24.  How can I identify ACM?

There is no way, of course, to simply look at a material and determine whether or not it contains asbestos.  However, OSHA made it a simple matter to identify those asbestos materials that are most likely to put workers at risk of exposure to fibers.  OSHA simply ruled that these materials, by law, are “presumed asbestos containing materials” (PACMs) if they were installed before 1981:

· Sprayed-on or troweled-on surfacing material (SM),
· Thermal system insulation (TSI),
· Resilient flooring, and
· Dust and debris from PACM and known ACM.

By law these materials contain asbestos unless analysis of a bulk sample shows they contain 1% or less asbestos.

Even though your employer is responsible for:

· Telling you where asbestos is in your workplace,
· Maintaining ACM in good condition, and
· Making sure you use the controls and follow the work practices set forth in the OSHA regulations.
you still need to be able to recognize ACM to minimize your risk of exposure and to minimize the risk of asbestos fibers contaminating the air in your facility because your employer may:
· Fail to tell you where all the ACM is in your workplace (inspectors rarely if ever identify all the ACM when they make an inspection),
· Fail to maintain the ACM properly, either through negligence or because he is unaware of ever-changing conditions throughout the facility (such as when a fork lift driver accidentally hits a steam pipe and dislodges some insulation from the pipe), and as a result may,
· Fail to inform you of procedures needed to protect yourself such as procedures for clean up of asbestos spills and repair of damaged or deteriorated ACM.

You, as the person who carries out activities that may bring you into contact with asbestos, are most likely to be aware of what’s taking place and are in the best position to make sure that your employer is aware of deteriorating conditions or of ACM that he may have overlooked.  Since, in the final analysis, we’re all ultimately responsible for our own safety, it’s only fair that you be given information needed to recognize when a potential hazard exists in your workplace and what to do to eliminate it.

If you see troweled-on plaster on a wall or ceiling, for example, that’s cracked, peeling, or crumbling, you need to tell your supervisor right away so the area can be properly decontaminated and the plaster repaired.  Otherwise, even though there may be no visible accumulation of dust or pieces of debris in the area, asbestos fibers can be released over time and migrate throughout the building.

SM and TSI installed before 1981 are PACMs because they:

· Are widely prevalent,
· Contain asbestos fibers that are loosely bound and easily released,
· Are easily damaged, and are readily accessible as a rule.

27.  How can I identify surfacing material?
 

The main use of SM has been for fireproofing.  Look above the ceiling tiles for fireproofing sprayed onto steel beams and decking. This material was frequently a mixture of asbestos fibers, vermiculite, and binder.  Vermiculite consists of hydrous silicates that expand markedly when they are heated.   Amosite was the type of asbestos generally used in sprayed-on fire proofing.  This is not normally accessible but you may be called upon to clean up small spills of this material.

Fibrous, fluffy SM has been applied to ceilings, pillars, and walls for soundproofing and to form nice, soft-looking decorative surfaces.  These materials are usually white but sometimes they are colored or look like brown mud.

Acoustical plaster may be covered by ceiling tiles or with a paper jacket that may be painted any color.  Acoustical plaster is specially formulated and sprayed or trowelled on.

Plaster, even hard plaster, is considered to be surfacing material and must be presumed to contain asbestos if installed before 1981.  Plaster is a pasty composition made up largely of water, lime, and sand that hardens on drying and is used for coating building components such as walls, ceilings, and partitions. Browncoat plaster, also called “scratch coat”, is a base coating of plaster, usually applied over perforated plaster board, wooden lath, or wire mesh.  Topcoat plaster is a surface finish layer that is usually white and smooth and may contain sand to produce a grainy surface.

On the other hand, plasterboard is not PACM.  Plasterboard is a board used in large sheets as a backing or as a substitute for plaster in walls and consists of several plies of paper, fiberboard, or felt, usually bonded to a hardened gypsum plaster core.  It’s also called gypsum board, drywall, wallboard, and sheetrock.  While the plasterboard itself seldom contains asbestos, there is usually asbestos in the joint compound, spackling compound, and tape used to produce a smooth surface.  These materials are not PACM, either.

Stucco is a fine plaster used in the decoration and ornamentation of interior wall.  Stucco made of Portland cement, sand, a small amount of lime, and occasionally some asbestos, has been applied to form a hard covering for exterior walls.

Apparently not.  Occupants have been concerned in the past that fibers are picked up as the air flows over the decking and are carried throughout the building.  It’s unlikely that this is a problem.  Studies show that even in buildings where ceiling decks are covered with damaged, non-intact, sprayed-on materials containing 10 to 20% asbestos and where the space between the suspended ceiling and the deck serves as a return air plenum, fiber concentrations do not exceed background.

Look for TSI on steam pipes, elbows, valves, and on boilers as well as on hot water tanks and hot water lines.  Insulation on pipes, elbows, etc., requires an external covering to provide protection against entry of water and other liquids and against mechanical damage; e.g., a coating such as paint, a membrane such as paper, or sheet material such as fabric, metal or plastic.  TSI may also be cardboard-like pipe wrap or a papery covering.

If a hot water tank was installed before 1981, assume the tank insulation and the insulation on the pipes contain asbestos.  If there are patches on the tank, assume the patches contain asbestos if the patching was done before 1981.

In the same boiler room, one pipe may have asbestos insulation and insulation on another pipe may have no asbestos in it; one patch may contain asbestos and another may not.

Since it inhibits heat transfer, TSI is used to prevent condensation on cold water systems and HVAC systems.  Duct insulation is usually a thin layer and is often painted to match the room.  It may be also be covered with paper, cloth, or metal.

There’s no problem identifying resilient flooring.  Resilient flooring includes:

· Asphalt, rubber, and vinyl asbestos tile
· Latex backing on tile and sheet flooring
· Rubber and vinyl felt backing on sheet flooring
· Asphaltic cutback adhesive

Latex adhesive, linoleum and the wear layer of vinyl sheet flooring have never contained asbestos.

Asphalt, rubber, and vinyl asbestos tile come in 9” x 9” or 12” x 12” squares.  Asphalt tile is typically dark colored, but light colors are also available.  Before 1981, about half the 12” x 12” tiles and nearly all 9” x 9” tiles contained asbestos.  Asbestos was also used in the backing material on some sheet goods and linoleum and some asphaltic “cutback” adhesives to make them more durable.  Sheet vinyl flooring comes in 6’ and 12’ widths.

You can’t tell if flooring contains asbestos just by looking at it.  Many flooring materials look the same, whether they have asbestos in them or not.  Tiles made by different companies are made to look the same so they can be used interchangeably.  Tiles with 10% asbestos may look exactly the same as tiles with 30% asbestos or as tiles with no asbestos at all.

Cutback adhesives are easy to identify because they are black.  Most asphaltic cutback adhesives manufactured today do not contain asbestos.

OSHA classified resilient flooring as PACM because:

· Resilient flooring is probably the most prevalent asbestos-containing building material.
· Although resilient flooring is not as easily damaged as TSI and SM, it is frequently damaged and is frequently subjected to abusive practices such as mechanical buffing and stripping.
· It is accessible.

Dust and debris traceable to TSI or SM or other known ACM that is deteriorated or damaged is PACM.  It’s relatively easy to spot dust and debris in areas where accessible TSI or SM or other ACM that is deteriorated or damaged is present. If you see any of these signs of deterioration, presume the dust and debris at the site contain asbestos and tell your supervisor repairs are needed:

· Surface is crumbled, cracked, peeling, or blistered
· Material is delaminated or showing adhesive failure
· Surface is gouged, crushed, punctured, marred, or abraded
· Material is water stained
· Jackets are missing on thermal insulation
· Material is hanging from the surface

If you come in some morning and see TSI on the floor because a hot water pipe has been damaged, you need to report this to your supervisor immediately so the insulation can be cleaned up promptly to prevent release of asbestos fibers in your workplace and throughout the building.  You must presume that all visible dust associated with the damaged insulation also contains asbestos and treat it accordingly using wet methods and a HEPA vacuum to remove it and promptly disposing of the collected dust.

No.  Ceiling tiles may have asbestos in them but OSHA has not designated ceiling tiles as PACM for these three reasons:

· Asbestos-containing ceiling tiles are not as prevalent as TSI and SM, although a lot of acoustical ceiling tile that contained asbestos was installed in schools in the 1950s through the 1970s.
· The asbestos fibers in ceiling tiles are more tightly bound than in TSI and SM.
· Ceiling tiles are not as easily or frequently damaged and are not as susceptible to deterioration as TSI and SM.

If you have reason to suspect ceiling tile contains asbestos, OSHA requires that your employer use “due diligence” and have a bulk sample collected and analyzed.  Acoustical ceiling tile typically contains about 10% amosite.

The building owner needs to tell contractors of the presence of asbestos in their work areas and make sure that contractors are complying with OSHA asbestos regulation.  If, for example, you see telecommunication workers dislodging asbestos-containing fireproofing from deckings and scattering it all over the place when they string wires in the space between drop ceilings and deckings, you need to tell your supervisor so the job can be brought to a halt.

This notification should be signed by the contractor who employs the workers and returned to the owner for documentation of the notification.