ASTM E1368-23

This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the
Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
Designation: E1368 − 23
Standard Practice for
Visual Inspection of Asbestos Abatement Projects
This standard is issued under the fixed designation E1368; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
1. Scope 1.3.5 The criteria for certifying work as complete on the
basis of the visual inspections.
1.1 This practice covers procedures for performing visual
inspections of asbestos response actions to: 1.4 The values stated in inch-pound units are to be regarded
1.1.1 Establish the extent of the required work before it as standard. The values given in parentheses are mathematical
begins; conversions to SI units that are provided for information only
1.1.2 Determine the progress and quality of the work and and are not considered standard.
evaluate the completeness of the response action; and
1.5 Warning—Asbestos fibers are acknowledged carcino-
1.1.3 Evaluate the cleanliness of the work area prior to final
gens. Breathing asbestos fibers can result in disease of the
air testing for clearance (if performed), and subsequent to
lungs including asbestosis, lung cancer, and mesothelioma.
dismantling of critical barriers.
Precautions in this standard practice should be taken to avoid
1.2 This practice can be used on an abatement project, or for creating and breathing airborne asbestos particles from mate-
operations and maintenance (O&M) work, performed by the rials known or suspected to contain asbestos. See 2.2 for
building owner’s staff. It can also be used in conjunction with regulatory requirements addressing asbestos.
contract documents between the building owner and other
1.6 This standard does not purport to address all of the
parties involved in an abatement project.
safety concerns, if any, associated with its use. It is the
responsibility of the user of this standard to establish appro-
NOTE 1—Standard contract documents (such as AIA and EJCDC
documents) define contractual relationships and responsibilities for proj- priate safety, health, and environmental practices and deter-
ects within the construction industry. Asbestos abatement projects differ
mine the applicability of regulatory limitations prior to use.
from traditional construction projects in the manner of their design and
For specific safety statements, see 12.2.
execution, as well as in the type and level of oversight required to
1.7 This international standard was developed in accor-
substantiate their successful completion. Non-traditional responsibilities
dance with internationally recognized principles on standard-
are given to the building owner, project designer, and abatement contrac-
tor by this practice. Furthermore, responsibilities related to project ization established in the Decision on Principles for the
oversight, inspections, and approvals are placed upon an additional
Development of International Standards, Guides and Recom-
non-traditional representative of the building owner; the project monitor,
mendations issued by the World Trade Organization Technical
as defined by this practice. All parties are cautioned that the subject
Barriers to Trade (TBT) Committee.
authorities and corresponding responsibilities be understood, mutually
agreed upon, and correspondingly addressed with appropriate
2. Referenced Documents
modifications, if necessary, to the contract documents for a specific
project.
2.1 ASTM Standards:
1.3 This practice provides the following information:
D7521 Test Method for Determination of Asbestos in Soil
1.3.1 The objectives of the visual inspection process;
D7712 Terminology for Sampling and Analysis of Asbestos
1.3.2 The responsibilities and qualifications of the individu-
E631 Terminology of Building Constructions
als involved in the visual inspections;
E1494 Practice for Testing Physical Properties of Friable
1.3.3 The schedule of visual inspection activities during an
Surfacing Materials
abatement project and O&M work;
E2356 Practice for Comprehensive Building Asbestos Sur-
1.3.4 The inspection procedures for the various types of
veys
abatement work and O&M tasks; and
E2394 Practice for Maintenance, Renovation, and Repair of
Installed Asbestos Cement Products
F141 Terminology Relating to Resilient Floor Coverings
This practice is under the jurisdiction of ASTM Committee D22 on Air Quality
and is the direct responsibility of Subcommittee D22.07 on Sampling, Analysis,
Management of Asbestos, and Other Microscopic Particles. For referenced ASTM standards, visit the ASTM website, www.astm.org, or
Current edition approved May 1, 2023. Published June 2023. Originally contact ASTM Customer Service at service@astm.org. For Annual Book of ASTM
approved in 1990. Last previous edition approved in 2014 as E1368 – 14. DOI: Standards volume information, refer to the standard’s Document Summary page on
10.1520/E1368-23. the ASTM website.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
E1368 − 23
2.2 Code of Federal Regulations: 3.2.4 competent person, n—one who is capable of identify-
29 CFR 1910.134 Respiratory Protection Standard ing existing asbestos hazards in the workplace and who has the
29 CFR 1910.1001 Occupational Exposure to Asbestos authority to take prompt corrective measures to eliminate them.
(OSHA General Industry Standard)
3.2.5 contract documents, n—the specifications, drawings,
29 CFR 1915.1001 Occupational Exposure to Asbestos
terms and conditions, general provisions, and other compo-
(OSHA Shipyard Standard)
nents of the agreement between the building owner and the
29 CFR 1926.1101 Occupational Exposure to Asbestos
contractor.
(OSHA Construction Standard)
3.2.6 crawl space, n—an accessible area that may have a
29 CFR 1926 Subpart AA Confined Spaces in Construction
dirt floor, usually with low head room.
40 CFR Part 61 National Emission Standards for Hazardous
Air Pollutants: Subpart M—Asbestos
3.2.7 critical barriers, n—one or more layers of rigidly-
40 CFR Part 763, Subpart E Asbestos-Containing Materials supported plastic sheeting sealed over all openings into an
in Schools and Model Accreditation Plan. Appendix C to
asbestos work area (with the exception of make-up air provi-
subpart E (EPA AHERA Regulations) sions and means of entry and exit), designed to prevent
4 airborne asbestos fibers or asbestos-contaminated water from
2.3 NIOSH Document:
migrating to an adjacent area.
Method 7400 Asbestos and Other Fibers by PCM, NIOSH
Manual of Methods (Issue 3, April 29, 2019.) 3.2.8 decontamination area, n—an enclosed area adjacent
and connected to the regulated area and consisting of an
3. Terminology equipment room, shower area, and clean room, which is used
for the decontamination of workers, materials, and equipment
3.1 Definitions—For definitions of building terms, see Ter-
contaminated with asbestos.
minology E631.
3.2.9 dust and debris, n—visible particles, fragments, or
3.2 Definitions of Terms Specific to This Standard:
chunks of material, large enough to have settled in the work
3.2.1 asbestos-containing materials, n—materials contain-
area by virtue of their weight, that are presumed to have
ing more than one percent asbestos.
originated from the material abated by the response action, or
3.2.1.1 miscellaneous materials, n—material, other than
from a fiber release episode.
surfacing material and thermal system insulation, on interior
3.2.10 encapsulant, n—for friable asbestos-containing
and exterior structural, mechanical, electrical, or architectural
materials, a material that surrounds or embeds asbestos fibers
components, and surfaces; miscellaneous material includes but
in an adhesive matrix to prevent release of fibers; the word
is not limited to ceiling tiles, gaskets, floor coverings and
encapsulant should not be used in contract documents when
mastics, wallboard joint compound, roofing materials, and
referring to post-removal treatment of abated surfaces and
cementitious products.
components; the proper term is sealer, as defined in 3.2.25.
3.2.1.2 surfacing material, n—material that is sprayed,
3.2.10.1 bridging encapsulant, n—an encapsulant that
troweled-on, or otherwise applied to interior and exterior
forms a discrete layer on the surface of an in-situ asbestos
structural and architectural surfaces; surfacing material in-
matrix.
cludes acoustical plaster on ceilings, fireproofing on structural
3.2.10.2 penetrating encapsulant, n—an encapsulant that is
members, textured paint and exterior stucco, and other mate-
absorbed by an in-situ asbestos matrix without leaving a
rials applied to surfaces for acoustical, decorative, fireproofing,
discrete surface layer.
and other purposes.
3.2.11 enclosure, n—(1) a rigid, air-tight barrier constructed
3.2.1.3 thermal system insulation, n—material which is
around an asbestos-covered component or structural element to
applied to interior and exterior mechanical components to
protect the asbestos material from impact and to contain any
reduce heat gain or loss; thermal system insulation includes
release of asbestos fibers; or (2) a space, within which asbestos
insulation on pipes, fittings, boilers, breeching, tanks, ducts,
abatement operations are performed, whose limits are defined
and other mechanical components.
by rigid or non-rigid barriers for the purpose of controlling
3.2.2 building asbestos survey, n—an activity to determine
access and limiting fiber escape.
the presence, location, condition, and quantity of asbestos-
3.2.12 fiber release episode, n—uncontrolled or uninten-
containing materials in a building or facility, or on the property
tional disturbance of asbestos-containing materials which re-
containing the building or facility.
sults in the generation of dust and debris.
3.2.3 clean room, n—an uncontaminated room having fa-
3.2.13 friable material, n—material, that when dry, is easily
cilities for the storage of employees’ street clothing and
crumbled or powdered by moderate hand pressure.
uncontaminated materials and equipment.
3.2.14 glovebag, n—a 6-mil minimum thickness transparent
polyethylene plastic bag with inward projecting long-sleeved
gloves, designed to enclose an object from which an asbestos-
Available from U.S. Government Printing Office Superintendent of Documents,
732 N. Capitol St., NW, Mail Stop: SDE, Washington, DC 20401, http:// containing material is to be removed.
www.access.gpo.gov.
3.2.15 high effıciency particulate air (HEPA) filter, n—the
Available from Centers for Disease Control and Prevention (CDC), 1600
Clifton Rd., Atlanta, GA 30329-4027, http://www.cdc.gov. final stage filter on a negative pressure ventilation device (see
E1368 − 23
3.2.19) or on a vacuum cleaner, capable of trapping and 3.2.27 testing laboratory, n—a laboratory that determines
retaining at least 99.97 % of all mono-dispersed particles of (1) airborne fiber concentrations from air sample filters, and (2)
0.3 μm in diameter. the amount and type of asbestos in bulk samples.
3.2.28 unremoved material, n—any material which was
3.2.16 industrial hygienist, n—a professional trained in the
required to be removed by a response action but remains
health and physical sciences who is qualified to recognize,
substantially undisturbed.
evaluate, and monitor potential occupational and environmen-
tal exposures to hazardous materials, and to formulate mea-
3.2.29 visual inspection process, n—the activities before,
sures for their control.
during, and at the conclusion of a response action that are
associated with detecting the presence of visible residue, dust
3.2.17 load-out area, n—a structure attached to, but not
and debris, or unremoved material and verifying the absence
within, the abatement area into which containers of removed
thereof at the completion of a response action.
material are passed and stored for subsequent transfer to a
dumpster or a truck for disposal.
3.3 Terms Defined in Practice E2356
3.3.1 non-friable organically bound (NOB) materials,
3.2.18 mini-enclosure, n—an enclosure as defined in 3.2.11
n—materials that are not friable and that consist of fibers and
(2), consisting of a change room and work room (no shower),
other particulate matter embedded in a solid matrix of
that is large enough for one or two workers, is under negative
asphaltic, vinyl or other organic substances.
pressure by a HEPA-filtered exhaust device, and is used for a
relatively short period of time. 3.3.2 skim coat, n—a thin finish coat applied to an existing
plaster surface or other substrate to improve appearance or
3.2.19 negative pressure, n—slightly reduced pressure
other reasons.
within the work area, relative to the space outside the work
area, to prevent leakage of contaminated air from the work 3.4 Terms Defined in Practice D7712
area.
3.4.1 asbestos, n—a collective term that describes a group
of naturally occurring, inorganic, highly-fibrous, silicate min-
3.2.20 OSHA Class of Work, n (as found in §1926.1101):
erals that are easily separated into long, thin, flexible, strong
3.2.20.1 Class I work, n—removal of surfacing material and
fibers when crushed or processed.
thermal system insulation.
3.4.1.1 Discussion—Included in the definition are the asbes-
3.2.20.2 Class II work, n—removal of any other ACM other
tiform varieties of serpentine (chrysotile); riebeckite (crocido-
than surfacing material and thermal system insulation.
lite); grunerite (grunerite asbestos [Amosite]); anthophyllite
3.2.20.3 Class III work, n—small scale removal such as the
(anthophyllite asbestos); tremolite (tremolite asbestos); and
use of one glovebag or a mini-enclosure.
actinolite (actinolite asbestos). The amphibole mineral compo-
3.2.21 pre-bid conference, n—a meeting held at the job site
sitions are defined according to the nomenclature of the
to discuss and clarify contract requirements and allow prospec-
International Mineralogical Association. This practice is also
tive bidders to view the work.
applicable to other mineral fibers of interest.
3.2.22 project monitor, n—the person, often a representative 3.5 Acronyms:
for the building owner, who observes abatement activities
3.5.1 ACM—Asbestos-containing material(s)
performed by contractors to ensure that abatement work is
3.5.2 AHERA—Asbestos Hazard Emergency Response Act
completed according to specifications and in compliance with
3.5.3 EPA—U.S. Environmental Protection Agency
all relevant statutes and regulations.
3.5.4 HEPA—High Efficiency Particulate Air
3.2.23 regulated area, n—an area established by the em-
3.5.5 NESHAP—National Emission Standards for Hazard-
ployer to demarcate areas where airborne concentrations of
ous Air Pollutants; specifically, National Emission Standard for
asbestos exceed or can reasonably be expected to exceed the
Asbestos (40 CFR Part 61, Subpart M)
permissible exposure limit.
3.5.6 NIOSH—National Institute for Occupational Safety
3.2.24 residue, n—visible material which remains on the
and Health
abated surface due to incomplete removal and cleaning.
3.5.7 NOB—Non-friable, organically bound
3.2.25 response action, n—a method of abatement (such as
removal, encapsulation, or enclosure) or operations and main-
3.5.8 OSHA—U.S. Department of Labor, Occupational
tenance (such as repair, clean-up, or preventive measures) of Safety and Health Administration
asbestos-containing material in any form, for any purpose
3.5.9 PPE—Personal Protective Equipment
whatsoever.
3.5.10 PLM—Polarized Light Microscopy
3.2.26 sealer, n—material applied to a pipe or substrate after
3.5.11 TSI—Thermal system insulation
completion of the final cleaning operation to bond unremoved
fiber residue to the pipe or substrate, that is compatible with
4. Summary of Practice
intended retrofit requirements and operating temperature con-
ditions; while the term “lockdown” is common in industry, the 4.1 Visual inspection of asbestos abatement projects is an
term would have to be specified as such in contract documents, important process in determining whether the work has been
in addition to, but not in place of, sealer. acceptably performed. The owner representative(s) must be
E1368 − 23
involved throughout the entire process, the success of which 5.2 The specific objectives of the visual inspection process
depends on the cooperation of all participants. before, during, and at the conclusion of an asbestos abatement
4.1.1 The visual inspection process begins at the earliest project are: to review the extent of asbestos-containing material
stages of planning and continues through completion of the (ACM) within the scope of work, to monitor performance of
work. the work, and to verify if visible residue, dust or debris, or
4.1.2 The fundamental criterion for completeness of re- unremoved material are absent at the completion of removal
moval and clean-up is the absence of visible residue, dust and and clean-up activities.
debris, and unremoved material. General refinements of this
5.2.1 The visual inspection process is used to evaluate all
criterion are set forth in this practice, and the visual inspection
four aspects of an asbestos abatement project as follows:
procedures and criteria applicable to a specific project must be
5.2.1.1 Extent of ACM within Scope of Work—The building
clearly stated in the contract documents.
survey which is intended to locate and quantify asbestos-
4.1.3 Protective measures, including critical barriers and
containing materials is not properly called a “visual inspection”
enclosures, decontamination chambers, protective clothing,
within the context of this practice. To define the extent of ACM
and respirators, must remain in effect until visual inspection is
involved, a building survey is a necessary prelude to the first
completed and final air testing for clearance meets the provi-
step of the visual inspection process. The building survey,
sions in the specification.
which may use other building records, is intended to locate and
assess the condition of ACM with confirmation by laboratory
4.2 Visual inspection of operations and maintenance
(O&M) work is an important process in determining whether analysis of bulk samples. Additional surveys may be required
during project design to find ACM in locations not entered or
the work has been acceptably performed. Visual inspection of
O&M work is critical in the absence of other controls for fiber accessible during the initial building survey. The extent of the
ACM to be abated must be known in order to properly design
release, such as negative pressure, particularly if air testing for
the abatement project. See 40 CFR Part 61, Subpart M.
clearance will not be performed.
5.2.1.2 Project Work Performance—Observation of work
4.3 Visual inspection is only one component of a complex
activities throughout the abatement project confirms acceptable
set of procedures involved in asbestos abatement or O&M
work performance and aids the visual inspection for complete-
work. Consultation of reference materials and publications,
ness of removal of ACM from the surfaces and components
including the ASTM Manual on Asbestos Control, and Man-
and for completeness of cleanup of the work area. Careful
aging Asbestos in Buildings are suggested for orientation to
examination of the work area may be required at the start of the
the broader aspects of asbestos control.
project for debris that may have been generated after the
building surveys and project design.
5. Significance and Use
5.2.1.3 Completeness of Abatement—The presence of
5.1 This practice applies to response actions for all types of
residue, visible without the use of magnifying devices, on
asbestos-containing materials, including surfacing materials,
surfaces and components from which asbestos has been re-
thermal systems insulation, and miscellaneous materials,
moved indicates that additional cleaning of these surfaces is
whether friable or not, regardless of the quantities involved and
required. All ACM required to be removed by the contract
the reason for conducting the response action.
documents must be gone in order to pass the inspection for
5.1.1 Abatement for the purpose of removing asbestos-
completeness of removal. Similarly, the presence of improperly
containing materials or encapsulating or enclosing them, re-
encapsulated or insufficiently enclosed material indicates that
gardless of the engineering controls and work practices used,
these measures, if used for abatement or as an adjunct thereto,
requires performance of visual inspections as described in this
were inadequately performed and corrective action shall be
practice.
taken.
5.1.2 Operations and maintenance (O&M) activities, such
5.2.1.4 Completeness of Clean-up—The presence of dust or
as removal, encapsulation, or enclosure of asbestos-containing
debris on surfaces in areas where abatement has taken place
materials incidental to repair or replacement of a component,
indicates that these areas were not properly cleaned following
clean-up of debris from a fiber release episode, or other
the abatement. Final air samples for clearance and re-
preventive measures, require the performance of visual inspec-
occupancy shall not be taken until the visual inspection for
tions as described in this practice. See Managing Asbestos in
completeness of clean-up is passed.
Place and Guidance Manual.
5.2.2 Visual inspection is not a substitute for air monitoring
5.1.3 This practice applies to response actions performed
at any stage of the work and is particularly not a substitute for
under a contract from the building owner, as well as to work
final air testing for building re-occupancy following an asbes-
performed by the building owner’s staff.
tos abatement project. The basic premise of this practice is that
a surface, component, or work area where residue, dust or
5 debris, or unremoved material, visible without the use of
Asbestos Control: Surveys, Assessment, Abatement and Maintenance: 3rd
magnifying devices, is still present is not sufficiently clean for
Edition, Manual No. 23, ASTM, West Conshohocken, PA, March 2015.
Managing Asbestos in Buildings: A Guide for Owners and Managers, Envi-
subsequent stages of work. Any residue, dust, or debris found
ronmental Information Association (EIA), March 2015.
during the inspections is assumed to contain asbestos, and the
Managing Asbestos in Place How to Develop and Maintain a Building Asbestos
surfaces, components, and area must be re-cleaned before
Operations and Maintenance (O&M) Program. See http://www.epa.gov/asbestos/
pubs/management_in_place.html. proceeding further.
E1368 − 23
5.2.3 Passing the visual inspections for completeness of AHERA-accredited project monitor and field experience in
abatement and clean-up improves the chances, but does not performing asbestos building surveys.
guarantee, that the area will pass final air testing for clearance.
6.2 Accreditation as an AHERA asbestos inspector is a
5.3 Visual inspection is an important means of determining
desirable credential. However, neither this practice nor the EPA
acceptable completion of O&M work. The objectives of the
Model Accreditation Plan requires accreditation to perform
visual inspection process as it applies to O&M work are similar
visual inspections for completion of response actions.
to those for abatement projects with specific procedures and
6.3 Completion of a project monitor course as described in
acceptance criteria that recognize the following aspects of
the EPA Model Accreditation Plan may be accepted as evi-
O&M activities:
dence of appropriate training to perform visual inspections, but
5.3.1 O&M work is generally more limited in scope than
does not substitute for asbestos abatement project field expe-
abatement projects, involves less ACM, and is consequently
rience.
referred to as “small-scale, short-duration” in the EPA rule
6.3.1 Some jurisdictions (as with a state or local asbestos
known as AHERA which regulates asbestos activities in
program) can vary on the requirements for those that perform
schools, K through 12; public and private. This work is also
abatement final visual inspections and may have training and
covered in the OSHA requirements as Class III work where
certifications required for those performing these services. As
there are rules for permissible quantities and operations. These
such, many state or local programs do not require the Model
requirements may vary according to other applicable regula-
Accreditation Plan-defined project monitor program. As such,
tions and are not specified in this practice.
these training programs may not be available in certain state or
5.3.2 O&M work often lacks such protective measures as
geographical areas. In the absence of a certified project
negative pressure and decontamination facilities that provide
monitoring program, as an example, there are some state
protection to workers and building occupants during abatement
asbestos programs that require the combination of an AHERA-
projects.
accredited supervisor program and a NIOSH 582 (equivalent)
program to gain a certification to perform these services.
6. Qualifications
6.4 Performing visual inspections involves physical activity
6.1 The following credentials are evidence of the ability to
and requires visual acuity. The absence of physical and vision
perform the visual inspections as described in this practice:
limitations that might compromise the inspection may be
6.1.1 Credentials that indicate knowledge of building design
considered a prerequisite for performing the duties of the
include the following:
project monitor.
6.1.1.1 Experience in building design, construction, or op-
erations;
7. Responsibilities of Abatement Project Participants
6.1.1.2 Classroom training as an AHERA-accredited project
monitor or project designer; and
7.1 During an abatement project the participants include the
6.1.1.3 Academic degree(s), licensure or registration as an
building owner, the owner’s representative(s), and the abate-
architect or engineer, or both.
ment contractor. Their responsibilities vary and are detailed
6.1.2 Credentials that indicate knowledge of building con-
below.
struction and operations include the following:
7.2 Building Owner:
6.1.2.1 Field experience in building construction,
7.2.1 The building owner who is responsible for an asbestos
renovation, demolition, or maintenance, or combination
abatement project large enough to involve a contract for the
thereof;
service will often hire an experienced and competent asbestos
6.1.2.2 Classroom training as an AHERA-accredited project
consultant, such as an architect, construction engineer, or
designer or supervisor; and
industrial hygienist, to act as the owner’s representative.
6.1.2.3 Formal or on-the-job training in construction tech-
7.2.2 The responsibilities of the consultant retained by the
nology or management, with particular emphasis on commu-
building owner shall be mutually agreed upon and shall include
nications with construction supervisors and workers.
the items in 7.3.
6.1.3 Credentials that indicate familiarity or expertise in
7.2.3 If the building owner is directly monitoring the work
asbestos abatement and operations and maintenance (O&M)
techniques include the following: of the abatement contractor, the building owner is responsible
for performing the visual inspection or ensuring that the visual
6.1.3.1 Training as an AHERA-accredited supervisor or
project designer, or completing an O&M training course; inspection is performed by others in accordance with the
contract documents. If a consultant is retained to prepare the
6.1.3.2 Field experience in asbestos abatement project
contract documents and enforce their implementation, the
surveillance, provided that such experience includes inspec-
consultant is responsible, even though he or she may have
tions as described in this practice and is not limited to air
delegated the visual inspection functions to others.
monitoring; and
6.1.3.3 Academic degree(s) or certification in industrial 7.2.4 If anyone other than the building owner has the
hygiene, or both, with experience that includes inspections as authority to stop the contractor from removing asbestos-
described in this practice and is not limited to air monitoring. containing material and require the contractor to correct
6.1.4 Credentials that indicate familiarity or expertise with violations of the specification or regulations, this must be
suspected ACM and its substrates include training as an clearly stated in the contract documents. The building owner
E1368 − 23
retains the final responsibility for accepting the performance of available to report to the job within a reasonable time after
the work done by the contractor and all others employed on the notification and must perform the inspection quickly and
project. efficiently without sacrificing thoroughness. To do this, the
project monitor must have all of their equipment available and
7.3 Owner’s Representative(s)—The owner may have vari-
in proper working order at the job site when it is needed.
ous people helping their firm complete an abatement project,
7.3.7 The project monitor must report work practices not in
and this section discusses four of them: the consultant, project
accordance with the contract documents, citing the applicable
designer, project monitor, and accredited inspector.
page and paragraph number of the document, and also any
7.3.1 At the beginning of the project, the project designer
potential violations of federal and state regulations.
will prepare contract documents, based on a project design
7.3.8 The project monitor is also responsible for regularly
survey according to Practice E2356 to establish the presence
advising the building owner or their representative of work
and condition of asbestos-containing materials and to provide
progress and of any schedule changes, work problems, or other
other information needed for the plans and specifications. The
information obtained from visual inspections.
documents should include the procedures for the visual inspec-
tions and the degree of cleanliness required as each stage of
7.4 Abatement Contractor:
work is completed and at the conclusion of the project.
7.4.1 Unless the building owner is performing the abate-
7.3.2 During the project, an experienced individual will
ment project with their own personnel, an abatement contractor
perform the visual inspections, identify corrective actions
will have been selected for the work.
needed, and certify when abatement is complete and acceptable
7.4.2 The abatement contractor has a responsibility contrac-
visual cleanliness has been achieved. The building owner, or
tually to the building owner, and also a responsibility to protect
the consultant he or she has retained for assistance in managing
their contractual rights by the following:
an abatement project, may hire this individual.
7.4.2.1 Performing an inspection immediately prior to be-
7.3.3 The project monitor may be an industrial hygienist, an
ginning work to identify and document any existing contami-
employee of an experienced environmental consulting firm, or
nation or other changes in site conditions. During this
other individual experienced in asbestos abatement. For Class
inspection, the contractor should be accompanied by the
III operations, the visual inspections must be performed by a
building owner and consultant, or by the project monitor;
person designated as the Class III competent person.
7.4.2.2 Performing their own visual inspections of each
7.3.4 The project monitor assists the project designer in
phase of work, to ensure that the work area is ready for
defining inspection methods and criteria in the contract
inspection by the owner’s representative; and
documents, preferably through the involvement in the building
7.4.2.3 Assisting the project monitor during the inspection
survey. The accredited inspector should, if necessary, collect
and subsequently correcting problems found.
for analysis representative samples of suspected asbestos
7.4.3 The contractor’s competent person (3.2.4), usually an
containing materials, including debris or contaminated soil
AHERA-accredited supervisor, must work closely with the
samples from a crawl space that is part of an abatement project.
project monitor and notify the project monitor in a timely
7.3.4.1 The project monitor should know the testing meth-
manner when an area is ready for inspection. Sufficient time
ods for the encapsulant used, if the project is to involve
must be provided for cleanup of areas that do not pass the final
encapsulation of asbestos-containing materials.
visual inspection, for resolution of unexpected or difficult
7.3.4.2 The project monitor may have other duties on the
situations, and for subsequent reinspection, if required.
project related to air monitoring and project surveillance. For
example, as part of pre-work visual inspections, the project 7.4.4 The contractor must provide the project monitor with
monitor may take air samples to establish background levels of all resources required by the contract documents that are not
airborne fiber counts in all areas slated for asbestos abatement. normally considered the project monitor’s “tools of the trade.”
7.3.5 The project monitor must be familiar with the parts of These resources may include ladders or scaffolds, mechanical
the contract documents for which they are responsible, includ- scissor lifts, adequate lighting, electrical power, and personnel
protection and decontamination provisions. If contractor per-
ing:
sonnel are to assist with the inspection or to perform concurrent
7.3.5.1 The locations and types of asbestos to be abated and
cleaning during the inspection, these personnel and the neces-
the correct methods to properly carry out the type of abatement
sary supplies must be available at the time of inspection.
involved,
7.3.5.2 The work area isolation methods to control debris 7.4.5 Ladders and scaffolds must be in good condition and
accumulation and air sampling procedures to verify their comply with OSHA regulations for guardrails, structural
effectiveness, integrity, stability, and conditions of use. Exercise care on wet
plastic surfaces, which are very slick and potentially hazardous
7.3.5.3 The visual inspection procedures, the techniques for
performing them properly, and the schedule of their to walk or climb on. Comply with OSHA regulations and
facility safety policies for fall protection, including harnesses
performance, and
and restraint devices, as applicable.
7.3.5.4 The definition of clean in the contract specifications
or procedure.
7.4.6 Ultimately, the caliber of the work performance and
7.3.6 The project monitor must be timely with the inspec- the quality of the completed project are the sole responsibility
tion and analyses (if the project monitor is taking air samples) of the contractor, who warrants and guarantees that the finished
to expedite the abatement work. The project monitor must be project fulfills the requirements of the contract documents.
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8. Visual Inspection Schedule, Procedures and 8.2.3 During the Pre-Bid Conference—The project designer
Acceptance Criteria for Abatement Projects and project monitor should attend the pre-bid conference and
project walk-through to address questions from bidders on the
8.1 This section provides a generalized schedule for con-
inspection criteria in the contract documents.
ducting visual inspections for abatement of friable asbestos-
8.2.4 During the Pre-Construction Activities—The building
containing materials including surfacing materials and TSI
owner and project monitor should walk through the work area
using what is commonly referred to as “gross removal,” as well
with the contractor immediately before abatement activities
as encapsulation and enclosure operations.
begin in order to verify the current building conditions and
NOTE 2—For the purposes of the removal of surfacing material and TSI,
changes since the pre-bid conference.
OSHA defines this as Class I work. Removal of all other categories of
8.3 Inspection During the Project:
materials is defined as Class II work. See §1926.1101(g) for further
information.
8.3.1 The project monitor must carry out inspections during
the project to confirm that the means and methods of abatement
8.1.1 Section 9, Special Considerations, discusses removal
conform to specified procedures. On a large asbestos abate-
in crawl spaces, dry removal, glove bag operations for
ment project, it is likely that work will proceed in phases
abatement, work in mini-enclosures, removal of flooring
through several areas. Consider each location isolated from
materials, and removal of wallboard systems. Small-scale,
another as an independent area, and inspect it as work is
short-duration, or operations and maintenance (O&M) tasks
completed. Visual inspection activities must keep pace with the
are covered in Section 11.
work progress and sequence so that the work in one area does
8.1.2 The project monitor must be familiar with the various
not risk contaminating areas still undergoing preparation, or
tasks associated with each phase of work described in these
areas that have already been cleaned, inspected, and released.
sections, and should use the acceptance criteria to determine if
8.3.2 Inspections During Abatement:
abatement work has been satisfactorily completed. The stan-
8.3.2.1 Barriers of plastic sheeting, plywood, or equivalent
dards of performance to which an abatement contractor will be
materials should isolate the regulated areas, and should be left
held must be explicitly stated in the contract documents.
in place and intact throughout the work period. Closely inspect
8.2 Inspection Prior to the Project:
all barriers to ensure integrity throughout the project, including
8.2.1 Project Design Survey—A project design survey shall
tears in the plastic floor covering prior to their being mended to
be conducted according to Practice E2356 to determine the
see if any debris or water has leaked through to the surface
location and condition of asbestos-containing materials to be
below, particularly if carpeting is underneath. If carpeting
abated and to provide other information for preparation of a
becomes contaminated with ACM debris or water, or both,
complete and accurate set of plans and specifications.
during work activities, it should be considered contaminated
8.2.2 During Preparation of the Contract Documents—The
and disposed of as asbestos-containing waste material. The
building owner should accompany the project designer during
integrity of the decontamination areas for personnel and
the project design survey of the work site to define the limits of
equipment must be maintained throughout the work.
the area in which the asbestos hazard is to be abated. Identify
8.3.2.2 If the abatement project involves removal, the re-
existing contamination from previous activities at this time and
moved material and contaminated water must not be allowed to
agree on appropriate action. If encapsulants are to be used, test
accumulate inside the regulated area, but must be bagged or
several on small areas according to Practice E1494 to choose
wrapped with leak-tight seals, or otherwise collected in water-
the most effective and to determine post-abatement test meth-
tight containers as soon as practicable. Monitor the perimeter
ods. This process establishes the depth to which a penetrating
of the regulated area from inside and outside the isolation
encapsulant will be absorbed, and the thickness of the film
barriers. If the duct tape sealing the plastic sheeting is allowed
formed by a bridging encapsulant. If a crawl space is present,
to become wet, it may loosen and allow contaminated water
inspect the area and take samples of debris and contaminated
and debris to run under the barriers to areas outside the
soil. The procedures for determining the extent to which the
regulated area. Similarly, the decontamination area must be
crawl space must be free of asbestos at the completion of
kept strictly clean of any visible dust or debris.
abatement must be fully and explicitly described.
8.3.2.3 Review air monitoring data on a regular basis to
8.2.2.1 The contract documents should stipulate all proce-
measure the effectiveness of barrier integrity. The correlation
dures and performance measures to which the contractor will
between any observed debris inside a work area and the
be expected to conform, the criteria for visual cleanliness that
airborne fiber counts provides an indication of proper wet
will be used to judge the quality of work, and a clear
removal performance. Air samples collected in the decontami-
description of the methods to be used for inspection. At this
nation area and load-out area are effective management tools
time, decide which items are to be removed from the work area
for enforcing the cleanliness provisions for these spaces and
by the owner’s personnel before the project begins, and which
complement the visual inspection effort.
items are to be cleaned and removed by the contractor.
8.3.2.4 Negative pressure ventilation devices should be in
8.2.2.2 Clearly state the sequence of cleanup activities and
continual operations in a regulated area throughout the period
visual inspections in the contract documents. It is particularly
of abatement work. Record the readings on negative pressure
important to specify the inspections that will be performed
monitoring devices on a regular or continuous basis for
before the removal of plastic sheets, decontamination areas, or
comparison to the required pressure differential.
any isolation barriers that separate work areas from occupied
parts of the building. 8.4 Inspection at the Conclusion of the Project:
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8.4.1 Inspections for Completeness of Abatement: 8.4.2.2 Pay special attention to areas that are difficult to
reach or see to find unremoved material and residue. Use a
8.4.1.1 Enter all spaces where asbestos abatement was
small screwdriver or other sharp, pointed tool for poking into
performed in order to inspect the work at close range. Get close
such places as the spaces between steel beams and the roof or
enough to touch the surface from which asbestos-containing
ceiling frames (if left in place), or air duct flanges. Give special
materials were removed, or on which other abatement opera-
care to elbows, valves, and tees on mechanical systems, as
tions were performed. This may require the use of a ladder or
insulation usually adheres to these fittings more tightly and
scaffold to reach elevated locations, or entering areas of
becomes trapped in their crevices more readily than on the
restricted mobility, such as pipe chases and manholes.
straight runs of pipe.
8.4.1.2 The contractor’s competent person should always
8.4.2.3 If unremoved material or residue is found during the
accompany the project monitor on any visual inspection. A
visual inspection, re-cleaning and re-inspection are mandatory
worker equipped with cleaning materials and a HEPA-filtered
until all residue has been removed. Any residue that absolutely
vacuum must be present to wet-clean and vacuum the surfaces
cannot be removed must be securely adhered to the substrate so
whenever residue or debris is found. Unless a thorough job of
that it may not be rendered airborne during aggressive air
removal and cleaning has been done, this approach can be very
sampling or by any conceivable future building operations,
time-consuming and inadvertently results in the project moni-
renovations, maintenance, or demolition of the building.
tor supervising the final cleaning operation. If the project
8.4.2.4 This inspection should occur with at least one layer
monitor recognizes that this situation is occurring, he or she
of plastic sheeting covering all protected surfaces inside the
should terminate the inspection and direct (or advise) a
enclosure; all seals on windows, doors, and vents intact; and
re-cleaning of the entire area before repeating the inspection.
the critical barriers separating the work area from the adjacent
For small scale, short-duration operations, a final cleaning may
areas in pla
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