When building owners and managers hear the word asbestos, heads turn, and often times heads turn the other way.  Asbestos has come to be a troublesome thing that often carries a hefty price tag, but it is not something that can be ignored. 

What is Asbestos?

Asbestos was widely used in building materials primarily from the 1950’s through the 1970’s.  Asbestos quickly became popular in roofing due to it’s fire resisting properties as well as its resistance to aging.  The low oxidation and rotting process of asbestos containing roofing felts made for long lasting built-up roofs and increasing popularity of asbestos felt use.   These felts contain chrysotile asbestos fibers that are natural fibers obtained from crushing and refining chrysotile ore.  ASTM specification D250 required that the dry felt must contain a minimum of 85% asbestos.  Other roofing materials, such as mastics, coatings, transite panels, and shingles were also manufactured with the use of asbestos.

The fibers are small serpentine fibers that can become airborne for long periods of time, making them easily inhaled by humans.  These fibers, once in the lungs, stay in the lungs.  Asbestosis, mesothelioma and cancers of the lung, esophagus and stomach are deadly diseases that are a result of an accumulative dose of asbestos.  In the early 1980’s, this danger set into action the Asbestos Hazard Emergency Response Act (AHERA) requiring that K-12 schools in the U.S. develop a management plan for dealing with any and all asbestos containing building materials.  The Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA) also set their own regulations for dealing with asbestos.  OSHA set a standard that occupational exposure to asbestos should not be more then 0.2 fibers per cubic centimeter of air longer than 5 micrometers in length.  EPA controls the removal and/or disposal of asbestos containing building materials under the National Emission Standards for Hazardous Air Pollutants (NESHAP).  Local governing authorities may also have their own removal and/or disposal requirements, which might be totally different from OSHA or the EPA.  Prior to any asbestos removal project, check with the local governments so their requirements can be met.

Removal Requirements

OSHA has regulated the removal of asbestos containing roofing materials for a long time. Removal of roofing felts, shingles and transite panels are so-called Class II work, and removal of mastics and coatings are so-called incidental work.  Some of the early requirements for removal of asbestos-containing roofing materials included proper worker training, air monitoring, protective clothing, respiratory protection, and wet/dry cleaning.  In 1994, a revision by OSHA imposed more stringent removal requirements for asbestos containing roof removal, regardless of exposure level. 

These strict requirements have been protested by the roofing industry saying that the asbestos in roofing is not friable, that the asbestos is encapsulated, and that the asbestos fiber release is little to none.  The National Roofing Contractors Association (NRCA) took on OSHA, saying that most asbestos containing roofing materials posed very little to no health hazard, as they are considered non-friable.  In 1995, OSHA and the NRCA reached an agreement on a relaxed set of procedures for Class II work and incidental work.  This agreement still requires air monitoring, respiratory protection, protective clothing and proper cleaning.  However, these practices are not required if an exposure assessment is determined to be below the Permissible Exposure Limit (PEL). 

The assessment is to be based on air monitoring results collected by the contractor on like jobs over the previous 12 months, air monitoring results collected by the NRCA, or air monitoring results collected during the start of the project.  However, if the air monitoring is to be done on the job, all requirements, such as for personnel protection and cleaning must be followed until the results are found to be below the PEL.

Intact roofing materials are considered non-friable and removal of such materials must remain non-friable or the job will fall back in to the stringent removal requirements set by OSHA.  The roofing materials must be removed without the use of power tools such as a roof cutter.  If the contractor decides to use power tools for the removal of, lets say, the roofing felts, then the roof cutter must be equipped with a sprayer to put a mist of water on the roofing at the cutter blade.  As the roof is cut, the felts become friable and the mist of water is needed to settle any dust and fiber release.  The cut area should then be vacuumed with High Efficiency Particulate Air filters.  Dry removal is allowed with the proper notification and approval of the EPA.

Summary

As a building owner or manager, faced with an upcoming roof removal project, you must first test the roof to determine the presence of asbestos.  The field membrane, as well as the flashings, need to be tested.  In many cases, flashings were installed using asbestos felts but the field was not.  Therefore, it is important that both the field membrane and flashings be tested.  An approximately 3” x 3” sample of the field and flashings is usually large enough for testing.  The membrane samples should then be labeled as membrane type, location and project reference, and be sent to a National Institute of Occupational Safety and Health accredited asbestos testing laboratory to determine if the roofing materials contain asbestos.  The laboratory will return a report with the test results.  This report should be kept in the project file for any future reference.  Prior to collecting the roof samples to be tested, check with local governments to see if there are any requirements that the person collecting the samples must meet.  Some local governments require the person collecting the samples to be trained and certified in asbestos removal. 

If the field membrane and/or flashings test positive for asbestos, it is then time to take a level headed, common sense approach.  Select a core group of contractors trained in asbestos removal and familiar with notifying and dealing with OSHA, the EPA, and even the DOT.  Contact local governments to obtain their requirements.  Discuss with the selected contractor their removal process, including personnel and environmental protection.  Obtain the projects exposure assessment and/or on the job air monitoring results.  Require that the asbestos containing materials are disposed of at an EPA approved landfill and that the contractor follows all requirements of the landfill and obtain all manifests.  Lastly, keep very good, step-by-step records and keep all records in the project file just in case they are needed in the future.  Remember, even though the roof has been properly removed and disposed of in an EPA approved landfill, you still own and are responsible for the asbestos containing materials.