Date: Sun, 28 Sep 2008 14:58:28 EDT
Reply-To: ACTSNYC**At_Symbol_Here**CS.COM
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: ACTSNYC**At_Symbol_Here**CS.COM
Subject: Re: Asbestos management
My experience is primarily in art and theater portions of the campus where I 
recommend absolutely complete surveys because art faculty and students bang 
huge sculptures into insulated pipes or hang them from pipes. Theater riggers 
climb into every crevice all the way up to exposed beams. Both art and theater 
artists are likely to accidentally (or on purpose) drill or bang holes into 
floors or walls. They find unsecured utility rooms and use them for storage or 
studios. They hold pot parties in confined spaces (even found evidence of this 
once in a large air supply plenum under the theater!!) etc., etc. There is no 
potentially hazardous thing I have not found them doing.

Science students and faculty are usually more demure, but a complete survey 
is really not a big deal. We all know how to read a set of mechanical drawings 
to follow the pipes. If there aren't any, we can sketch them onto a full floor 
plan. If the pipes were installed before the ban, a little piece of an elbow 
and another from the straight run sent to a certified lab and $25 each ($15 
each if you work a deal) will get you answers. If that becomes too expensive 
because there are too many, PACM labels go on the pipes. When you are done, you 
shouldn't see any insulated pipe that is not labeled one way or the other. 

Making a survey of the other sources is equally simple. We all know what 
possible asbestos materials look like: old 9 x 9  and 12 x 12 vinyl tiles almost 
surely are (I been informed by Peter Zavon who used to work for a tile 
manufacturer, that both are equally likely to contain asbestos), old fume hoods and 
lab counters built with Transite, sprayed or troweled on stuff on exposed beams, 
insulation on old ovens and other lab equipment from braided rows of asbestos 
fibers around doors to fiber blanket or textile-like materials, any old 
electrical equipment with a white fuzzy surfaces (which I still find in abundance 
on old theater lights in some schools), all that stuff. You all know it when 
you see it. Mark it down on the survey or pitch it. 

If I were EPA, I'd sock to any school that didn't have a pretty complete 
survey. I just can't see a good reason not to do it all. 

Monona Rossol, M.S., M.F.A.,
industrial hygienist
Arts, Crafts &Theater Safety, Inc.
Safety Officer,
United Scenic Artist's, Local USA829
International Alliance of Theatrical Stage Employes (IATSE)
181 Thompson St., #23
New York NY 10012-2586 212/777-0062

In a message dated 9/27/2008 10:14:06 PM Eastern Standard Time, 
pzavon**At_Symbol_Here**ROCHESTER.RR.COM writes: 
> -----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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