Why ‘asbestos-free’ insulation may contain asbestos
Thursday, April 06, 2017
In June of 1996, the Building Owners and Managers Association (BOMA) lobbied the Occupational Safety and Health Administration (OSHA) to put a date in their new asbestos regulation — 29 CFR 1926.1101, the Occupational Exposure To Asbestos (Construction Industry Standard) — to say all materials installed after 1980 were, in essence, not asbestos-containing materials.
I was chairman of the Survey, Administration, Design Committee for the National Asbestos Council at the time, and we asked OSHA where the 1980 date came from. OSHA never responded.
The after-1980 date had nothing to do with any ban of asbestos or anything else. Asbestos-containing materials (ACM) were not banned on Jan. 1, 1981. So, were any asbestos-containing materials put into facilities after 1980? Absolutely!
In fact, OSHA removed the significance of the after-1980 date in the "Communication of Hazards," Section K, of the same regulation: "If the employer/building owner has actual knowledge, or should have known through the exercise of due diligence that other materials are asbestos-containing, they too must be treated as such."
So, OSHA put in the after-1980 date and later voided the date in Section K.
The problem is everybody assumes that any facility built or materials installed after 1980 are "asbestos free." This is not always the case.
According to this regulation and Environmental Protection Agency (EPA) regulations, the only way to determine if insulation and other materials are "asbestos free" is to sample them.
There are numerous examples of ACM installed in facilities between 1981 and 2015. To say, "It's new insulation (materials) so, we know it is not asbestos" is false and in violation of every asbestos-related regulation.
In addition, the EPA has never had a date in their asbestos regulation — 40 CFR Part 763, Section 763.86. This regulation states in Subpart (b)Thermal System Insulation (pipe insulation), "an accredited inspector shall collect ... at least three bulk samples from each homogeneous area of thermal system insulation that is not assumed to be ACM."
In the EPA regulation, insulation can be assumed (OSHA it is presumed) to contain asbestos and treated as such, but to call it "asbestos-free," it must be sampled for those results. This and the OSHA regulations are still in effect today.
In conclusion, whether insulation materials were installed before or after 1980, they could contain asbestos. The materials must be treated as asbestos-containing materials until they are sampled to determine whether they contain asbestos.
If the facility has insulation that is labeled or called "asbestos-free," there must be sampling with laboratory analysis to prove this. OSHA and EPA do not recognize, according to regulations, Safety Data Sheets and/or company specifications banning the installation of ACM as evidence.
Individual workers are potentially being exposed, unnecessarily, to asbestos because of "asbestos-free" insulation that may contain asbestos. And, yes, the exposure of workers to a known carcinogenic material matters to those individuals and their families.
Unless there has been proper laboratory analysis of bulk samples proving the results, please stop calling insulation "asbestos-free."
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