NVIC 06-87: Asbestos and respiratory hazard control guidance

NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 6-87 Subj: Recommended Procedures for Control of Asbestos and Other Respiratory Hazards On Board Merchant Vessels, Outer Continental Shelf (OCS) Facilities and Deepwater Ports

Recommended Procedures for Control of Asbestos and Other Respiratory Hazards on Board Merchant Vessels, Outer Continental Shelf (OCS) Facilities and Deepwater Ports — PURPOSE. This Circular recommends procedures for controlling potentially

hazardous exposure of marine personnel to asbestos and certain mineral fibers and provides guidance in selection of control techniques to reduce such exposure on board merchant vessels, OCS facilities and deepwater ports.

Recommended Procedures for Control of Asbestos and Other Respiratory Hazards on Board Merchant Vessels, Outer Continental Shelf (OCS) Facilities and Deepwater Ports — PERIODICALS AFFECTED. Navigation and Vessel Inspection Circular (NVIC) 5-80

is cancelled.

Recommended Procedures for Control of Asbestos and Other Respiratory Hazards on Board Merchant Vessels, Outer Continental Shelf (OCS) Facilities and Deepwater Ports — BACKGROUND.

a. Ships that were constructed between 1940 and 1975 used substantial amounts of asbestos for insulation and fire protection. Concerns about the health effects from exposure to asbestos have forced limited use, if not total elimination, of this material in the construction of new vessels. b. Initial guidance for control of personnel exposure to asbestos on board vessels and facilities was outlined in NVIC 5-80 dated 13 March 1980. NVIC 5-80 outlined procedures for vessel/facility owners, operators and crewmembers to identify asbestos hazards and prescribed controls available to minimize the risk of asbestos fiber exposure. At the time that NVIC was issued, several government sponsored studies were underway. Those studies eventually provided more detailed information concerning asbestos exposure. c. On June 20, 1986, the Occupational Safety and Health Administration (OSHA) issued a final rule in the Federal Register (51 FR 22612) that amended the regulations in 29 CFR §1910.1001, concerning occupational exposure to asbestos which was the basis of NVIC 5-80. That rule substantially reduced the exposure level of asbestos to which personnel can safely be subjected. d. Certain mineral and artificial mineral fibers, that have been used as an alternative to asbestos, have been identified by the manufacturers as presenting a possible health hazard when personnel are exposed to concentrations in excess of the manufacturer's permissible exposure level.

Recommended Procedures for Control of Asbestos and Other Respiratory Hazards on Board Merchant Vessels, Outer Continental Shelf (OCS) Facilities and Deepwater Ports — DISCUSSION.

a. Responsibility. When shoreside contractors are hired for repair work, OSHA has jurisdiction over operations where 29 CFR §1910.1001 and §1915 apply. In instances where crewmembers are engaged in maintenance and repair work as part of their regular shipboard duties, the vessel owner/operator is responsible for the health and safety of the crewmembers. b. Asbestos Exposure. This Circular recommends the use of OSHA's new standards and provides additional guidance as to what action should be taken to reduce overall asbestos exposure. Monitoring and surveillance activities are outlined in this Circular should be implemented to determine if the action level and permissible exposure limit (PEL) are reached so that appropriate medical monitoring and abatement measures are taken to ensure that personnel exposure does not exceed the PEL of 0.2 fiber per cubic centimeter (f/cc). c. Suspect Material. Asbestos materials are believed to have been installed on all types of vessels. Enclosure (1) contain a list of commonly encountered asbestos materials. Since visual recognition is unreliable, all suspect material should be considered to contain asbestos unless known otherwise. Suspect materials that are damaged, deteriorated or scheduled for removal can be analyzed at a chemical laboratory using techniques such as high x-ray diffraction techniques to determine the presence of asbestos prior to repair/rebuilding work. d. Definitions.

(1) "Action Level" - An airborne concentration of asbestos, tremolite, anthophyllite, actinolite, or a combination of these minerals of 0.1 f/cc of air calculated as an 8-hour time weighted average (TWA).

(2) "Asbestos" - For purposes of this NVIC, environmental monitoring, and medical monitoring 'Asbestos' includes both the asbestiforms and non-asbestiforms of chrysotile, amosite, crocidolite, tremolite, anthophyllite, actinolite, and any of these minerals that have been chemically treated and/or altered. For purposes of compliance with OSHA standards contained in 29 CFR, the specific regulatory definitions should be used.

(3) "Employee Exposure" - Exposure to airborne asbestos, tremolite, anthophyllite, actinolite, or a combination of these minerals that would occur if the employee were not using respiratory protective equipment.

(4) "Encapsulation" - Application of a sealant via airless spray equipment to an asbestos-containing material to prevent release of asbestos fibers. A bridging encapsulant is a sealant designed to form a membrane over the surface of an asbestos-containing material. A penetrating encapsulant is a sealant designed to saturate the material to bind the asbestos fibers together and to other substances in the material.

(5) "Enclosure" - An airtight barrier between the asbestos-containing material and the working or living environment.

(6) "Fiber" - A particulate form of asbestos, tremolite, anthophyllite, or actinolite, 5 micrometers or longer with a length-to-diameter ratio of at least 3 to 1.

(7) "Friable Asbestos" - Where the asbestos-containing material can be easily crushed, crumbled, pulverized or reduced to a powder in the hand. The asbestos may be soft or loosely bound in a matrix.

(8) "High-Efficiency Particulate Air (HEPA) Filter" - A filter capable of trapping and retaining at least 99.97 percent of 0.3 micrometer diameter mono-dispersed particles. [NOTE: On May 12, 1987 (52 FR 17752) OSHA modified the respirator selection tables codified at 29 CFR §1910.1001 Table 1, and 1926.58 Table D-4 to specifically exclude the use of disposable respirators for use in areas with airborne concentrations not in excess of 2 f/cc.]

(9) "Lagging" - A specific type of enclosure usually reserved for thermal insulation on boilers, machinery and piping. Lagging is the insulation material and protective jacket or covering placed over the insulation material and made of cloth, tape, paper, cement, metal, and/or board, usually finished with cement, paint or other coating. Friable asbestos-containing material covered with lagging is considered to be non-friable as long as the lagging remains intact.

(10) "Non-Friable Asbestos" - Where asbestos fibers are firmly bound or encased in the material. These usually are hard asbestos-containing materials (e.g. vinyl/asbestos floor tile) that generally do not generate exposure problems unless disturbed (e.g. scraping, grinding, drilling, etc.).

(11) "Regulated Area" - An area established to demarcate areas where airborne concentrations of asbestos, tremolite, anthophyllite, actinolite, or a combination of these minerals exceed, or can reasonably be expected to exceed, the PEL.

(12) "Removal" - Controlled elimination of asbestos that keeps airborne concentrations of asbestos within PEL's through the use of engineering controls and work practices. Short term use of respiratory equipment may be required during the actual removal of the asbestos.

(13) "Rip-Out" - Uncontrolled elimination of asbestos that keeps airborne concentrations of asbestos above the PEL even with the use of engineering controls and work practices. Long term use of respiratory equipment may be required well after the removal of the asbestos.

(14) "Tremolite, Anthophyllite, Actinolite" - The non-asbestos form of these minerals, and any of these minerals that have been chemically treated and/or altered. For environmental and medical monitoring purposes these forms are considered to be asbestos, as defined in subparagraph 4.d.(2) above. e. Permissible Exposure Limit (PEL).

(1) OSHA standards require that an employee's exposure to an airborne concentration of asbestos should not exceed 0.2 f/cc of air over an 8-hour TWA based on Appendix A of 29 CFR §1910.1001.

(2) If asbestos exposure exceeding the PEL cannot be prevented, exposure should be controlled using the methods prescribed in enclosures (2),

(3), (4) and (5). f. Exposure Monitoring.

(1) OSHA standards require that monitoring be conducted initially to determine employee exposure to asbestos in their assigned work or other areas that are representative of an 8-hour TWA as specified in 29 CFR §1910.1001(d).

(2) Periodic monitoring, at intervals not greater than 6 months, should be conducted if exposure to asbestos may reasonably be expected to exceed the action level (0.1 f/cc). g. Limitation On Fabrication, Installation Or Use. The fabrication, installation or use of asbestos-containing materials should be avoided except for essential applications where no acceptable substitute material exists. h. General Asbestos Control Alternatives. There are four generic control alternatives for asbestos: repair, encapsulation, enclosure and removal. [NOTE: Non-friable asbestos usually does not require control. However, monitoring of the environmental conditions should always be done to assess the magnitude of the problem because non-friable asbestos can also become airborne if disturbed.]

(1) Although each is a unique approach, they all have the following common features:

(a) They all require knowledge of the surface to be controlled based on the purpose of the covering (i.e., fire protection, thermal insulation, decoration), the level of activity in the area, the size of the area under consideration, the thickness of the material, and the method of application (sprayed, bolted, taped, wired, cemented, etc.); and

(b) They all require personnel protection during handling which should be accomplished in accordance with the guidelines of this Circular.

(2) Repair should be considered as the first option in controlling asbestos concentrations whenever possible. The situations that lend themselves best to repair are:

(a) Small cracks, breaks, indentations, tears, and gouges in the covering material.

(b) Areas of limited deterioration or damage (e.g. small areas of moisture damage) where removal of the non-friable asbestos to a natural boundary, break, or joint can be accomplished without significantly increasing the exposure level. Any replacement should be with non-asbestos material.

(c) Areas where the damage can be effectively taped, caulked, or cemented to prevent fiber release.

(3) Enclosures may be constructed as new installations or as adaptations of existing installations. Many friable asbestos materials aboard ship are covered but not enclosed, i.e. not sealed behind an airtight barrier. The use of tape, caulking, or cement may serve as an enclosure necessary to comply with an enclosure. Lagging may serve as an enclosure for boilers, machinery, and piping insulation. The following factors regarding the characteristics and location of the asbestos material, regarding the characteristics and location of the asbestos material, and the characteristics of the enclosure should be considered:

(a) The underlying structure must be capable of supporting an enclosure.

(b) Construction of the barrier may require drilling or other precautionary abrasive handling of asbestos-containing material. Precautionary measures for personnel protection should be followed as specified in 29 CFR §1910.1001.

(c) The construction of enclosures may be preferable to removal of asbestos-containing material in areas of high activity.

(d) The area behind the enclosure must be isolated to the extent that there is no communication with an air plenum or work or living areas.

(e) Access to areas behind the enclosure should be restricted or otherwise kept to a minimum.

(f) Personnel entering the enclosed area must observe appropriate protective measures due to the potential for high concentrations of airborne asbestos fibers.

(g) The enclosure should be impact resistant.

(h) Where lagging is installed and subject to chafing, abrasion, or oil contamination, metal lagging covers should also be installed to protect the enclosure. Where personnel may step on it, a rigid metal cover should be installed.

(i) Lagging should fit snugly to the underlying material.

(4) Encapsulation is generally recommended only for sprayed asbestos surface asbestos that are not highly friable (e.g. acoustical plaster) and, therefore, has very limited applications aboard ship. It is not recommended for areas subject to vibration, personnel exposure, or frequent disturbance. The key factors to consider for encapsulation are the characteristics and location of the asbestos material, and the characteristics of the encapsulant as follows:

(a) Encapsulation should not be used in areas subject to vibration. This includes most areas of a vessel, particularly the machinery spaces, fan rooms, and adjacent compartments.

(b) Encapsulation should not be used in areas subject to abrasion, severe impact or other disturbances (e.g. areas where machinery is frequently operated or maintenance is performed).

(c) Encapsulation should not be used on material that is deteriorated, delaminated, or shows extensive damage.

(d) The encapsulating material should have good cohesive and adhesive strength. It should not be applied more than 1 inch thick (the weight of the encapsulant may accelerate the deterioration).

(e) The material should be resistant to water damage (some encapsulant binders are water soluble).

(f) Encapsulants should be evaluated based upon the results of the following tests: 1. Adhesion or tensile bond strength; and 2. Fire hazard evaluation: a. Flame spread; b. Smoke generation; c. Toxic combustion products; and d. Flash point/ignition temperature.

(g) Impact resistance.

(h) Abrasion resistance.

(i) Aging resistance, including resistance to water vapor aging

(resistance to continuous high heat and humidity), and ultraviolet radiation aging.

(j) In locations where the installed material must meet Coast Guard fire safety standards (e.g. bulkhead panels), encapsulants applied to their surface must comply with the following: 1. Penetrating encapsulants are to be approved as a non-combustible material under 46 CFR §164.009. 2. Bridging encapsulants are to be approved as an interior finish under 46 CFR §164.012.

(k) Encapsulants should be field tested for specific installations prior to in-service usage.

(l) Encapsulation may be considered as a preventive maintenance measure when applied to non-friable asbestos.

(5) Removal implies three steps: controlled removal ("rip-out" is not recommended), proper disposal, and replacement with non-asbestos materials. Removal is always an alternative for asbestos control. Other methods previously mentioned should be considered first before undertaking large scale removal of asbestos materials. This is due primarily to the difficulty for efficient removal and the increased probability of exposing personnel to a higher concentration of airborne asbestos during the removal process. Existing installations of asbestos materials may be allowed to remain in place as long as they are maintained in an intact condition. The following factors should be considered prior to removal of any asbestos material:

(a) Asbestos materials damaged by oil or water should be removed in their wet state.

(b) Asbestos materials damaged beyond repair, such that the damage is either too extensive or the insulation no longer provides the intended thermal protection, should be removed.

(c) Removals beyond the damaged or deteriorated area should be taken to the nearest "natural" boundary (i.e. either section by section or panel by panel removal of pipe insulation or wall covering, respectively, rather than cutting out and inserting new sections or panels). i. Guidance For Selecting Controls. Enclosures (6) and (7) provide guidance for selecting a control method and the proper protective equipment to be used when materials containing asbestos are encountered in the maritime industry. [NOTE: On May 12, 1987 (52 FR 17752) OSHA modified the respirator selection tables codified at 29 CFR 1910.1001 Table 1, and 1926.58 Table D-4 to specifically exclude the use of disposable respirators for use in areas with airborne concentrations not in excess of 2 f/cc.] j. Asbestos Exposure Control Training. Enclosure (8) contains information regarding training in Asbestos Exposure Control Procedures. k. Identification. Following the removal of asbestos thermal insulation, the replacement material should be identified as "asbestos free" by the application of a red undercoat sealer (see enclosure (2)). During subsequent removal or repair, the repairer will be able to determine if asbestos or asbestos free insulation is installed by scraping through the exterior paint to determine if a red undercoat is present. l. Medical Monitoring. Enclosure (9) provides guidance for medical monitoring of personnel occupationally exposed to asbestos.

Recommended Procedures for Control of Asbestos and Other Respiratory Hazards on Board Merchant Vessels, Outer Continental Shelf (OCS) Facilities and Deepwater Ports — IMPLEMENTATION.

a. At sea emergency repairs to piping or other equipment or material covered by asbestos-containing material should not be undertaken unless the by asbestos-containing material should not be undertaken unless the personnel protection controls contained in enclosure (3) are followed. b. An employee's exposure to an airborne concentration of asbestos should not exceed 0.2 f/cc of air over an 8-hour TWA based on Appendix A of 29 CFR §1910.1001. If asbestos exposure exceeding the PEL cannot be prevented, exposure should be controlled using the methods prescribed in enclosures

(2), (3), (4) and (5). c. It is recommended that owners/operators monitor and document ambient and personnel asbestos exposure levels aboard their vessels or facilities in accordance with 29 CFR §1910.1001 to determine employee exposure to asbestos in their assigned work or other areas based on an 8-hour TWA as follows:

(1) Survey the vessel or facility for areas suspected of having asbestos-containing materials, reference enclosure (1);

(2) Monitor those areas where asbestos-containing material is suspected for at least 8 hours, reference enclosure (5);

(3) Initiate personnel training and medical surveillance programs if the action level of 0.1 f/cc (TWA) is exceeded, reference enclosures (8) and (9);

(4) If the permissible exposure limit exceeds 0.2 f/cc (TWA):

(a) Implement personnel protection controls outlined in enclosure (3).

(b) Use enclosure (6) as guidance in determining control measures.

(c) Implement asbestos control measures to reduce airborne concentrations of asbestos.

(5) Periodically monitor those areas that have samplings that exceed the action level. However, in no case should intervals exceed 6 months.

(6) Monitor subsequent to shipyard or other repair those areas involving asbestos-containing material. d. Where possible, the exposure of unprotected personnel to airborne asbestos should be prevented. If exposure cannot be prevented, it is recommended that the exposure be controlled in a manner consistent with the guidance provided in this Circular. e. Asbestos removal should only be undertaken at a shoreside facility. Abatement contractors should be carefully selected. Considerations which should be taken into account during the selection of a contractor include the overall qualifications and reputation, experience and training, and willingness to perform work in accordance with detailed work specifications. J. W. KIME Rear Admiral, U.S. Coast Guard Chief, Office of Marine Safety, Security and Environmental Protection Encl: (1) Frequently Encountered Asbestos-Containing Materials

(2) Asbestos Work Practice Controls

(3) Personnel Protective Controls Involving the Disruption of Asbestos

(4) Asbestos Ventilation Controls for Working Environments

(5) Personnel and Environmental Monitoring of Asbestos Exposure

(6) Recommended Asbestos Control Techniques

(7) Asbestos Protective Equipment List

(8) Asbestos Exposure Control Training

(9) Medical Monitoring and Surveillance Guidelines NON-STANDARD DISTRIBUTION: Cte Baltimore (45); Alameda (40); Port Arthur, Honolulu, Puget Sound (35); Miami, Mobile, Long Beach (25); Norfolk, Jacksonville, Portland OR (20); Boston, Portland ME, Charleston, Anchorage, Galveston (15); Cleveland (12); Louisville, Memphis, Nashville, Paducah, Pittsburgh, St. Louis, Savannah, San Juan, Tampa, Buffalo, Chicago, Detroit, Duluth, Milwaukee, San Diego, Juneau, Valdez (10); Providence, Huntington, Wilmington, Corpus Christi, Toledo (5). Cim New Orleans (140); New York (70); Philadelphia (35); Houston (25); St Ignace

(5); Sturgeon Bay (4). D:1 CG Liaison Officer MILSEALIFTCOMD M-4E4, CC Liaison Officer JUSMAGPHIL (1). ZTC-68