Accidents and injuries occur more readily in the demolition stage of a construction project, than any other phase. The primary reason for this, are hidden dangers, often obscured to the naked eye, and/or concealed by years of accumulated debris. Such materials, when exposed, are ripe to churn up lethal amounts of carcinogens, into the work environment, in the form of dust, fumes, and gases that can be extremely damaging to the health and wellbeing of workers.
That is why it is important, as part of pre-construction protocols to identify hazardous building materials before beginning a restoration or remediation project. Although there are many hazardous building materials, the most common include asbestos, lead, mercury, polychlorinated biphenyls (PCB), chlorofluorocarbons, and radioactive sources. Surprisingly, these dangers will remain contained, when left unmolested inside the walls and framework of the structure, and do not become weaponized until commencement of the demolition process. As it is the uncontrolled nature of this process, in even the most controlled settings that will unleash unsafe poisonous substances upon contractors and employees. Additionally, the nefarious nature of the randomized sequelae inherit in the demolition process will often lead to contaminated buildings, project delays, additional expenses and even regulatory violations. Understanding the health, safety and applicable environmental regulations associated with the disturbance and disposal of these materials, are a necessary aid to owners and contractors, when attempting to navigate these very dangerous and unpredictable waters.
It is incumbent upon any professional contractor, no matter the specialty, to recognize hazardous building materials, existent in the structure prior to initiation of the demolition process to keep the workplace safe. It is equally important, said contractors and owners, maintain a working knowledge of applicable, federal, state and local regulations, prior to undertaking a building remodel, as the risk of running astray of such regulations becomes all too real once the process has begun.
Although certain uses of asbestos have been banned, the U.S. continues to import raw asbestos for use in roofing materials, coatings and compounds, plastics and other applications. Other finished asbestos-containing products that continue to be imported include drywall, floor tiles, and similar building materials.
The Environmental Protection Agency’s (EPA) asbestos regulations found under 40 CFR 61-National Emissions Standards for Hazardous Air Pollutants (NESHAP) require an inspection regardless of the age of the structure before any renovation or demolition activities are undertaken. Certain asbestos-containing materials (ACMs) must be removed before any work begins.
The EPA also requires notification 10 business days in advance of structural demolition, regardless of the presence of ACMs. If asbestos is present in the structure, the contractor or property owner submitting the notification must have documentation that an asbestos survey was conducted. If suspect ACMs are discovered, the work must stop until the materials can be sampled and analyzed for asbestos. Should ACMs be found, an abatement contractor must be hired and the 10-day notification submitted before abatement work can begin again.
Local and state asbestos regulations are often more stringent than federal regulations, which may dictate the need for more thorough surveys and more complex abatement methods, both of which can lead to increased costs if not properly accounted for at the beginning of the project.
The Occupational Safety and Health Administration (OSHA) has established permissible exposure limits (PELs) to protect employees in general industry and in construction. The regulations require initial exposure monitoring to evaluate representative eight-hour time weighted average (TWA) exposures and periodic monitoring where exposures may be expected to exceed the PEL. Specific control measures are required to prevent asbestos fibers from being released from the ACM during abatement.
Lead-based coatings are common in older buildings. In addition to paints and varnishes, lead-containing building materials can include window glazing putty; batteries for lighting, exit signs, and security systems; solders and pipes; mortar; acoustic materials; flashing; plastic coloring (wiring and blinds); and ceramic glazes.
While the EPA defines lead-based paint (LBP), it does not require an inspection for lead-containing materials. It does, however, recognize that common renovation activities like sanding, cutting and demolition can disturb LBP and create hazardous lead dust and chips which can be harmful to adults and children. To protect against this risk, the EPA issued the lead-safe practices rule aimed at preventing lead poisoning. The rule requires contractors performing renovation, repair and painting projects that disturb lead-based paint in homes, childcare facilities, and schools built before 1978 to be certified and follow specific work practices to prevent lead contamination.
The U.S. Department of Housing and Urban Development (HUD) regulates LBP in target housing that is federally owned and target housing receiving federal assistance. Requirements vary with the age of the structure and type of HUD assistance.
OSHA does not define a specific hazardous level of lead in paint: any concentration of lead triggers some portion of the standard. OSHA’s construction standard requires specific respiratory protection based on how the lead-containing material will be disturbed. This is most often referenced in personal injury lawsuits, during victims’ appeal for compensation. Initial exposure monitoring is required to evaluate representative eight-hour TWA exposures.
Mercury is used in many types of equipment and devices including batteries (smoke detectors, emergency lighting systems, elevator control panels, etc.); lighting (fluorescent and high intensity discharge lamps and “silent” wall switches); heating, ventilating, and air conditioning (HVAC) systems (thermostats, fire stats, manometers, thermometers); and switches (sump pumps, pneumatic controls).
The EPA regulates mercury as a hazardous waste. A spill of just one pound of mercury (a little more than one fluid ounce) triggers a federal reporting requirement. Mercury spills are difficult to clean up, making it easier to identify and remove mercury-containing building materials prior to demolition and dangerous urban renovation activities.
Polychlorinated Biphenyls (PCBs)
PCBs are mixtures of synthetic organic chemicals that are non-flammable, chemically stable and have high boiling points and good chemical insulating properties. They were used in hundreds of industrial and commercial applications including electrical, heat transfer, and hydraulic equipment; as plasticizers in paint, plastics and rubber products; and in pigments, dyes and carbonless copy paper. The EPA banned certain uses (i.e., plasticizers, adhesives, paints and waterproofing) in 1973 and banned U.S. PCB production in 1979; however, PCBs may still be present in older transformers, capacitors, and light ballasts.
Recently, the EPA learned that caulk containing PCBs was used in buildings in the 1950s through the 1970s. Based on construction dates of schools and commercial buildings, as many as 60 percent are estimated to have caulk containing PCBs. PCBs may be found throughout building structures including windows, doors, vents, walls and possibly school sidewalks. PCBs may leach and contaminate indoor air, masonry and other building materials they contact.
The EPA considers PCBs hazardous waste and requires proper disposal.
Chlorofluorocarbons and Radioactive Sources
Chlorofluorocarbons and other ozone-depleting substances used in stationary refrigeration and air-conditioning systems must be recovered by technicians certified according to EPA regulations. Additionally, smoke detectors and some exit signs contain radioactive sources. Disposal of radioactive sources in these items is regulated by local and state governmental authorities.
Aggressive Inspection and Identification
Regardless of which hazardous material(s) are encountered on a project, identifying and remediating their presence is the best way to ensure a restoration project proceeds smoothly. Such measures include:
Identify the locations of hazardous materials. Suspect ACM and LBP must be sampled and analyzed to confirm their presence, while other materials can be visually identified and quantified.
Evaluate the material’s condition and understand factors that may affect condition and potential exposure. Inspect deteriorating material that may be prone to cause work casualties from weak structural bases.
Determine what local, state and federal regulations apply to the project.
Remove any known damaged or suspected hazardous building materials.
Prepare, implement and maintain an operations and maintenance (O&M) plan to manage hazardous building materials that remain in the building.
Notify building occupants and maintenance and custodial staff of the location of hazardous building materials and how to avoid disturbing or damaging them.Every renovation and/or remodel project has its challenges; however, it is important in each to implement proactive, practical measures in the identification and remediation of potential hazardous materials to minimize risk and maximize safety for everyone involved.
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