This may sound like one of those scare-you-into-using-us missives. And, in effect, that’s what it gets down to. But as you know, that isn’t my style, so why?
I’m writing this because we still see building owners attempt to manage and administer asbestos abatement projects on their own. I know, this sounds ridiculous in 2015, but otherwise reasonable people pick up this loaded gun, spin the cylinder and pull the trigger.
Why? Perhaps because you’ll save some money. Or it may not seem that “bad” or “big” a problem. In, out, we’ll get it all and move on. But, and we all know there’s a “but” (several, actually). . .
California OSHA is clear:
The administration of an asbestos abatement project is a “Health and Safety” service requiring the participation of a Certified Asbestos Consultant (CAC). (California Title 8 Section 1529)
Very simple. You are in violation if a CAC is not involved in an asbestos abatement project of any size, flavor or type. Period. No interpretation required. In fact, they even define by law the activities that must be performed under the direction of a CAC:
- Building Inspection
- Abatement Project Design
- Contract Administration
- Sample Collection
- Preparation of Asbestos Management Plans
- Clearance Monitoring
- Supervision of Site Surveillance Technicians
In abatement projects without CAC participation we often see no inspection or documentation of engineering safety controls, no monitoring of occupied areas during abatement and no final inspection. Seriously?? Why not just bring a marching band to a robbery you’re about to commit? These things are glaringly obvious after the fact -- marching band obvious.
All of which begs the questions, Was ALL the asbestos removed and Were people exposed to asbestos contamination during the abatement process? Think AQMD penalties, delays and re-abatement costs. Not to mention putting people’s health at risk, lawsuits and just plain bad karma.
Why take such risk? Obviously, there’s no good reason. The reality is CAC participation in a typical project is about 10% of the total abatement costs. Plus, abatement without participation by a CAC, regardless of how small a job, puts you in violation of OHSA laws. Clearly, not worth it. Case in point, Ellis was asked to manage the re-abatement of an entire 11-story building after a contractor performed an incomplete abatement project. They thought they got it all without the use of a CAC. They didn’t. The general contractor found the older (beige) asbestos material under newer (blue) fireproofing when they began welding iron to columns for a seismic retrofit project. The schedule stopped, the new fireproofing came out and the re-abatement project began. Along with the lawsuits. It was just a mess. And all avoidable.
The consequences of playing with that loaded gun is a violation of OHSA laws at a minimum, and can be so much worse. So much worse that the statement “That could never happen. . .” makes sense. Except we see it time and time again.