OSHA's General Duty Clause states employers have a duty to provide a workplace and work that are safe and healthful to their employees. Employers are not supposed to expose employees to airborne asbestos fibers above OSHA's permissible exposure limit (PEL) or excursion limit (EL).
It is important to know the employer must not use employee rotation as a means of compliance with OSHA's PEL or EL limits.
It's important to know that before work in areas containing asbestos-containing material (ACM) and potentially asbestos-containing material (PACM) is begun; employers must identify the presence, location, and quantity of ACM, and/or PACM through tests, evaluation, and sample collection. The tests, evaluation and sample collection must be conducted by an accredited inspector or by a Certified Industrial Hygienist (CIH).
When an employer knows that employees may be exposed to asbestos above the 8-hour PEL or 30-minute EL, it is important they develop and deploy an Asbestos Safety Program. Let's discuss some of the most important components of the Asbestos Safety Program.
The employer must have an accredited asbestos inspector or CIH test, evaluate, and perform sampling to assess workplaces covered by the standards to determine if asbestos is present and if the work will generate airborne fibers.
It's important that the assessment be conducted only by a properly trained and accredited asbestos professional (inspector). It is crucial to have materials tested by an accredited asbestos testing lab for definitive analysis because asbestos can be positively identified only with a special type of microscope.
It's important to evaluate the effectiveness of the Asbestos Safety Program to make sure OSHA, EPA, and state regulations are met. A good tool to use in evaluating the company's program is OSHA's Asbestos Self Inspection Checklist.
Employers should determine employee exposure to airborne asbestos by monitoring within the “breathing zone.” The breathing zone is an area within 12 inches of the employee's nose and mouth. Air samples indicate:
Initial Monitoring: Employers should conduct initial monitoring if employees are, or expected to be, exposed to airborne asbestos at or above the PEL/EL.
Additional Monitoring: After initial monitoring, the employer should continue monitoring as frequently as necessary to assure accurate measurements. Conduct monitoring at least every six months if the employer expects employees to be exposed at or above the PEL/EL.
Changes in monitoring frequency: If the results of periodic monitoring statistically (repeatedly and accurately) indicates employee exposures are below the PEL/EL, the employer may discontinue the monitoring of affected employees.
Changes in operations: The employer should begin additional monitoring if:
Notifying employees: The employer should notify the affected employee individually or by posting the results in an accessible area. The notification must:
Observation of monitoring: The employer should provide affected employees and their designated representatives an opportunity to observe any monitoring of employee exposure to asbestos conducted.
When observation of the monitoring of employee exposure to asbestos requires entry into an area where the use of protective clothing or equipment is required, the observer must:
Hazard Communication: Proper hazard communication and demarcation with warning signs containing specified language in areas that have exposures above the PEL/EL is necessary. The same hazard communication provisions will protect employees who perform housekeeping operations in all three industries covered by OSHA standards.
Housekeeping Employees: Housekeeping employees, regardless of industry designation, should know whether building components they maintain might expose them to asbestos. Employees who perform housekeeping activities during and after construction activities are covered by OSHA's asbestos construction standard, 29 CFR 1926.1101. Building owners are often the only and/or best source of information concerning the presence of previously installed asbestos containing building materials. Therefore, they, along with employers of potentially exposed employees, must covey information and educate their employees.
For employers in general industry, construction and shipyard operations, a Medical Surveillance Program is required for all workers who are or will be exposed to airborne concentrations of fibers of asbestos at or above the PEL/EL.
Questionnaires: Employees will complete medical questionnaires detailed in OSHA standards 1910.1001, 1926.1011, and 1915.1001 Appendix D if they are or will be exposed to airborne asbestos hazards above the PEL. These employees will also be included in their employer's medical surveillance program.
Examination: Employers need to provide a pre-placement exam before the employee begins work. Periodic examinations may also be required. The employer should make sure all medical examinations and procedures are performed by or under the supervision of a licensed physician. Here are some important points to remember about examinations:
On multi-employer worksites, an employer performing work requiring a regulated area should inform other employers of the following:
The Creating/Controlling Employer: The contractor who creates or controls the source of asbestos contamination should abate the hazards. For example, if there is a significant breach of an enclosure containing Class I work, the employer responsible for erecting the enclosure should repair the breach immediately.
In addition, employers should comply with applicable protective provisions to protect their employees. For example, if employees working immediately adjacent to a Class I asbestos job are exposed to asbestos due to the inadequate containment of the job, their employer should either:
Other employers: All employers of employees working adjacent to regulated areas established by another employer on a multi-employer work site should daily check the following to make sure asbestos fibers do not migrate to adjacent areas:
General contractors: All general contractors who expose workers to airborne asbestos are considered by OSHA to have supervisory authority over the work even though the general contractor is not qualified to serve as the asbestos "competent person."
As supervisors of the entire project, general contractors should:
Keep records on exposure measurements obtained from monitoring for asbestos for at least 30 years. Retain worker medical surveillance records for the duration of employment plus 30 years. Recordkeeping requirements also include the following:
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