21 Keys To Asbestos Visual Inspections
Specifically, it offers guidance on looking for conditions that, if not corrected during removal, repair, or O&M work, could result in the incomplete removal of residue, dust and debris. It also details how to examine a work area for evidence that a project has been successfully completed.
As "asbestos fever" has died down in recent years, it's easy to take for granted steps to minimize exposure risks. This article is intended to familiarize readers with a valuable standard relating to one critical task-visual inspections during asbestos-related work. It excerpts the recently published ASTM "Manual on Asbestos Control: Removal, Management and the Visual Inspection Process," by Andrew F. Oberta, CSP, PE. Oberta, an environmental consultant in Austin, Texas, is chairman of the ASTM task group that developed the E 1368-90 standard, and the principal author of the document.
Here are some key points raised by Oberta that relate to visual inspections (note that they do not cover initial building inspections to determine the presence of asbestos-containing material):
1. Visual inspection should begin early in an asbestos management program. It is not just looking for dust and debris at the end.
2. It is an integral part of project design and O&M programs, and should continue throughout activity until final clearance is given. Visual inspection is not a substitute for final air sampling as a method of clearance.
3. Inspectors should get involved as early as possible in an abatement project-ideally, participating in the original building survey. The inspector should know the scope of the work.
4. Inspectors should visit the job site regularly for ongoing oversight and to handle problems when they arise. The intent of ASTM E 1368 is to maintain a worksite as clean as possible on a continuing basis.
5. The inspector begins surveillance as the work areas are being prepared. This includes construction of barriers and protecting surfaces inside the enclosure. Surveillance is maintained during the removal phase to detect conditions that could lead to breaching critical barriers and contaminating occupied areas of the building.
6. Two visual inspections are required by the standard at the conclusion of a project. The first is for completeness of removal, and the second covers completeness of cleanup.
7. The standard requires inspectors to be available and prepared on reasonable notice when the contractor is ready for the visual inspections. The inspector, not the contractor, should set the tone and pace of the inspections.
8. Temporary lighting provided by contractors inside enclosures is usually inadequate for visual inspections. These require looking closely at surfaces with a strong light to detect minute amounts of material.
9. The inspection for completeness of removal requires the inspector to get close enough to the surface from where the asbestos-containing material was removed to touch it. Inspectors go everywhere abatement workers have gone.
10. The ASTM standard advises the inspector to pay attention to areas that are difficult to see.
11. But remember, under no circumstances should an inspector be responsible for supervising final cleanup.
12. To pass the inspection for completeness of removal, there must be no material or residue remaining on the surfaces from which the asbestos-containing material was removed, according to the standard.
13. How clean is clean? The standard states that all friable material is to have been removed. Complete removal according to the specification is the objective.
14. The standard requires a visual inspection for completeness of removal before cleanup begins, regardless whether the work is abatement, O&M, or a removal task.
15. During the inspection for completeness of cleanup, the contractor provides the same assistance as for inspection for completeness of removal. This includes furnishing ladders, scaffolding, and lights, as well as workers with cleaning materials.
16. No residue, dust, dirt or debris should be visually detectable on the final inspection of the work area.
17. ASTM E 1368 covers Operations and Maintenance in a much more limited scope than removal work. For O&M, the standard says visual inspections can be performed by a foreman or supervisor. Oberta says it's important that the inspection is done by someone other than the person doing the removal or O&M work.
18. In his book, Oberta says applying ASTM E 1368 to O&M instead of abatement is a matter of degree. Anything that can go wrong during an abatement project can go wrong during O&M, he says.
19. Inspectors must comply with all applicable regulations for respiratory protection, protective clothing, and safety.
20. The EPA AHERA regulations do not define visual inspections procedures or criteria in any detail. ASTM E 1368 represents a standard of care set by participants in the asbestos abatement industry. It should not be used as minimum requirements, but as a basis for building your approach to asbestos visual inspection.
21. OSHA's 1994 final rule on asbestos in construction covers four types of abatement work and O&M activities with detailed methods of compliance. You should study these regulations carefully to decide how the use of ASTM E 1368 might be affected.
The standard is being revised to reflect developments in the industry since its publication, including more emphasis on O&M as well as recent EPA and OSHA regulations. The updated version is expected to be published in 1996.
For more information on ASTM E 1368, the "Manual on Asbestos Control", and the "ASTM Standards for Asbestos Control" training courses, call ASTM at (610) 832-9585.