Operations and Maintenance Practices Recommended by Regulatory Agencies

Abstract

The U.S. Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) are the major federal agencies that regulate work on asbestos in buildings. This article considers the development of the current positions of these agencies on asbestos operations and maintenance (O&M) in buildings, and the impact of these positions on O&M programs. Broad suggestions are made for changes in the positions of these agencies to facilitate the creation and implementation of O&M programs. The position of the EPA has evolved considerably. Initially the EPA was concerned about exposures to building occupants and promoted asbestos removal as the solution. Now, in-place management of asbestos-containing materials through an O&M program is encouraged, although the EPA has just begun to describe the components of such programs. However, we lack a national knowledge base about O&M, and it is recommended that the EPA collect and disseminate relevant information. After a suitable knowledge base is gained, the EPA may need to revise its guidance on O&M programs. The position of OSHA on asbestos has become progressively more protective. However, ambiguities are evident in its current position on asbestos O&M in buildings. It is unclear whether O&M work activities that result in exposures below the permissible exposure limit need to be performed within an enclosure. OSHA has moved from recommending engineering controls toward enclosure for O&M activities. However, enclosures are less protective of workers and they may reduce the effectiveness and the efficiency of asbestos O&M programs.