Asbestos Abatement >> Asbestos Flooring

Question 1: Are we correct that Asbestos Flooring floor tile cleaning activities (normal maintenance such as stripping and buffing operations) are covered under both the Asbestos flooring General Industry Standard (§1910.1001) and the Asbestos flooring Construction Standard (§1926.1101)? 

Answer: Yes. Both standards contain the same requirements for care of Asbestos-containing flooring material. The Asbestos Flooring requirements are at 29 CFR 1910.1001(k)(7) and 29 CFR 1926.1101(l)(3). 

Question 2: Are we correct that for normal cleaning (routine stripping and buffing) that the Asbestos flooring General Industry housekeeping procedures apply, Asbestos Flooring however the Asbestos flooring Construction Standard applies when floor tile clean-up activities are performed as a result of or incidental to a Class I, II or III job? 

Are we also correct, that asbestos flooring floor tile cleaning under the Construction standard is considered a Class IV job? Answer: Stripping or buffing asbestos flooring-containing flooring material previously soiled with asbestos flooring-containing dust or Asbestos Flooring debris from a Class I, II, or III Asbestos Flooring job is not part of the clean-up activity. 

The clean-up activity consists of picking up the debris and vacuuming up the dust. As such, Asbestos Flooring stripping or buffing asbestos flooring-containing flooring material does not come under any of the designated classes of asbestos flooring work defined in the Construction Asbestos flooring Standard. 

The stripping or buffing of asbestos flooring-containing flooring material usually comes under the scope of the General Industry Asbestos flooring Standard. However, stripping or buffing of the flooring material comes under the scope of the Construction Asbestos Flooring Standard if a construction company does it as part of the completion of a construction project. 

Question 3: Both standards discuss stripping operations and [stipulate] that low abrasion pads, wet methods, and Asbestos Flooring speeds lower than 300 rpm must be employed. If higher speed machines are used and current Negative Exposure Assessment (NEA) data exists (by TEM) showing the PEL was not exceeded, is it necessary to submit a written alternative work procedure and/or seek a variance? 

Answer: The Construction Asbestos flooring Standard does not allow the use of alternative procedures Asbestos Flooring for care of asbestos flooring-containing flooring material. The Standard makes allowances for using alternative control methods for only Class I or II asbestos flooring work. 

The fact that the asbestos flooring PELs are not exceeded when the floor stripping uses low abrasion pads at speeds greater than 300 revolutions per minute (rpm) is not a sufficient condition Asbestos Flooring to warrant the receipt of a variance permitting such use. 

In order to receive a variance, Asbestos Flooring the employer must have implemented some means of maintaining asbestos flooring aerosol levels in the employees' breathing zones at levels equal to or less than the levels occurring at speeds lower than 300 rpm. Question 4: While the Construction Standard discusses submitting alternative work procedures, the General Industry Standard does not. 

How does one handle an alternative work procedure regarding the General Industry Standard? Answer: As we noted in our reply to your third question, Asbestos Flooring the Construction Asbestos flooring Standard makes allowances for alternative control methods for only Class I or II asbestos flooring work. 

Therefore, whether the stripping or buffing of asbestos flooring-containing flooring material is covered by the Construction Asbestos flooring Standard or the General Industry Asbestos Flooring Standard, Asbestos Flooring the employer who wishes to use alternative stripping or buffing procedures must seek a permanent variance.

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