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Ellis Environmental Management Inc.

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Visual Inspections on VFT and Associated Mastic Abatement

I wanted to share some protocols and "tips" I've learned and followed during my years with Ellis performing inspections on vinyl floor tile (VFT) and mastic abatement. Though these jobs are often viewed as fairly straight forward, challenges and obstacles can arise quickly, and owners can often land themselves in some fairly sticky situations as a result. 

Here's how Ellis approaches these inherently complex jobs:

What is the substrate material?

This is critical to the abatement and inspection process for VFT & mastic, and it's something that must be learned long before abatement begins --during bulk sampling. Inspectors and consultants performing building surveys should always make a note and include substrate material in their sampling reports. Because:

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A Year In Review

2015/2016 were Ellis’ most successful back-to-back years since the company was formed 22 years ago. Some of our more notable accomplishments:

Ellis assisted a large Glendale landowner in assessing possible contaminants at an adjacent property prior to purchase. The project required Ellis to assemble, coordinate and review the efforts of geologists, toxicologists, contractors and developers. In this case, potential cleanup costs were significant, and the buyer made the difficult choice to pass on the purchase. Ellis provided AHERA 3-year, asbestos re-inspections for Palos Verdes, Inglewood and other public school districts. After identifying the asbestos materials (ACMs), Ellis prioritized identified ACMs for removal based on their condition, damage, accessibility and “friability” (ability to become airborne). Ellis assisted a local/regional airport in identifying toxic substances (primarily lead and zinc) released following 3 severe hangar fires. Procured bids for and managed the subsequent hazardous materials cleanup. Ellis provided lead and asbestos surveys, lead surveys, and testing for lead in potable and drinking water for more than a dozen regional charter schools. Provided countless indoor air quality studies, testing for airborne carbon dioxide, ultra-fine particles (UFPs), carbon monoxide, volatile organics, asbestos dust, lead dust, mold, gram-positive cocci, enterococcus and a host of other contaminants. Ellis assisted in responding to more than 100 water intrusion events for various clients. Most of the water intrusions were rainwater, but we also responded to gray water, sewage and water supply line leaks. Ellis is the best first call here; we identify wet wallboard (and other damaged materials) and then manage their timely removal before mold has a chance to grow. For sewage-related spills, clearance enterococcus swabs are collected to insure a complete cleanup. Ellis assisted UCLA Housing, Loyola Marymount University, Mt. St. Mary’s, Santa Monica College, and other regional colleges and universities in procuring bids and managing the removal of moisture-damaged, asbestos-containing and/or lead-containing materials classrooms and housing facilities.

And so on. Our employees are, without exception, degreed chemists or industrial hygienists. Clients seem to appreciate and rely on the confidence, experience and professionalism those employees bring to each project. We’re thankful for each opportunity to do so.

All the best for 2017.

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Lead In Drinking Water

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Ellis is retained by a number of local school districts to test potable (drinking) water for lead content. 

BACKGROUND - Dissolved lead in drinking water is poisonous.  It can lead to nerve and brain damage, particularly in exposed children.  Lead can enter a school's water supply in one of two ways:

Through a contaminated municipal water supply (ala Flint, Michigan); or Through deteriorating lead joints in the building's branch, copper supply lines.  As the joints deteriorate, they can release lead directly into the water.  This is of particular concern in older buildings.

CASE HISTORY – So far, results from testing at different schools have been fairly consistent; lead has been identified in a small percentage of water fountains at each school.  So let's use the first school tested as an example:

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Friable vs. Non-Friable

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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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Certified Asbestos Consultant

California OSHA considers the administration of an asbestos abatement project to be a “Health and Safety” service, requiring the participation of a CAC.

Ellis recently responded to an asbestos emergency at a major southern California university. An abatement contractor had been given an asbestos survey report prepared by Ellis. They were then hired to remove the asbestos materials in that report prior to renovation.

And here's where it got odd: An outside "construction manager" suddenly convinced the college that this newest project could be managed "in-house," i.e. without assistance or input from Ellis or from any other California-certified asbestos consultant (CAC).

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California, Asbestos, and Disclosure Protocols

A potential client asked me an important question: "After performing an asbestos building survey, does [Ellis] have an obligation to disclose any asbestos findings to any State/regulatory agency? Or will it remain private to the client?"

I thought it was an important enough question to share the answer I gave, along with the opinions of a couple of Ellis employees:

Duane: "Unlike with lead paint, there is no legal requirement for a testing agency to share asbestos sampling results directly with any regulatory agency. It is the Owner and general contractor who must, by law, provide results of sampling to employees, building occupants and any trades working in the building."

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ASBESTOS REQUIREMENTS - Cal-OSHA vs. SCAQMD

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Both California OSHA and the South Coast Air Quality Management District (SCAQMD) regulate the disturbance, removal and disposal of asbestos-containing materials. However, significant differences between the two agencies exist, and it’s important to know the difference.  They are listed below:

SCAQMD Rule 1403

1Prior to renovation or demolition, the SCAQMD requires an asbestos survey for ALL structures REGARDLESS OF BUILDING AGE. The SCAQMD is relatively active in southern California. They require notification of any abatement project >100 s.f., and will often visit abatement projects at random. Penalties for non-compliance can be severe. The SCAQMD does not regulate asbestos at concentrations <1%. (1.0%) . The SCAQMD enforces limits on airborne emissions of hazardous dusts and fumes. The SCAQMD is a federally funded agency.

Cal-OSHA - Cal Title 8 Section 1529

Prior to renovation or demolition, Cal-OSHA requires an asbestos survey for pre-1980 construction. Routine site visits from Cal-OSHA are rare. They do respond to written complaints, worker injury or death. Like the SCAQMD, OSHA requires notification of any abatement project >100 s.f. Cal-OSHA regulates asbestos at concentrations greater than one-tenth of 1% (0.1%). Cal-OSHA enforces worker safety rules in California. Cal-OSHA is funded by the state of California.
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Ultra-Fine Particles (UFPs) Air Quality in Airport Areas

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Ellis has recently performed a number of preliminary air quality assessments in office buildings in and around Los Angeles and other airports.  The sampling is often prompted by office occupants’ observations of settled carbon black dust on shelves, desks and ventilation grilles. 

As a matter of standard practice in such efforts, Ellis will include sampling for various types of dusts: PM10, nuisance, respirable, fibrous (including asbestos and fiberglass) . . . . and something relatively new in the industry; “ultra-fine particles,” or “UFPs.” 

UFPs are those particles measuring less than 0.1 micron in diameter.  In any given sample of air, UFPs constitute the greatest number of particles, yet make up only a small fraction of the mass.  Although researchers are currently studying UFPs to identify any links to specific health effects, actual IAQ investigations in thousands of buildings have already shown that UFPs can be directly related to complaints. Due to their numerous quantity and ability to penetrate deep within the lung, UFPs are a major concern for respiratory exposure and health.  This is of special concern in airport areas.  Why?  Read on . . .  

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ASBESTOS IN POST-1980 BUILDINGS

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Rule 1403(d)(1)(A) states an asbestos survey is required for both these buildings before an renovation is begun.

In any building older than 1980, California OSHA (Title 8 Section 1529) has always required asbestos bulk sampling prior to renovation or demolition. But asbestos continued to be installed in new construction up to around 1989.

More recently, we've found asbestos flooring and roofing materials in buildings constructed as recently as 2002! The South Coast Air Quality Management District (SCAQMD) is clear:

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Lead-Based Paint - XRF Sampling

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We just put a new, state-of-the art XRF lead paint analyzer, the Heuresis Pb200i, into field operation.  This is currently the smallest, lightest-weight, highest-performance XRF instrument ever produced. With a color touchscreen display, active shock sensing, Wi Fi / Bluetooth capability, a built-in camera and GPS system, this new precision instrument continues Ellis’ position as a leader in lead-testing services in California.

We plead guilty to loving our gadgets.  But as with every new piece of equipment we invest in, our goal is to deliver more accurate testing results, faster for less money.  And the Heuresis certainly qualifies.

 
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Ellis typically accepts only commercial/ industrial projects but in this case, we made an exception. . . .

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An Ellis team of three has just completed a full-on asbestos survey of a 10,000 s.f. private residence in Beverly Hills. – yes, that’s 10,000 square feet, not including various detached buildings. The home was owned and occupied for years by a female performer and icon of the entertainment industry. It includes a guest house, a separate exercise wing, FIFTEEN bathrooms, a pool and detached pool house, a poker room and other amenities. Just the basics, really.

The assessment phase now complete, Ellis will assist the new owner and architect in completing desired renovations, with removal of identified hazardous materials the first step in the process.

 
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Ellis tests for residual methamphetamine

Last week, Ellis provided swab testing for potential, residual methamphetamine in a private residence. The town home, located in an affluent neighborhood, was clean and well maintained. But the new owner was concerned with an odor he thought might be from a former (or nearby) meth lab. A meth lab in "the nice part of town"?  More and more, as reported by Time Magazine, labs are being placed in locations you would not suspect, including inside a Cedar Rapids, IA Taco Bell (Time, 8-5-15 by Tanya Basu). There is a happy ending in our town home.  The homeowners' association retained Ellis for the required testing and, fortunately, no trace of meth was found. All is well. :-)  And, there has been no talk of "Ellis CSI" in our future. Crystal Meth facts:  http://chemistry.about.com/od/medicalhealth/a/crystalmeth.htm

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Asbestos Abatement Roulette

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). . .

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Indoor Air Quality

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We wanted to share information about Indoor air quality because it is such a challenge. 

It’s a challenge because-

On the one hand, it is serious.  Poor quality or contaminated air quality can affect employee productivity and health.  Plus, most complaints are difficult to distinguish from common flu or cold symptoms.

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Formaldehyde Testing In The News

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Lumber Liquidators and Formaldehyde Exposure

A recent report on the news program "60 Minutes" has linked hardwood flooring sold by Lumber Liquidators to formaldehyde exposure.  

We've received a number of calls inquiring whether Ellis tests for this contaminant.  Yes, Ellis can and does provide testing for exposure to airborne formaldehyde. (We've been providing the service to mortuary service providers for years as part of their Cal-OSHA compliance programs.) 

Costs for a full testing effort - travel, time on site, lab delivery and reporting - range from $800 to $1400, depending on the number of samples collected (around $90 each just for the analysis) and the distance from our office near Torrance to the impacted site. 

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Portuguese Bend Land Slide Area 

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Ellis is assisting the City of Rancho Palos Verdes in administering abatement and demolition of various structures and utilities in the Portuguese Bend Land Slide area. 

During its initial study, Ellis identified damaged asbestos and lead paint in two structures, both of them badly damaged by the slow, inexorable movement of land in the area. Ellis submitted the required permit applications (“Procedure 5”) to the South Coast Air Quality Management District. 

With the City, we showed the work to and procured bids from 5 qualified contractors. Ellis is now administering the abatement, demolition and grading of the site on behalf of the city.

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Photo Processing Contaminants

For most photographers, digital photography has become the medium of choice and convenience.  Still, traditional photography offers a range of special effects and other advantages not yet available with digital.  Traditional darkroom techniques are thus still taught and used at most universities and high schools. Ellis was recently retained to conduct an environmental assessment of an operating photo processing lab at a major university in LA County.  Existing material safety data was first reviewed.  Air and surface samples were then collected and analyzed for the following contaminants:

Airborne

Volatile Organic Compounds (VOCs)Carbon Dioxide, Carbon MonoxideUltra-Fine Dust ParticlesParticulates (PM10) and nuisance dustMold and Fungal Spores

 Surface Dust

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Lead Risk Assessments

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"Lead is a toxic metal that was used for many years in products found in and around our homes. Lead also can be emitted into the air from motor vehicles and industrial sources, and lead can enter drinking water from plumbing materials. Lead may cause a range of health effects, from behavioral problems and learning disabilities, to seizures and death. Children six years old and under are most at risk." - US Environmental Protection Agency

Lead was common in household paints prior to 1977 when it was banned by the Consumer Product Safety Commission. It can be found in lead plumbing and the solder used on newer copper pipes.  And until it was banned in the late 1970s, lead dust was a primary constituent of auto and truck exhaust. 

Using chemical analysis (Flame AA, TTLC, STLC and TCLP) Ellis can assess lead concentrations in soil, paint and in surface dust.  Where lead is found to be present, Ellis provides recommendations based on the client's intended action.  For example, a building to be demolished would need peeling and flaking lead paint stabilized prior to removal.  In some cases, lead has migrated into soils.  Ellis will provide a simple work plan to identify the horizontal and vertical extent of contamination, required volume of excavated soil, clearance criteria, etc.   Ellis maintains 2 State-Certified Lead Assessors on staff. 

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Asbestos - Clearance Sampling

Q1:  Following an asbestos removal action, who can perform final clearance sampling?

A1:  In California, clearance air sampling must be performed under the direct supervision of a California-certified asbestos consultant, or "CAC."  Requirements vary in other states, but generally require a combination of training, experience, testing and licensure.

Q2:  I've hired a licensed abatement contractor to remove asbestos from my building.  Can't I just ask him to have the clearance sampling performed?

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SCAQMD, Notice to Comply, Procedure 5



                

The South Coast Air Quality Management District (SCAQMD) responds to complaints of possible asbestos disturbance lodged by building occupants, tenants and employees.  They can be reached at (909) 396-2000 or 800-CUT-SMOG (800-288-7664).

The SCAQMD is by far the most active environmental regulatory agency in California, responding to complaints 24 hours a day.  When investigating the possible disturbance of asbestos-containing materials, the AQMD inspector will first request a copy of an Asbestos Survey. By law, AQMD Rule 1403, an asbestos survey is required prior to any demolition or renovation effort).  If no survey report is produced, the agency will immediately issue a "Notice to Comply", or "NTC," requiring that a Certified Asbestos Consultant conduct an asbestos hazard assessment.  If asbestos is identified, that same CAC must prepare and submit a "Procedure 5" (P5) cleanup plan on behalf of the building owner.

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