The following procedures are for drilling holes through asbestos-containing materials (ACM). If utilized correctly, these work procedures will keep exposure levels below the permissible exposure limit (PEL) and excursion level (EL) of 0.1 f/cc and 1.0 f/cc respectively. This is based on previous air monitoring data developed by numerous industry sources.
The abatement procedure involves drilling holes into the ACM through an upside-down waxed paper cup filled with shaving cream. The use of a waxed paper cup (such as a Dixie Cup) is recommended due to the fact that the drilling activities can cause styrofoam cups to disintegrate. The shaving cream collects the asbestos-containing debris and does not allow it to become airborne.
RecommendationsTo facilitate the proper cleanup of the drill bit and the impacted asbestos area, Wonder Makers Environmental recommends these steps:
- Center a wet paper towel over the end of the cup.
- After placing the drill bit through the paper towel, and then through the cup, add the shaving cream.
- Completely fill the cup with shaving cream to ensure there are no air gaps.
- When drilling into ceilings, or above your head, fill the cup over the brim to maintain a good seal.
- After drilling, use the wet paper towel to clean off the drill bit flutes as you slowly remove it from the cup. If the paper towel is long enough (has not been contaminated), you can use it to wipe up any shaving cream/debris around the drill site.
A new cup, towel, and clean shaving cream must be used with each hole drilled. All old cups, paper towels and other debris generated from the drilling are to be treated as asbestos waste and placed in two six-mil disposal bags with the appropriate labels.
PPE requirementsPersonal protective equipment needs vary depending on the type of ACM being impacted. If thermal system insulation or surfacing materials are being disturbed, then a minimum of a half-facepiece respirator with P100 filters must be used.
PPE requirements for miscellaneous materials typically would not require a respirator, but this must be decided on a case-by-case basis. A competent person has to make the determinations for the proper PPE requirements for each type of ACM impacted.
Eye protection requirements demand that safety glasses or full-face respirators be worn at all times during the drilling operations.
TrainingOSHA training requirements (29CFR1926.1101) depend on the type of work being done:
- For OSHA Class I work, the training requirements are 32 hours for workers and 40 hours for supervisors/competent persons.
- OSHA Class II work requirements are a minimum of eight-hour task-specific training for workers and 40 hours for supervisors/competent persons. This training is good for only one type of ACM, such as transite or tile or roofing.
- OSHA Class III work training requirements are a minimum of 16 hours for workers and supervisors/ competent persons.
Class II and Class III work activities may be performed by personnel with Class I training.
WarningsAll Class I, II, and III work activities are to take place in a regulated area. Ensure that the proper signs are posted at the boundary of the area which state:
CANCER AND LUNG DISEASE HAZARD
AUTHORIZED PERSONNEL ONLY
If respirators and protective clothing are required to be worn in the regulated area, the warnings signs shall include the following:
RESPIRATORS AND PROTECTIVE CLOTHING ARE REQUIRED IN THIS AREA.
Other hazardsIn addition to the asbestos PPE requirements, other hazards in the workplace pose different PPE selection criteria. Some of the hazards workers may be exposed to are noise, confined spaces, chemicals, and, in the case of drilling into sewer lines, bloodborne pathogens and methane. Again, the competent person is responsible for determining the proper PPE requirements for each job site.
The shaving cream drill procedure is a safe, effective, and common sense approach to disturbing small quantities of ACM. This method protects the workers, building occupants, the environment, and your bottom line. There is nothing "easy" about dealing with asbestos, but utilizing this method can make things somewhat easier.
David T. Woods is an environmental specialist for Wonder Makers Environmental. Call Wonder Makers at (888) 382-4154 with any questions or to help determine the proper PPE requirements for this procedure.
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