analysis? The answer that was given was: Within the upcoming revision to NYS Industrial Code Rule 56, minimum air sample volume requirements
are being added for both background and clearance PCM air samples. The minimum volume will be 1,200 liters for all background and clearance PCM air samples collected. Hopefully, you all see the problem here...the code rule has not been revised to include this requirement, and even if it did change this is a minimum volume of air and does not comply with the NIOSH 7400 method requirement.
Next up is the NYCDEP Title 15. NYCDEP Title 15 was just updated on May 28th, 2022. See our blog post "New York City's Asbestos Regulation Revised, Again!" for more information on the changes. However, these changes did not make any significant changes to what we are discussing. Under Subpart D, 1-37 (b) "Area air sampling equipment for PCM shall be utilized in accordance with the sampling procedures specified within the NIOSH7400 Method modified for area sampling." Again, it means you must follow the LOQ requirements in the NIOSH7400 method, even though NYCDEP Title 15 does give you minimum sample volumes. For clearance by NIOSH7400 method, it's 1800 liters and for the AHERA TEM method, it's 1250 liters. Remember these are minimums. In addition, NYCDEP Title 15 limits the flow rate to a maximum of 15 liters per minute. This means to achieve the LOQ requirement it would take 256.7 minutes which is just short of 4 hours and 15 minutes (total volume of air of 3,850 liters). The NYCDEP Title 15 minimum volume would not meet the LOQ requirements in the NIOSH7400 method. We hope this post has helped to resolve those pesky questions regarding clearance and convince you that probably the best air sampling method for clearance is the AHERA TEM method!
Over the past two months, Future Environment Designs Training Center has been working on creating these asbestos air sampling charts that have reference information regarding the asbestos air sampling requirements. At this time there are three charts one listing Federal asbestos air sampling requirements (see below), another listing New York State asbestos air sampling requirements, and the third listing New York City asbestos air sampling requirements.
Federal Asbes Air Sampling Chart
The charts are referenced to the regulations and methodologies so you can quickly cite the section of the regulation that requires the asbestos air sampling and what is required. The charts include the flow rates allowed, the volume of air to be collected, the number of samples collected, the type of cassette to use, how to position the cassette, and other important information on sample collection. These charts are invaluable tools to easily and quickly access information regarding asbestos air sampling. We are selling the charts for $15 per chart. Two charts for $28 and all three charts for $40. To purchase the charts click here.
New York State Asbestos Air Sampling Chart
In addition, if you are interested in purchasing the charts and having your logo and your business address placed on the title of the charts, we can arrange for that and possibly other information such as examples of the sample numbers you use, etc. We are packaging these orders at $7,000 for all three charts, $5,000 for two charts, and $3,000 for one chart. That includes logo placement, includes 150 charts, and additional purchases (100 minimum) at $10 per chart. Contact us at 1-800-969-3888 to make arrangements.
Future Environment Designs Training Center (FEDTC) in our August 2022 Safety Suzy Newsletter proudly announced that the International Sales Director of FermionX, Dan Crothers will be attending our Monday, September 19, 2022, Project Sample Technician/Project Monitor Refresher course. FermionX, Ltd. is a UK electronics manufacturer of industrial product brands including the Airbox Sampling Pumps. Dan Crothers has filled sales, marketing, and senior leadership roles in the company, Dan brings extensive product sales and electronic manufacturing experience with in-depth knowledge of the company’s supply chain and quality processes. Originally from New Zealand, Dan spent 15 years in UK and Singapore developing global sales and distribution channel management for FermionX product brands in North America, Asia Pacific Region, and the Middle East.
Dan Crothers
Airbox’s award-winning Variflow air sampling pumps for asbestos air monitoring combine robust sampling performance with unique features for hassle-free setup and decontamination (back-to-back carrying, in-built telescopic mast, IP-65 rated casing {an IP65 Rating means the product has the highest level of dust protection and is able to withstand low-pressure water jets from all directions}, and battery operated). The user-friendly control features support site-specific calibration protocols to safeguard sampling compliance. Coming soon to the USA, the Airbox Variflow will be a powerful new tool in asbestos and mold air sampling.
Airbox Sampling Pump
Mr. Dan Crothers will be demonstrating the features of the AirBox pumps at our Monday, September 19, 2022, Asbestos Project Sample Technician/Project Monitor Refresher Course. These pumps are battery-operated and can run between 5 and 17 liters per minute. So they can be used for both ambient and clearance sampling. The built-in mast means no carrying extra stands for sampling. The pump is showerproof so decontamination is not an issue. Two units fit together for easy carrying with one hand. The hose stores easily on the side of the unit again for ease of transport. Easy to use control panel with highly visible OLED display. We think these pumps will be outstanding and are looking forward to seeing them in operation. To register for the NYS Asbestos Project Sampling Technician Refresher course click here or to register for the NYS Asbestos Project Monitor Refresher course click here!
Well, the annual salmon fishing trip was a success, again! We had a great time and enjoyed the time on the lake. We took the 8th Annual journey to Point Breeze to participate in the Professional Abatement Contractors of New York (#PACNY) Salmon Fishing Pro-Am Derby. This year 18 boats participated in the derby. We left Orchard Creek to fish the Great Lake of Ontario at 6 AM. Future Environment Designs (#FEDTC) was represented by Ms. Sheryl Exposito, Ms. Veronica Hansen-Garcia, Mr. Matt Dech, and Mr. Angelo Garcia, III, and we were in the same boat as last year's "Catchin Hell" piloted by Captain Tom. This year we hoped to defend the trophy we won last year.
Sunrise from our Hotel Room in Warwick
As always, a great big "THANK YOU" to Darren Yehl of Cornerstone Training (CTI) and PACNY for organizing this event. This event allows us to catch up with many of the PACNY members and see how the year is doing. Here was this year's line-up of PACNY members and boats:
Cornerstone - Sunrise II
Cornerstone - Legacy
Expert Environmental - get Hooked
Expert Environmental - Richmond 4
Expert Environmental - Lucas
AAC Contracting - Bite Me
Future Environment Designs - Catchin’ Hell
US Ecology - Shotgun
US Ecology - Bait Master
Abscope Environmental - Reel Excitement
Metro Environmental - Rusty Lure
Paradigm Environmental - Trolling Tails
Lozier - Screem
Sessler Environmental Services - Intimidator
First On-site - Creeper
Aramsco - Mister
Aramsco- Lake Runner
United Rentals - Tomahawk
It was a beautiful day, the Lake was a little rough and because of it, we bounced around a bit on the way out and during the fishing. Captain Tom did a great job handing us the poles and giving us encouragement as we reeled in our catches. We stayed on the lake until about noon and then came ashore to weigh our catches and see who won the derby. After the weigh-in, a catered buffet lunch was provided by the Black North Inn, and the trophies/prizes were awarded. This year's winners were:
Expert 1/Get Hooked won Big Fish & Aramsco/Mister won Big Box
We had a great time, we caught 1 King Salmon and 3 Rainbow Trout. We are looking forward to some good eating over the year as we usually bring all the fish home to have some over the next few days and then freeze the rest to have until next year's catch. Thank you to Darren Yehl for adding to what we brought home. This year we were a little disappointed in that we didn't bring home more King Salmon or maintain our title from last year, however, we have been very fortunate in the past and we are very grateful for attending the event every year. Looking forward to next year on Wednesday, July 12, 2023, save the date!
In 2008, the Environmental Protection Agency (EPA) responded to a question by the New York State Department of Labor (NYSDOL) regarding the minimum number of bulk samples required for suspect asbestos-containing miscellaneous materials (see our blog post dated 6/24/08 and rebooted 07/09/22). This clarification determined that the minimum number of samples is two (2) samples for each suspect homogeneous miscellaneous materials. This clarification was determined based on a review of the EPA's Asbestos Hazard Emergency Response Act (AHERA) section 763.86 -Sampling. This section of the AHERA regulation is used by asbestos inspectors to determine the number of samples to take for each homogeneous area. However, it is important to remember when sampling joint compound and add-on material (which are miscellaneous materials) that EPA's "Sampling Bulletin 093094", requires 3 samples per homogeneous area for joint compound and 3 samples per homogeneous area of add-on material.
The core of all asbestos inspections is the determination of the type of material (surfacing material, thermal system insulation, or miscellaneous material) and whether the materials are homogeneous. A homogeneous area is defined as a type of material that is uniform in color and texture (as per 763.83). Once the type of material is determined and the material is classified as a homogeneous area, then the number of samples for each area is determined.
If the suspect asbestos material is a surfacing material, the square feet of the homogeneous area is determined which provides the inspector with the minimum number of samples that shall be taken. If the homogeneous area is less than 1,000 square feet, the inspector shall take 3 samples. If the area is between 1,000 and 5,000 square feet, the inspector shall take 5 samples. When the area is over 5,000 square feet, the inspector shall take 7 samples. This is sometimes known in the industry as the 3-5-7 rule. In addition, EPA also published "Asbestos in Buildings: Simplified Sampling Scheme for Friable Surfacing Materials," otherwise known as the "Pink Book." This document not only describes the process for random sampling but also recommends that for surfacing materials the number of samples should be 9 per homogeneous area no matter the number of square feet.
Should the suspect asbestos material be classified as thermal system insulation then the inspector must determine if the material is a homogeneous area, a patch material, or a cement or plaster used on fittings (tees, elbows, or valves). Homogeneous areas of thermal system insulations shall require 3 samples, while each homogeneous area of patch material less than 6 linear feet or 6 square feet shall require only 1 sample. Cement or plaster used on fittings shall be sampled based on each insulated mechanical system (hot water, cold water, steam, chilled water, etc.) and shall require a minimum of 2 samples to be taken. In addition, EPA strongly recommends that at least three samples be taken in large homogeneous areas, even when the regulations do not require it. This recommendation was published in EPA's700/B-92/001 A Guide To Performing Reinspections Under AHERA.
Some general rules to remember when taking bulk samples is sampling should be taken in a randomly distributed manner, samples cannot be composited, and shall be submitted to laboratories accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) and, in New York State, approved New York State Department of Health Environmental Laboratory Approval Program (NYSDOH ELAP). Asbestos Inspectors determine a homogeneous area contains asbestos when one of the required numbers of samples contains asbestos in the amount greater than 1%. Should all the required samples taken in a homogeneous area result in asbestos amounts less than or equal to 1%, then the area does not contain asbestos as per EPA. However, you must make sure your client is aware that under the Occupational Safety and Health Administration (OSHA) regulation 1926.1101 these materials are still regulated as asbestos and there are specific requirements under the OSHA regulation on handling these materials, see OSHA's standard interpretation letter dated November 24, 2003.
As Asbestos Inspectors we should also remember that the American Society of Testing and Materials (ASTM) has a Standard Practice for Comprehensive Asbestos Survey ASTM E2356-18. This standard practice has also been approved by EPA as the method for performing asbestos surveys for the purposes of complying with the National Emissions Standards for Hazardous Air Pollutants (NESHAPS) regulation. That regulation requires a "thorough inspection" of the facility for asbestos and EPA expects an owner/operator to follow the steps described in Sections 1 through 5 and section 8 (the pre-construction survey) in the ASTM standard. Being an Asbestos Inspector and performing an asbestos survey is not an easy task. There are a lot of different documents that you have to have knowledge about to be able to perform your task and then on top of that you must have knowledge regarding where asbestos was used in building materials.
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