The Asbestos NESHAP is intended to minimize the release of asbestos fibers during activities involving the handling of asbestos. Accordingly, it specifies work practices to be followed during renovations of buildings that contain a certain threshold amount of friable asbestos, and during demolitions of all structures, installations, and facilities (except apartment buildings that have no more than four dwelling units).

Most often, the Asbestos NESHAP requires action to be taken by the person who owns, leases, operates, controls, or supervises the facility being demolished or renovated (the “owner”), and by the person who owns, leases, operators, controls or supervises the demolition or renovation (the “operator”). The regulations require owners and operators subject to the Asbestos NESHAP to notify delegated State and local agencies and/or their EPA Regional Offices before demolition or renovation activity begins. The regulations restrict the use of spray asbestos and prohibit the use of wet-applied and molded insulation (i.e., pipe lagging). The Asbestos NESHAP also regulates asbestos waste handling and disposal.

The Asbestos NESHAP was amended for several reasons. EPA wanted to clarify existing regulatory policies, and to add regulations which explicitly address monitoring and record keeping at facilities which mill, manufacture, and fabricate asbestos. Also, because of the high risk associated with the transfer and disposal of ACM, EPA also wanted to strengthen the requirements which govern asbestos waste disposal by requiring tracking and record keeping. Furthermore, EPA determined that the Asbestos NESHAP needed to take into account the availability of improved emission controls. EPA also wanted to make the NESHAP consistent with other EPA statutes that regulate asbestos.

The following activities and facilities are currently regulated by the Asbestos NESHAP:

• The milling of asbestos
• Roadways containing ACM
• The commercial manufacture of products that contain commercial asbestos
• The demolition of all facilities
• The renovation of facilities that contain friable ACM
• The spraying of ACM
• The processing (fabricating) of any manufactured products that contain asbestos
• The use of insulating materials that contain commercial asbestos
• The disposal of asbestos-containing waste generated during milling, manufacturing, demolition, renovation, spraying, and fabricating operation
• The closure and maintenance of inactive waste disposal sites
• The operation of and reporting on facilities that convert asbestos containing waste material into non-asbestos material
• The design and operation of air cleaning devices
• The reporting of information pertaining to process control equipment, filter devices, asbestos generating processes, etc.
• Active waste disposal sites

Milling, Manufacturing, and Fabricating Sources
Businesses that are involved in asbestos milling, manufacturing, and fabricating now must monitor for visible emissions for at least 15 seconds at least once a day (during daylight hours), and inspect air cleaning devices at least once a week. The facilities must maintain records of the results, and submit each quarter a copy of the visible emissions monitoring records if visible emissions occurred during the quarter. Facilities that install fabric filters (to control asbestos emissions) after the effective date of the revision must provide for easy inspection of the bags.

Demolition and Renovation
All facilities that are “demolished” are subject to the Asbestos NESHAP. The definition of demolition was expanded to include the intentional burning of a facility, in addition to the “wrecking or taking out . . . any load-supporting structural member of a facility”. Owners and operators of all facilities that are to be demolished, and of facilities that contain a certain amount of asbestos that are to be renovated, must now provide more detailed information in notifications, including the name of the asbestos waste transporter and the name of the waste disposal site where the ACM will be deposited.

Owners and operators must give a 10-day notice for planned renovations and demolitions. They must re-notify EPA in advance of the actual start date if the demolition or renovation will begin on a date other than the one specified in the original notification. Telephone re- notifications are permitted, but must be followed by written notice.

Starting one year after the promulgation of the regulation, a person trained in the provisions of the Asbestos NESHAP, and in the methods of complying with them, must supervise operations in which ACM is stripped, removed, or otherwise handled. This supervisor is responsible for all on-site activity. Before wetting is suspended, the EPA administrator must approve. When wetting of asbestos during its removal is suspended due to freezing temperatures, owners or operators must measure the air temperature in the work area three times during the workday, and must keep those records for at least two years.
The revisions also clarify EPA’s position regarding the handling and treatment of non-friable asbestos material. The owner and operator must inspect the site for the presence of non-friable ACM, and include in the notification an estimate of how much non-friable ACM is present. Also, the owner and operator must describe the procedures to be followed if unexpected ACM is found in the course of demolition or renovation and if non-friable asbestos becomes friable in the course of renovation or demolition.

Waste Transport and Disposal
Vehicles used to transport ACM must be marked according to new guidelines during loading and unloading. Labels indicating the name of the waste generator and the location where the waste was generated must be placed on containers of RACM. When ACM waste is transported off-site, a waste shipment record (WSR) must be given to the waste site operator or owner at the time that the waste is delivered to the waste disposal site. The owner or operator must send a signed copy of the WSR back to the waste generator within 30 days, and attempt to reconcile any discrepancy between the quantity of waste given on the WSR and the actual amount of waste received. If, within 15 days of receiving the waste, the waste site owner or operator cannot reconcile the discrepancy, he or she must report that problem to the same agency that was notified about the demolition or renovation. New disposal sites must apply for approval to construct and must notify EPA of the startup date. Existing disposal sites must supply EPA with certain information concerning their operations, such as the name and address of the owner or operator, the location of the site, the average weight per month of the hazardous materials being processed, and a description of the existing emission control equipment. If a copy of the WSR signed by the waste site owner or operator is not received by the waste generator within 35 days of the date that the waste was accepted by the initial transporter, the waste generator must contact the transporter and/or disposal site owner or operator to determine the status of the waste shipment. If a signed copy of the WSR is not received within 45 days of the date that the waste was accepted by the initial transporter, the waste generator must submit a written report to the same agency that was notified about the demolition or renovation.

Owners of disposal sites must record on the deed to the disposal site that the property has been used for ACM disposal. They must also keep records that show the location, depth, area, and volume of the asbestos waste; they must indicate on the deed that these records are available. Owners of inactive disposal sites must obtain written approval before they excavate or otherwise disturb ACM waste that has been deposited on the site.

Many studies have shown that the combination of smoking and asbestos exposure is particularly hazardous. Smokers who are also exposed to asbestos have a greatly increased risk of lung cancer. However, smoking combined with asbestos exposure does not appear to increase the risk of mesothelioma.

There is evidence that quitting smoking will reduce the risk of lung cancer among asbestos-exposed workers. People who were exposed to asbestos on the job at any time during their life or who suspect they may have been exposed should not smoke. If they smoke, they should stop.

Individuals who have been exposed (or suspect they have been exposed) to asbestos fibers on the job or at home via a family contact should inform their physician of their exposure history and any symptoms. Asbestos fibers can be measured in urine, feces, mucus, or material rinsed out of the lungs. A thorough physical examination, including a chest x-ray and lung function tests, may be recommended. It is important to note that chest x-rays cannot detect asbestos fibers in the lungs, but they can help identify any lung changes resulting from asbestos exposure. Interpretation of the chest x-ray may require the help of a specialist who is experienced in reading x-rays for asbestos-related diseases. Other tests also may be necessary.

As noted earlier, the symptoms of asbestos-related diseases may not become apparent for many decades after exposure. If any of the following symptoms develop, a physical examination should be scheduled without delay:

• Shortness of breath
• A cough or a change in cough pattern
• Blood in the sputum (fluid) coughed up from the lungs
• Pain in the chest or abdomen
• Difficulty in swallowing or prolonged hoarseness
• Significant weight loss

Asbestosis
Asbestosis is a serious, chronic, non-cancerous respiratory disease. Inhaled asbestos fibers aggravate lung tissues, which causes them to scar. Symptoms of asbestosis include shortness of breath and a dry crackling sound in the lungs while inhaling. In its advanced stages, the disease may cause cardiac failure.

There is no effective treatment for asbestosis; the disease is usually disabling or fatal. The risk of asbestosis is minimal for those who do not work with asbestos; the disease is rarely caused by neighborhood or family exposure. Those who renovate or demolish buildings that contain asbestos may be at significant risk, depending on the nature of the exposure and precautions taken.

Lung Cancer
Lung cancer causes the largest number of deaths related to asbestos exposure. The incidence of lung cancer in people who are directly involved in the mining, milling, manufacturing and use of asbestos and its products is much higher than in the general population. The most common symptoms of lung cancer are coughing and a change in breathing. Other symptoms include shortness of breath, persistent chest pains, hoarseness, and anemia.

People who have been exposed to asbestos and are also exposed to some other carcinogen — such as cigarette smoke — have a significantly greater risk of developing lung cancer than people who have only been exposed to asbestos. One study found that asbestos workers who smoke are about 90 times more likely to develop lung cancer than people who neither smoke nor have been exposed to asbestos.

Mesothelioma
Mesothelioma is a rare form of cancer that most often occurs in the thin membrane lining of the lungs, chest, abdomen, and (rarely) heart. About 200 cases are diagnosed each year in the United States. Virtually all cases of mesothelioma are linked with asbestos exposure. Approximately 2 percent of all miners and textile workers who work with asbestos, and 10 percent of all workers who were involved in the manufacture of asbestos-containing gas masks, contract mesothelioma.

People who work in asbestos mines, asbestos mills and factories, and shipyards that use asbestos, as well as people who manufacture and install asbestos insulation, have an increased risk of mesothelioma, and so do people who live with asbestos workers, near asbestos mining areas, near asbestos product factories or near shipyards where use of asbestos has produced large quantities of airborne asbestos fibers.

The younger people are when they inhale asbestos, the more likely they are to develop mesothelioma. This is why enormous efforts are being made to prevent school children from being exposed.

Other Cancers
Evidence suggests that cancers in the esophagus, larynx, oral cavity, stomach, colon, and kidney may be caused by ingesting asbestos. For more information on asbestos-related cancers, contact your local chapter of the American Cancer Society.

Employers are required to follow regulations dealing with asbestos exposure on the job that have been issued by the Occupational Safety and Health Administration (OSHA), the Federal agency responsible for health and safety regulations in maritime, construction, manufacturing, and service workplaces. The Mine Safety and Health Administration (MSHA) enforces regulations related to mine safety. Workers should use all protective equipment provided by their employers and follow recommended work practices and safety procedures. For example, National Institute of Occupational Safety and Health (NIOSH)-approved respirators that fit properly should be worn by workers when required.