Date: Sat, 27 Sep 2008 21:56:36 -0400
Reply-To: Peter Zavon <pzavon**At_Symbol_Here**ROCHESTER.RR.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Peter Zavon <pzavon**At_Symbol_Here**ROCHESTER.RR.COM>
Subject: Re: Asbestos management
Comments: To: "Gary M. Kehoe"
In-Reply-To: <OFF6D1686A.D2F6C77E-ON862574D1.005EFA2F-862574D1.005F4021**At_Symbol_Here**>
Of course limited surveys if areas to be disturbed is compliant with OSHA.
The OSHA regulation permits applying building history and visual assessment
to identify building materials that are presumed to be ACM, and acting
accordingly. Then one may choose to do a more detailed survey of areas to be
impacted by specific projects as they come along.

The real issue is, how do you effectively document whatever information you
have so it is accessible to colleagues and successors.

Peter Zavon, CIH
Penfield, NY


> -----Original Message-----
> From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**] 
> On Behalf Of Gary M. Kehoe
> Sent: Saturday, September 27, 2008 1:20 PM
> To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
> Subject: [DCHAS-L] Asbestos management
> Please excuse the cross-posting.  We are in the process of 
> revising our asbestos management procedures and was wondering 
> how our peer companies comply with the OSHA requirements to:
>       1.    ".determine the presence, location, and quantity 
> of ACM and/or
>       PACM at the work site."  (1901.1001(j)(2)(i)
>       2.    ".maintain records of all information required to 
> be provided
>       pursuant to this section and/or otherwise known to the 
> building owner
>       concerning the presence, location and quantity of ACM 
> and PACM in the
>       building/facility." 1910.1001(j)(2)(ii)
> In an earlier post I asked about performance of comprehensive 
> inspections and received 3 replies that generally indicated 
> full surveys were not practiced but focused inspections were 
> done prior to disturbance which appears practical but may not 
> be OSHA compliant.  So, if you are in that ballpark, how do 
> you maintain compliance with the regs referenced above?
> Thanks in advance for past responses and any light you can 
> shine on this question.
> Gary M. Kehoe, CIH
> Senior Industrial Hygienist
> Midwest Generation EMG
> 773-650-5732
> 312-925-1813 (C)
> 312-788-5533 (F)

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