by Andrew Johnson,CSP, CHST, CRIS, AGC Safety Management Consulatant
The presence of asbestos in older buildings and materials poses a significant health risk to workers across various industries. Asbestos, known for its durability and resistance to heat, chemicals, and electricity, becomes hazardous when its fibers are released into the air and inhaled. To mitigate these risks, regulatory agencies like the Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA) have established comprehensive training and protection guidelines for those potentially exposed to asbestos-containing materials (ACMs) or presumed asbestos-containing materials (PACMs). However, some differences between the two agencies may cause some confusion when working around asbestos.
Who Requires Asbestos Awareness Training?
A wide range of professionals may encounter asbestos during their work, necessitating asbestos awareness training:
- Construction workers performing repair, renovation, or demolition on older buildings.
- Maintenance and custodial staff in schools and other buildings that contain ACMs or PACMs.
- Technical specialists such as HVAC personnel, electricians, and plumbers who might disturb asbestos in their daily tasks.
OSHA requires asbestos awareness training for workers that have a measured or anticipated exposure to asbestos fibers at or above the permissible exposure limit (PEL).
In schools where ACMs are present, EPA regulations require all custodial and maintenance workers to have some degree of asbestos awareness training, as mentioned above.
The EPA’s asbestos training must be completed within 60 days of beginning employment, and OSHA asbestos awareness training must be completed before or on the day of assignment to a project containing ACM’s or PACM’s.
Exploring the Levels of Asbestos Awareness Training
Training is categorized based on the potential for exposure and the specific tasks a worker performs. OSHA specifies varying durations and contents for training, depending on whether the exposure is within the construction, maritime, or general industry sectors. The training might range from a brief overview to detailed sessions with a hands-on component for those in direct contact with ACMs. Under this system, the following four classes of construction work are matched with increasingly stringent control requirements:
- Class I asbestos work is the most potentially hazardous class of asbestos jobs. This work involves the removal of asbestos-containing thermal system insulation and sprayed-on or troweled-on surfacing materials.
- Class II work includes the removal of other types of ACM that are not thermal system insulation such as resilient flooring and roofing materials.
- Class III asbestos work includes repair and maintenance operations where ACM or presumed ACM (PACM) are disturbed.
- Class IV work includes custodial activities where employees clean up asbestos-containing waste and debris produced by construction, maintenance, or repair activities.
EPA delineates its training into three distinct types, with escalating detail and duration from the 2-hour Awareness Training (Type 1) to the more intensive Operations and Maintenance Training (Type 2) and the comprehensive training for abatement workers (Type 3).
- EPA Type 1 training is a 2-hour Awareness Training. It’s required for maintenance and custodial staff that are involved in cleaning or minor maintenance where ACM may be accidentally disturbed.
- EPA Type 2 training is a special operations and maintenance (O&M) training for maintenance and custodial workers that will be directly involved in the maintenance and repair of ACMs. It’s at least 14 hours long and includes an extended discussion of Type 1 topics plus more detailed attention to work practices and personal protective equipment (PPE). It also includes hands-on EPA Type 3 training is for abatement workers. It’s even more extensive, with specialized abatement topics and more hands-on practice. Type 3 training typically takes between 32 and 40 hours.
Training Requirements
To comply with OSHA regulations, asbestos awareness training to be repeated at least once a year. Employers are allowed to conduct it more frequently, and OSHA often encourages additional training if a worker demonstrates a lack of awareness or competence on the subject matter.
The EPA’s O&M program doesn’t require a refresher. However, since OSHA rules apply, at-risk employees will need some sort of annual training anyway.
Key Training Components
The rules are slightly different whether you fall under General Industry or Construction standards. But generally, OSHA asbestos awareness training must cover the:
- Health effects associated with asbestos exposure
- Relationship between smoking and asbestos exposure in producing lung cancer
- Methods of recognizing asbestos (if Construction standards apply)
- Quantity, location, manner of use, release, and storage of asbestos
- Specific nature of operations that could result in asbestos exposure
- Appropriate engineering controls and work practices associated with their job assignment
- Specific procedures implemented to protect them from exposure, such as appropriate work practices, emergency and cleanup procedures, personal protective equipment (PPE), and more
- Purpose, proper use, and limitations of respirators and protective clothing (if appropriate)
- Purpose and description of OSHA’s required medical surveillance program
- Contents of the relevant OSHA asbestos standard, including appendices
- Names, addresses, and phone numbers of public health organizations where they can get information on how to quit smoking
- Requirements for posting signs and using labels, as well as the meaning of the relevant legends
EPA Type 1 training is similar in content but instead of the OSHA standard, it focuses on the O&M program.
Who Can Provide Asbestos Awareness Training?
Asbestos awareness training must be provided by qualified trainers who have a deep understanding of asbestos management and removal practices. This includes:
- Professionals certified in asbestos management and abatement, often with backgrounds in industrial hygiene, occupational health, or a related field.
- Training organizations or institutions that specialize in occupational health and safety standards, including those approved by OSHA or the EPA.
- In-house trainers who meet the competency requirements set forth by OSHA and the EPA, provided they have extensive experience and knowledge in asbestos handling and safety protocols.
- It is crucial for employers to ensure that the chosen training provider is fully compliant with the regulatory standards and capable of delivering comprehensive, up-to-date information and practices related to asbestos safety.
Conclusion
Understanding the nuances between OSHA and EPA regulations regarding asbestos awareness training is essential for employers and workers alike. By ensuring that training is conducted by competent and certified professionals, we can significantly reduce the health risks associated with asbestos exposure. If you need additional information regarding safe work practices when working with or around asbestos, please contact your AGC safety management team for assistance. For more information please see OSHA’s ”Asbestos Standard for the Construction Industry” and EPA’s O&M program.