Asbestos Tidbid for July

Hi everyone! Vern, Jr. here.

I trust you all had a happy and safe Independence Day…

Allow me to take this opportunity to announce that I will be taking over the monthly tidbit festivities. Vern Sr. is doing fine and will be pulling back a little. He has prepared me extremely well to fill his shoes, and I get the feeling he’ll be wearing flip-flops a little more often nowadays, but we will still be in contact (most of the time!)…

I have been teaching the lion’s share of our classes in the past year, and I am very excited about the prospect of developing a solid and trusting intellectual relationship with each and every one of you. I am grateful for the opportunity to serve your training and coaching requirements, and I look forward to providing you with the level of service and expertise you have naturally come to expect from Vern Roberts Environmental Training, Inc.

As many of you know, we have moved from the Treasure Island location to 4902 113th Ave N., Clearwater, FL 33760. We are at the north end of the building (Emerald City Comics) and it is about a mile or two from I-275.

Recently, I was asked to clarify a few points about who’s responsibility it is to notify building occupants about an upcoming abatement project under a few different scenarios. The questions regarding notification requirements are as follows:

Are there any specific notification requirements for doing abatement in an occupied building for the following scenarios:

A) If the abatement is to occur during working hours (when occupied)
B) If the abatement is to occur after hours when no employees should be present
C) if the abatement is to occur after hours and there is a chance a few employees could be there

These questions are answered a few different ways…
My first response would be to ascertain the class of work involved. Assuming that the idea of setting up a containment points to Class I work (the REMOVAL of Thermal System Insulation or Surfacing Material), I would automatically submit the required 10-day notification to the local NESHAP office. As for the building occupants, it is the responsibility of the building owner to notify these folks. As a Contractor, prior to beginning the project, I would ask the building owner to set up a meeting with the various occupants. I would participate in the meeting and serve to field questions from the occupants and explain what is about to take place. This might not be within the building owner’s area of expertise.

A “Regulated Area,” defined under OSHA 1926.1101 as “an area established by the employer to demarcate areas where Class I, II, and III asbestos work will be conducted, and any adjoining area where debris and waste from such asbestos work will accumulate…” is the area an asbestos contractor considers his own, and NO unauthorized persons are allowed to enter. As such, there are NO requirements to the occupants other than the DUTY of the OWNER to notify the occupants about the presence of a hazardous or toxic substance in the building they are occupying.

Refer to 1926.1101(k)(2)(iii) A, B, and C; also 1926.1101(k)(2)(ii) D

It sounds complicated, but it might be a topic of discussion in of my upcoming refreshers… 🙂

Please check the website Home Page for dated and times. Since your schedule might be tight, I can always adjust my schedule to accommodate yours.

If all else fails, call me on 727-239-1445 to set it up. I look forward to hearing from you!!!

Stay Safe…

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