Yesterday I completed my annual 8-hour Asbestos Hazard Evulaution Specialist Refresher training; a requirement in the State of Ohio to maintain your certification. The training was as expected, with the exception of a topic brought up at the beginning of the class. Representatives from the Ohio Environmenal Protection Agency (OEPA) and Ohio Department of Health (ODH) were both in attendance, also for the purpose of renewing their respective certifications. Before we began the prescribed agenda for the day, the representatives announced a shift in Asbestos Emission Control regulations (Ohio Administrative Code (OAC) Chapter 3745-20), that will become effective by early March 2012.
Changes of particular interest include a couple of definition revisions which will have a significant impact on demolition and rehab/renovation contractors.
Changes of particular interest include a couple of definition revisions which will have a significant impact on demolition and rehab/renovation contractors.
- The definition of "facility" formerly held and exemption for "residential buildings having four or fewer dwelling units." This language has been struck from the definition of a facility, and the following language has been added: "..any operation involving the renovation/demolition of multiple residential structures identified by an owner or operator within a scheduled period of time." Translation: single family residential structures are no longer exempt if they are part of a larger project involving the demolition or renovation of multiple single family residences.
- The definition of "friable asbestos material" has been updated with the following language: "Any category I or category II asbestos containing material that becomes damaged from either deterioration or attempts at removal or abatement resulting in small fragments the size of four square inches or less shall also be considered friable or RACM." Translation: if you're renovation/demolition activities are going to reduce any ACM to a size of four square inches or smaller, that ACM is now considered friable, or Regulated ACM (RACM), and must be disposed of as such.
These changes will have have an effect on any contractor involved in a demolition or rehab project, but I felt it was appropriate to discuss in this forum due to the impact it will have on our affordable housing developers. Be prepared to allocate more funds to pre-demolition/rehab asbestos abatement activities. Your single family dwellings may no longer be exempt by definition of "facility." Also, if you don't abate your ACM, your activites are now going to make the ACM friable, and you're going to contaminate your entire debris pile with RACM. This will result in much higher disposal costs.
For more information, check out all of the rule changes here:
http://www.epa.ohio.gov/Default.aspx?tabid=2906#3745-20
For more information, check out all of the rule changes here:
http://www.epa.ohio.gov/Default.aspx?tabid=2906#3745-20
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Comments for Changes for Ohio Asbestos Emission Control Regulations