Asbestos-containing textured surfacing materials, as well as other types of asbestos containing materials, were historically applied in significant quantities to concrete bridges and other structures built as late as the early 1990’s. During renovation (surface preparation for overcoating or total coating removal and replacement) or demolition of bridges, just like buildings, there are specific regulatory requirements such as licensure, inspections, procedures and notifications that must be followed to avoid compliance violations, litigation and to avoid unwanted asbestos exposure to employees and the environment.
Product Number:
41-COAT_DEC21
Author:
Gary Caldwell / Chris Lovelace
Publication Date:
2021
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Asbestos-containing textured surfacing materials, as well as other types of asbestos containing materials, were historically applied in significant quantities to concrete bridges and other structures built as late as the early 1990’s. During renovation (surface preparation for overcoating or total coating removal and replacement) or demolition of bridges, just like buildings, there are specific regulatory requirements such as licensure, inspections, procedures and notifications that must be followed to avoid compliance violations, litigation and to avoid unwanted asbestos exposure to employees and the environment.
These requirements are often overlooked even by the savviest Owner.
There are specific EPA, OSHA and State regulations regarding activities associated with work activities that may affect asbestos containing materials. EPA’s National Emission Standards for Hazardous Air Pollutants (NESHAP) requires an inspection for the presence of asbestos-containing materials prior to renovation and/or demolition of a facility or a facility component, and bridges are considered facilities. The NESHAP regulation, as well as some State’s regulations, require a 10-day notification prior to disturbance of facilities where asbestos containing material (ACM) is present.
If ACM is present, then specific work practices are required to be implemented under the NESHAP. Further, OSHA’s asbestos regulation (29 CFR 1926.1101), contains specific requirements regarding employee training, personal protective equipment, exposure monitoring, waste packaging, medical surveillance, etc. Lastly, States may have specific requirements for managing and disposing ACM.
This Paper covers the regulatory framework concerning renovations and demolitions of concrete bridges where ACM is present and an overview of traditional and novel approaches concerning the issue.