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Monday, March 13, 2023

Counting Down to a Month of Conferences - First it's PACNY's Environmental Conference and Then EIA's!

The Professional Abatement Contractors of New York (PACNY) have announced the dates and schedule for their annual Environmental Conference on March 16th and 17th, 2023.  It will be held at the Turning Stone Resort & Casino in Verona, New York.  To register for the conference or sponsor the conference click here!  Also, this month is the Environmental Information Association's (EIA's) 2023 National Conference & Exhibition being held from March 25th to March 29th, 2023.  It is being held at Renaissance Nashville Hotel, Nashville, Tennessee.  To register for the conference or sponsor the conference click here!

PACNY 2022

Both of these conferences provide tons of information that helps keep our classes up-to-date.  We are looking forward to several presentations that should provide information about some current issues such as "Managing Typical Regulated and Hazardous Wastes Generated on Abatement/Remediation Projects in NYS", "Asbestos Building Inspectors - an Open Discussion", "Exposure Assessments", "Asbestos-Myth Busters", and "What Your Injured Employee Think of You, Navigating the NYS Worker's Compensation Law and Related Benefits" just to name a few.

EIA Conference 2022 in Phoenix, AZ

We will have a table at the PACNY conference and we will be tweeting the conference using the hashtag #FEDTCPACNY.  We will be selling our asbestos air sampling tables ($15 per table) and we will be selling and signing our book "Do As I Say, Not As I Did" ($15 per book) at the table.  Come by and say hello!  Sheryl Esposito will be womaning the booth as she has for the past couple of years.  Our co-host for Two Guys Talking Pumps, Dan Crothers, the International Sales Director of FermionX maker of the Airbox Sampling Pump, will also be attending the conference and is also a sponsor.  To know more about the Airbox sampling pumps see our YouTube video "Two Talking Pumps" below or visit him at his booth where he will have the Airbox sampling pump in person!  Looking forward to seeing you there.  



Wednesday, January 18, 2023

Safety Training That Works: How FED Keeps Its Courses Fresh and Engaging by Natasha Serafimovska

At the beginning of last summer, Safety + Health Magazine released the 2022 Training Survey with some telling results.  Companies are tired of the same old safety training that is stale, repetitive, and ineffective.

When asked about their greatest challenges around worker safety training, companies identified these five common concerns as their biggest pain points:

  • Keeping training interesting, relevant, and up-to-date;
  • Offering consistent training across the organization;
  • Flexible schedule to accommodate various shift structures and work models;
  • Getting employees to complete their training and implement what they’ve learned;
  • Getting management buy-in about the importance of the training;

As a safety training provider who’s been around for over 30 years, this got us thinking at Future Environment Designs Training Center (FEDTC) about why that is the case.  Why do training providers struggle to keep safety training fresh and engaging at a time when there are so many tools and learning models at our disposal? 

Here, we share how FEDTC keeps our training fresh, engaging, and flexible.  We hope that this will help our current and new customers better assess our course offerings as well as give other training providers some insights into how they can improve their approach so that we can all raise the safety training standards and reduce injuries across the board.

Asbestos Handler 

Keeping Employees Interested and Engaged

Safety training is a regulatory requirement which means that most workers go through the same content each year.  Not only that, but safety content in itself can sometimes be a bit dry as there’s a lot about rules, regulations, and what workers should and shouldn’t do in different scenarios. 

That said, it doesn’t mean that safety training should be boring.  At FEDTC, for instance, we take great care in making our courses as engaging as possible.  At the beginning of the pandemic, we implemented Poll Everywhere, a polling tool that allows students to interact during virtual and in-person classes and helps the trainer check in with students as part of their presentation. 

This breaks up the one-way communication of the training format and gives students the desire to ask questions, comment, and give feedback.  All of this has significantly increased participation, and discussions, and has helped us make our courses much more interesting for our students.

Asbestos Operations & Maintenace

Offering Training That’s Consistent and Tailored to the Organization

If safety training is to work, it needs to be consistently delivered across the organization.  Likewise, the content needs to be adapted to the organization’s specific scenarios for it to resonate with the employees, as not all businesses face the same safety concerns.

At FEDTC, we review our training materials annually to determine if they need to be updated.  We also adjust our classes to meet specific work procedures and practices our clients use, such as working with asbestos cement pipe or asbestos electrical wire insulation.  All of this makes the training relevant and consistent with the working environment in which our clients operate. 

Not only that, but we regularly attend conferences such as Professional Abatement Contractors of New York (PACNY)Environmental Information Association (EIA), the American Council for Accreditated Certifications (ACAC), and others to stay abreast of the latest research, regulations, and standards in the industry. 

40-hour HAZWOPER 

Making Training Flexible

A large portion of our courses is available as both an in-person course and a virtual class which students can choose based on their location, work schedule, and availability.  We also run the same courses several times each month so that students have more options to choose from. 

When it comes to online training, we offer courses that are on-demand and students can take whenever they want or virtual instructor-led classes which can enrich the learning experience but do require student participation in a specific time. 

Mold Worker/Remediation/Supervisor/Assessor Course

Driving Course Completion and Compliance

For us, the training doesn’t end in the (virtual) classroom. Instead, we engage with learners post-training via email, text, or phone to answer questions and keep engagement high.  If we go back to the polling tool, we also use polls to keep the communication going in between courses if they take place on different days or months.

When it comes to compliance, we use polls at the beginning of our training sessions to see how much our learners remember from the previous year.  This helps us identify key areas we need to put extra focus on or update the content to make it more memorable and engaging.  This has dramatically improved learners’ knowledge retention and improved the overall outcomes of our training courses. 

At FEDTC, we understand that learners may need several touchpoints with the content in order to learn it. That’s why we try to provide as much and as diverse content as possible through our website, blog, and LinkedIn New York Asbestos Group.  For example, learners (and their employers) can use our Resource Page to get access to a plethora of recordings, papers, and conference presentations which are constantly updated via Dropbox.  We also provide a Negative Air Calculator for learners to get a better understanding of how negative pressure can keep work areas safe and lower contamination levels. 

OSHA 10-hour Construction Safety Course

Showing the Value of Safety Training

Finally, we don’t take things for granted.  We use Coursecheck, an online course feedback tool, to invite students' feedback and use that as a guide for improvement.  So far, we’ve received over 1500 online reviews with an overall 4.8 out of 5-star rating. 

Other than looking at what other people are saying, the best way to demonstrate the value of the training FEDTC provides is to give it a go.  FEDTC offers many short and refresher courses which you can use as a test drive to see if our methods suit your needs.  Once you’ve assessed the outcomes of those courses, we’d be happy to have a wider discussion about how we can deliver holistic safety training that is going to meet the needs of your particular business. 

OSHA 30-hour Construction Safety Course
The Bottom Line

Safety training may not be your favorite pastime activity, but its value in the workplace is indisputable. The Bureau of Labor Statistics has found that in 2020 there have been 4,764 work-related deaths where construction and transportation fatalities accounted for nearly half of those.  Construction, in fact, is cited as the industry with the highest rate of workplace fatalities in the United States.   

This highlights the importance of delivering quality and engaging workplace safety training.  The onus is both on training providers and employers to collaborate and come up with solutions that are relevant, engaging, and tailored to the circumstances workers face each and every day.




Tuesday, December 27, 2022

Merry Holidays and a Happy New Year from Future Environment Designs! What Do We Have In Store for the New Year!

A Merry Holidays and a Happy New Year to all of you who journeyed with us this past year.  It has been a see-saw kind of year with some ups and some downs.  As some of you know we were trying to sell the business.  We've decided we are not going to sell the business and instead will ride the business into the sunset (as we prepare and get ready for retirement probably another 10 years).  As we go into our 35th year of being in business we continue to adjust and modify the services we offer to our clients, allowing our clients to utilize our 35 years of experience and Angelo Garcia, III's 40+ years of experience.  

Christmas Tree at Rockefeller Centre

In 2023, we will continue our At Your Convenience service.  The At Your Convenience service brings the training or respirator fit testing to your location.  All we need are five or more people and we're At Your Convenience!  Tired of traveling through rush hour traffic to get to your training center?  Tired of paying travel expenses for your employees for training?  Tired of the same old non-productive training classes?  Or are you just tired of the same old training?   If you have answered yes to any of the above questions, then you need to give us a call.  Future Environment Designs Training Center (FEDTC) (with a Coursecheck rating of 4.8 out of 5) is now providing training At Your Convenience.  We can perform the training in your office. We provide a laptop, a projector, PowerPoint presentations, and a wireless device for internet access. You provide the seating and the blank wall (no blank wall, we’ll provide the screen). We do the rest.  We can do this training for any of the courses and services in our Course Offerings and Training Services Catalog.

The Bergdorf Goodman Windows

In 2023, we will be expanding our collaboration with SiteDocs to help you elevate your safety programs.  Future Environment Designs can work with you to create the various Occupational Safety and Health Administration (OSHA)-compliant safety and health programs (i.e., hazard communication, respiratory protection, confined space entry, bloodborne pathogen, and construction safety & health programs) that would go into the SiteDocs platform.  We can help you meet the training requirements, develop the data (such as Safety Data Sheets and Chemical Inventories), and create the checklists that would be used by your staff to meet the regulatory requirements.  With the SiteDocs platform that information would be readily available to all your staff.  To learn more about what SiteDocs can do for your safety program, you can book a quick call with Brent Martyniuk here.  To learn how Future Environment Designs can help you with developing your various safety and health programs contact us here.  We believe the SiteDocs platform would greatly impact your business helping you save time and money, and elevate your safety program from being on the shelf to being part of your day-to-day operations.

Saks Fifth Avenue

FEDTC continues to offer our One-Stop Service which allows employers to contact us or register online to:

  • Schedule staff development on asbestos, mold, or other safety and health regulations (see our Course Offerings and Training Services Catalog.),
  • Schedule respirator medical evaluations to comply with the OSHA respiratory protection standard 1910.134,
  • Order the proper respirator and filters for your staff, and
  • Schedule quantitative respirator fit testing to comply with the OSHA respiratory protection standard 1910.134, to be performed on the day of the class.

We provide this One-Stop Service making your occupational safety and health requirements simple and easy to complete.  Contact us here or register online here.



Finally, FEDTC will continue to lead the field by attending the Professional Abatement Contractors of New York (PACNY) Environmental Conference (save the dates March 16-17, 2023) and the Environmental Information Association (EIA) National Conference & Exhibition (save the dates March 25 - 29, 2023).  We will bring back the current information from these conferences and share it in our classes.  FEDTC is one of the few training providers that provide the FEDTC dropbox folder (with hundreds of reference documents regarding indoor air quality, asbestos, lead, mold, etc.), we also provide our students with the negative air app (to help calculate the number of negative air units for a work area), our project monitor and air sampling technician courses include a New York State or New York City asbestos air sampling table (these can be purchased here) and for those considering opening your own business our book "Do As I Say, Not As I Did What I've Learned After 30 Years of Being in Business" discusses the four pillars of operating a successful business, you can purchase the book here.  We wish you a Merry Holidays and Hope to see you in the New Year!

Monday, November 21, 2022

Top 10 Most Frequently Cited Standards for Fiscal Year 2021 (Oct. 1, 2020, to Sept. 30, 2021)

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.  

  1. Fall Protection, construction (29 CFR 1926.501) [related safety resources]
  2. Respiratory Protection, general industry (29 CFR 1910.134) [related safety resources]
  3. Ladders, construction (29 CFR 1926.1053) [related safety resources]
  4. Hazard Communication, general industry (29 CFR 1910.1200) [related safety resources]
  5. Scaffolding, construction (29 CFR 1926.451) [related safety resources]
  6. Fall Protection Training, construction (29 CFR 1926.503) [related safety resources]
  7. Control of Hazardous Energy (lockout/tagout), general industry (29 CFR 1910.147) [related safety resources]
  8. Eye and Face Protection, construction (29 CFR 1926.102) [related safety resources]
  9. Powered Industrial Trucks, general industry (29 CFR 1910.178) [related safety resources]
  10. Machinery and Machine Guarding, general industry (29 CFR 1910.212) [related safety resources]
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.



Wednesday, November 09, 2022

Two Guys Talking About Pumps

Future Environment Designs Training Center (FEDTC) in our August 2022 Safety Suzy Newsletter and our August 29th blog post announced that the International Sales Director of FermionX, Dan Crothers was attending our 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.   

Airbox Sampling Pump

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.





Monday, October 24, 2022

The Reality of Asbestos Clearance Air Sampling! Are You Sampling Enough?

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 AHERA transmission 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 method does 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 Âµm 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.

This TEM asbestos image is from the Centers for Disease Control (CDC) "Asbestos Fibers and Other Elongate Mineral Particles: State of the Science and Roadmap for Research"

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 NIOSH 7400 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 millimete(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. 

Airbox High-Performance Air Sampler

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 NIOSH 7400 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 NIOSH 7400 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's 1985 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 NIOSH 7400 method is not the best choice for clearance, you can see it below. 

This doesn't count that we have called for the AHERA TEM 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 NIOSH 7400 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 AHERA TEM 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 ICR56 Subpart 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 NIOSH 7400 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.

Buy our Asbestos Air Sampling Chart here.
Read about our Asbestos Air Sampling Charts here.

Next up is the NYCDEP Title 15NYCDEP 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 NIOSH 7400 Method modified for area sampling."  Again, it means you must follow the LOQ requirements in the NIOSH 7400 method, even though NYCDEP Title 15 does give you minimum sample volumes.  For clearance by NIOSH 7400 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 NIOSH 7400 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! 


Friday, September 23, 2022

Future Environment Designs Creates Asbestos Air Sampling Charts That Can Be Used In the Field or the Office.

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.   



New York City Asbestos Air Sampling Chart





Conference Season Starts in 3 Months Save the Date: PACNY 2025 Environmental Conference & EIA 2025 National Conference

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