In the early to mid-1900s, asbestos, under certain conditions, was proven to positively relate to certain kinds of cancer. From a medical or epidemiological perspective, it is not so much that asbestos causes cancer, it is more correct to state that research shows that extensive exposure to certain kinds of asbestos in certain situations seems to correlate with certain kinds of cancer. To this day, there has not been a responsible medical or epidemiological study implying that cancer level among building occupants increases in relation to asbestos in the building. Data shows that those who work with it extensively (including those who remove it), have higher levels of certain kinds of cancer, as well as those who have sporadic exposure (electricians, plumbers, etc.).
Inhaling certain forms and amounts of asbestos does have a clear relationship to cancer, and given that, it is enough to say that a building owner should move in reasonable patterns to keep asbestos particles out of the breathing zones of building occupants. This does not necessarily equate with removal, which often has been shown to exacerbate contamination, nor does it particularly relate to simply following federal or state EPA and OSHA guidelines. One can follow those guidelines and still have excessive exposures. The regulations should be followed in ways that complement both sound public health and public relations, with an eye toward pre-empting successful civil litigation.
What should a building manager do?
1. Determine which asbestos-containing products are present in your building. This is accomplished by hiring a certified asbestos building inspector to inventory and sample for suspect building materials.
2. Develop an Operations and Maintenance (O & M) Plan for managing the asbestos-containing materials. O & M plans typically contain provisions for training, notification of tenants, occupants and employees, abatement procedures, recordkeeping, etc.
3. Protect against civil litigation. The survey of the building and the procedure for responding to asbestos should be accomplished in an order and sequence which would best defend a building owner, whether school district or private building owner, should an occupant ever develop an asbestos-related cancer. It may be necessary for the building owner to carefully defend their responsiveness to dealing with the asbestos. This absolutely does not equate with proving that large amounts of asbestos have been removed, nor does it necessarily equate with EPA/OSHA compliance.
4. Avoid citations involving EPA, OSHA and state guidelines. Citations destroy confidence and may push occupants or employers to demand unrealistic or unwise engineering controls.
5. Be prepared to assure occupants of their safety. Based upon the relationship between asbestos exposure and cancer (as medical science permits us to understand it), a reasonable O & M program (along with cautious and well-documented removal when it must occur), would permit medical assurances to building occupants that they are not at undue risk because of asbestos in a building. This assurance cannot come from a contractor or an engineer. This is a sensitive communication that should originate from a medical/public health source. This is achievable in nearly any building at a reasonable cost through a non-disruptive management system that ties into maintenance systems and remodeling/renovation systems.
Moving to protect and safeguard the health of occupants and pre-empting successful civil suits go hand in hand. You move to keep the asbestos formations that are most likely to cause cancer out of the breathing zone of occupants. You cautiously document these procedures to, 1) understand the level of exposure you may have and, 2) to limit it.
Remember, asbestos is everywhere. Walking outside in a metropolitan area, one is likely to inhale perhaps nine nanograms per cubic meter of asbestos. While you have been reading this article, if you are in a building containing asbestos or if it ever did contain asbestos, it is possible that you have been inhaling between 4 and 100+ nanograms per cubic meter. Fortunately, your body has mechanisms to purge small doses of asbestos. The issue is to limit exposure.
Understandably, since it is in ambient air, you cannot get rid of asbestos. What you can do is limit the level of exposure and document that you have acted responsibly to do so. The engineering procedures you use to deal with this are many and varied, and they are not limited to encapsulation, encasement or removal. Water damage often promotes the entrance of degrading asbestos into the atmosphere. Repairing a roof membrane may be an effective response to limit asbestos exposure.
The geologic type of asbestos fiber has had profound impact in terms of how long it will stay in the air and even the level of damage it may be expected to cause once it is embedded in lung tissue. The type of asbestos in your building should influence the response priority.
The air exchange system in your building is continually purging and diluting ambient air; to the extent there is air turnover, there is less likelihood of inhaling asbestos. Finally, one of the most responsible patterns for purging asbestos is simply good housekeeping. Wet mopping, wet vacuuming, HEPA vacuuming, wet dusting lateral surfaces - all serve to cut off reintroduction of asbestos into a building’s breathing zone.
The bottom line is, you have to understand the building from a medical/public health perspective and implement sets of rules that limit exposure. Then (the part that is often missed) cautiously, in a disciplined pattern, record and archive your asbestos program - those elements that would relate to limiting asbestos exposure - in terms of health and potential litigation.
Protection from citation involves doing the above in ways that complement those postings, notifications, measurements and record systems that are required or recommended by EPA, OSHA and other state agencies. Certain systems must be employed in normal building operations, others must be implemented when there is removal, encasement, encapsulation, etc.
Assuring occupants of their safety is a rewarding part of this effort. If the above is implemented correctly, a public health/medical authority can state clearly and calmly to occupants or parents of students that there is no reasonable risk to health associated with involvement in the building.
Accomplishing the effort relative to more favorable property taxation and potential litigation against the asbestos manufacturer is an internal affair for each building owner. But if information is gathered for the above objectives in the correct pattern, that information can generally be recast in a responsible appeal for property tax relief and in a way that may complement requests for public relief for associated costs.
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