When the term asbestos is used it is often associated with images of floor tile in basements, pipe insulation in a warehouse, or vermiculite in attics. One place that is often left is office buildings. From the late 1800s until the late 1970s asbestos was widely used in common building materials. These materials can be found in industrial, residential, and commercial settings. In this blog, we will be focusing on asbestos-containing materials (ACM) in offices and other commercial settings and how it can be managed.
As asbestos was used in various office building materials it can be found in numerous locations of an office building. In mechanical areas, thermal system insulation such as asbestos-containing pipe insulation, boiler insulation, and gaskets may be present. Spray on fireproofing may also be observed in these spaces. Flooring materials such as vinyl floor tile, linoleum, and rarely in the grout or adhesive of ceramic tiles may contain asbestos. Asbestos can also be found in ceiling materials such as ceiling tile and textured or popcorn ceilings. Wall materials such as drywall, drywall tape and joint compound, plaster, or wall tile adhesive or grout can also be asbestos-containing. Fire doors in commercial spaces may also contain asbestos. These are just a few examples of possible asbestos-containing materials and should not be seen as a comprehensive list.
While asbestos-containing materials are thought to have been banned or phased out in the late 1970s, this is a common misconception. In 1989, The EPA, under the Toxic Substances Control Act (TSCA) and the Clean Air Act (CAA), as well as the Consumer Product Safety Commission (CPSC), banned certain uses of asbestos and also prevented newer uses of asbestos. This 1989 Partial Ban included: Asbestos Pipe Insulation, and Block Insulation, Spray-applied Surfacing Materials, Corrugated Paper, Rollboard, Commercial Paper, Specialty Paper, Flooring Felt, Wall-patching Compounds, Artificial Fireplace Embers, and new commercial uses after August 25, 1989.
This did not ban the use of asbestos in other materials, and due to this, some items used after the 1970s may possibly contain asbestos in modern office spaces. In 2019, the EPA issued the Final Rule which effectively restricts uses of asbestos in materials that were not subject to the 1989 Partial Ban. This restriction is not a ban, but allows the EPA to evaluate the non-banned products containing asbestos, before they can be produced or sold in the U.S. These restrictions include the following products that can be commonly found in commercial buildings: adhesives, sealants, roof and non-roof coatings, roofing felt, cement products, and vinyl-asbestos floor tile. The complete list of restricted materials can be found here: https://www.epa.gov/asbestos/list-uses-covered-under-april-2019-final-rule-restrictions-discontinued-uses-asbestos
Public buildings such as office spaces or residential buildings with 4 or more dwelling units are regulated by National Emission Standards for Hazardous Air Pollutants Compliance Monitoring (NESHAP) and additional regulations and requirements may be enforced by local city, county, and state regulatory agencies. This rule requires that testing of materials in these properties are done by a licensed and certified asbestos inspector. This also regulates the removal of these materials during a demolition and renovation of the property and requires a specific set of work practices. NESHAP regulations must be followed if more than 260 square feet, 160 linear feet or 35 cubic feet of asbestos-containing materials will be removed or disturbed prior to renovation or demolition activities. The Occupational Safety and Health Administration (OSHA) also regulates asbestos in commercial buildings and require an operation and maintenance for asbestos-containing materials.
Operations and Maintenance Programs (O+M Programs) are required by the EPA and OSHA. OSHA specifically protects workers who work in buildings that contain ACM, but who do not repair or remove the ACM. These rules require the owner of a building that contains suspect or known ACM to have a written O+M Program that lists all known and suspect ACM, as well as addresses the following work activities (and applicable individuals):
- Activities that are unlikely to involve any direct contact with ACM
- Individuals commonly include office/retail workers
- Activities that may cause accidental disturbance of ACM
- Individuals commonly include custodial/janitorial (such as buffing vinyl floor tile) or light facilities maintenance activities that inadvertently damage ACM (such as accidental damage of pipe insulation during routine plumbing/ventilation checks/repairs)
- Activities that involve relatively small disturbances of ACM (≤3 linear feet or ≤3 square feet)
- These small-scale, short-duration activities may include maintenance, repair, or installation that may purposely disturb ACM (such as installation of new light fixtures, glovebag operations to repair a pipe in a boiler room, etc.)
O+M Programs do not address large-scale disturbance, such as renovations or demolitions. Intentional renovation and demolition activities that disturb ACM, known as abatement, require removal by EPA-certified and state licensed workers and supervisors.
Building owners should consult and hire trained and accredited asbestos professionals for maintaining or removing ACM. If you suspect asbestos in your office building, reach out to Indoor Science to discuss your concerns with one of our licensed professionals.