Over the past few weeks, we have discussed the common issues of in-house asbestos management programs. The first blog post was about medical monitoring. The second blog went in-depth about ignored training requirements. Today, this blog will discuss another common issue.
Another common deficiency is a failure to perform OSHA required personal air sampling while the staff is working. This is specified under paragraph (f) of the OSHA Construction Standard (most intentional disturbances are governed by the Construction Standard). The results of the monitoring determine the level of respiratory protection, protective clothing, personal decontamination procedures, engineering controls, and work practices that will be required for the specific project. Records of this monitoring should be kept for 30 years and be available to anyone whose exposures are represented. Thus regulatory liability exposure (in the event of an employee complaint or of OSHA inspections) from a deficiency in compliance will last at least that period of time.
Personal Air Monitoring of asbestos maintenance work has to be performed “at intervals sufficient to document the validity of the exposure prediction”. This prediction must be made before each project. The monitoring must include two types of samples. The full shift (or as much of the shift that is asbestos work) sample(s) determine the 8 hour TWA. The excursion sample is a 30 minute sample collected at the time of peak exposure.
The process is not difficult to incorporate into operations for an employer doing it daily, or for an employer with an in-house safety department. Although, for other employers the process may be daunting and relatively expensive. The pumps are about $500. A supply of cassettes must be available, and a calibration device is necessary. Samples must be sent to a qualified lab for analysis along with field blanks that would indicate any contamination in the process. A written Standard Operating Procedure should be done. It is no wonder that employers with one or two trained employees fail to implement this process.
One way to simplify the responsibilities of the employer is to utilize the services of an asbestos laboratory that will loan or rent the necessary equipment. Typically the renter’s obligation is to use the lab’s analysis services. The lab will provide sampling pumps, sampling media (in this case cassettes with MCE filters), calibration devices, and sampling protocols. If this option is chosen it simplifies the employers management of the OSHA responsibility for a modest cost, and includes some expert advice in the event in-house skill sets become rusty in the long intervals between sampling sessions.
META Environmental does not rent equipment. However, we do provide asbestos air sampling services and on-site immediate analysis. We can also prepare written standard operating procedures and training for the in-house staff performing the function.