Asbestos Containing Resilient Floor Coverings and Associated Adhesive/Backing
An Analysis of Existing EPA (AHERA and NESHAP) and
OSHA Regulations, Policies and Guidance
Table summarizing the guidance, policies and regulations used to develop this paper
Definitions
Asbestos Containing Resilient Floor Coverings: For the purpose of this paper, resilient floor coverings include asbestos-containing floor tiles (including asphalt and vinyl asbestos tiles) and sheet vinyl floor coverings (including linoleum) and associated adhesive/mastic and backing.
Under EPA’s AHERA asbestos-in-schools regulations, resilient floor coverings are assumed to contain asbestos, unless sampled by a MAP-accredited inspector and tested using either the 1982 polarized light microscopy (PLM) analytical method appearing in Appendix E, or the 1993 improved test method entitled “Method for the Determination of Asbestos in Bulk Building Materials” (EPA/600/R-93/116), by a laboratory approved by the National Voluntary Laboratory Accreditation Program (administered by the National Institute of Standards and Technology, formerly the National Bureau of Standards), and found to contain 1% asbestos or less. EPA recommends that schools assume floor tiles with negative results (based on the 1982 PLM method) to be asbestos containing, or that they resample and re-analyze them using the 1993 EPA test method. This method is especially useful for detecting the presence of asbestos in asbestos-containing resilient floor coverings and other building materials that may contain fibers too small to be detected by the PLM method, and where the presence of asbestos is obscured by a matrix binder such as vinyl or asphalt floor tiles.
Under EPA’s asbestos NESHAP regulations, resilient floor covering is considered to be asbestos containing if it has more than 1% asbestos as determined using PLM according to the method specified by EPA. If the material is friable, and if it contains less than 10% asbestos, the NESHAP regulations would require the material to be analyzed at 1% or less by point-counting in order to be exempt (the 1993 improved test method would also be allowed).
In the OSHA regulations, "asbestos containing material" means any material containing more than 1% asbestos. Vinyl and asphalt floor coverings and associated mastic and backing in materials installed prior to 1981 must be considered asbestos containing, unless an industrial hygienist determines that any of these materials are asbestos-free using recognized analytical techniques.
Intact: Under the OSHA regulations, asbestos-containing flooring material which is broken during a removal could be considered "intact" as long as the flooring material has not been crumbled, pulverized or otherwise deteriorated so that the material is no longer likely to be bound with its matrix. Therefore, incidental breakage of tiles does not, by itself, mean that the material is not intact.
Friable: Under EPA’s AHERA and NESHAP regulations, friable means that the material, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure, and includes previously nonfriable material after such previously nonfriable material becomes damaged to the extent that when dry it may be crumbled, pulverized, or reduced to powder by hand pressure.
Maintenance
The OSHA standard regulates the maintenance of asbestos containing flooring materials as follows: sanding of asbestos-containing flooring material is prohibited; stripping of finishes must be conducted using wet methods, low abrasion pads and at speeds lower than 300 rpm; and burnishing or dry buffing may be performed only on flooring which has sufficient finish so that the pad cannot contact the flooring material. Vacuums cleaners equipped with HEPA filters must be used when cleaning waste, debris and accompanying dust on floors containing asbestos. Signs and/or labels are required to be posted in areas where they will be noticed by persons doing work in the building and who may be potentially exposed. The signs must be posted at the entrance to the mechanical room or any similar area. Signs and/or labels could be posted in the equipment room or on the buffing machine.
EPA recommends that certain work practices be used, such as wetting coverings and using the lowest speeds and least abrasive pads for any machines used for stripping wax coatings, scrubbing, spray buffing, and refinishing.
Removals
Under the OSHA construction standard, removal of asbestos containing resilient floor coverings and adhesives is considered Class II work. The OSHA regulations prohibit the use of highspeed abrasive disc saws without specific engineering controls at the point of operation, compressed air, dry clean up methods (except when using heat if tiles can be removed intact), sanding, rip-up of resilient sheet floor material, and mechanical chipping (unless performed inside a negative pressure enclosure). With few exceptions, OSHA requires the use of HEPA vacuum cleaners, wet methods, prompt clean-up and disposal of waste and debris in leak-tight containers for all asbestos removal operations.
The OSHA regulations require removal of asbestos containing floor tiles “intact” unless the employer demonstrates that intact removal is not possible (see the OSHA definition of “intact”). Floor tiles must be wetted then individually pried up. Heat may be used to soften the adhesive holding the tiles to the substrate. If heat is used, wetting may be omitted if tiles are removed intact. If tiles cannot be removed intact, then aggressive techniques such as mechanical chipping may be used. However, removal of non-intact floor tiles must be conducted in a negative pressure enclosure and additional protective work practices, personal protective equipment, monitoring and training must be provided. After removal, each tile must be placed in an impermeable trash bag or other impermeable waste container.
OSHA requirements prohibit the ripping up of resilient sheet flooring. The flooring must first be HEPA vacuumed. While making a series of parallel cuts, the snip point must be wetted. The sheet flooring must then be removed in strips 4 to 8 inches wide. As a strip is removed, the point of separation must be constantly misted to minimize fiber release. A strip must be rolled up as it is removed and the roll placed in an impermeable trash bag or other impermeable container. Residual felt and adhesive are then removed by wet scraping, and the floor is HEPA vacuumed.
OSHA does not require removal of residual adhesive, but it is often necessary to remove or smooth residual adhesive to prepare the surface for installation of a new floor. Wet methods must be used when removing residual adhesive. The adhesive must either be wet-scraped manually or removed using low speed floor machine and wetted sand or a removal solution. The adhesive residues must be placed in an impermeable trash bag or other impermeable container while still wet. Remaining water or dirt in the area must then be HEPA vacuumed.
OSHA does not require monitoring for asbestos levels for most flooring removal jobs. Monitoring is only required if compliant work practices are not followed, if the material is not removed intact, or if the employees are not properly trained in accordance with the standard.
OSHA generally requires that respirators be worn when Class II work, including removal of resilient floor coverings, is not performed using compliant work practices. If compliant work practices are followed, respirators would only be needed if their use is required under another provision of the standard.
If, in a school building, resilient floor coverings (known or assumed to contain asbestos) are in such poor condition that they are already friable or are likely to become friable during removal, then EPA’s AHERA regulations require the removal to be conducted as an AHERA response action, which requires the use of an accredited project designer, accredited workers and supervisors, and air clearance. Use of certain techniques such as sanding, grinding, mechanical chipping, drilling, cutting, and abrading create a high probability that the floor coverings and/or its adhesive will be damaged or weakened to such an extent that it would be rendered friable and would need to be conducted as an AHERA response action. EPA generally requires analysis by the Transmission Electron Microscopy (TEM) analytical method, as described in Appendix A to the AHERA schools rule, as the air clearance method for removal of friable resilient floor coverings (when conducted as an AHERA response action), due to the potential of elevated fiber levels and the small size of the fibers. However, with regard to projects which are greater than small scale, short duration and less than or equal to 160 square feet or 260 linear feet and conducted as AHERA response actions, EPA permits the use of Phase Contrast Microscopy (PCM) through the National Institute for Occupational Safety and Health (NIOSH) Method 7400, entitled "Fibers," as an analytical method for air clearance purposes.
Under asbestos NESHAP, the owner or operator of a demolition or renovation activity must first thoroughly inspect the facility or part of the facility where the activity will occur. With respect to resilient floor covering and its adhesive, this inspection includes determining if the covering is in poor condition or friable, as indicated by peeling, cracking, or crumbling of the covering. If the resilient floor covering is in poor condition, friable or is likely to become friable through sanding, grinding, cutting, or abrading and is at least 160 square feet in size, then it must be handled in accordance with the NESHAP regulation; that is, it must be removed before the demolition activity and comply with the NESHAP notification, work practices and disposal requirements. This includes where there is a high probability of the material becoming crumbled, pulverized, or reduced to powder by the forces expected to act on the materials in the course of the demolition operations. Resilient floor coverings and its adhesives in an undisturbed state that are not in poor condition and where it is unlikely that the covering will become crumbled, pulverized, or reduced to powder by the forces expected to act on the materials in the course of demolition or renovation operations or are less than 160 square feet in size are not subject to NESHAP notification (except notifications are always required for demolitions), work practices and disposal requirements and do not need to removed prior to the demolition activity. Although, in theory, the paper backing which contains asbestos could be classified as nonfriable, practically speaking, it is very difficult to keep asbestos-containing paper backing from crumbling or abrading during removal.
Asbestos containing adhesives are generally considered Category I nonfriable ACMs and are not subject to NESHAP requirements, unless they are in poor condition or subjected to sanding, grinding, cutting or abrading. Therefore, when the floor tile is not friable and not being removed prior to demolition, the adhesives can remain in the building during the demolition, as long as the demolition does not render it friable and regulated. If the demolition will be done by burning, then all asbestos materials, including resilient floor coverings and adhesives, must be removed in accordance with the asbestos NESHAP regulation prior to burning.
If the resilient floor coverings are not in poor condition, then, according to the EPA NESHAP interpretations, proper use of certain technologies for removal tend not to render the floor coverings friable. These technologies include infrared heaters, solvents (which do not use abrasive methods to wipe the material up), and “normal demolition procedures.” Use of other technologies, such as sanding, grinding, cutting, abrading, drilling, sawing, and shot blasting, will render resilient floor coverings friable and regulated.
Training and Accreditation
If, in the process of removal, the asbestos containing resilient floor covering or its adhesive may be rendered friable and/or the covering or adhesive is in such poor condition as to be considered friable, then the EPA AHERA regulations require a MAP-accredited project designer to design the removal project and a MAP-accredited supervisor and MAP-accredited workers to supervise and conduct the removal at schools or at public or commercial buildings. If a school uses its own maintenance and custodial employees to remove or otherwise disturb asbestos-containing resilient floor coverings and uses methods that will not render the coverings friable, then the AHERA regulations require that these employees take 16 hours of asbestos awareness and operations and maintenance training. A MAP-accredited project designer is not required for a project in which nonfriable resilient floor coverings are encapsulated or otherwise abated in a nonfriable state.
EPA’s AHERA regulations require building inspector accreditation under the MAP for all persons who determine the presence or location, or to assess the condition of, friable or nonfriable asbestos containing building material (ACBM) or suspected ACBM, whether by visual or physical examination, or by collecting samples of such material, in school buildings or public or commercial buildings. EPA’s MAP does not require building inspector accreditation when a person looks at or touches a resilient floor covering or evaluates the condition of such a covering when these activities are undertaken solely to evaluate the adherence capabilities of the existing material, its suitability as a foundation for new flooring, or the need for leveling compounds. Persons engaged in those activities on floor covering which is intact (not damaged) do not have to be accredited because they are not determining the presence or location of ACBM or suspected ACBM, or assessing the flooring covering’s potential for asbestos fiber release, even though they may have visually or physically examined the floor covering to evaluate its condition. However, persons who are assessing the condition of the floor covering that has been damaged to determine its potential for fiber release (i.e., its friability) must be accredited as a building inspector under the MAP. This building inspector accreditation requirement applies to all school, public, and commercial buildings.
OSHA requires removal of asbestos-containing floor covering to be supervised by a "competent person." If the flooring material is not removed intact and/or compliant work practices are not followed, the "competent person" must successfully complete a training course meeting the criteria of EPA’s MAP accreditation course for contractors/supervisors. The removal must be conducted by workers who have completed training that is equivalent to EPA’s MAP accreditation course for workers. A project in which resilient floor covering is removed using OSHA-compliant work practices and in which the covering is removed "intact" may be supervised by a competent person who has successfully completed a 12-hour training course. The workers who perform such projects must have completed an 8-hour training course.
Table summarizing the guidance, policies and regulations used to develop this paper
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