Three Fundamentals
Rule #1 - Do not allow anyone to be hurt.
Rule #2 - Be able to prove that you followed Rule #1.
Rule #3 - Follow all local, state and federal regulations to the extent they clearly do not conflict with Rules #1 and #2.
Keep People Out - Put up physical barrier or warning between the area and people.
De-energize air handling systems
Seal off any passive air circulation systems
Be alert for water-saturated, asbestos-containing materials that may potentially become dislodged from the component(s) of which it is a part.
Use a respirator and protective clothing or significantly limit the time in which you or others may be exposed. If the material becomes dislodged because of water, it has a greater likelihood of becoming airborne as it dries.
Immediately begin testing of the suspected bulk material. Air tests of approximately 1,200 liters of air should be taken throughout the affected area to determine extent and limits of contamination. Do not use electron microscopy at first. Do not aggravate contamination as a result of testing. Do not perform aggressive testing until passive test results have been obtained.
Keep a written record of What happens to Whom, When. This will help to eventually better understand the limits of exposure that occur in the building and to reconstruct the limits of contamination. (Archive all physical samples used for testing.)
First, get public health and safety advice*, then seek advice from federal, state and local regulators, then focus on interim operations for the facility.
*You may contact: The Institute for Environmental Assessment 24-hour emergency phone: (763) 315-7900
(Read and familiarize yourself with this information before a crisis occurs.)
Over the past few years, the Institute for Environmental Assessment (IEA) has been called in for asbestos situations in which the "unthinkable" happened. Conditions had changed suddenly, in a crisis fashion, causing human exposure to asbestos-containing materials. In some cases, these situations were handled correctly, with prudence and caution. In others, however, errors in approach caused contamination, resulting in problems with insurance agencies, concern among building occupants and their families regarding possible exposures and litigation concerns for building managers. What happens in the first 20 minutes of an asbestos "crisis" is extremely important to the long-range outcome. We want to discuss those first 20 minutes.
Each asbestos release crisis is different. It can result from excessive vandalism, a broken water main, an explosion in a boiler or, sometimes, unthinking contractors who are either removing the asbestos using unwise procedures or who during remodeling or renovation seriously disrupt areas that are asbestos-containing.
The following is a general discussion of what we believe are the most important issues in the first few minutes after discovering a major fiber release. Remember, each crisis is different, requiring a somewhat different response.
Immediate Response: Isolate the Contamination Site
The first and primary issue is to keep contamination away from people, including yourself.
Look at the contamination point and discover who at that moment may be exposed to asbestos and under what conditions the asbestos may migrate to other areas within or outside the building, especially where people could be exposed through debris, contaminated water, contaminated ambient air, etc. Remember, "the map is not the terrain." Look at the situation, not just the blueprints. In a flood situation, for instance, one needs to identify potential asbestos-containing materials, either through assumption or analytical backup.
Health risk from asbestos exposure, even that from more highly toxic, mineralogic forms of asbestos, is dependent upon the extent of exposure. Exposures are cumulative. Brief exposures are of less risk than more extensive ones, and time is as significant as the level of contamination. In terms of both regulatory and civil law, building owners and managers are required to responsibly protect people by removing them from contaminated areas and by isolating the area. It is wrong to overreact, but it is worse to fail to act.
Using commonsense is best in determining how far you go in terms of evacuation, shutting down or a "quarantine" of the building. For example, depending upon the type of asbestos fiber or nature of release involved, an explosion in a boiler room that contaminates the area may not involve evacuation if the door from that area to other portions of the building can be shut and if the air handling system is unique to the contaminated area. On the other hand, if there is contamination within an air duct, it is necessary to evacuate the building quickly and in an organized manner.
In the case of flooded areas, drying asbestos fibers could be released into the ambient air, causing potential health risk to workers who are not properly trained, fitted and supplied with personal protective equipment. As these areas dry, properly trained individuals should clean up any asbestos-containing materials (ACM) that remain attached to the component or substrate to which they were applied or any ACM that has become dislodged.
Building evacuation, which must occur if you cannot isolate or contain the area where there is contamination, should be handled calmly and not treated as a "bomb threat" type of evacuation. Visit with the occupants, explain that there has been some damage in the building and, because there may be some contamination of the air handling system, it would be best to leave the building for the present until a determination is made about exactly what happened.
Protective Equipment
It is important that someone who understands the building reviews the situation directly. Consultation by telephone with experts in the area of environmental engineering can also be helpful.
IEA recommends that protective equipment, including a HEPA-filtered respirator and perhaps disposable coveralls, be maintained in all buildings containing substantial amounts of asbestos. Hopefully, a knowledgeable individual on site would be fitted with protective equipment and could observe the situation directly. The obvious factors in limiting contamination can be quickly checked, e.g. sealing off the contaminated area, stopping water sources, heading off individuals who may inadvertently walk into a contaminated area, and shutting down automatic air handling systems.
Isolation Procedures
Once the evacuation has been completed, the area must be absolutely isolated:
- Put up warning signs, barriers, lock the doors, etc. - every effort must be made to keep people out of the area. Some situations may warrant your collecting keys or changing locks.
- HVAC systems and pneumatically controlled air handling structures should be shut down, locked out and, if possible, sealed with polyethylene and taped.
- Take precautions regarding passive air exchange. It is not enough to simply power down the air handling system. As barometric pressure and temperature change, internal air systems will cause contamination to migrate throughout the building and potentially increase the risk and costs associated with the more extensive exposure. Vents and holes between building areas, open ventilation systems, even air intake systems from the roof that are normally designed to purge the air may begin to work in reverse as pressure and temperature change. All air handling systems should be sealed up with polyethylene (polyethylene, duct tape and caulking should be kept on site). It is often a good idea to shut off the lights in a contaminated area and turn lights on in areas around the contaminated area.
- Have the appropriate utility shut down the gas and possibly de-energize pertinent electrical. (Pressure changes caused by isolating or "sealing up" a portion of a building may cause gas to leak into the areas isolated. This is usually of concern only in mechanical room areas.)
Testing
Once the potential contamination has been cut off from building occupants, it is time to try to determine what really happened. All testing should be non-disruptive, i.e. the testing should not make the situation worse. Aggressive air testing that purposely circulates and spreads contamination to get a "worst case" reading should not be attempted unless an area is presumed to be clean, is completely sealed off and operating under controlled conditions.
Those designing the testing protocol, executing the testing, and interpreting its meaning should be directed solely toward safeguarding the public health and working in the interests of the building owner. Neither a knowledge of federal and state guidelines nor completion of a federally certified training course necessarily equates with competence to respond to emergency environmental engineering.
The following testing protocols should be considered:
- An asbestos-certified inspector should draw samples of the bulk material that has been disrupted and retest all bulk materials involved in potential contamination, even if the material was previously identified as asbestos containing or non-asbestos containing.
- The method of analysis for the bulk material should involve the standard polarized light microscopy (PLM) method, i.e. U.S. EPA 600/R-93/116 Method for the Determination of Asbestos in Bulk Building Materials.
Simultaneous to PLM testing, air testing using phase contrast microscopy (PCM) should be conducted. Using 1,200 liters of air, testing should be conducted in the worst case scenario, i.e. closest to the perceived source of contamination, and tests should be taken in areas that would be presumed not to have contamination levels. This difference will help define the extent of the problem and will dictate the engineering response. Testing by transmission electron microscopy (TEM), which specifically identifies asbestos fibers, should be avoided until after the PCM tests are taken, and then used selectively and as indicated by the PCM results.
Remember, when there is high moisture or water damage at or near the area of contamination, asbestos particles will migrate into the atmosphere as the water evaporates and contamination will likely increase. If the contamination is being held down by high moisture, air tests may not adequately profile the level of potential contamination, but this period of high moisture may be an opportune time to begin clean up procedures.
If there is a substantial amount of water, the water should not be sewered unless it is filtered. Water should be removed as soon as possible since increased humidity will possibly degrade the materials binding the asbestos, especially if the asbestos building material has high clay content.
Communicating With The Public
Concerned building occupants, their families and the media can be either a disruptive or a supportive force as you are attempting to deal with the emergency response. It is important to be clear and honest with those interested in what has occurred in order to limit speculation. To the extent information is held back or appears to be incomplete, one can expect both the media and building occupants to assume a hostile attitude toward the recovery operation. Establishing set times for meeting with occupants and the media in one controlled setting will be helpful - the same message can be given to all concerned, and this structured, formal release of information provides a calming atmosphere.
Follow-Up Medical Review
If individuals have been exposed, an assessment needs to be made as to whether or not an increased level of monitoring for health problems should be initiated. In some situations this is recommended, but not in most situations. Unless exposures have been heavy, or related to a mineral type of asbestos more closely associated with disease, formalized medical follow-up is generally not recommended by industrial physicians.
Periodic Media Information Updates
If there is continuing concern on the part of the public, which is often the case, it is advantageous to issue a formal written press release or hold media information sessions. This is time-effective and permits a single, coherent and organized description of what is occurring, which can be simultaneously communicated to all concerned. Giving individualized interviews to different reporters at various points in time can increase the level of confusion regarding a situation. A press release describing what has occurred and what steps are being taken, with direct comments regarding human risk, is important. Concern usually is not focused on regulatory mandate but on whether or not individuals were exposed or will suffer increased likelihood of disease. Levels of property damage, costs, and reoccupation logistics are also of interest, but the real issue correctly focuses upon whether or not someone has been endangered.
End the Crisis - Replace it With a Controlled Engineering Response
The ultimate goal of an emergency response is to stabilize the situation and allow subsequent work to be treated as a disciplined engineering project. This can happen by making certain you have appropriate counsel in terms of analytical testing techniques, engineering situations and capacity to establish appropriate guidelines for managing the contractual clean up that usually follows.
You can expect that costs relative to emergency response will be much higher than those incurred in a planned, competitively bid project. |