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HomeMy WebLinkAboutRe_ Homeowners performing their own abatement.pdf From: Steve/Suzanne Hickox To: Glen Morgan; Christopher Jarecki;steven hickox Subject: Re: Homeowners performing their own abatement Date: Tuesday,September 11,2018 10:02:39 AM Good morning Glen, I wanted to check back to make sure we are in agreement regarding the abatement and air quality testing prior to the Town of Vail issuing our building permit for our home. Kindest regards, Suzanne Hickox On Sat, Sep 8, 2018 at 1:59 PM Steve/Suzanne Hickox<swhickox2@gmail.com>wrote: Dear Glen and Christopher, As to Mr. Jarecki's question on the State Permit requirement for homeowner abatement of asbestos,please see the email conversation below with the Colorado Air Pollution Control Division. In this email conversation, I specifically ask about any required permits from the State and was informed there is none. My husband and I agree to supply the Town of Vail with an air quality test after we remove the walls in question per the guidelines given to us by the State,prior to the issuance of our building permit from the Town of Vail (Permit Application B 18-0323). I hope this resolves the questions and issues you may have,please contact me if this is not the case. Kindest regards, Suzanne Hickox Forwarded message From: SW Hickox<swhx2trustn,gmail.com> Date: Sat, Sep 8, 2018 at 1:51 PM Subject: Fwd: Homeowners performing their own abatement To: <swhickox2@gmail.com> Forwarded message From: Strosnider- CDPHE, Trevor<trevor.strosnider@state.co.us> Date: Tue, Sep 4, 2018 at 2:21 PM Subject: Re: Homeowners performing their own abatement To: SW Hickox<swhx2trust@gmail.com> Hello again Suzanne, We're happy to help, hopefully that information is of some use to you. In answer to your question: no. There is no (state-level) application, certification, etc for a homeowner performing work in their own home. The long and short is that as long as you comply with the waste handling instructions I've quoted for you, you're in good shape as far as CDPHE is concerned. Thank you, -Trevor Strosnider Trevor Strosnider Environmental Protection Specialist Indoor Environmental Program ®❑ P 303.692.3180 I F 303.782.0278 4300 Cherry Creek Drive South, Denver,CO 80246-1530 trevor.strosnider@state.co.us I www.colorado.gov/cdphe/ashestos As of January 1,2017,the Indoor Environment Program will not accept incomplete forms for certification, abatement or demolition.Any application with missing information may result in longer processing times or the application may be returned to you which will restart the required notification period. Please note that all submissions must be completed using forms supplied by the Division.If you need assistance,please refer to:https:// v.colorado.gov/pacific/cdphe/asbestos- forms or https://www.colorado.gov/pacific/cdphe/certification-and-lead-abatement-forms or contact the Indoor Environment Program at 303-692-3100. On Tue, Sep 4, 2018 at 2:18 PM, SW Hickox<swhx2trust@gmail.com>wrote: Good afternoon Trevor, Thank you for taking my call today and offering to decipher these rules and regulations. I will review the information you have sent, note any questions I have and get back to you in a day or 2. My initial question is, will we need to register or apply for this exception? I'm just thinking of the requirement by the Town of Vail that we abate per State rules. Thank you again Trevor. Kindly, Suzanne Hickox On Tue, Sep 4, 2018 at 11:34 AM Strosnider- CDPHE, Trevor <trevor.strosnider@state.co.us>wrote: Good morning m'am, Thanks for your questions this morning. Since this is a complicated issue I'm going to break my response to you into several sections. I'll start with the legal bits and then move on to more practical matters. First of all, I'm going to link the full text of Regulation 8, Part B, which is the controlling asbestos legislation in Colorado. It's the legal document I'll be interpreting for you. Tip: this linked document is fully searchable, so you can use ctrl+F to find keywords if you ever want to do so. https://www.colorado.gov/pacific/sites/default/files/AP ASB Regulation-No-8-Part-B- Asbestos-amended-December-21-2007-effective-January-30-2008.pdf Demolition/renovation of asbestos-containing materials outside of a regulated full containment setting can release significant quantities of asbestos fibers into the air, where they are a respiratory hazard and a class 1 known carcinogen. However, homeowners do have options for doing work in their own home, as long as they don't plan to rent, sell, or demolish the space. Although I appreciate that professional abatement is expensive, from a public health standpoint I always recommend having the job done professionally by an independent, certified General Abatement Contractor. Since it sounds like you're interested in doing the work yourself, the following sections might apply to you. From section III.X. (EXEMPTIONS): "If you own a Single Family Residential Dwelling that is your primary residence and you choose to do the abatement yourself, certification is not required." "Ill.G.5. Asbestos abatement permits are required for asbestos abatement projects in single family residential dwellings for which the amount of asbestos-containing materials to be abated exceeds the trigger levels, unless either of the following conditions apply: IIl.G.5.a. The homeowner has requested that the single-family residential dwelling not be considered an area of public access pursuant to section III.E.2.; or IlI.G.5.b. The individual is performing the abatement project himself/herself in a single family residential dwelling that is the individual's primary residence." In the case where you are performing work in your own home, the only sections of Colorado's asbestos laws that you MUST comply with are those contained in III.R (Waste Handling), which begins on page 49 of the linked regulation. The way the regulation is written, as long as the asbestos hazard is confined to the inside of your home, the state cannot intervene. However, the material is considered hazardous waste, so once it leaves the protected envelope of your four walls and goes out into the greater world, it constitutes a public health hazard unless stored, transported, and disposed of properly at an approved landfill. As long as you follow the provisions in III.R then you should be okay legally speaking. As for safe work practices, I can offer you some tips, though they are no substitute for using trained and certified personnel with the equipment to handle the situation properly. Firstly, you'll want to do the work clean-shaven, while wearing a tight fitting respirator with P100 (magenta) filter cartridges. Disposable Tyvek or paper suits with no clothing on underneath are also highly desirable; that way, you don't have to worry as much about contaminating your washer and dryer by attempting to launder contaminated working clothes. It's also highly advisable to isolate your work area from the remainder of the building using polyethylene sheeting. Establishing a containment (nearly airtight) that covers exits to other rooms, vents, floor drains, etc helps keep fibers from migrating out of your work area. Covering the floors, walls, and ceiling surfaces that you WON'T be impacting is also helpful as it makes cleanup far easier and leaves less residual contamination once your job is complete. This sheeting is often available from big- box construction and home improvement stores. Once you have your containment built, you'll want to wet the material you're going to remove with a low-pressure garden sprayer. Mix a little hand soap into the water so it can function as a surfactant; this helps it wet asbestos-containing materials more deeply and captures more fibers as they try to peel away. Remove the drywall in intact sheets wherever possible, disturbing them as little as possible and wetting continually with your sprayer as you go along. Stay away from power tools (reciprocating saws, etc) and massive blunt force (sledgehammers) as once again these invasive methods release far more fibers than more conservative hand demolition methodologies. Once you have the material down, package it up properly according to III.R, complete with the required warning labels- I should reiterate that this is a LEGAL requirement that you must adhere to when disturbing these materials. Finally, you'll want wet-wipes (disposable rags in water or pre-wetted towelletes) for cleanup when you're done. Renting a commercial-grade HEPA vacuum is also a great idea. However, don't mistake garden-variety home vacuums with a HEPA label as the real thing; they don't have the filtering capacity to grab asbestos fibers and end up dispersing them all over your work area. Vacuum the work area of gross debris and then wet-wipe ALL surfaces thoroughly, including your poly walls, floors, and ceilings. Then you can fold the poly carefully in on itself and dispose of it as contaminated debris as per the instructions in III.R. The issue of build-back by another contractor is a separate legal complication, but it is outside my regulatory purview. Suffice it to say that there are potential legal ramifications of hiring tradesmen who are protected under OSHA to do work in a space where asbestos has been disturbed by uncertified workers. Unfortunately I can't offer any legal advice on this issue, so contact OSHA if you have more questions on this topic. I've also attached our general asbestos fact sheets, which have a wealth of information about the legal and health issues surrounding asbestos. Feel free to contact us here by email or by phone at 303-692-3100 if you have any additional questions. Thank you and best of luck, Trevor Strosnider Environmental Protection Specialist Indoor Environmental Program P 303.692.3180 F 303.782.0278 4300 Cherry Creek Drive South, Denver,co 80246-1530 trevor.strosnider@state.co.us www.colorado.gov/cdphe/asbestos As of January 1,2017,the Indoor Environment Program will not accept incomplete forms for certification, abatement or demolition.Any application with missing information may result in longer processing times or the application may be returned to you which will restart the required notification period. Please note that all submissions must be completed using forms supplied by the Division. If you need assistance,please refer to:https://www.colorado.gov/pacific/cdphe/asbestos- forms or https://www.colorado.gov/pacific/cdphe/certification-and-lead-abatement-forms or contact the Indoor Environment Program at 303-692-3100.