Resilient Flooring

Resilient Flooring

General Notes for

Resilient Flooring

The levels for each work practice included in this section are defined principally in relation to the OSHA asbestos standards. There are two standards that may apply. The OSHA construction standard, 29 CFR 1926.1101, applies to most O&;M activities that involve removal of resilient flooring. Normal cleaning, and buffing of resilient flooring that is not associated with construction or other O&;M work is covered by the OSHA general industry standard, 29 CFR 1910.1001. When maintenance and custodial activities are incidental to construction this work is Class IV under the construction standard, 1026.1101.

In general, an O&;M program is easier to implement and is more cost effective if maintenance work can be performed without the need for enclosures. Maintenance work that contacts or disturbs asbestos-containing materials (ACM) is governed by OSHA. To be able to perform maintenance work governed by the Construction Standard (1926.1101) without an enclosure and still comply with OSHA, it is necessary to make a negative exposure assessment. This effectively makes the OSHA PEL a limit on the level of airborne asbestos that can be generated by a work practice before enclosure is required. In general, Level A and B+ maintenance work practices are unenclosed and as such require a negative exposure assessment.

The two work practice levels in this section are defined as follows:

Level A: is Class II work with a negative exposure assessment that involves removal or repair of resilient floor covering materials. It also encompasses certain housekeeping operations, such as cleaning, buffing or polishing of resilient flooring, governed by the general industry standard, 29 CFR 1910.1001, where initial monitoring is required for such work unless: (1) a determination has been made that these activities using the work practices in this manual (which are based on those contained in the OSHA regulations ) are not reasonably expected to result in exposures exceeding the PEL; (2) the employer has monitored after March 31, 1992 for the TWA permissible exposure limit and/or excursion limit and the monitoring satisfies the requirements of 1910.1001(d); or (3) the employer has relied on objective data (see pg. 4-8 for explanation of objective data). In addition, housekeeping operations performed incidental to construction work are governed by the construction standard, 29 CFR 1926.1101(l), and are also within Level A when an NEA has been made in accordance with paragraph 1926.1101(f)(2).

Level B+: Level B+ is removal of resilient flooring materials that are not intact, or will become non-intact during removal, or where a negative exposure assessment cannot be made. Augmented Level B+ work practices can be used for work on resilient flooring where flooring materials become friable, if the OSHA PEL is not exceeded and release of ACM, dust and debris is confined to the immediate location of the disturbance. To comply with OSHA, Level B+ work practices used for this purpose require the addition of critical barriers to the respiratory protection, air monitoring and other work practices normally associated with Level B work. If more that a small quantity of material is disturbed during the work, then the activity exceeds the limitation of the work practices in this manual. Refer to the NIBS manual Model Guide Specifications, Asbestos Abatement and Management in Buildings for more information.

Using the Resilient Floor Covering Manufacturer’s Recommended Work Practices for the removal of Resilient Flooring.

The Resilient Floor Covering Institute (RFCI) and Armstrong World Industries (hereinafter referred to as the Resilient Floor Covering Manufacturers) have developed work practices that apply to the removal of asbestos and non-asbestos-containing resilient floor covering materials. Some of the Level A work procedures in this section are based on those work practices. Work procedures that incorporate the RFCM procedures are noted as (RFCM Procedures).

OSHA revised its asbestos standard, in August of 1994. Resilient flooring manufacturers filed petitions for judicial review of parts of the standard. A settlement agreement resolving these petitions was reached with OSHA on June 15, 1995 before a court decision was rendered. This «Settlement Agreement» is included in Appendix D to the OSHA Compliance Directive that relates to the new OSHA standard (CPL 2-2.63, November 3, 1995, Inspection Procedures for Occupational Exposure to Asbestos Final Rule 29 CFR Parts 1910.1001, 1926.1101, and 1915.1001). The O&;M designer and asbestos program manager should acquire a copy of the OSHA Compliance Directive from the local OSHA office and review it during the development of facility specific work procedures for resilient flooring.

The EPA NESHAP regulation (40 CFR Part 61, Subpart M) addresses the handling and disposal of ACM during renovation and demolition of buildings. The position of the EPA on resilient flooring was clarified in the November 1990 revision of the NESHAP regulation. Asbestos-containing resilient floor products are defined by this regulation as a Category I nonfriable material, which is not regulated by the NESHAP unless it becomes friable or is subjected to sanding, grinding, cutting or abrading. Cutting in this instance includes sawing, but not shearing, slicing or punching. The EPA has determined that resilient flooring materials that have not been made friable before or during the work do not need to be disposed of as asbestos waste.

Any work procedures used must, at a minimum, meet the requirements of the OSHA and NESHAP regulations. This introduction describes the steps necessary to insure that O&;M activities using the Manufacturers'; Recommended Work Practices will be in compliance with these regulations. The O&;M designer and APM should realize that state or local regulations may have requirements that differ from federal regulations and some may be more stringent. The work procedures in this section may have to be modified to comply with state or local regulations.

OSHA: During development of the OSHA regulation exposure data for workers involved in removal of resilient flooring was submitted. In the Settlement Agreement with the flooring manufacturers, OSHA agreed that data submitted during the rulemaking shows that removal of asbestos-containing resilient flooring material consistently results in worker exposures below the PEL (both the TWA and excursion limit), as long as certain work practices are followed. These work practices are referred to as «compliant work practices.» OSHA has determined that a data set called the «Environ Data» is an example of this sort of exposure data, and that work practices recommended by the resilient floor covering manufacturers is an example of compliant work practices. This means that the Environ Data can be used as the basis for a «Negative Exposure Assessment» as long as the «Recommended Work Practices» are used, and the material remains «intact» throughout the removal process. If a negative exposure assessment is made OSHA does not require that the work area be enclosed or that workers wear respirators or other asbestos specific protective clothing. Some of the Level A work procedures in this section are based on the manufacturers'; «Recommended Work Practices.»

During design of the O&;M program, the O&;M designer needs to make a determination that a negative exposure assessment (NEA) is feasible for O&;M work involving removal of resilient flooring using the Recommended Work Practices. This should be done before this work is permitted under the O&;M program as a Level A activity. An administrative framework should be established to ensure that a negative exposure assessment is made and documented for each resilient flooring project. This can be accomplished by making the APM responsible for the NEA. This is appropriate if the workers are directly supervised by the APM, and the APM is acting on behalf of the building owner or property manager who employees the workers. In this instance the APM must be a competent person as required by OSHA for work on intact resilient flooring. The APM should evaluate each O&;M project to insure OSHA compliance before issuing a work order. This can be documented by having the APM complete the job form from «Using Compliant Work Practices to Remove Resilient Floor Covering» (see Appendix E) published by the Resilient Floor Covering Institute (RFCI) and Armstrong World Industries, Inc. This form should be signed by the APM as the Competent Person making the negative exposure assessment. The designer needs to decide if any additional procedures need to be added to comply with the owner’s goals for the O&;M program. If O&;M work on resilient flooring is going to contracted out refer to the NIBS Model Guide Specification, Asbestos Abatement and Management in Buildings for more information.

There are several steps necessary to insure OSHA compliance when using the recommended work practices for O&;M work. These must be accomplished by the APM to insure OSHA compliance.

A negative exposure assessment must be made by the competent person. The OSHA asbestos rulemaking record contains many measurements, collected under a variety of worksite conditions, showing worker exposures during removals of asbestos-containing «flooring material» (floor tile, sheet vinyl floor covering and flooring adhesive). As part of the Settlement Agreement, OSHA has agreed that these data show that use of Compliant Work Practices during removal of intact flooring material consistently result in worker exposures below the TWA and Excursion Limit established by the revised OSHA standard. As such, before removal begins a Competent Person trained under requirements set forth in the Settlement Agreement may assess the job and make a negative exposure assessment when:

Compliant (Recommended) Work Practices will be used. Work practices R1 and R2 are based on «Recommended Work Practices for the Removal of Resilient Floor Coverings,» revised August, 1995, published by the Resilient Floor Covering Institute (RFCI) and Armstrong World Industries, Inc. OSHA has agreed that these «Recommended Work Practices» are an example of compliant work practices. If these work practices need to be modified due to specific circumstances of a facility, caution should be used to insure that the changes do not change their status as examples recognized by OSHA. If any change is going to be made to the work procedures, the O&;M designer should refer to the original «Recommended Work Practices» and the OSHA Compliance Directive to insure that the new procedure is still a «Compliant Work Practice» Workers are properly trained. Workers using the Recommended Work Practices for the removal of resilient floor covering materials must have completed an 8-hour training program as required by the OSHA regulation 29 CFR 1926.1101 and the compliance directive. The course must cover asbestos subjects as well as training in the Recommended Work Practices. A Competent Person involved in removal of intact flooring material using compliant work practices must have completed an 8-hour worker training program and additional 4 hours of training (a total of 12 hours of training) as required by the Settlement Agreement.

The resilient flooring is intact and is likely to remain intact throughout the removal process. Intact in this instance means that the ACM has not crumbled, been pulverized, or otherwise deteriorated so that it is no longer likely to be bound with its matrix. In the Settlement Agreement OSHA agreed that the incidental breakage of flooring material, including slicing of sheet vinyl floor covering with a sharp-edged instrument, during removal operations using «Compliant Work Practices» does not mean that the material is not removed in an «intact» condition. Rather, the issue of whether flooring material is «intact» is determined by whether the flooring material (whether broken or not) has crumbled, been pulverized, or has otherwise deteriorated so that it is not likely to be bound with its matrix.

A Negative Exposure Assessment is not justified if these three conditions are not met. If a negative exposure assessment is not or cannot be made, or if applicable OSHA exposure limits are exceeded, other provisions and requirements of the OSHA asbestos regulation remain in full force and effect.

If a job begins as an intact removal, but the material being removed becomes non-intact or no longer can be removed intact, work must be stopped until workers and a competent person with the appropriate training and engineering controls required for non-intact (or aggressive) removal methods, are put into place. For a discussion of these removal methods, refer to the NIBS Model Guide Specifications Asbestos Abatement and Management in Buildings specification section 02087, «Resilient Flooring Removal — Aggressive Asbestos Abatement.» OSHA reserved the right to reconsider its determination that a negative exposure assessment for particular floor removal operations may be based solely on the data in the rulemaking record if OSHA field data or other information, weighed against the data in the rulemaking record, show that exposures during particular floor removal operations in which compliant work practices are used are likely to exceed the TWA or Excursion Limit.

A «Competent Person» must supervise the work and have authority to take prompt corrective measures to eliminate hazards to the health and safety of workers. This does not mean that the Competent Person is required to be on-site at all times during the work, but that person must inspect the job site frequently and regularly, at any time at an employee request, and at other appropriate times, such as to access if conditions have changed. (Note that a project may have more than one Competent Person.) For work on intact resilient flooring, the Competent Person must, as a minimum, have the 12 hours of training required by OSHA for a Competent Person involved in removal of intact flooring material using compliant work practices. If non-intact resilient flooring is involved, or if the flooring cannot be removed intact, then the competent person must have completed a 40 hour training course meeting the criteria of EPA';s Model Accreditation Plan for supervisors. The training required for intact resilient flooring removal differs from that required for competent persons for other asbestos abatement activities. Most other abatement activities require a minimum of 40 hours of training for a Competent Person, as opposed to the 12 hours required for intact resilient flooring work. The training required for resilient flooring work could be included in the longer course, but this needs to be verified by the designer.

Recommended Work practices must be used. The designer must insure that the work procedures used in a facility are equivalent to the «Recommended Work Practices» published by the resilient flooring manufacturers. Work practices R1 and R2 are equivalent to the «Recommended Work Practices» which OSHA has accepted as an example of «Compliant Work Practices.» If these work practices need to be modified to suit conditions in a particular facility, the designer should make a determination about whether the work practice is equivalent to the «Recommended Work Practices.» A negative exposure assessment will be necessary before using a work procedure that is changed enough that it is no longer equivalent. Refer to the NIBS Model Guide Specification Asbestos Abatement and Management in Buildings specification Section 02085″Resilient Flooring Removal — Resilient Floor Covering Manufacturers'; Recommended Work Practices,» for information on additional work practices.

Compliance with OSHA is a minimum requirement. If the owner or O&;M designer wants to specify more stringent standards than OSHA requires, then refer to the section later in this introduction on «Optional Quality Control Measures.»

Compliance with state and local regulations: In addition to federal regulations, various other state and local government agencies have regulations governing the removal of in-place ACM. Some state and local regulations differ from federal regulations and may be more stringent. It is recommended that the specifier determine whether such regulations apply.

Considerations regarding the use of Work Practices R1 and R2:

The use of work practices R1 and R2 is dependent upon a competent person making a Negative Exposure Assessment (NEA) as described above. The O&;M designer and the Asbestos Program Manager should be familiar with the requirements for the NEA and with the OSHA Compliance Directive (2-2.63 November 3, 1995) that sets forth these requirements. The O&;M designer should be convinced that it is realistic to make an NEA for materials and conditions in the facility.

Compliant work practices such as the Manufacturers'; Recommended Work Practices upon which work practices R1 and R2 are based, when followed, can provide an effective means to control occupational exposures below those limits set by OSHA. [The air monitoring performed for OSHA exposure monitoring does not distinguish between asbestos and non-asbestos fibers and cannot measure the short or thin fibers that may be detected using transmission electron microscopy (TEM) analysis.] Refer to APM-6 for more information on air monitoring

O&;M program designers considering resilient flooring removal work practices should consider means to prevent influence of other asbestos related work on any clearance monitoring (especially using TEM analysis) which may be specified for the flooring removal. The reverse, i.e. preventing influence from the flooring removal project on the TEM clearances of other asbestos related work, should also be considered. Methods to consider include proper sequencing of the different removal projects, use of critical barriers and project decontamination procedures, and having the resilient flooring removal performed using the «Optional Quality Control Measures» discussed later in this introduction.

Use of compliant work practices such as the Manufacturers'; Recommended Work Practices upon which work practices R1 and R2 are based, have been found by OSHA to consistently result in worker exposures below the TWA and Excursion Limit established by the revised OSHA standard. However, under certain circumstances such as sanding, drilling, sawing, or mechanical chipping the flooring material may be rendered (or already have been rendered) friable or not intact. In general, Level B+ worker and area protection work practices should be used if flooring material has been found to be asbestos-containing and is or becomes friable or not intact, or if additional quality control measures are desired.

If asbestos-containing resilient floor covering material is found to be friable, or becomes friable during removal, it is regulated as ACM under the NESHAP, and NESHAP notification, emission control, transportation and waste disposal requirements may apply. Similarly, if floor covering in schools (grades K-12) is or becomes friable, removal performed as an abatement action is covered by EPA Asbestos Emergency Response Act (AHERA, 40 CFR 763.90(I)(v)) regulations, and design, contractor and abatement worker accreditation, and area clearance requirements apply for work greater than small-scale, short duration.

To obtain a complete copy of the work practices booklet and/or a copy of the reports discussed above, contact:

Resilient Floor Covering Institute

966 Hungerford Drive, Suite 12-b

Rockville, Md 20850

Resilient Flooring

(301)340-8580

Armstrong World Industries, Inc.

P.O. Box 3001

Lancaster, Pa 17604

(800) 438-5954

This section presents several optional quality control measures that the designer may want to consider when working in occupied buildings, although these measures are not required by OSHA. These optional measures can provide a range of quality assurances for the owner including: assurance that asbestos fibers will not migrate beyond the work area in case of method failure; indication of whether the work practices are performing as expected; and indication of whether additional clean-up is necessary.

Critical Barriers: Critical barriers over openings into the work area may be specified: if the owner or designer wants to physically isolate the work from adjacent areas, for example, in occupied buildings, or if there is a requirement for TEM clearance sampling in an adjacent abatement work area. This can be specified by adding Worker General Procedure W5 «Critical Barriers» to the work practice.

Air Monitoring: The Owner may specify air monitoring inside the area where work is occurring to verify that the work practices are resulting in airborne asbestos levels within the owner’s parameters. Air monitoring may be performed in adjacent areas to assure that these areas are not affected by the work. Air monitoring may be desired to help avoid conflicts with TEM clearance of adjacent asbestos abatement project areas. This can be specified by adding Worker General Procedure W 8 «Beginning and Conduction Air Monitoring» and/or W16 «Visual Inspection and Completing Air Monitoring» to the work practice.

Full-time On-site Competent Person: The owner or O&;M designer may specify a full-time on-site competent person to supervise the work and help assure that flooring materials stay intact during the entire work process and that proper work practices are followed throughout the job. This can be accomplished by adding this specification at the beginning of the work practice.

Respirators: The owner or designer may specify respiratory protection for workers to assure minimal exposure to airborne asbestos, including fibers which are not counted under the OSHA standard. This can be specified by adding Worker General Procedure W6 «Putting On Respirators and Performing Fit Checks» to the work practice.

Worker Decontamination: The Owner to Designer may specify worker decontamination (e.g. workers HEPA vacuuming off clothing while standing on drop cloths) as an additional assurance that asbestos-containing debris or dust will not be carried to areas outside the work area, or to workers'; homes. If respirators are specified, there should be some sort of worker decontamination procedure to precede removal of respirators. Worker General Procedure W15 «Worker Decontamination and Removal of Protective Clothing and Respiratory,» contains work practices such as changing suits and HEPA vacuuming workers as a dry decontamination procedure. These work practices can be adapted by adding W15 to the work practice.

Other Controls: If other controls such as bagging and labeling clothing and equipment can be specified by adding the appropriate Worker General Procedure to the work practice.

Cleaning, Polishing, and Buffing Resilient Flooring:

Level A: This work is defined in terms of «housekeeping» in the general industry standard (29 CFR 1910.1001) and the construction standard (29 CFR 1926.1101(l). It encompasses certain housekeeping operations, such as cleaning, buffing or polishing of resilient flooring, governed by the general industry standard, 29 CFR 1910.1001, where either: (1) a determination has been made that these activities using the work practices in this manual (which are based on those contained in the OSHA regulations ) are not reasonably expected to result in exposures exceeding the PEL; (2) the employer has monitored after March 31, 1992 for the TWA permissible exposure limit and/or excursion limit and the monitoring satisfies the requirements of 1910.1001(d); or (3) the employer has relied on objective data (see pg. 4-8 for explanation of objective data). In addition, housekeeping operations performed incidental to construction work are governed by the construction standard, 29 CFR 1926.1101(l), and are also within Level A when an NEA has been made in accordance with paragraph 1926.1101(f)(2). See Level A2 in Figure 2 in the introduction for a checklist of requirements.

Work practices: required for this work are those set forth in the OSHA general industry standard for non-construction-related housekeeping activities. Awareness training is required for workers. Paragraph (k) of the general industry standard has specific requirements for stripping of finishes and burnishing or dry buffing asbestos-containing flooring. Work practices R5 «Wet Strip Floor Wax from Resilient Flooring,» R6 «Dry or Spray Buffing Resilient Asbestos Flooring,» and R7 «Cleaning Resilient Asbestos Flooring,» are based on the OSHA work practices.

The NESHAP regulates the disposal of ACM. Non-friable materials such as resilient flooring are treated differently from friable materials such as surfacing materials and thermal system insulation. Resilient floor covering is classified by the EPA NESHAP as Category 1 non-friable ACM. If Category I ACM has become friable, or will become friable, or has been or will be subjected to sanding, grinding, cutting or abrading, it is defined as Regulated ACM by NESHAP, and its wetting, labeling and disposal requirements apply. State and local regulations may have different requirements, and these may be more stringent.

Careful work practices should be the primary means used to prevent releases of asbestos fibers during O&M work. Such practices include control measures such as wetting and local exhaust that control or collect fibers at the source. The goal of all asbestos O&M work should be to prevent any exposure of the worker and unnecessary contamination of the work area, drop cloths, mini-enclosures and other secondary control devices. Mini-enclosures should never be used to excuse sloppy work or creation of «bigger» messes.


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