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7.2 NON-ASTM SERVICES 7.2.1 ASBESTOS-CONTAINING BUILDING MATERIALS OSHA For buildings constructed prior to 1981, the Code of Federal Regulations (29 CFR 1926.1101 and 29 CFR 1910.1001) define presumed asbestos-containing material (PACM) as 1. Thermal System Insulation (TSI), e.g., boiler insulation, pipe lagging, fireproofing; and 2. Surfacing Materials, e.g., acoustical ceilings. Building owners/employers are responsible for locating the presence and quantity of PACM. Building owners/employers can rebut installed material as PACM by either having an inspection in accordance with Asbestos Hazard Emergency Response Act (AHERA) (40 CFR Part 763, Subpart E) or hiring an accredited inspector to take bulk samples of the suspect material. Typical materials not covered by the presumptive rule include but are not limited to: floor tiles and adhesives, wallboard systems, siding and roofing. Building materials such as wallboard systems may contain asbestos but unless a building owner/employer has specific knowledge or should have known through the exercise of due diligence that these other materials contain asbestos, the standard does not compel the building owner to sample these materials. NESHAP The applicability of the EPA's National Emission Standards for Hazardous Air Pollutants (NESHAP, 40 CFR Chapter 61, Subpart M) apply to the owner or operator of a facility where an inspection for the presence of asbestos-containing materials (ACM), including Category I (asbestos containing packings, gaskets, resilient floor coverings and asphalt roofing products), and Category II (all remaining types of non-friable asbestos containing material not included in Category I that when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure), non-friable ACM must occur prior to the commencement of demolition or renovation activities. NESHAP defines ACM as any material or product that contains greater than 1% asbestos. It should be noted that the NESHAP regulation applies to all facilities regardless of construction date, including: 1. Any institutional, commercial, public, industrial, or residential structure, installation, or building; 2. Any ship; and 3. Any active or inactive waste disposal site. This requirement is typically enforced by the EPA or by local air pollution control/air quality management districts. The information below is for general informational purposes only and does not constitute an asbestos survey. In addition, the information is not intended to comply with federal, state or local regulations in regards to ACM. Although the cutoff date of 1981 is generally accepted for estimating the likelihood that a building contains ACMs, building materials manufactured after 1981, while not expected to, may still contain asbestos. AEI presents the following observed materials that would be considered suspect ACMs in the event of a thorough survey. Suspect Asbestos Contai ing Materials ACMs Material Location Friable Condition Drywall Systems Throughout Subject Property Interior Yes Good Acoustic Ceiling Tiles Subject Property Office Areas Yes Good Project No. 297376 AE1 June 22, 2011 Page 27 ConSUltantS