An asbestos management inspection is the foundation of any facility asbestos management program. There are three general types of asbestos inspections: Limited, Management, and Project Design.
An example of the limited inspection is the collection of a few screening samples of major building systems conducted as part of a financial transaction., or limited sampling for a small renovation project.
A Management Inspection, such as a school AHERA inspection, identifies and maps all accessible suspect materials. AHERA limits its scope to interior space, so exterior materials may not be identifiable. The suspect materials are sampled to determine asbestos content or may be assumed to be asbestos containing material (ACM, >1% asbestos), depending on the needs of the facility owner or manager. Materials that may receive damage from sampling such as decorative surfaces or intact pipe coverings will often be assumed. Hidden materials not available to access by building occupants will not be part of sampling in a management inspection.
Project design inspections will be done before renovations or demolitions. This asbestos inspection will generally have more extensive sampling of materials that will be disturbed as part of the project, including accessing hidden materials inside walls, etc. It will often have more precise quantification of materials required for preparation of quality bid documents.
An accredited inspector must conduct asbestos inspections in most structures. In many states the inspector must have a state license. In some states, the inspector's employer must have state licensing and meet other requirements.
The EPA AHERA school asbestos management rules require a re-inspection every three years, limited to previously identified asbestos containing materials. The inherent shortcomings of the rule as written include perpetuating errors made in the original inspection, which have proven to be incomplete in a significant number of cases. OSHA cites a study of over 700 school AHERA inspections. This study found that over 30% of the friable surfacing was missing from the initial inspection. The reinspection also ignores the potential addition of new asbestos containing materials. Until the United States adopts a comprehensive ban this will remain a possibility. The Management Planner must review AHERA inspections and re-inspections.
AHERA also requires a review of the condition of the identified ACM every 6 months, called periodic surveillance. There are no federally specified qualifications for the staff person conducting the periodic surveillance.
The most commonly used inspection protocol is based on the AHERA sampling requirements. OSHA asbestos rules cites AHERA protocols. ASTM has also published a protocol. A few states, including Texas and Hawaii, have additional requirements.
Asbestos sample analysis is by polarized light microscopy (PLM, 400X magnification). EPA specifically recommends follow up of negative floor tile results with transmission electron microscopy (TEM, 20,000 magnification). Additionally, some states require TEM follow up on all negative floor tile and other nonfriable organically bound (NOB) materials like mastics, caulks, and adhesives. Laboratories performing asbestos analysis for AHERA must successfully participate in the National Voluntary Accreditation Program (NVLAP).
OSHA additionally recognizes the laboratory accreditation program of the American Industrial Hygiene Association (AIHA). EPA NESHAP allows a quantitative method called point counting if the visual percentage estimate of the standard PLM protocol is less than 10%. Point counting proves the material is less than 1% asbestos which in turn means it will not fall under regulation. Even if there is less than 1% of asbestos in a material, OSHA will still regulate it.
The asbestos management inspection serves as the basis for OSHA and AHERA required labeling and signage. It provides required information for employee hazard communications programs, and housekeeping and maintenance worker annual training. OSHA requires inter-employer project related notifications of presence, location, and quantity of asbestos in project areas. AHERA requires a program of asbestos location notification to outside contractors.
A project design inspection serves as the basis of regulatory agency project notifications required by EPA NESHAP for demolitions and renovations, and more stringent notifications of many state and local asbestos programs.
META Consulting LLC inspectors and Management Planners maintain licenses in several states, and are eligible for licensing in many others as needed. META provides asbestos inspection and management planning services.
