Forum

E2356 Standard Practice for Comprehensive Building Asbestos Surveys was published in 2004 and ASTM requires that their standards be re-approved every five years. It is proper, therefore, to consider revisions to E2356 at this time. This discussion forum and Session 26 of the EIA2009 conference in Nashville will initiate the revision process. Some prefatory comments:
    1. You do not have to be an EIA or ASTM member to offer comments and suggest revisions. Membership in both organizations is encouraged; you can join EIA on this website and ASTM on www.astm.org. To vote on whether the proposed changes are incorporated, you must be a member of ASTM Committee E06 on Performance of Buildings.
    2. ASTM copyright restrictions prevent me from distributing copies of E2356, which can be purchased on-line from ASTM. Once I have prepared a draft of the revised standard I will be allowed to distribute it for solely for review purposes.
    3. Session 26 is scheduled for Wednesday, March 18, probably in the afternoon. I will give a brief overview of the standard and then go through the issues and possible revisions that I have compiled as well as those brought up by attendees. Notes taken at this session will form the basis for a draft revision after the conference.
    4. Session 26 will constitute a meeting of the ASTM Task Group on Asbestos Management, which normally takes place at an ASTM Committee Week. After circulating the draft revision and responding to comments I receive, I will initiate an ASTM Work Item and send the revision to ASTM members for approval through the balloting process. If things go smoothly the revised edition could be published this year.
    5. You don’t have to wait until March to offer comments and suggest revisions. Post them on this forum or send them to me at andyobe@aol.com. I am particularly interested in hearing from those who have decided not to use E2356 for their surveys or to reference it in their regulations. I’d like to know why and what is needed to change your minds.
   
    The following are some of the initial topics to open the discussion.
    1. Is a third type of survey needed to find out if any ACM exists in the area to be renovated, or a building to be demolished, when no previous sampling has been done and a full Baseline Survey is not wanted?  This survey would not include an assessment or the elements of a Project Design Survey – other than inspection for concealed ACM – because the need for an abatement project may or may not result from this survey.
    2. ASTM E2308 Standard Guide for Limited Asbestos Screens of Buildings was published in 2005 by Subcommittee E50.02 on Real Estate Assessment and Management. The purpose is to facilitate property transactions and, as the name implies, the scope of work is much less than a Comprehensive Building Asbestos Survey per E2356. E2308 refers to E2356 and it seems a reciprocal reference is in order.
    3. Should the important but lengthy section on determining the cost of a Baseline Survey become an appendix instead? Can some items be simplified and do others need more explanation?
    4. Analysis of Non-friable Organically Bound Materials (NOBs) is discussed in several places in E2356. A related discussion involves visual estimation of <1% asbestos These discussions could be clarified and incorporation of the flow chart from the Manual on Asbestos Control – Second Edition might help.

    5. Appendix X1 on sampling techniques has several issues:
    a. Wallboard – The complex nature of wallboard materials and some of the permutations could be better explained.
    b. Vermiculite Attic Insulation – Currently Note 6 recognizes the difficulty of analyzing VAI and recommends that it be assumed to contain asbestos. EPA has published a Research Method for analysis and labs are now offering it commercially. A sampling method should be added for VAI and the EPA method referenced, with appropriate caveats.
    c. Soil – It may be stretching the definition of a “building” but soil sampling seems to be an appropriate addition to E2356. A crawl space under a building is often part of an abatement project, for example. The sample collection section of the Test Method being developed by D22.07 could be incorporated with reference to the analytical procedures in that method. (This assumes the D22.07 method is published before the E2356 revision.) Does adding soil sampling and analysis to E2356 opens the question of clearance criteria for abatement of crawl spaces in E1368, which is now done by concurrent visual inspection and air sampling? How do you assess a crawl space using the E2356 protocols?
    6. The Appendix X2 on Assessment protocols also has several issues to consider:
    a. The 10%/25% localized and distributed criteria for determining Current Condition is discussed briefly in the text. Should this approach be incorporated in the tables as an optional factor to use in determining the qualitative rankings and quantitative ratings?
    b. Table X2.1 contains “AHERA analogies” to the qualitative rankings for Current Condition. Should this section make further attempts to compare the AHERA and E2356 assessment protocols and reconcile the important differences? For example, E2356 doesn’t recommend response actions other than abatement vs O&M based on the assessment while AHERA mandates them.
    c. Would it help to include photos illustrating combinations of Current Condition and Potential for Disturbance ratings? Should the tabulation of the ratings as an approach to prioritizing abatement vs O&M decisions be explained?
    d. No distinction is made between assessing friable and non-friable ACM. Should it affect how Current Condition and Potential for Disturbance ratings are determined or is friability implicitly covered by the existing descriptions? Should the factors that determine the ratings be expanded? Should asbestos content be a factor?
    e. The rationale for the shape and location of the line on the Abatement vs O&M Decision Chart is fairly complex. The criteria bear discussion and a simpler way to explain them is in order. Alternately, the line could be done away with and abatement priority indicated by position on the chart or shading from the upper left to lower right corners.
    f. ASTM copyright policies discourage people from copying the charts, which rather defeats the purpose of putting them in the standard. If this policy issue can be overcome, the charts could be copied from the downloadable PDF file. The charts can also be provided on Excel spreadsheets, which facilitate drawing the line, but this would be a quantum leap in how ASTM distributes standards on-line.
    7. The copyright and distribution issues above also apply to the forms in Appendix X3. They would be more useful if provided in a format that could be saved, edited and distributed electronically. Revisions to their format and content should be considered.
   
    I’m looking forward to your responses and to seeing you in Nashville in March.

Andy Oberta
Chairman, ASTM Task Group E06.24.03 on Asbestos Management
The Environmental Consultancy 
www.asbestosguru-oberta.com
(512) 266-1368