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Environmental Risk Advisor:
Asbestos in Commercial Buildings - Abate or Manage In Place?

Charlotte, North Carolina - Health hazards associated with airborne asbestos exposure were originally known to impact workers involved in building trades, the maritime industry, mining, and the manufacturing/processing of products which contained asbestos. Three of the major adverse health effects associated with long term (10-40 years) exposure to airborne asbestos fibers include asbestosis, lung cancer, and mesothelioma. Asbestos exposure associated with the industries noted above are radically different than the potential exposure expected for building occupants in commercial buildings with asbestos containing building materials (ACBMs). ACBMs are defined as building materials containing greater than 1% asbestos.

ACBMs, if undamaged and properly managed, should pose no airborne exposure to building occupants.

However, to ensure that ACBMs were properly identified and managed, the air toxic regulations under the Clean Air Act required the EPA to specify work practices intended to minimize the release of asbestos fibers during renovation and demolition activities in buildings containing asbestos. These EPA National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations require 1) a thorough asbestos inspection where demolition or renovation activities are planned, 2) notification of the appropriate delegated entity (or state agency) before initiating the demolition of a commercial building that contains regulated amounts of ACBMs (these threshold amounts are discussed in detail below) and 3) designation of specific work practice standards designed to control asbestos emissions during demolition and/or renovation of these facilities.

The paranoia surrounding asbestos has driven many professionals involved in commercial building management and financing to consider asbestos abatement as the only alternative available to address concerns regarding ACBMs. Removal of asbestos to address concerns surrounding ACBMs is often a costly alternative to managing ACBMs in place. The vast majority of ACBMs in commercial buildings are not damaged and pose no health hazard to the building occupants when properly managed in place. 

Asbestos

The majority of ACBMs in commercial buildings are typically non-friable (cannot be crushed or manually manipulated to render the material airborne). These materials primarily include resilient floor coverings, floor tile, and construction adhesives where the asbestos is embedded in a matrix. Friable asbestos (ACBMs that can be crushed or manipulated, rendering the material airborne) include ACBMs such boiler insulation, pipe insulation, duct insulation, spray applied fire-proofing for structural steel and textured ceiling treatments. Friable and non-friable asbestos pose no health hazard if these materials are not disturbed or damaged.

A thorough asbestos inspection performed by an accredited and licensed inspector should identify whether an ACBM is friable or non-friable, the condition of the material, the potential for disturbance and if the ACBM poses a potential airborne exposure hazard.  Asbestos building inspections must only be performed by an accredited, licensed and experience asbestos inspector capable of identifying, sampling and characterizing all building materials that are presumed to contain asbestos.  At a minimum, asbestos inspectors must meet minimum accreditation requirements established by the USEPA.  Licensing requirements for asbestos professionals may also vary between states, as some states have developed specific accreditation requirements, which go beyond the minimum licensing requirements established by the USEPA for asbestos inspectors, asbestos management planners, asbestos third party air monitors and asbestos abatement design professionals, among others.

ACBMs can EASILY be managed in place by drafting and implementing an Asbestos Operations and Maintenance Plan (O&M Plan), which identifies the type, location and condition of all ACBMs.

The Asbestos O&M Plan should be accessible for review by all building maintenance and renovation professionals. Adherence to an Asbestos O&M Plan will ensure that any building maintenance/renovation activities performed by these professionals, which impact ACBMs, include the proper precautions to prevent personal exposure to asbestos and that those activities are performed in a manner which will also prevent an airborne health hazard to building occupants. Costs for the development of an Asbestos O&M Plan for a commercial building can vary, depending on building size and the amount of ACBMs identified, but typically range from $1,000-$2,000 and are usually closer to the low end of this cost range. However, the cost associated with engaging a third party consultant to manage the asbestos abatement process are only a fraction of the overall cost of physically removing ACBMs. In fact, engaging an experienced third party consultant to develop an effective asbestos abatement design, solicit competitive bids and manage ACBM removal performed by abatement contractors are key to cost-effective ACBM abatement.   

If the asbestos inspection does identify damaged ACBMs, which may result in occupant exposure to asbestos fibers, asbestos removal or abatement should be performed. Costs for ACBM removal depends on the type and quantity of the ACBM and are fairly standard. Some good “rules of thumb” for unit prices for ACBM removal:

1)   Floor tile and mastic (glue which adheres the floor tile to base floor) is typically $3.00-$5.00/square foot (depending on substrate and mastic used a glue)

2)   Pipe insulation or ductwork insulation-$10-15/linear foot (depending on diameter and accessibility of piping)

3)   Sprayed on structural steel insulation and spray on ceiling texture ranges from $25-40/square foot (depending on substrate and accessibility)

The unit costs for asbestos abatement above do not include the 1) the original asbestos abatement design developed by a licensed asbestos design professional, 2) performance of abatement contractor pre-bid meetings to obtain competitive asbestos abatement pricing, 3) third party air monitoring during performance of abatement activities by an accredited asbestos air monitor or 4) post abatement inspection and air sampling prior to building re-occupancy. These asbestos abatement management activities should be performed by a competent, accredited and experienced third party asbestos consultant, who is unrelated to the company performing actual abatement activities. Some states prohibit asbestos air monitors from working directly for an abatement contractor to prevent a conflict of interest.


Gregory P. Lathan

President

About Environmental Risk Innovations (ERI)
ERI is the nation’s largest environmental risk consulting firm, specializing in the management of environmental risk for commercial lenders.  ERI’s clients include small regional banks to large banks with national footprints.  ERI develops internal environmental risk policy for commercial lenders, provides third-party review of environmental assessment reports, and conducts Records Search with Risk Assessments (RSRAs)/“desktop reviews” on commercial properties.  ERI is not a traditional environmental consulting firm that performs Phase I or Phase II Environmental Site Assessments.  As a result, ERI’s recommendations represent a truly independent, third-party opinion that conforms to the client bank’s specific risk tolerance.  

For more information on ERI's environmental consulting expertise, please contact Karen Nelson at knelson@eRiskInnovations.com or 704.548.9333.

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