Identification & Management of Hazardous Materials

Asbestos

Material

Asbestos-containing materials, such as insulation, fireproofing, textured or acoustic ceilings and walls, roof felts and papers, drywall joint tape, and flooring

Hazard

When asbestos-containing materials are damaged or disturbed by repair, remodeling, or demolition activities, microscopic fibers can become airborne and can be inhaled into the lungs, where they can cause cancer, asbestosis, and other significant health problems. There is no safe level of exposure to asbestos.

Where To Look

Asbestos is a mineral fiber used for fireproofing and insulation in building materials such as:

Insulation

  • Cement-based insulation (sheets, shingles, and pipes)
  • Furnace, water heater, and heating duct blanket or tape insulation

Ceilings and floors

  • Textured ceilings
  • Ceiling panels and tiles
  • Vinyl floor tiles and backing on vinyl sheet flooring
  • Mastic adhesive

Roofing shingles and mastic

Several websites have lists of example products:

What To Do

For help with identifying asbestos-containing materials, see a photo guide provided by InspectAPedia.com. The Bay Area Air Quality Management District (BAAQMD) provides a factsheet for building owners and managers. The California Department of Toxic Substances Control (DTSC) provides additional information about proper management and disposal.

In many cases, it is necessary to hire a Certified Asbestos Consultant to conduct a survey of possible asbestos-containing materials. If asbestos is present, a Registered Asbestos Contractor should remove it prior to demolition.

The pre-demolition survey to identify asbestos-containing material should be conducted by Cal/OSHA Certified Asbestos Consultant, who must have detailed training, asbestos work experience, and pass a state examination. The survey consists of a thorough building inspection, collecting samples of suspect material and submitting them for laboratory analysis. You can find Cal/OSHA Certified Asbestos Consultants online or in the Yellow Pages under “Asbestos Consulting and Testing.” Check certification at this database.

BAAQMD requires notification of all demolitions of a structure, and/or any load-bearing building component and all renovations removing greater than 100 square feet of asbestos material. Contact BAAQMD to submit a notification at least 10 days prior to demolition. The one-page application describes the work, location, and duration. BAAQMD will issue a “J-number” that most municipalities require prior to the initiation of demolition or renovation work.

If any building materials contain more than 1% asbestos, they must be removed prior to demolition. Removal entails specialized containment, ventilation, and protective gear. For example, California regulations call for strict asbestos worksite control, including: access/egress restrictions; signage; covering floors and furniture with plastic sheeting; worker protections (typically Tyvek suits and respiratory protection); and establishment of a negative pressure containment area (vacuum pumps, filters, and plastic sheeting with duct tape). (CCR Title 8, Construction Safety Order, Article 4. Dusts, Fumes, Mists, Vapors, and Gases, Section 1529).

To protect worker and occupant safety, ensure compliance with detailed regulatory requirements (BAAQMD Regulation 11, Rule 2), and minimize liability, removal should be conducted by a Cal/OSHA Registered Asbestos Contractor.

Find a Cal/OSHA Registered Asbestos Contractor online or in the Yellow Pages under “Asbestos Abatement.” Check contractor registration status at this database.

All asbestos-containing waste material must be kept wet and must be sealed in labeled, leak-tight containers. This waste must be deposited in an approved landfill. In many cases, the asbestos-containing waste is considered hazardous waste and must be transported by a licensed hazardous waste hauler using a hazardous waste manifest. Some municipal solid waste landfills have permits to accept asbestos-containing waste. Always call the transfer or disposal site for specific requirements before attempting to deliver asbestos-containing waste to any landfill or waste disposal facility.

Some property owners also hire a Certified Asbestos Consultant independent of the asbestos abatement company to assure that the work is performed properly and to ensure that it is safe to enter the area after the work is completed. The independent consultant may provide abatement project design, contract administration, supervision of site surveillance technicians, preparation of asbestos management plans, clearance air monitoring, and may prepare a closeout report summarizing the abatement work, worker health and safety measures, results of visual inspection, and any air sampling results to provide documentation of safety and regulatory compliance.

Resources:

BAAQMD Asbestos Program

DTSC factsheet: “Managing Asbestos Waste,” December 2006

Cal/OSHA Asbestos certification program

U.S. EPA background information about asbestos

Chemically Treated Wood Waste

Material

Chemically treated wood waste

Hazard

Arsenic, chromium, copper, creosote, and pentachlorophenol are among the chemicals added to preserve wood. These chemicals are known to be toxic or carcinogenic. Harmful exposure to these chemicals may result from dermal contact with the wood waste, or from inhalation or ingestion of particles (e.g., sawdust and smoke).

Where To Look

This wood is typically treated with preserving chemicals that protect the wood from insect attack and fungal decay during its use. Examples include fence posts, sill plates, pressure-treated dimensional lumber, landscape timbers, creosote-treated railroad ties, pilings, guardrails, and decking.

What To Do

Segregate treated wood waste from other demolition waste. Do not burn or scavenge. Follow storage, labeling, transport, and disposal requirements developed by DTSC. DTSC provides a factsheet about storage, handling, and disposal of treated wood waste.

See additional information at DTSC and DTSC Treated Wood Waste Factsheets

Light Ballasts

Material

Light ballasts

Hazard

Type 1:
PCBs, used as insulators in electrical equipment, are probable human carcinogens and have a variety of other health impacts. If simply disposed of with other debris, the PCBs can be released into the environment.

Type 2:
DEHP, also used as an insulator, is a toxic phthalate (Bis(2-ethylhexyl)phthalate) classified by the U.S. EPA as a probable carcinogen. If such ballasts are disposed of with other debris, the DEHP can be released into the environment.

Where To Look

Type 1:
Light ballasts manufactured prior to 1980 or those without a “No PCBs” label

Type 2:
Ballasts that are designated “No PCBs.” These ballasts fall into two categories: “wet” and “dry.” “Wet” contain a dielectric fluid, DEHP. DEHP is a colorless liquid with almost no odor. “Dry” ballasts are entirely electronic.

What To Do

Type 1:
Remove all light ballasts prior to demolition.

U.S. EPA provides guidance for how to remove and dispose of PCB-containing light ballasts at this web link. Further, the California DTSC has a PDF about proper management and disposal.

There is a limited exemption for disposal of PCB-containing ballasts that is found in Title 22 of the California Code of Regulations (22CCR) section 67426.1 et seq. This section allows up to two (2) 55-gallon drums per vehicle to be transported to an authorized location without use of a hazardous waste manifest or hazardous waste transporter. A shipping paper such as a bill of lading must be used.

To find where to dispose of light ballasts, go to www.lamprecycle.org or use the earth911 form at baywise.org and insert the phrase “ballasts.”

Resource:

DTSC web site

Type 2:
Remove all light ballasts prior to demolition. Separate ballasts from the recyclable metal shade fixture. Segregate the non-PCB ballasts from other construction debris.

Recyclers must drain out the DEHP from “Wet / No PCBs” ballasts before they can recycle the metal and must manage the DEHP as a hazardous waste.

“Dry” ballasts are entirely electronic and may be sent intact for recycling with electronic waste.

To find where to dispose of light ballasts, go to www.lamprecycle.org or use the earth911.org form at baywise.org and search for “ballasts.”

Fluorescent, High-Intensity Discharge (HID), and Neon Lamps

Material

Ceiling light fixtures, neon building signage, parking lot lighting

Hazard

Mercury is contained in these lamps. If the lamp is broken, mercury vapors may be inhaled by workers and occupants. Improper disposal (e.g., in compaction vehicles) may result in further release of mercury into the environment. Mercury is toxic, impacting the central nervous system, kidneys, and other organs.

What To Do

Remove all fluorescent and HID lamp bulbs and all neon lamps prior to demolition. All of these mercury-containing lights are part of the group of wastes regulated as “universal waste,” which is easier to manage than most other hazardous waste. See this DTSC factsheet for details.

To find where to dispose of universal hazardous waste, use the earth911.org form at baywise.org and enter your zip code and the name of the item.

 

Wall Thermostats

Material

Wall thermostats

Hazard

Mercury vapors may be inhaled by workers and occupants if the thermostat breaks during site demolition. Improper disposal may result in further release of mercury into the environment. Mercury is toxic, impacting the central nervous system, kidneys, and other organs.

Where To Look

Mercury is contained in one or more switches (ampoules) inside the thermostat.

What To Do

Remove all mercury thermostats prior to demolition. Collect the entire thermostat. Keep it intact for handling and transport; do not try and remove the switch(es) (ampoules) from the device.

Contractors are required by law to recycle mercury thermostats. It is illegal to dispose of mercury thermostats with solid waste or to leave them at the customer’s site. The latest regulatory information is available here.

California HVAC wholesalers are required to collect mercury thermostats (http://www.calpsc.org/products/thermostats). The Thermostat Recycling Corporation makes it easy to comply with the law. Use its search engine to find locations nearest to you.

Industrial Material

Material

Industrial electrical switches and relays, laboratory fume hoods, gym flooring, medical/dental equipment, facilities, and associated sewer lines

Hazard

This equipment contains mercury. During demolition, mercury vapors may be inhaled by workers and occupants. Further, improper disposal may result in the mercury being released into the environment. Mercury is toxic, impacting the central nervous system, kidneys, and other organs.

Where To Look

All: Any building that used mercury or dental amalgam may have mercury in the sewer plumbing. Mercury is very heavy and can settle at low points in the sewer plumbing such as a sump or sink trap and remain there for many years.
Industrial Facility: switches and relays
Dental Office: P-traps under sinks in operatories; filters for vacuum pumps
Medical Facility: Blood pressure cuffs, thermometers, lab chemicals, esophageal dilators, electrical instruments
Industrial Lab: manometer (pressure measuring device) in chemical fume hood
Dairy Barn: dairy manometer
School: manometer in chemical fume hoods, rubber gym flooring from 1970s contains mercury catalyst
Wastewater Treatment Plants:
mercury switches and relays

What To Do

Remove all mercury-containing switches, relays, and other equipment prior to demolition.

Whenever sewer pipes, sumps, or sink traps are to be moved or cleaned, the plumber must be notified about the potential of finding mercury in the sludge. If the sewer lines are not being demolished, but rather are staying in place, this website describes how to “clean” pipes for continued in-place use (scroll down to Appendix D).

The following mercury-containing items are part of the group of wastes regulated as “universal waste”: thermostats, mercury switches, mercury thermometers, pressure or vacuum gauges, dilators and weighted tubing, mercury rubber flooring, mercury gas flow regulators, dental amalgams, counterweights, dampers. Universal wastes are easier to manage than most hazardous waste. See this DTSC factsheet for details.

To find where to dispose of universal waste, use the earth911 form at baywise.org and insert the phrase, “universal waste.”

Lead Paint

Material

Lead paint

Hazard

Lead dust can form when building materials coated with lead-based paint are disturbed. Lead is dispersed when materials are dry scraped, dry sanded, or heated during renovations.

Demolition creates dust that can move into neighboring buildings. Lead dust remaining at the job site can harm future occupants.

Dust also forms when any painted surface is bumped. Lead chips and dust can get on surfaces and objects that people touch. Settled lead dust can re-enter the air when people vacuum, sweep, or walk through it.

Lead can also collect in soil at a structure’s roof dripline when dust that falls on the roof is washed off by rain and fog.

Even small exposures to lead can seriously harm people and the environment. Childhood lead poisoning remains a major environmental health problem in the United States. Lead is also harmful to adults, who can suffer from:

  • Reproductive problems
  • High blood pressure and hypertension
  • Nerve disorders
  • Memory and concentration problems
  • Muscle and joint pain

Where To Look

Many buildings built before 1978 have paint with enough lead content to meet the legal definition of lead-based paint. Any painted surface could have lead. Sometimes the lead is not in the top layer of paint; however, it can create harmful lead dust when disturbed by demolition or renovation. For a photo guide of some example lead hazards in a structure, go to this link.

What To Do

Before starting demolition of any pre-1978 building, hire a state-certified lead assessor/inspector to inspect a building for lead. Without testing, lead-based paint is presumed to be present and lead-safe work practices must be employed. Alternatively, a homeowner has options for testing for lead, and these are described by the California Department of Public Health. There may be additional local requirements. Check with your local public health department or building inspection department BEFORE starting work.

To conduct the demolition, hire a state-certified lead contractor. All building contractors doing lead abatement must have special certification from the California Department of Public Health. For all such certified professionals, go to the following link for a list in your area. For additional information about finding a lead certified professional, see this link.

It is a violation of California’s Health and Safety Code to create a lead hazard. Further, employers are responsible for worker safety (see the summary of Cal/OSHA’s Lead in Construction Standard).

If one is renovating a building (rather than demolishing it), there are federal requirements to protect the building occupants, in the event that renovations may unintentionally disturb lead-based paint. Before renovating six square feet or more of painted surfaces in a room for interior projects or more than 20 square feet of painted surfaces for exterior projects in a building built before 1978, federal law requires that contractors transmit the document “Renovate Right” to occupants and owners. Further, if the building is a child care facility or school built before 1978, the contractor is responsible for transmitting that information to the facility management, owners, and parents. Contact your local health department to find out about any additional lead-safe work practices to prevent poisoning yourself, children, or neighbors. In San Francisco there are additional requirements, see here for details.

Lead-painted materials that are removed should not be reused, chipped, composted, or burned. Waste materials with lead paint should be contained on site and during transport to prevent releases of dust and debris.

The California Hazardous Waste Management Act requires the segregation of any lead waste from other debris and regulates the disposal of building renovation debris that may contain lead-based paint. While guidance from the U.S. EPA states that IF building debris is derived from a residence the disposal is excluded from federal hazardous waste laws, California does NOT have this exclusion for household hazardous waste. The generator, even if a homeowner, must make a determination to classify the lead-containing debris as hazardous waste or not. This is determined based on measuring lead concentration or by generator knowledge of the material. When measuring lead concentration, one may elect to conduct representative sampling or to measure each debris item separately. While representative sampling may reduce analytical work, it may result in hazardous waste disposal of all the debris. Ultimately, the building owner bears responsibility regarding correct identification of lead waste. If classified as hazardous waste, the debris will need to be disposed of in a Class 1 hazardous waste landfill.

CDPH and the U.S. EPA have oversight for dealing with removal of lead-based paint and demolition of lead-painted materials; enforcement is conducted through local agencies using state laws and regulations.

In California, following lead paint removal from a site, a CDPH clearance inspection or other closeout process may be required. The DTSC and U.S. EPA may require testing of surface soil within the dripline of a recently demolished structure that contained lead-based paint. Results can lead to required excavation of affected surface soil (6 inches to 1 foot) and additional sampling and reporting.

Resources:

For California lead laws, go to this CDPH web link.

CDPH Occupational Lead Poisoning Prevention Program

Summary of Cal/OSHA’s “Lead in Construction” Standard

An employer educational document on setting up a lead safety program for employees

U.S. EPA Lead Information

OSHA Lead factsheet

Caulk, Sealants, and Other Materials

Caulk Tutorial (PowerPoint)

Material

Caulk, sealants, and other materials

Industrial or institutional structures may have these PCB-containing materials: paint, plastics, molded rubber parts, applied dried paints, coatings or sealants, adhesives, paper, Galbestos, sound-deadening materials, insulation, or felt or fabric products such as gaskets.

Hazard

In pre-1980 buildings, caulk and other materials may contain PCBs—probable human carcinogens that have a variety of other health impacts. When disturbed, PCB-containing caulk can be released into the air and inhaled. Dust can wash away into San Francisco Bay, where already elevated PCB levels make some fish unsafe to eat.

Where To Look

PCB-containing caulk is typically found on any structure built or remodeled prior to 1980, but especially concrete and masonry buildings. This material is commonly used in expansion joints; at structure/walkway interfaces; and around windows and doorframes.

In general, indoor caulk applications (other than window caulking and gasket material) do not have to be screened unless past remodeling of the building expanded the structure such that a previous exterior wall is now interior.

If in doubt, assume caulk contains PCBs.

What To Do

If the building was built or remodeled between 1950 and 1980, exterior caulk should be very carefully managed during demolition. See EPA’s flow chart for steps to take when the building may have PCBs in caulk. You can either obtain assistance from a hazardous waste professional to test caulk for PCBs or assume that caulk contains PCBs.

Management entails specialized containment, removal procedures, and protective gear. See EPA’s web page “Steps to Safe Renovation and Repair Activities” and the San Francisco Bay Area PCBs in Caulk Project Best Management Practices for management of sites with PCB-containing material. To protect worker and occupant safety, ensure compliance with safety requirements, and minimize liability, PCB caulk management should be conducted by a professional hazardous materials contractor, who can assist with identifying an appropriate disposal option for PCB waste.

If you find caulk with greater or equal to 50 parts per million PCBs, the caulk and surrounding materials should be carefully managed to protect workers, neighbors, and the environment. Start by working with an expert professional hazardous materials professional to prepare a management plan.

Look for a professional to conduct testing and manage any PCB caulk online or in the Yellow Pages under “Hazardous Material Control & Removal.” The contractor should be thoroughly familiar with U.S. EPA PCBs regulations (40 Code of Federal Regulations Part 761) and applicable California and local laws and regulations.

To see lists of sites that are licensed to accept PCB waste, go to the Western USA List from EPA Region 9 or the Federal EPA List.

Resources:

U.S. EPA PCBs in Caulk – information, abatement procedures, management recommendations, regulations.

San Francisco Bay Area – PCBs in Caulk

Tritium EXIT Signs

Material

Tritium EXIT signs

Hazard

If dropped or smashed during a demolition, tritium (a radioactive form of hydrogen) can escape from the damaged sign, posing an inhalation hazard.

Where To Look

Exit signs that glow in the dark typically contain tritium. The signs glow either green or red in the dark and should have a permanent warning label indicating the presence of radioactivity.

What To Do

According to the U.S. Nuclear Regulatory Commission factsheet:

Tritium EXIT signs must NOT be disposed of as normal trash.To dispose of a sign properly, a general licensee must transfer the sign to a specific licensee—such as a manufacturer, distributor, licensed radioactive waste broker, or licensed low-level radioactive waste disposal facility. These facilities may charge a fee for disposing of the sign.

Further insights regarding disposal can be found at the U.S EPA website regarding discarded EXIT signs.

Smoke Detectors

Material

Smoke detectors

Hazard

Although the amount of radioactive material contained in these detectors is small, disposal with municipal waste should be avoided.

Where To Look

Interior walls of structure

What To Do

The most common type of smoke detector used in residential homes contains a minute amount of radioactive material. Smoke detectors that contain radioactive material can be returned to the manufacturer for disposal. When returning a smoke detector to the manufacturer, include a note that indicates that the detector is intended for disposal and mail it to the address listed on the back of the detector. For a list of manufacturers and addresses, see the following web link.