"Asbestos." Is there another word that has caused more concern, project delays and cost overruns for so many years? Even today, more than 20 years after a general ban, we are still dealing with government regulations to handle asbestos, and are still bombarded with advertisements from personal injury lawyers, promising compensation for asbestos-related health issues. In 1989 the Environmental Protection Agency (EPA) issued a final rule under the Toxic Substance Control Act (TSCA) prohibiting the manufacture, importation, processing and distribution of asbestos-containing products, but this was overturned in 1993, allowing certain asbestos-containing products to be manufactured in the U.S. Because it presents a significant health risk when released to air, asbestos is considered a hazardous air pollutant regulated under the EPA National Emission Standards for Hazardous Air Pollutants (NESHAP).
What are EPA NESHAP
Regulations and How Do They Impact Business?
EPA NESHAP are Federal Clean Air Act (CAA) regulations that apply to business owners and contractors. Asbestos NESHAP regulations address activities such as demolition, renovation, and waste disposal.
Since it has been used in building components since the 1880s, Asbestos can be found in over 3600 widely available products. In a 1988 report to Congress, the EPA found that "friable" (easily crumbled and rendered air-borne) Asbestos-containing building materials (ACBM) could be found in over 700,000 businesses.
NESHAP regulations require that prior to any renovation or demolition, an accredited Asbestos Inspector must inspect your facility for any of the 3600 asbestos-containing building materials (ACBM) in use. It is critical that you retain an experienced Asbestos Inspector who, in consult with an accredited Asbestos Project Designer, can effectively find these products.
Additional Considerations
Renovation projects can involve many other hazardous materials and safety concerns:
* Lead Based Paints;
* PCBs;
* Mercury;
* Mold/Bacteria;
* Bird/Animal wastes;
* Workplace safety, etc. .
As with Asbestos, proper hazard identification, abatement and disposal are critical. Pre-planning can eliminate budget and schedule breakers while protecting personnel and the environment.
The Scott Lawson Group, Ltd. has assisted customers with a full range of hazardous building materials management services since 1978. We can provide a comprehensive building survey identifying the type and quantity of hazardous building materials in your facility. If removal or remediation is needed, we can design a customized abatement project covering legal and regulatory compliance aspects, and ensure safe and compliant disposal of hazardous building materials. We can also provide project management oversight as "Clerk-of-the-Works" for hazardous building materials abatement during the project.
As part of this service, we routinely monitor the work of a remediation contractor to assure that it is conducted in accordance with the project's scope of work, collect appropriate samples to determine that workers are adequately protected and the environment is safe from contamination. We monitor the packaging and disposal of all project waste material to make sure that all hazardous building materials from a particular job are properly handled and disposed. For more information on how we can help, contact us today!
Scott Lawson is the founder and president of The Scott Lawson Companies, Concord, N.H.