Why does MOORING require an asbestos-containing building material (ACBM) report prior to the demolition of certain building materials?
1. It’s to keep our clients safe.
2. It’s to keep our people safe.
3. It’s the law (federal and state).
Many disaster restoration companies will tear out drywall, floor tiles, and other building materials without an asbestos report. The fact is, it’s irresponsible, it’s potentially unhealthy, and it’s illegal.
When should an asbestos-containing building material (ACBM) report be presented?
Many times, customers advise that a building has only been built recently, and there is no asbestos in it. While this certainly seems reasonable, the fact is, that some contractors do not always install the specified building materials. Many drywall boards, for example, are manufactured abroad and do in fact contain asbestos. If a statement of record is available from the design professional (architect or engineer) and states that no ACBM is present, additional testing may not be required.
The Code of Federal Regulations (CFR), Title 40, Chapter 1, Part 61 National Emissions Standards for Hazardous Air Pollutants (NESHAP) require that buildings be thoroughly inspected for ACBM prior to demolition. States may prescribe more stringent guidelines, but they cannot prescribe below federal standards. For example, Texas utilizes The Texas Asbestos Health Protection Rules (TAHPR) in addition to the federal regulations. These regulations are thoroughly enforced, and, as a highly insured, Certified Mold Remediation Contractor (CMRC), IICRC Certified Restoration Firm, NADCA Certified Air Duct Cleaning Contractor, licensed general contractor, and licensed HVAC contractor, MOORING complies with all regulatory agencies.
What does an ACBM report assess?
MOORING engages the services of independent industrial hygienists who are state-licensed to conduct asbestos testing. The industrial hygienist takes limited samples of the building materials in question and sends them to a laboratory for analysis. These results are typically delivered quickly, the cost is negligible and typically covered under the insurance claim, and the building air quality does not suffer from “waiting” for demolition approval.
Occasionally, during large-scale emergencies, demolition or renovation projects may be exempted from asbestos testing by order of the United States Environmental Protection Agency. Otherwise, testing must be performed each and every time.
So, what happens if you don’t have an ACBM test, asbestos is present, and you get caught?
The employer has a duty to ensure that no employee is exposed to an airborne concentration of asbestos in excess of 0.1 fiber per cubic centimeter of air as an eight (8) hour time-weighted average (TWA), as determined by the method prescribed in Appendix A, or by an equivalent method. Bottom line, this is not a place you want to find yourself as an employer, owner, or representative. Aside from damaging the health of other people and yourself, you
can receive a recordable asbestos citation. In Texas, for example, violation of any portion of the TAHPA can result in fines of up to 10,000 dollars per day.
Important to remember…
Although demolition will not occur until a negative ACBM test is obtained, the environment of the building will be stabilized to maintain indoor air quality and prevent microbial growth. This is accomplished through various means including air movement, dehumidification, air scrubbing, and potentially the introduction of desiccant air.
What can you do to get ahead of a potential casualty to your building?
Consider obtaining ACBM tests to have on record for your files now instead of when an event occurs. If you can get a statement of record from your architect or engineer, make sure to keep that in your emergency file. If no such statement exists, contact MOORING or an independent industrial hygienist to get an ACBM report on file. Doing so will save you time in the event of an emergency.