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Ellis Environmental Management Inc.

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Friable vs. Non-Friable

In its normal state, asbestos-containing floor tile is "non-friable" - that is, cannot be crushed under normal hand pressure. Because asbestos is an inhalation hazard, this quality makes non-friable materials safer to work around and remove.  In California, OSHA (Title 8 S1529) and the SCAQMD (Rule 1403) recognize this fact, and regulate the two types of  materials (ACMs) differently.  Removal of non-friable materials (such as roofing mastics) often require little more than proper signage and trained workers, while the removal of friable fireproofing requires numerous additional engineering controls:  negative air filtration, critical barriers at doors and windows, poly sheeting on walls, 3-stage decon unit, and so on. 

In the eyes of the SCAQMD, removal of asbestos flooring mastic, if performed with scrapers and mild solvents, does NOT render the material friable, and it may be transported as non-friable / non-hazardous asbestos waste. For larger work areas, most abatement contractors find it best to supplement the use of solvents with abrasive pads affixed to rotary scrubbing machines.  The SCAQMD views this as "removal by mechanical means", which automatically re-classifies the mastic as "friable."  This in turn triggers the requirement for tenting, HEPA filtration, 3-stage decon unit, and other OSHA Class 1 engineering controls.

But what about the waste that is generated during this process?  We recently observed a contractor install Class 1 engineering controls as required prior to the use of mechanical buffer machines to remove mastic.  All good and in compliance with AQMD rules. 

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But THEN, they placed all of the removed mastic and solvent into unmarked bags and produced a non-hazardous waste manifest for the Owner's signature.  We balked, and directed the contractor to re-bag, re-label and re-manifest the material as hazardous asbestos waste, in keeping with their SCAQMD.  They made this change, but reluctantly, stating their belief that it was not required. 

Wrong.  It IS required.  In response to our query on the matter, the SCAQMD confirmed this, stating, "Good catch. Please refer to 1403(f)(1)(A)(viii): . . . [asbestos shall be] classified, packed, marked, and labeled, and in proper condition for highway transport according to applicable federal, state, and local regulations."

The SCAQMD further advised that, whenever friable asbestos waste is improperly packaged and transported as non-friable waste, the violation should be reported to the DTSC.

Duane Behrens, CAC #92-0226