If Senator Bob Graham had an aunt named Anna, would she be “Aunt Anna Graham”??
On with the tidbit… Osha ‘s 1926.1101 states they will not accept a composite sample from Dry wall and dry wall compound… Yet, EPA suggests a composite sample of dry wall and dry wall compound is OK.
Conflicting Agencies?? Not at all… One must understand the difference between these agencies.
Lettuce go to Osha first, The determination of asbestos in dry wall compound is done by sampling by layer… Not a composite sample… Each layer is read by PLM and the determination is made for asbestos content. Osha wants the people who may come in contact with the asbestos in the compound to be protected while they remove these systems from a building. The Asbestos Contractor, in Florida will establish a NEA on all the tasks associated with this Class 2 removal and follow waste disposal guidelines accordingly
Go to 1926.1101 and look up Osha’ position on Dry Wall and compound over nail holes and seams.
EPA on the other hand, has established rules for compositing these materials.
It is impossible to separate the two materials from each other. The composite sample can result in the material being less than 1 % asbestos thus eliminating the Neshap especially in the areas of disposal, but NOT OSHA!
Where the renovation or demolition is about to occur it would be the smart LAC to sample accordingly to the needs and regulations of these two great agencies… And the smart Florida asbestos contractor to do the removal tasks under Osha’s class two requirements.
Anything not understood in the above? Maybe U need a refresher course… We offer the traditional classroom activity and NOW U can take the class on your PC at home in your spare time ON-Line!
Go to asbestoschool.com and follow the prompts… yep, its that simple!!!