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EPA Building Air Quality Guide-1991

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Asbestos 149 After the material is identified, the build- ing management and staff can then insti- tute controls to ensure that the day-to-day management of the building is carried out in a manner that prevents or minimizes the release of asbestos fibers into the air. These controls will ensure that when as- bestos fibers are released, either acciden- tally or intentionally, proper management and clean-up procedures are implemented. Another concern of EPA, NIOSH, and other Federal, State, and local agencies that are concerned with asbestos and public health is to ensure proper worker training and protection. In the course of their daily activities, maintenance and service work- ers in buildings may disturb materials and thereby elevate asbestos fiber levels and asbestos exposure, especially for them- selves, if they are not properly trained and protected. For these persons, risk may be significantly higher than for other building occupants. Proper worker training and protection, as part of an active in-place management program, can reduce any unnecessary asbestos exposure for these workers and others. AHERA requires this training for school employees whose job activities may result in asbestos distur- bances. In addition to the steps outlined above, an in-place management program will usually include notification to workers and occupants of the existence of asbestos in their building, periodic surveillance of the material, and proper recordkeeping. EPA requires all of these activities for schools and strongly recommends that other build- ing owners also establish comprehensive asbestos management programs. Without such programs, asbestos materials could be damaged or could deteriorate, which might result in elevated levels of airborne asbes- tos fibers. While the management costs of all the above activities will depend upon the amount, condition, and location of the materials, such a program need not be expensive. PROGRAMS FOR MANAGING AS- BESTOS IN-PLACE In some cases, an asbestos operations and maintenance program is more appropriate than other asbestos control strategies, in- cluding removal. Proper asbestos manage- ment is neither to rip it all out in a panic nor to ignore the problem under the false pre- sumption that asbestos is "risk free." Health concerns remain, particularly for custodial and maintenance workers. In-place management does not mean "do nothing." It means having a program to ensure that the day-to-day management of the building is carried out in a manner that minimizes release of asbestos fibers into the air, and that ensures that when asbestos fibers are released, either accidentally or intentionally, proper control and clean-up procedures are implemented. Such a pro- gram may be all that is necessary to control the release of asbestos fibers until the as- bestos-containing material in a building is scheduled to be disturbed by renovation or demolition activities. The first responsibility of a building owner or manager is to identify asbestos- containing materials, through a building- wide inventory or on a case-by-case basis, before suspect materials are disturbed by renovations or other actions. The Asbestos Hazard Emergency Response Act (AHERA) program requires that in schools an inventory of asbestos materials be done by properly accredited individuals. Starting in late 1991 or 1992, there will also be a requirement that if an inventory of asbestos materials is done in public and commercial buildings, the inventory must be done by properly accredited individuals. In public and commercial buildings facing major renovations or demolition, inspections for the presence of ACM are required, accord- ing to the 1990 revision of the EPA Asbes- tos NESHAP. A carefully designed air monitoring program can be used as an ad- junct to visual and physical evaluations of the asbestos-containing materials.

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