Replacing vinyl asbestos floor tiles

&HEADLINE>Key concepts&/HEADLINE>

It’s not possible to tell whether tiles contain asbestos by appearance, size, or when installed.

If asbestos is present, regulatory and removal issues must be faced.

Asbestos floor tile work is a regulatory jungle.

Ask members of the plant maintenance staff what they consider the most difficult asbestos material to deal with and the likely answer is “vinyl asbestos floor tiles (VATs).” The same reply would probably be received from environmental and safety managers.

Not only are floor tiles plentiful, but are usually very difficult to remove during renovation projects. Also, each state looks at asbestos floor tile removal differently from a regulatory standpoint.

Background

From 1940 into the 1980s, asbestos floor tiles and mastics containing asbestos used as an adhesive to lay the tiles were manufactured by several prominent companies. As a general rule, older 9-in.x9-in. floor tiles often contain asbestos; however, that is not a hard and fast rule. The newer tiles are typically 12 in.x12 in. and usually are nonasbestos, but again, this is not always the case. Add in adhesives and it is difficult to know for sure if floor tiles are asbestos free by appearance, size, or time period installed. Even today, VATs and mastics containing asbestos could be reinstalled.

The only foolproof way to know for sure is to have a licensed building inspector collect a small sample of the tile and a scraping of the mastic and have them analyzed by an accredited laboratory. If asbestos is found, there are regulatory and removal issues to face.

Regulatory issues

Under OSHA’s Asbestos Construction Standard (29 CFR 1926.1101), removal of asbestos flooring materials is addressed under Class II work requirements. Class II asbestos work involves the removal of any asbestos-containing material that is not thermal system insulation or surfacing material.

The EPA refers to these as “miscellaneous” materials and classifies asbestos VATs as a Category I nonfriable material (a friable material can be crumbled or pulverized by hand pressure). According to EPA, vinyl asbestos floor tiles typically do not need to be removed during renovation or demolition because they generally do not release significant amounts of asbestos fibers. However, if they are in poor condition or likely to become friable during work activities, they must be removed. Also, if VATs are sanded, ground, abraded, or chipped, they must be considered friable and stricter work practices apply.

There has been much debate recently about how much fibers are released when asbestos floor tiles are removed. As such, almost every state has taken a different stance on the issue.

The table shows how each state views asbestos floor tiles work activities from a regulatory standpoint. The 50 states and the District of Columbia are broken into two categories, based on Resilient Floor Covering Institute (RFCI) guidelines. Glancing through these charts and the footnotes reveals that asbestos floor tile work is a regulatory jungle.

Note that some states have threshold amounts that vary from the federal regulations of 160 sq ft of material that trigger notification requirements. Also, some states have different notification timelines for asbestos floor tile work, and various training requirements.

It would be wise for any facility owner contemplating asbestos floor tile removal work to be familiar with “Recommended Work Practices” (RWPs) mentioned in the table by contacting the state regulatory agency or seeking help from the RFCI at 301-340-8580.

Whether performing this work internally or hiring an asbestos abatement contractor to do the removal, it is important that someone within the organization be familiar with the applicable state and federal rules.

Removal issues

After moving through the regulatory maze, the issues of carefully removing and disposing of the asbestos floor tiles remain. If state RWPs are followed, the work should be completed safely.

Preparing the floor for new carpet or new tiles by removing all the adhesive may be the most difficult task at hand. Don’t sand or grind the floors without taking the proper precautions because airborne fibers could be released. If shot blasting and mastic grinding using circular head adapters on floor scrubbers are conducted, it is almost certain that OSHA and state agencies will consider the operation a friable removal activity.

Care is required when selecting the proper solvents for removing mastics. Some products penetrate air handling systems and cause respiratory irritation among sensitive personnel. Selecting a citrus-based solvent is usually the best choice because it is not as harmful an irritant as traditional products.

Solvents also need to be examined in terms of how they might affect the new product being installed. Flooring manufacturers, particularly carpet tile producers, may void their warranties if solvents are used. Manufacturers are concerned about solvents soaking into the porous concrete and leaching out later, causing failures with their products. Therefore, removal solvent must be compatible with the new mastics used to adhere the replacement choice.

Flooring maintenance

OSHA’s housekeeping rules in the Asbestos General Industrial Standard (29CFR 1910.1001) require that certain precautions be taken when cleaning asbestos floor tiles. To comply, strip floors using the least abrasive pad and the low speed setting (175-190 rpm). Make sure to keep the floor adequately wet during the stripping operation. Remove all dirty stripping solution with a wet vacuum or strip mop.

OSHA recommends three layers of wax on asbestos floor tiles before buffing. Although not required, dry buffing should be done using low abrasion pads at speeds less than 300 rpm. There have been several studies showing elevated airborne asbestos levels using high speed buffing machines (1000-1500 rpm). If high-speed equipment is used, conduct air monitoring to prove levels are lower than the permissible exposure limit of 0.1f/cc. In addition, an official variance from the state regulatory agency may be required.

– Edited by Ron Holzhauer, Managing Editor,

630-320-7139; rholzhauer@cahners.com

&HEADLINE>State regulatory requirements&/HEADLINE>

Category 1 – 41 states

These states generally do not require licensed asbestos abatement personnel to remove nonfriable asbestos containing floor tiles when Recommended Works Practices (RWPs) are used, except as explained in the footnotes.

Alabama

Alaska

Arizona

Colorado (1)

District of Columbia (2)

Florida (3)

Georgia (4)

Hawaii

Idaho

Illinois

Indiana

Iowa

Kansas (5)

Kentucky (6)

Louisiana

Maine

Maryland (7)

Massachusetts

Michigan

Minnesota

Mississippi (8)

Missouri

Montana (9)

Nebraska

Nevada

New Hampshire

North Carolina (10)

Ohio

Oklahoma (11)

Oregon (12)

Rhode Island (13)

South Carolina (14)

South Dakota

Tennessee

Texas (15)

Utah

Vermont

Virginia (16)

Washington (17)

West Virginia (18)

Wyoming

Category 2 – 9 states

These states require licensed asbestos abatement contractors to remove asbestos floor tiles using Recommended Work Practices.

Arkansas

California

Connecticut

Delaware

New Jersey (19)

New Mexico

New York

Pennsylvania

Wisconsin

&HEADLINE>Footnotes&/HEADLINE>

(1) Colorado: Ten-day prior notification for removal of 32 sq ft or more of VATs must be provided to the Department of Health, Air Pollution Control Div.

(2) District of Columbia: Ten-day prior notification of 18 sq ft or more of VATs must be provided to the Department of Consumer and Regulatory Affairs.

(3) Florida: State laws require 8-hr worker and 12-hr supervisor training in RWPs and asbestos awareness for VAT removal. Three-day prior notification must be provided to the Department of Business and Professional Regulation.

(4) Georgia: Licensed asbestos abatement personnel are not required if nonfriable VATs are not rendered friable during removal and there are no visible emissions of asbestos fibers. Flooring personnel must take the industry sponsored RWP training course. Ten-day notification should be submitted to the state EPA’s Asbestos Licensing and Certification Unit.

(5) Kansas: Licensed asbestos abatement personnel and notification requirements do not apply to removal of VATs using RWPs, but do apply for asbestos vinyl flooring.

(6) Kentucky: Licensed asbestos abatement personnel are not required if: (a) VATs are nonfriable and in poor condition, (b) RWPs are strictly followed by trained workers and extensive breakage does not occur (considered less than five pieces), (c) Extra caution is used when removing multi-layered floors, and (d) 10-day notification for VAT removal over 160 sq ft (3 sq ft in schools) is provided to the Department of Environmental Protection.

(7) Maryland: Licensed asbestos abatement personnel required for removal in schools.

(8) Mississippi: Two working days prior notification for a VAT removal must be made to the Commission on Environmental Quality.

(9) Montana: Asbestos abatement project permit and licensed personnel generally not required if the RWPs are used to remove nonfriable VATs because RWPs help keep breakage to a minimum. However, a permit and licensed personnel are required if greater than 10% of the floor tiles removed are broken. Permits and licensing do not apply to VAT removal by homeowners in private residences.

(10) North Carolina: Licensed asbestos personnel are not required for the removal of nonfriable VATs that remain or will remain intact during removal. The Department of Environment, Health, and Natural Resources has stated in the majority of cases that if RWPs are followed, the licensing requirements do not apply.

(11) Oklahoma: Licensed personnel and prior notification do not apply to removals of VATs and associated adhesives using the RWPs, but do apply to the removal of sheet vinyl flooring. However, complete removal of adhesive using the floor machine and cutting sand cannot be performed without a license. A license is not required for removals in private residences or apartments with fewer than six units

(12) Oregon: Licensed personnel and prior notification do not apply to removals of VATs using RWPs or to wet scraping of adhesives which are pliable and tacky or rendered that way by use of solvents or water/liquid detergent solutions. However, a license and prior notification are required for removal of sheet vinyl flooring and adhesives that remain hard and brittle. Asbestos licensing requirements do not apply to the removal in private residences by owner-occupant. Oregon OSHA sets forth RWPs with two differences: (1) Trash bags are labeled “Danger, Contains Asbestos Fibers; Avoid Creating Dust, Cancer and Lung Disease Hazard;” and (2) Work clothes must be cleaned with HEPA-vacuum prior to removing or leaving the work area.

(13) Rhode Island: Licensed personnel and state approved asbestos abatement plant required for removals or more than 25 sq ft of floor tile in poor condition, except in private residences.

(14) South Carolina: Licensed personnel and 10-day advance notification do not apply to removal of VATs provided RWPs are strictly followed. However, these requirements do apply for removal of sheet vinyl. In removing small amounts of “cutback” asphaltic adhesive, the adhesive must be pliable; and bumps and ridges must be carefully scraped, after misting rather than chipped. Complete removal of adhesive with a floor machine and cutting sand cannot be done without an asbestos license. Residue from the solvent-based remover must be completely cleaned up to prevent solvents from attacking the new adhesive.

(15) Texas: State law requires 8-hr training in the RWPs before a person may remove VATs in public buildings, and they must be analyzed for asbestos content. Ten-day prior notification must be provided to the Department of Health, Asbestos Licensing Section.

(16) Virginia: A Roofing, Flooring, and Siding license is required, which involves 8-hr worker and 12-hr supervisor training in the RWPs and asbestos awareness.

(17) Washington: Licensed personnel and prior notification requirements do not apply to the removal of VATs using the RWPs; however, they do apply to the removal of sheet vinyl and adhesives.

(18) West Virginia: Licensed personnel and 10-day prior notification requirements do not apply to removal of VATs in single family dwellings if the flooring personnel obtain a special worker license by taking an approved training course for such removals. However, all licensing and notification requirements apply for VAT removal in public buildings

(19) New Jersey: Department of Health has the power to exempt certain asbestos related activities from asbestos licensing and permit requirements; however, at this time there is no exemption for VAT removal.

Note: Check with your state on a regular basis for changes.

&HEADLINE>More info&/HEADLINE>

The author is willing to answer technical questions concerning this article. Mr. Onderick is available at 847-855-8357; e-mail: RFM@asbestosmart.com.

The company web site is located at www.asbestosmart.com.

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