REGULATIONS and STANDARDS

The inspection was conducted in accordance with applicable sections of the United States Environmental Protection Agency's (EPA's) Asbestos Hazard Emergency Response Act (AHERA) and the United States Occupational Safety and Health Administration's (OSHA) asbestos regulation 1926.1101. 

The AHERA regulation provides stringent standards and guidelines for the sampling, identification and management of asbestos-containing materials.  Originally promulgated to assist local education agencies with the identification and management of asbestos-containing materials in school buildings, certain aspects of the regulation's procedures were extended in 1994 through the EPA's ASHARA (Asbestos School Hazard Amendments and Reauthorization Act).  The ASHARA regulation adopted the sections of the AHERA regulation covering the inspection and sampling of asbestos-containing materials.  The ASHARA regulation covers these activities in all government, commercial and industrial facilities.  Nova Environmental, Inc. followed applicable parts of sections 763.85, 763.86 and 763.87, which cover inspections, sampling and analysis for purposes of this inspection.  In addition, all applicable provisions of the ASHARA regulation were followed.

The OSHA regulation states that a building owner is required to identify all "Presumed Asbestos-Containing Material" ("PACM" - which is all thermal system insulation and sprayed-on or trowelled-on ceiling material constructed before 1980) in order to provide building employees, contractors and other parties, which may come in contact with the materials, information on asbestos-containing materials.

ASBESTOS INSPECTION TERMINOLOGY

For purposes of the Asbestos Inspection, Nova Environmental, Inc. completed all aspects of the inspection in accordance with EPA and OSHA regulations.  AHERA, ASHARA, the EPA's "Purple" and "Green" books and the OSHA regulation outline procedures for identifying, sampling, analyzing and assessing potential asbestos-containing materials. 

All work was completed by experienced inspectors properly trained in AHERA's Inspector courses and who maintain accreditations through the State of Michigan's Department of Labor and Economic Growth.  All material analysis ("bulk sample analysis") was conducted by an independent third party laboratory - The Electron Microscopy Service Laboratory of Michigan (EMSL of Michigan - Ann Arbor, Michigan).  EMSL is an accredited laboratory through the EPA's NVLAP program.

SAMPLING STRATEGIES

Nova Environmental, Inc. sampled all commonly sampled materials in accordance with AHERA (763.86 "Sampling").  For each homogeneous area identified, Nova Environmental, Inc. collected at least one sample of the material to determine if the material contained asbestos, unless identified as fiberglass, foam insulation by an accredited Asbestos Inspector.    

SAMPLING EXCEPTIONS

Nova utilized industry standards in determining samples collected. Destructive sampling, however was not conducted. While every effort has been made to identify all materials with in the facility, it is possible hidden (i.e. above a plaster ceiling, inside a wall) materials were missed. Should any material be encountered during maintenance/renovation activity that is not identified with in the inspection report, samples should be collected prior to disturbing the material. It should also be noted that these may be materials be identified with in the facility where sample(s) were analyzed less than 1%. While considered non-asbestos pursuant to applicable regulations, Nova Environmental, Inc. recommends that additional samples be collected and possibly more sophisticated analysis be utilized should the material be potentially impacted.

ASSUMED MATERIALS

Fire doors and frames require sampling techniques that are extremely destructive and leave very visible damage; thus, Nova Environmental, Inc. assumed all tagged fire rated doors and frames to be asbestos containing.  No roofing materials have been sampled yet and should be treated as asbestos containing.  Sampling can be attempted when a definitive scope of work is complete that includes direct impact of these materials.  .

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