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hello everyone welcome to the post-lunch most exciting presentation there is I'm Joe Scanlon I am one of five new shap asbestos inspectors for the DEQ my territory is the whole Upper Peninsula and most of northern lower actually did give this presentation in April I think of this year in Gaylord so if some of you might have seen this I'm not sure basically I'm gonna end up flying through this I usually have a over an hour just start the presentation with kind of going over the basics who regulates asbestos there's two entity entities in the state of Michigan there's DEQ and there's our asbestos nisha program and then there's Department of Licensing & regulatory affairs they operate the MIOSHA portion of it which you'll see a minute here focuses mostly on workers safety whereas I focus mostly on waste handling and disposal technique so I can get a little confusing between the two yep there we go so Michigan was granted authority by the US EPA to enforce their nisha asbestos program they monitor us they require us to submit annual reports outside of US EPA can come in and do their own inspections on and they have in the state of Michigan they tend to not communicate with us when they do that sometimes sometimes they just show up and and take over but for the most part 95% of asbestos cases in the state are handled by DEQ City Michigan adopted the knee shamp dry reference I think you guys can come on in everybody's everybody's probably familiar with asbestos because of these billboards like this that you see all over the state and all over the country really these mittigar leza asbestos law attorneys they have a pretty good business going what is asbestos it's a naturally occurring mineral it's actually a wonderful product when it's used correctly unfortunately it was not used correctly or handled correctly over the last hundred years or probably much longer than that the big problem with asbestos is that its crystallized mineral the crystals are very long they're very minut there are five microns much smaller than human eye can see and the problem is once they become airborne they can stay airborne for a very extended period of time and once they get into your lungs or your respiratory system it's very difficult for them to be removed most time they end up staying in place and what happens then is they can scar your tissue of your lungs and that's where you get asbestosis or mesothelioma music female mesothelioma is actually a cancer asbestosis is kind of more about around like emphysema this is a picture of Crystal Light I believe this is what it looks like in its natural state you can actually find outcroppings of this exposed in lost or outside Las Vegas in Henderson Nevada there is actual rocks of this just laying around on the ground and as you would expect mesothelioma and asbestosis case cases are much higher there than anywhere else in the country get your warning mm-hmm in fact the loss Nevada Highway Department wanted to put a highway through here and I think they had to reroute the whole thing because there was so much surface contamination of asbestos that it would have been a nightmare so what's applicable to the nice app there's three main questions we go over is the facility subject is the activity subject and are the materials subject the materials that are going to be handled there's friable asbestos containing material which is basically your powdered can be anything that's pulverized by a hand pressure or crushed non friable is typically your floor tiles asphalt building products things that generally cannot be crushed by hand pressure it's very basic it's like there can be crushed by hand pressure cannot be crushed by any pressure but there's also different things about friable where nine friable can become friable if it's sanded or ground releasing fibers two types of non friable asbestos containing material category one category to category one is gaskets packings for covering like your vinyl sheet flooring vinyl tiles asphalt roofing products category two is anything else like transite siding translate exciting is a tricky one because it can easily become friable just by breaking apart so that's your definitions of your types of asbestos two kinds friable non friable facility types I the knee shaft does not handle anything residential that has less than four units if it's an apartment building with more than four units then it falls under the knee shat program other than that any commercial institutional it all falls under the niche so privately-owned residential I don't even address now MIOSHA on the other hand they do but that's typically only if there's a contractor involved if it's just a residential homeowner that's stripping asbestos out of their house nobody has any control over that it's kind of a free-for-all but as soon as there's a contractor that's got employees where somebody's getting paid my OSHA does get involved so surprisingly ships are fall under the asbestos program for the neish app most people don't realize that ships were loaded with asbestos thermal insulation on the pipes a lot of transit siding in the ships boats are actually just floating floating pods of asbestos and then the other interesting structures are culverts bridges you can have slip joints between the bridge decking and the frame of the bridge that are sometimes asbestos-containing expansion joints between the bridge decking and the roadway the sealants that they used to install those were often had high high concentrations of asbestos and that's some we're constantly having problems with contractors is trying to convince them that they need to do asbestos inspections on a bridge or a culvert because it's kind of hard to understand that logic once subject to always subject it's kind of an interesting part of the knee shafts so if you had a I don't know it's a good example like a school that was converted into residential units or something like that that had less enforce for dwelling units in it it would still be under the knee shack program even though even if all that asbestos had been removed or vated if a wall comes down and it's privately owned and even if it's residential it still falls under danisha it doesn't happen very often where we come across that so just some examples of what falls under there bridges tunnels dock ships lots of military installations are loaded with asbestos that is a big problem and then privately owned privately controlled structures like I said earlier are exempt unless it's owned or controlled by a government entity which is where we get into the blight programmes blight removal programs that you're seeing you've seen a lot of in Detroit and Flint those are considered projects so anytime there's more than one house involved it becomes a project and a project does fall under the knee shap you puts municipal owned if there is a single house that's not part of a large project it does not fall under the knees yep so it can get a little confusing sometimes if it's a resonance and it's not part of a larger project if it's just a one-off house then no even if government-owned but this is where it gets tricky because a project can be any length of time so if you're a county land bank and say you only got grant funding to knock down a single house but you intend knocking down other houses then you have a project so it gets a little it can get a little ridiculous essentially just fill out the notification anyway it's we do for intentional burns yeah yeah that's a little different fire trainings are different yeah because we do require them to to notify but that's coming up here too so activities that are subject renovations and Dennett demolitions what's a renovation a renovation is basically altering any facility component that might have asbestos containing material on it and that's anything from floor tile removal to removal of thermal insulation on pipes boiler bateman's anything like that would be considered a renovation if it falls below the threshold required here which is 264 linear feet linear feet we usually that's like safer pipe insulation on piping you would measure that in linear feet or 160 square feet which typically would be drywall plaster that kind of thing 35 cubic feet which is pretty rare we usually only see that in facilities where somebody had come in and ripped off a bunch of pipe wrap and it's laying on the pile on a floor and then you kind of guess and be like well it looks like 35 cubic feet I guess I better get my notification in but if it's if it's smaller than any of those numbers you don't have to submit your notification anything larger though or if it meets that threshold you do have to submit a notification demolitions are pretty straightforward it's room removing removal of a load-bearing structure so any load-bearing wall column anything like that automatically constitutes as demolition have to fill out a notification no matter what intentional burns of any facility as Janice was saying it's was residential municipal owned doesn't matter who owns it if it's getting burned it has they have to notify probably don't see that too often in this area we have it a lot in the U P you guys do probably on the outside Traverse area but it's a good training exercise we only allowed for fire training exercises you can't just say I want to burn my house it has it has to be yeah great like smoke training you're not saying Burton structure down in your day like a forensics kind of thing something like that I think we would allow that I mean as long as there is a legit purpose for the burning and it's not just hey we got a bunch of beer and some hot dogs and we want to see this thing go to the ground but it is great fire training practice for Rural Fire Department's because a lot of times these guys are volunteer units and they don't see a lot of action yeah they don't get a lot of opportunity so usually when we do see an intentional brain it's it's more than one fire department they usually get adjoining townships together and kind of do a big training where they do shuttle water shuttling and that's it's pretty interesting actually demolitions and intentional burns renovations anything that requires to be a notification requires 10 working days prior to the beginning of it even if there is no demo for a demo or even if there is no asbestos for a demolition renovations are a little different where am I here oh yeah okay sorry it's been a few months I gave this me I think I already went over all this so category one nine friable ACM which would be your floor tile asphalt building products things that are generally pretty safe because the asbestos is contained in some kind of you know sealant if that becomes sand if you sand it grind it cut it any with any kind of abrasive material technically we consider that friable now so if I walk in doing an inspection where the abatement contractor is removing vinyl floor tile with us with a floor sander you're in big trouble I mean you're not only you with me but also with the MIOSHA guy because typically they're not wearing proper protective gear for that kind of stuff category to none friable like I mentioned before that's typically transite siding which I don't know if any of your so you're familiar with them shirts it looks like cement board siding usually comes in I think there's three foot by maybe a foot and a half in pieces very brittle it's very durable if it stays on the house and it doesn't become impacted by some kind of hail storm or something like that it's actually a great material until it starts to become disturbed and then it gets brittle and it starts to fall apart automatically as soon as translight siding is broken if we consider that friable so contractors have a really hard time dealing with this sometimes because it is not easy to remove it's it's difficult to take out the house you basically have to start from the top pull the nails out and remove each piece one at a time it can take quite a long time it's pretty labor-intensive like I said non friable becomes friable when it's in poor condition it's being sanded grounds you've taken abrasive to it a lot of times on older buildings with even category 1 asphalt roofing products which are usually fairly pliable your sealants rubber material that stuff can get really dried out in an older building it gets really desiccated and you can actually go up and crack this stuff to the point where it's not imply ball anymore it's just brutal we do consider that friable at that point which sometimes we get contractors arguing with us about it because they want it to go to the dump you know it's easier for them to send this stuff to the dump than debate it so a lot of times I have to get up on roofs you know with the ladder and make sure the stuff's actually pliable because it can go with the demolition it doesn't have to be abated if it is pliable but if it is brittle technically its friable it has to be abated first pretty straightforward the asbestos has to be removed from the building prior to any activity for I guess we're on the types of notifications here there's the plan renovation which as we explained before it's the removal of any regulator dispenses containing material that's gonna be disturbed requires tend it working day notification not calendar day it's working day this can also be very confusing to contractors and government entities anyone that's a homeowner or structure owner emergency renovations those are an exception they do not require a ten day a ten working day notification we don't see these very often they're pretty rare most of the time we see them it's in heavy industry setting like a paper mill or some kind of manufacturing plant where there's they're operating 24/7 and they've got a lot of steam lines and you got a break in your steam line you can't you can't wait that 10 working days because it's like they're gonna impact your staff or it's gonna impact or the impact the safety of your staff or it's gonna impact your your business to the point when it becomes detrimental to wait that 10 working days most places you can't just shut it down like for a paper mill you can't just shut the whole thing down wait 10 days for us to show up so most paper a lot of paper mills actually will put in a notification once a year because this does happen a lot in paper mills so they'll just submit a notification at the beginning a year saying that in case we do have an emergency renovation here's our initial paperwork when it happens because it will happen we will call you and let you know exactly what's going on scheduled demolitions talked about that earlier requires a ten day working day notification even if there is no asbestos ordered demolition that is also another exception this requires some kind of government entity to actually I guess condemn a building be it government health department it has to be somebody some some organization of official capacity and we do require a notification they don't have to wait the ten working days but they do have to file the notification along with the notification though we do require a written copy of like the meeting minutes or a letter that was written by a building inspector or something that is proof that there is actually an order demo doesn't happen too often but it did just happen recently outside Marquette where I am this was just a couple weeks ago and these can be these can be controversial to this is a historic building that the city of Nogami had been fighting with the owner for I think ten years and they had ordered this thing condemned like half a dozen times but the owner kept holding it up in court because he thought he could save it and he thought he could save it and finally it just got to the point where it was about to fall on the neighboring building which was a bar could have been really bad but it wasn't the basically the owner got really lucky the judge finally threw the book at him and said sorry we're we're tearing it down so even though they don't require a 10-day notification some time making sometimes it can take years I know what happened as fast as you want it to the waste handling side of asbestos it has to go to a type 2 landfill unless it's non file then I can go to a type 3 landfill which typically only ap lies to industry type 3 landfills we usually only see in an industry setting like paper mills have their own type 3 landfill it's pretty rare I mean most of the time they just send it to the regular landfill anyway I work with the waste folks a lot in lampf or landfilling I mean they have to be licensed to accept waste asbestos waste and they have to choose to accept asbestos waste and almost every landfill I work with requires 24 hours of notice before you bring in a load of asbestos and the reason for that is because every asbestos load that comes in has to be geo-reference latitude longitude and depth so they know exactly where that asbestos is deposited within the cell within that landfill in case they have to go back in a later date and put in monitoring wells or some kind of gas collection system they know exactly where that asbestos is so you don't get a guy running a drill rig punching holes through bags of thermal insulation that's the worker safety issue really as I mentioned before Delora is the other regulatory agency our rules can conflict at times it does get a little confusing for people that are new they do not supersede each other they are equally important you must comply with both rules so it's suggested if you're confused contact both of us which happens a lot I work pretty closely with my OSHA guys if I see something going on at a jobsite if I see some kind of worker protection issue that I find very questionable I will contact in my OSHA guys and vice versa if they're on site and they see issues with removal or waste handling so I they call me so we work pretty closely together as I mentioned they do primarily worker protection I do prevention of emissions by either waste handling or removal practices as I mentioned before Delora can handle private residential homes if there's a hired contractor they do not do anything with waste handling that's all me so where do you start like we mentioned before or is it applicable is your structure applicable which basically means is a commercial industrial is it is it non-residential if it is residential are there four or more dwelling units this is some pictures of just some examples here and this is a picture of some pipe wrap or I mean a knot pipe wrap but mud I guess it's the I'm having a loss for worse to the locker this would be the the mud that they use on elbows and joints for the thermal system insulation typically on the older stuff it's almost always hot and this is in really bad shape so it's a good thing this person is wearing a tie vac suit with their PPE on who can conduct an asbestos survey the new shaft doesn't really specify that you have to be trained it's kind of a gray area it gets frustrating at times [Music] you can be trained though under the OSHA standards which is highly recommended where do you start with your building well if it's gonna be a demolition you can start knocking holes in walls that's always fun as long as you sample the drywall first to make sure it's not asbestos containing so typically you just go through the house to cut holes in the walls ceilings whatever sample anything that looks suspect which you'll see later it could be anything really asbestos isn't a lot of materials the asbestos neesh at my program does not have a cut-off date we require notifications and samplings for buildings that were built a month ago the D Laura and this is something that I think they can make exceptions to if they find a reason but typically MIOSHA d Laura they're cut-off dates I think I want to say 1981 and 882 typically but as I said you can still find asbestos containing material in many buildings after that date if the project is subject you gotta do your 10 working day notice my program the Nisha we hold liable the not just the contractor or the operator but also the facility owner so when I have to send out a violation notice there's two one goes to the property owner and one goes to the contractor and I have you both entities have to respond appropriately you can't just get a response from one where it can be found siting piping ceilings floors many many other things well did you do that John oh that's great so here's the trains exciting and it's talking about earlier it is really great stuff if you get a house that has it on there I would leave it unless you don't like the way it looks but really durable the problem is when you get stuff like this it starts breaking apart yeah that whole stuff along the bottom here this stuff is that's bad that's really bad and then this could be a double whammy there's probably wet paint on this and it's hiding all the time so you get facade sort of stuff like this where you know it looks innocent enough but then you get behind it what does this stuff actually mount it on it's mounted on translight board or translight paneling which is great building material just has asbestos in it this is something that we don't see too much but it's kind of a unique material it's called ghoul bestest it looks like galvanized corrugated galvanized paneling but it's not it's actually trans ight and it's very brittle the only time I've ever seen this is in an old maintenance shops basically it's a great fire barrier between areas that are using lots of solvents and other areas this is the one most people know about this is your thermal system insulation it's easy to tell because it's got this corrugated cardboard look when you do a cross section of it this stuff is almost always guaranteed asbestos nowadays a lot of the stuff that's been abated they replaced with fiberglass but interesting thing about the fiberglass thermal system insulation is the fiberglass itself is not asbestos containing of course but a lot of times they put this really thin tar paper around the pipe and then they put the fiberglass the tarpaper is almost always asbestos-containing so even if it's fiberglass you can still have asbestos containing material and on there underneath of it so I see this a lot in old buildings this is when you walk in the door and you walk right back out and you go get your respirator and you put on your Tyvek suit because this is not good here's some ceiling this is popcorn ceiling really popular during the 70's and 80's not all of it but a good portion of it is hot it's pretty easy to remove actually you can I think you can use steam and just a scraper my buddy if you have to do it in your own home like yeah I wouldn't recommend it a floor tile this is this is what floor tile goes from non friable to friable this stuff is obviously pretty brittle it's broken apart it's desiccated and dry you'd be surprised how quickly that can happen even in a building that's only been abandoned for two years if it hasn't been heated if there was water damage during that time you'd be amazed how quickly that floor tile can go from being pliable to really brittle and I've worked in actually as a Department of Corrections facility that was being torn down and it only been vacant for two years I think and I walked into there walked into the gymnasium because this was a it was a minimum security center and contractors in there driving over all this brittle floor tile with the high lift and he's just rolling across the gym and all you can hear - snap snap crack crack crack and I'm just like okay we got a problem this is the mastic that they use sometimes to put vinyl flooring over hardwood or any other solid surface like concrete it's kind of hard to see but it's this black looking stuff here that stuff can have a specialist in it as well so it's not just the actual floor covering it can be the adhesives that they use to put that floor covering down this is another common one that contractors or consultants missed a lot old electrical boxes these panels in the back sometimes they were trans like this is a this is an interesting one this is where window glazing becomes an issue a lot of times man probably almost all older windows the glazing is is hot the window glazing was is it's pretty high for asbestos the interesting part is though we measure in linear feet so you have to have a lot of windows before it triggers the knee shop so we typically only see this in like giant old warehouses that are being torn down no the actual caulking around the window that hold that seals the between the pane and the frame yeah yeah not not like a film on the glass this is actually the material that you know goes between the window and the frame along the edges here but like I said we measured that in linear feet and you need 160 or 260 linear feet before it requires the knee shaft so a linear feet no I'm linear feet yeah so well that's where this gets interesting because you have to take the width of the glazing and basically do a lot of math and come out with an equation that shows that you're gonna be below that threshold so usually it's about a quarter-inch wide and then you add up all of your windows yeah so we don't see it too often but like I mentioned MIOSHA has different rules and they don't have a threshold for that so while I might not get a notification for it because it doesn't meet my thresholds MIOSHA always does because if the bioship walks onto a site and sees them removing windows like this with the friable window blazing then the contractors get in trouble this is vermiculite this has been a recent touchy subject why is it touchy because we have a lot of instances where vermiculite test positive for asbestos because they were mined so closely together in fact a lot of times they were pulled out of the same pits vermiculite some other mineral in fact one of the more common sources of vermiculite was the Libby mine out of Montana which is famous for asbestos worker protection because that's essentially what started all of our my OSHA protection in the United States was because of employees a living mine and their families we're all many of them were inundated with mesothelioma and asbestosis so a lot of this vermiculite comes out of the Libby mine the problem with vermiculite is that there is no real good test there's no guaranteed test right now to prove that it is asbestos containing and we have a heart we're we have a hard time getting EPA to definitively say that all vermiculite is asbestos containing material but EPA will send basically all their correspondence with us it comes down to highly recommended highly recommended to abate highly recommended so while you can't test for correctly or accurately I should say as DEQ asbestos program we're working with contractors to make sure that it is removed as asbestos containing material we do get some pushback on that because it is cost prohibitive it's not easy to handle either a lot of times you got to use a vac truck or a Veck loader with a HEPA filter on it and get in there and literally vacuum it all out and a lot of times you can find it in cinder block walls where they actually pour it down inside the walls as they're building it those can be very difficult to remove no this is an attic which is more typical where you'd see it you'd see it mostly in attic spaces like this or inside a wall cavity of a stick-frame house listen your black one is kind of a rare one but they are out there pardon no it can be tested but there's flaws and all the tests they have right now there's three kinds of tests and EPA will not they won't settle on a single one they've they've been saying for about 15 years now that they're going to come out with a test method and they they have not so it takes a very large bulk sample yeah and it depends on where you sample right and it depends on where you sample from so it puts in a wall cavity are you sampling from the bottom of a wall cavity are you sampling from the top of the wall cavity because you're gonna have some settling there no matter what but yeah so there's a lot of discrepancies and the sampling method and the test methods just bills disposal it's treated as a friable so it goes it goes as friable ways to the landfill mm-hmm yeah actually this is that's an educational thing I need to work with more I'm landfill operators is getting them to recognize vermiculite as it comes in but we're getting there what we want you to do well if you're an agency that issues permits we would like you to take our handouts and combine them with your own not combined but I guess hand them out to your contractors as well as your own and I have all that information Jen's got most of that information as well we have a pretty good frequently asked questions pamphlet that basically gives the whole rundown of the nee sham program and how we operate what we do and what you would have to do to file a notification so it's a really good thing to give to your contractors if you work for a building department or something of that nature or you are a consultant we can definitely provide you with any of that information I did have a checklist at one time it needs revised though so I'm working on that one and then if anybody has questions please contact one of us I'm only a part-time asbestos inspector it's 20% of my job which doesn't sound like a lot but given the vast size of my area which is the whole you pianned kind of from lansing north it can get pretty pretty busy especially during the summer months but we all of us have cell phones you can contact any of us at any time during the week even if we're in the field so Kim dome she is our our notification system guru out of Lansing she's typically a never in the field but she's the one that will handle any of your notification requirements with our online notification system I handle you P northern lower we've got two inspectors out of Lansing Craig Gehrke and Jeremiah brown they handle basically they split actually some of the northern lower with me occasionally like for Traverse City area you could see either myself or Craig or Jeremy up here they are they also have a very large area to cover and then because of all the blight remediation going on in the Detroit in area and Southeast Michigan we have two dedicated asbestos personnel based out of the Detroit office and that's Tammy Belle and Joe got a key even if you're not in their area and you have a question you can't get a like say your if you have a question about a project and you pee if you can't get a hold of me for some reason you can call any of these people they we all have the same knowledge base and I handle questions all the time from Lower Michigan for contractors this is our website it's pretty easy at least to get to the main aqd website this is it's still accurate right okay michigan.gov slash air pretty easy and then once you're on that main page there's I think it's on the yeah the bottom or on the right side or both yeah on the bottom in on the right side of the main aqd page are links to the new shaft program which once you click on that it'll take you to all the notification requirements and the actual notification system we have a new asbestos notification system it's pretty user friendly it just came online about a year ago much more user friendly than the old one this one that it's it's very easy to work with I think that's about it if you need to get ahold of anybody in d Laura here's their hotline and that's about it anybody got any questions