Hazardous and unknown materials

Hazardous materials questions test three things: what you must know before you disturb a material, who must be notified and how far ahead, and which license certification allows the work. Remember two measuring words. The action level is the exposure level that starts some requirements, like air monitoring. The permissible exposure limit (PEL) is the most a worker may be exposed to, averaged over an 8-hour day.

Hazard communication: labels, SDS, and training

Under T8 §5194, every employer whose workers may be exposed to hazardous chemicals, including construction employers, must have a written hazard communication program. It lists the hazardous chemicals at the workplace and explains how the employer handles labels, safety data sheets, and training.

• Labels (GHS format) on containers from the manufacturer show the product identifier, signal word, hazard statements, pictograms, precautionary statements, and the name, address, and phone number of the responsible company.
• Safety data sheets (SDS) have 16 sections and must be readily accessible to workers in their work area during each work shift.
• Training is given when a worker is first assigned and whenever a new chemical hazard is brought into the work area.
• On multi-employer job sites, the program must explain how the employer tells other employers about hazardous chemicals their workers may be exposed to.

Unknown materials: stop, protect, identify

Old insulation, flooring, pipe wrap, paint, buried drums, stained soil, or strange odors can all mean hazardous materials. No worker may be required to work in an unsafe place except to make it safe (T8 §1511). Before asbestos-related work begins, building owners and employers must determine the presence, location, and quantity of asbestos-containing material (ACM) and presumed asbestos-containing material (PACM), and anyone who discovers such material must share that information with the other parties within 24 hours (T8 §1529(k)). PACM means thermal system insulation and surfacing material in buildings built no later than 1980; it is treated as asbestos unless testing proves otherwise.

1. 1Stop work that could disturb the material.
2. 2Keep workers and others away from the area.
3. 3Tell the supervisor, the building owner, and other employers on site.
4. 4Have a qualified person sample and test the material.
5. 5Resume only with the right certification, registration, notices, controls, and PPE, or bring in a properly licensed and certified contractor.

Asbestos

Cal/OSHA's construction asbestos rule (T8 §1529) sets a PEL of 0.1 fiber per cubic centimeter of air (8-hour average) and an excursion limit of 1.0 fiber per cubic centimeter over 30 minutes. Work is divided into classes. Class I is removing thermal system insulation and surfacing material. Class II is removing other asbestos material, such as flooring, wallboard, roofing, and mastics. Class III is repair and maintenance where asbestos is likely to be disturbed. Class IV is maintenance and custodial work that contacts but does not disturb asbestos, plus cleanup. A competent person must supervise. Dry sweeping and shoveling are prohibited, and compressed air may not be used to remove asbestos except with an enclosed ventilation system. Regulated areas get warning signs reading DANGER, ASBESTOS, MAY CAUSE CANCER. Workers doing Class I, II, or III work, or exposed at or above the PEL, for 30 or more days a year need medical surveillance. Exposure and medical records are kept at least 30 years.

Cal/OSHA registration: an employer doing asbestos-related work involving 100 square feet or more of asbestos-containing material must register with Cal/OSHA before starting. The registration is valid for one year (T8 §341.6). Noncontiguous areas at the same site are added together. The registered employer must also give the nearest Cal/OSHA district office written notice before each job starts; if an emergency needs immediate action, notice may be given by phone and confirmed in writing within 24 hours (§341.9).

CSLB certification: a contractor may not do asbestos-related work involving 100 square feet or more of asbestos-containing material unless the contractor holds the C-22 Asbestos Abatement classification or has passed the asbestos certification examination (B&P Code §7058.5). Every initial license applicant must complete CSLB's open-book asbestos examination. Installing, maintaining, and repairing asbestos cement pipe or sheets, vinyl asbestos floor materials, and asbestos bituminous or resinous materials do not require the certification.

Federal air rules also apply. Under the asbestos NESHAP (40 CFR §61.145), the owner or operator must inspect for asbestos before a demolition or renovation and must send written notice to the air agency at least 10 working days before asbestos removal or demolition begins. Every demolition needs this notice. A renovation needs it when regulated asbestos material reaches at least 260 linear feet on pipes, 160 square feet on other components, or 35 cubic feet.