NIOSH Testimony on the Environmental Protection Agency's Proposed Rule Revision, Including Disposal of Asbestos Containing Materials Removed from Schools by R. W. Niemeier, March 6, 1989.
This testimony concerned the proposal of the Environmental Protection Agency (EPA) to revise rules pertaining to the disposal of asbestos (1332214) containing materials from schools and the monitoring of asbestos particles in the air. In the first issue, the monitoring of emissions from asbestos, milling, manufacturing and fabricating, the EPA revisions suggested a visual inspection be made for a period of 15 seconds per day. NIOSH called for a more objective means of monitoring rather than using subjective visual observations. NIOSH suggested direct reading instruments such as continuous particulate monitors which are light scattering instruments, for this purpose. The second issue concerned the disposal of asbestos containing material such as packing, gaskets, asphalt roofing and vinyl tiles in good condition. The suggested revision stated that such material need not be removed before demolition if it cannot become friable during demolition. NIOSH commented that asbestos roofing and floor tiles, although in good condition prior to removal operations, emitted fibers on aging and when mechanical forces were applied. NIOSH studies made during removal operations have indicated that personal and area samples exceeded both NIOSH's Recommended Exposure Level and the OSHA Permissible Exposure Limit. NIOSH urged that all such materials be considered friable under any type of demolition or removal attempt.