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Previous by Date: Subject: Re: Asbestos management Date: Sat, 27 Sep 2008 21:56:36 -0400 Author: Peter Zavon |
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My experience is primarily in art and theater portions of the campus where I recommend absolutely complete surveys because art faculty and students bang huge sculptures into insulated pipes or hang them from pipes. Theater riggers climb into every crevice all the way up to exposed beams. Both art and theater artists are likely to accidentally (or on purpose) drill or bang holes into floors or walls. They find unsecured utility rooms and use them for storage or studios. They hold pot parties in confined spaces (even found evidence of this once in a large air supply plenum under the theater!!) etc., etc. There is no potentially hazardous thing I have not found them doing. Science students and faculty are usually more demure, but a complete survey is really not a big deal. We all know how to read a set of mechanical drawings to follow the pipes. If there aren't any, we can sketch them onto a full floor plan. If the pipes were installed before the ban, a little piece of an elbow and another from the straight run sent to a certified lab and $25 each ($15 each if you work a deal) will get you answers. If that becomes too expensive because there are too many, PACM labels go on the pipes. When you are done, you shouldn't see any insulated pipe that is not labeled one way or the other. Making a survey of the other sources is equally simple. We all know what possible asbestos materials look like: old 9 x 9 and 12 x 12 vinyl tiles almost surely are (I been informed by Peter Zavon who used to work for a tile manufacturer, that both are equally likely to contain asbestos), old fume hoods and lab counters built with Transite, sprayed or troweled on stuff on exposed beams, insulation on old ovens and other lab equipment from braided rows of asbestos fibers around doors to fiber blanket or textile-like materials, any old electrical equipment with a white fuzzy surfaces (which I still find in abundance on old theater lights in some schools), all that stuff. You all know it when you see it. Mark it down on the survey or pitch it. If I were EPA, I'd sock to any school that didn't have a pretty complete survey. I just can't see a good reason not to do it all. Monona Rossol, M.S., M.F.A., industrial hygienist Arts, Crafts &Theater Safety, Inc. and Safety Officer, United Scenic Artist's, Local USA829 International Alliance of Theatrical Stage Employes (IATSE) 181 Thompson St., #23 New York NY 10012-2586 212/777-0062 artscraftstheatersafety.org In a message dated 9/27/2008 10:14:06 PM Eastern Standard Time, pzavon**At_Symbol_Here**ROCHESTER.RR.COM writes: > -----Original Message----- > >From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] > >On Behalf Of Gary M. Kehoe > >Sent: Saturday, September 27, 2008 1:20 PM > >To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU > >Subject: [DCHAS-L] Asbestos management > > > > > >Please excuse the cross-posting. We are in the process of > >revising our asbestos management procedures and was wondering > >how our peer companies comply with the OSHA requirements to: > >1. ".determine the presence, location, and quantity > >of ACM and/or > >PACM at the work site." (1901.1001(j)(2)(i) > >2. ".maintain records of all information required to > >be provided > >pursuant to this section and/or otherwise known to the > >building owner > >concerning the presence, location and quantity of ACM > >and PACM in the > >building/facility." 1910.1001(j)(2)(ii) > > > >In an earlier post I asked about performance of comprehensive > >inspections and received 3 replies that generally indicated > >full surveys were not practiced but focused inspections were > >done prior to disturbance which appears practical but may not > >be OSHA compliant. So, if you are in that ballpark, how do > >you maintain compliance with the regs referenced above? > > > >Thanks in advance for past responses and any light you can > >shine on this question. > > > >Gary M. Kehoe, CIH > >Senior Industrial Hygienist > >Midwest Generation EMG > >773-650-5732 > >312-925-1813 (C) > >312-788-5533 (F) > >
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