Asbestos/Lead Surveys

Building Surveys for Asbestos and Lead

Asbestos and lead issues cover a great deal of environmental turf, extending into many specialized areas of business and industry. Building surveys are the most commonly encountered issue involving these materials in the public and private sectors. The purpose of this article is to assist building owners and managers in making informed decisions on building surveys, and to help them stay in compliance with government regulations.

Background on Asbestos and Lead
Asbestos and Lead in Buildings
Restrictions on Use
Restrictions on Exposure
When Buildings Must Be Inspected for Asbestos...
When Buildings Must Be Inspected for Lead...
Managing Asbestos and Lead

The CERL Solution!

More Information on Asbestos and Lead
Lead Regulations: Coordination & Conflicts
A Comparison of Field and Laboratory Methods for Lead Detection
EPA Asbestos Information
EPA Lead Programs

Background on Asbestos and Lead

Asbestos is a naturally occurring fibrous mineral; lead is a heavy bluish-gray metal. Throughout history, both minerals have proven to be extremely useful for a variety of applications. They have also been shown to be harmful to human beings, each in its own way.

Breathing sufficient quantities of asbestos fibers over an extended period of time can damage lung tissue, and may also cause cancer. Breathing and ingesting sufficient quantities of lead can cause brain and kidney damage, especially in children. The harmful effects of these minerals has prompted the Agency for Toxic Substances and Disease Registry (ATSDR) to issue public health statements for asbestos and lead. These statements provide descriptions of the materials and their health effects.

ATSDR Public Health Statement: Asbestos
ATSDR Public Health Statement: Lead

Asbestos and Lead in Buildings

Asbestos has been used in a wide range of building materials. Some of these uses include:

insulation on pipes, boilers and furnaces;
insulation on steel structural members;
sprayed-on acoustical and decorative finishes, especially on ceilings;
vinyl floor tile, and the "mastic" adhesive used to fix the tile in place;
paper backing on sheet vinyl flooring;
drywall panels, and the joint compound used to seal the panels;
asphalt roofing products;
acoustic ceiling tiles.

This list is not comprehensive - asbestos was used so pervasively, almost any product not made entirely of wood, metal, or masonry may contain it. Even in the case of masonry, there is a cementitious asbestos product known as transite, used mostly for siding, shingles, and pipes.

The primary use of lead in buildings has been as an additive to paint, and as solder for water pipes. Very old buildings may have water pipes and fixtures made of lead.

Restrictions on Use

The health risks presented by asbestos and lead have prompted public concern; as a result, government agencies have taken steps to limit the use of these materials. In 1971, the Consumer Product Safety Commission (CPSC) began limiting the amount of lead that could be used in paint. By 1978, the amount of lead allowed in paint manufacture was reduced to 0.06% by weight.

In 1989, the Environmental Protection Agency (EPA) placed a broad ban on certain types of asbestos materials, mostly paper products, that will achieve full force in 1997.

It should be noted that the use of lead and asbestos in building materials and paints has not been completely banned. Use of asbestos has been banned only in certain products. Low levels of lead may continue to be used in paints. These restrictions are meant not to eliminate the use of these materials, but to lower the risk of harmful exposures to the public.

Restrictions on Exposure

For roughly 30 years, federal agencies have been attempting to limit the public's exposure to airborne asbestos fibers. OSHA began setting limits on worker exposure in 1970. In 1982, EPA wrote regulations requiring the management of asbestos materials in schools; these regulations were broadened in scope in 1986. By 1990, EPA regulations covered emissions of asbestos fibers from renovation and demolition projects for public buildings.

OSHA also regulates occupational exposure to lead in general industry and in the construction industry, and also establishes work practices, monitoring and training requirements for the latter. The Lead Contamination Control Act (1988) required testing of school water systems for lead.

When Buildings Must Be Inspected For Asbestos...

Under EPA regulations, all primary and secondary school buildings must be inspected by an EPA accredited asbestos inspector. The same is true for any "facility" that is to undergo renovation or demolition. The word "facility" is used to denote institutional, commercial, industrial, and public buildings; it also includes residential structures containing more than four residential units.

Inspections are not required for private residences (including buildings holding up to four residential units). Some other buildings may not require an inspection under certain qualified circumstances; however, determination of almost all such exemptions must be made by an EPA accredited asbestos inspector.

When Buildings Must Be Inspected For Lead...

All primary and secondary school drinking water systems must be tested for lead content. The Lead-based Paint Poison Protection Act required the testing of all public housing for lead by 1994. Other than this, there are no regulations that require buildings to be tested for lead.

HUD currently has a program in place in which all public and Indian housing managed by HUD is being tested for lead-based paint. Under the HUD guidelines, lead-based paint includes any paint with a concentration of lead equal to or exceeding 1.0 mg/cm², or 0.5% by weight (depending on the analytical method used to test the paint).

EPA regulations require sellers and lessors of residential structures or units built prior to 1978 to disclose any information they might have regarding lead in the building, and must also provide EPA's pamphlet "Protect Your Family From Lead in Your Home" to the buyer or lessee. Sellers must also allow a prospective purchaser 10 days prior to commitment to conduct their own lead survey of the building, if they so desire.

Lead inspections must be carried out by EPA accredited lead inspectors, beginning in 1999. At this time, however, there are no federal accreditation requirements. Some states do have accreditation requirements, and HUD has published recommended qualifications for lead inspectors in their guidelines.

Managing Asbestos and Lead

When contaminated materials have been identified in a building, a decision must be made concerning what to do about them. There seems to be a general perception that materials contaminated with asbestos and lead must be eliminated from a building to protect the health of the occupants; this is not always the case.

Lead-based paint and most asbestos materials are similar in that, if maintained in good condition, and otherwise left undisturbed, they present no significant health hazard. In the case of lead-based paints, this means taking measures to prevent chipping and flaking, such as repainting at regular intervals.

For asbestos materials, it means making sure the materials aren't damaged or abraded to the point that they begin to lose their internal cohesion, allowing fibers to escape into the air. For example, breaking a piece of asbestos vinyl floor tile will not ordinarily cause a significant emission of asbestos fibers. On the other hand, sanding the same piece of tile, or subjecting it to forces that cause it to crumble, is likely to cause a significant fiber release.

There are times when action must or should be taken with regard to asbestos materials and lead-based paints. In the list below, the word "must" is used to indicate a federal mandate. The word "should" is used to indicate a recommendation that is not a federal requirement. Note that actions we indicate as recommended are required by some state governments:

Lead solders, pipes, and fixtures must be removed from school water delivery systems that show a level of lead in the water of 0.015 mg/L or greater. This should also be done for other water delivery systems.
Lead-based paint that is chipping or flaking should be stabilized or removed from buildings, especially any building which is regularly occupied by children aged 6 or under.
If a surface contaminated with lead-based paint is to be sanded or scraped prior to re-painting or re-finishing, specific precautions must be taken to protect the workers involved in the project, and other workers in the building. Beginning in 1999, EPA requires that precautions must also be taken to protect the building occupants; in any event, such precautions should be taken.
Beginning in 1999, all lead-based paint activities must be performed by accredited personnel. Activities involving lead-based paint should be performed by trained personnel.
Many asbestos materials must be removed from facilities (see the paragraph above on asbestos inspections) prior to any renovation or demolition activities that could affect these materials. Single family private residences are exempt from this requirement, as are apartments and condominiums in structures that contain no more than four of these units. However, in many cases asbestos materials should be removed from these buildings as well. Some specific asbestos materials are exempt from this requirement; this determination must be made by an accredited asbestos inspector.
Asbestos materials that are damaged and degraded to the point that significant amounts of asbestos fibers could be released must be stabilized or removed from primary and secondary schools, and should be stabilized or removed from other buildings.
When asbestos materials are to be removed from a building, specific precautions must be taken to protect the workers involved in the project, other workers in the building, and the general public inside and outside the building.
Asbestos related activities in schools and facilities must be undertaken by accredited personnel.