HRA_EH_Asbestos_FY22_IPD Saint Louis_102622.pdf

Commanding Officer United States Coast Guard Health, Safety and Work-life Service Center

1222 Spruce Street St. Louis, MO 63103 Staff Symbol: (se-fo) Phone: (314) 269-2467 Email: richard.c.dillahunt@uscg.mil

26 Oct 2022

MEMORANDUM

From: RICHARD C. DILLAHUNT, LT

OL-HSWL SC FIELD OPS-ST LOUIS

To: IPD SAINT LOUIS

Subj: ASBESTOS HEALTH RISK ASSESSMENT

Ref: (a) Safety and Environmental Health Manual, COMDTINST M5100.47 (series)

1. On 27 July 2022, members of the Health, Safety, and Work-Life Service Center, Safety and Environmental Health Division, Detached Saint Louis (OL-HSWL SC FIELD OPS-ST LOUIS) visited the Matthew E. Schlimme Coast Guard Industrial Facility (Bldg. 17) to collect bulk material samples of primary passageway floor tiles. The purpose of this assessment was to analyze floor tiles and mastic for asbestos content to determine if Coast Guard members may perform renovation. The assessment included the collection of bulk samples for laboratory analysis for asbestos.

2. Asbestos was detected in 12” x 12” white floor tile with multicolored dots and black mastic collected in the vestibule. March 2009 health risk assessment also revealed floor tile and black mastic in Bldg. 17 hallway tested positive for asbestos. There is no record of abatement following 2009 discovery. Due to no record of abatement, it is likely that asbestos is present in similar flooring on the first floor of Bldg. 17. Coast Guard members may not perform renovation of asbestos containing flooring and mastic material. To ensure the protection of Coast Guard members, this office recommends a Missouri licensed asbestos contracting service to determine the appropriate mitigation measures.

3. Occupational assessments for crew protection purposes should not be used for contractors, as it presents a legal liability. Failure for contracting officers to follow Federal Regulations for Appropriation is tantamount to negligence. Please incorporate this report into your Asbestos Management Plan.

4. We respectfully request your feedback by completing our Customer Satisfaction Survey at the following link: https://surveys.uscg.mil/Community/se.ashx?s=6F20F77431A8C415.

Enclosure: IPD ST LOUIS Health Risk Assessment Report

Copy: BASE DETACHMENT ST LOUIS CG HSWL SC (se) mailto:richard.c.dillahunt@uscg.mil https://surveys.uscg.mil/Community/se.ashx?s=6F20F77431A8C415 https://surveys.uscg.mil/Community/se.ashx?s=6F20F77431A8C415 https://surveys.uscg.mil/Community/se.ashx?s=6F20F77431A8C415 https://surveys.uscg.mil/Community/se.ashx?s=6F20F77431A8C415 https://surveys.uscg.mil/Community/se.ashx?s=6F20F77431A8C415 https://surveys.uscg.mil/Community/se.ashx?s=6F20F77431A8C415 https://surveys.uscg.mil/Community/se.ashx?s=6F20F77431A8C415 https://surveys.uscg.mil/Community/se.ashx?s=6F20F77431A8C415 https://surveys.uscg.mil/Community/se.ashx?s=6F20F77431A8C415 https://surveys.uscg.mil/Community/se.ashx?s=6F20F77431A8C415

Health, Safety, and Work-life Service Center Safety & Environmental Health Division

IPD ST. LOUIS ASBESTOS

Health Risk Assessment Report

Introduction On 27 July 2022, LT Richard Dillahunt and HSC Harold Thomas from the Health, Safety, and Work-Life Service Center, Safety and Environmental Health Division, Detached Saint Louis (OL-HSWL SC FIELD OPS-ST LOUIS) visited Industrial Production Detachment (IPD) Saint Louis to collect bulk material samples of primary passageway floor tiles. The facilities manager intends to have passageway flooring replaced. The purpose of this assessment was to analyze floor tiles and mastic for asbestos content to determine if Coast Guard (CG) members may perform renovation. The assessment included the collection of floor tile bulk samples to identify the presence/absence of asbestos containing material

(ACM).

References (a) Coast Guard Safety and Environmental Health Manual, COMDTINST M5100.47

(series)

(b) Asbestos Management Tactics, Techniques and Procedures, FORCECOM CGTTP 4-

11.1 (series)

Background The Matthew E. Schlimme Coast Guard Industrial Facility (Bldg. 17) was constructed in

1997. The primary function of this facility is production of Aids to Navigation day boards.

Additionally, the building houses offices for the MAT Team and ESD. All personnel assigned to the units within this facility often transit through the building hallways to conduct official business. The facility is typically occupied 8 hours daily excluding weekends.

Base Detachment Saint Louis plans to perform maintenance and replace the flooring in the main passageway. CG personnel do not maintain the training and certifications required to perform work that disturbs asbestos containing material (ACM). HSWL does not conduct health risk assessments for contract work.

Appendices A. Sample Results

B. Sampling Diagram C. Asbestos ID Analytical Report and Chain of Custody Sheets D. Bulk Asbestos Sampling Protocol E. Hazardous Conditions Notification Report

Methods & Evaluation Criteria

Staff collected 6 bulk asbestos samples from the locations listed in Appendix A.

Bulk samples of floor tile and mastic were collected in random locations representative of the homogenous area of the primary passageway per 40 CFR part 763.86. The material sampled included 12” x 12” white floor tile with multicolored dots and black mastic material underneath the tile.

Staff submitted all samples to the Navy Environmental and Preventative Medicine Unit Two laboratory (an American Industrial Hygiene Association accredited laboratory) for analysis.

Previous Reports May 2021: An assessment conducted by a third party licensed asbestos inspector tested one sample of floor tile and black mastic material. Analysis indicated no ACM above detectable limits.

August 2017: An assessment conducted by a third party licensed asbestos inspector tested six samples of floor tile and black mastic material. Analysis indicated no ACM above detectable limits.

March 2009: A health risk assessment conducted by CG MLCLANT (kse) SEH DET tested floor tile containing black mastic in Matthew E. Schlimme Coast Guard Industrial Facility hallway. Analysis indicated 5-10% chrysotile asbestos in the black mastic.

Results ACM is defined as any material containing greater than 1% asbestos by weight. A floor tile sample collected in the vestibule reported as being composed of 1% chrysotile asbestos.

Five floor tile samples reported as “None Detected” by the analytical laboratory.

Lab analysis report is in Appendix C. Bulk sample locations are in Appendix B.

Discussion Asbestos is a commercial name, not a mineralogical definition, given to a variety of six naturally occurring fibrous minerals. Commercially manufactured asbestos has many different colors and textures. Visual identification is impossible with the naked eye.

Asbestos is a confirmed human carcinogen. If asbestos is friable and subject to damage or disturbance, microscopic-size asbestos fibers can be inhaled or ingested. If asbestos is non-friable, fibers are generally not considered a health risk since the fibers are normally bound or contained in the building material itself. Breathing asbestos fibers can damage lungs and increase the risk for three chronic diseases: asbestosis, lung cancer, and mesothelioma.

Onset of illnesses occur after latency period of 10 to 50 years following initial exposure to airborne asbestos fibers. The risk of developing one of these illnesses correlates to the duration and extent of a person’s exposure to asbestos fibers.

Asbestos was detected in 12” x 12” white floor tile with multicolored dots and black mastic sample (i.e., IPD-02) collected in the Bldg. 17 vestibule. March 2009 record also indicates asbestos detected in floor tile and black mastic sample collected in Bldg. 17 hallway. There is no record of abatement following 2009 discovery. Due to no record of abatement, it is likely that asbestos is present in homogenous (i.e., similar flooring) areas on the first floor of Bldg. 17. Homogenous areas are uniform by color, texture, construction/application date, and general appearance. Description and location of floor tile and mastic sample collected in Bldg. 17 hallway in 2009 is homogenous to sample IPD-02 collected by team during 2022 assessment.

Floor tile and mastic are non-friable ACM. Non-friable means, that when material is dry, it cannot be crumbled, pulverized, or reduced to powder by hand pressure. Floor tile and mastic maintained in good condition (i.e., no visible damage or deterioration, or showing only very limited damage or deterioration) do not present a health risk.

Reference (a) prohibits Coast Guard personnel from removing, repairing, or disposing of ACM unless authorized by HSWL SC (se) and trained per federal, state, and local laws.

Areas identified as ACM should be included in your unit’s Asbestos Management Plan (AMP) inventory and require annual visual inspections.

Reference (b) provides a program template for AMP development. Per 29 CFR 1910. 1001 (j)(7)(iv) employers are required to provide an annual asbestos awareness training course for employees who perform housekeeping operations in areas where an ACM or presumed asbestos-containing material (PACM) is present.

Recommendations

1. Update unit asbestos inventory with the findings from this assessment.

2. Provide notification of sampling results and annual asbestos awareness training to

Bldg. 17 personnel who perform housekeeping operations in areas where ACM is present on the following topics:

a) Health effects and hazards of asbestos;

b) Locations, signs of damage and deterioration of ACM and PACM;

c) Proper response to asbestos fiber release episodes; and

d) Housekeeping standards.

3. Inquire with licensed and certified asbestos contractor to discuss abatement options (i.e., removal, enclosure, encapsulation).

4. Implement operations and maintenance plans to include routine inspections, monitoring procedures, and control measures to ensure ACM is not disturbed and maintained in good condition.

5. Document corrective actions for all findings in Appendix E, in the Hazardous Conditions Management System (HCMS).

Limitations The findings and potential health risks identified in this report are only representative of conditions at the time of assessment. Occupational assessments for crew protection purposes should not be used by contractors, as it presents a legal liability. Failure for contracting officers to follow the Federal Regulations for Appropriation is tantamount to negligence.

APPENDIX A: Sample Results

Sample Location Results IPD-01 Hallway Floor at North Exit Door ND1 IPD-02 Vestibule Floor 1% Chrysotile Asbestos IPD-03 Hallway Floor at Conference Room/ Chief’s Mess Door ND IPD-04 Hallway Floor at Locker Room Entrance ND IPD-05 Hallway Floor at East Exit Door ND IPD-06 Hallway Floor near Ice Machine at Head entrance ND

1. Below detectable limits (ND)

APPENDIX B: Sampling Diagram

No ACM Detected

ACM Detected

Appendix C. Asbestos ID Analytical Report and Chain of Custody Sheets

C-2

C-3

C-4

C-5

Appendix D: Bulk Asbestos Sampling Protocol

Scope This protocol provides guidance for collecting bulk samples of suspect asbestos-containing material (ACM) from CG-owned and/or operated facilities/vessels. This protocol cannot be used to collect suspect ACM bulk samples from housing, child development centers, or any non-CG owned or operated facilities, which must follow guidance in references (a) and (b). The collection of bulk ACM samples will be performed only by an accredited inspector or a Certified Industrial Hygienist (CIH) in accordance with reference (c).

References

a) COMDTINST 6260.1A - Asbestos, Lead and Radon in Coast Guard Housing

b) COMDTINST 6260.16A – Asbestos Exposure Control Manual

c) 29 CFR 1910.1001– OSHA Toxic and Hazardous Substances : Asbestos

d) 40 CFR 763 – AHERA Asbestos Containing Materials in Schools

Equipment The following equipment and supplies will be needed to collect bulk ACM samples:

• Scraper, chisel, utility knife & hammer

• Tape measure & duct tape

• Flashlight

• Camera

• TSI core sample collection device

• Sample site repair (caulk, cement patch)

• Spray bottle & amended water

• Asbestos bulk sampling forms

• Disposable wipes for tool cleaning

• Re-sealable plastic bags for samples

• Indelible marker

• Laboratory chain-of-custody forms

• Disposable plastic sheeting

• Plastic trash bags

PPE Respiratory Protection A NIOSH-approved half-mask air-purifying respirator (APR) equipped with N/R/P100-rated high-efficiency particulate air (HEPA) filtering cartridges will be worn. HEPA cartridges shall be changed as needed and properly disposed. Respirators shall be cleaned and stored properly after each use.

Protective Clothing When indicated, protect bare skin and eliminate surfaces/fabrics that will collect asbestos fibers and dust by donning disposable coveralls such as: Tyvek® disposable coveralls with hood, elastic wrists, and boot covers or smooth rubber boots. Seal coveralls at the wrists, ankles, and neck. Wear disposable gloves.

Head Protection Wear protective headgear in areas with low clearance to protect personnel from head bumps and lacerations (i.e. bump cap).

Eye Protection Wear eye protection (e.g. glasses, goggles), preferably non-fogging, that meets ANSI Z87.1 standard. This ANSI approval is indicated (i.e. stamped) on the eye protection.

Hearing Protection Appropriate levels of hearing protection (single and double) shall be used, as needed.

Ver.1.13

Method Bulk samples will be collected from suspect ACM in accordance with references (c) and (d).

NOTE: The inspector must be sure to remove and separate all layers of suspect ACM when multiple layers are identified, placed in separate sample bags, sealed, assigned unique sample identification numbers. For example, samples layers such as floor tile and mastic must be divided into separate samples.

All samples will be submitted to an independent laboratory accredited by the National Voluntary Laboratory Approval Program (NVLAP), and analyzed using EPA Method 600/R-93/116 by Polarized Light Microscopy (PLM) and Transmission Electron Microscopy (TEM) for non-friable, non-organically-bound (NOB) samples.

Evaluation Criteria

Any material containing more than one percent (>1%) asbestos as determined using the methods specified in AHERA 40 CFR Part 763, Section 1, Subpart F, Appendix A. The percentage of asbestos in a material can only be determined by laboratory analysis. A homogenous area will be categorically classified as ACM when bulk samples reveal more than one percent (>1%) asbestos by laboratory analysis.

Friability Friable ACM is defined as any material containing more than one percent (>1%) asbestos, which when dry, can be crumbled, pulverized or reduced to powder by hand pressure (i.e., spray-on insulation, TSI). However, friability is dependent on several factors and can vary somewhat even within a single homogenous area. Therefore, a test for friability should be conducted in one-third of the sampling locations per homogenous area.

Non-friable ACM is defined as asbestos-containing (>1%) products such as packing, caulks, gaskets, resilient floor covering vinyl asbestos tile (VAT), asphalt products, Transite board/pipe and siding material that cannot be crumbled, pulverized, or reduced to powder by hand pressure.

ASTM E 2356-04 defines NOB materials as “materials that are not friable and that consist of fibers and other particulate matter embedded in a solid matrix of asphaltic, vinyl or other organic substances.”

Sampling Strategy

The sampling strategy will primarily be dictated by the circumstances that prompted the assessment. However, all bulk ACM sampling evolutions must start with an administrative review of historical documentation including: unit asbestos management plan, previous sampling/assessment reports, and SFLC/CEU project documents to identify previous ACM findings, locations, and abatement projects. The administrative review must be completed prior to bulk sampling visit and will serve as a primary guide in developing the sampling strategy.

Sampling will be accomplished using homogenous areas as described below and bulk samples will be collected as directed in the category-specific sampling procedures that follow.

Homogenous Areas A homogeneous area is defined as an area of ACM surfacing material, thermal system insulation material, or miscellaneous material that is uniform in color and texture.

Homogeneous areas can be very small or extremely large depending upon the type and location of suspect ACM. During our assessments, we will define homogenous areas and use them as the basis for our condition assessments and bulk sample collection. Teams will define the homogenous areas (i.e. vermiculite coating) during their initial evaluations and indicate the locations of each on diagrams.

D-2

Bulk Sampling Procedures for Suspect ACM Scope The following sampling procedures are divided into three sections based on the type of suspect

ACM to be sampled including:

• Surfacing Material

• Thermal System Insulation (TSI)

• Miscellaneous Materials

Surfacing Materials

Introduction Materials that are trowel-on, applied-on, or sprayed-on surfaces (e.g., stucco, plaster, acoustical ceiling, vermiculite coatings, structural fireproofing, etc.). All bulk samples should be approximately one (1) square inch (in2) or one (1) cubic inch (in3) depending on the type of material to obtain the necessary sample weight for laboratory analysis. The 3-5-7 rule table below will be used to determine the appropriate number of samples to collect. Samples will be collected in a statistically random manner that is representative of the homogeneous area.

Number of Samples

Bulk Samples Collection for Surfacing Materials Homogenous Area Size # samples

< 1,000 ft2 3 1,000 to 5,000 ft2 5

> 5,000 ft2 7

Sampling Procedures

Step Action 1 Don all required PPE 2 Gather sampling tools and place in sampling kit/toolbox.

3 Secure the space/compartment from entry of unprotected personnel

4 Identify the bulk ACM sampling site following a statistically random manner that is representative of the homogeneous area.

5 Place clean plastic sheeting under the area to be sampled to protect floor/deck and collect sample if dropped. NOTE: Use new plastic sheeting between samples

6 Utilize the spray bottle to adequately wet the sample area using amended water.

Cut or scrape the approximate (1) square inch (in2) or one (1) cubic inch (in3) area directly off the substrate using sampling tools, being careful to not collect any substrate material. Be sure to remove and separate all layers of suspect ACM, if several layers are identified (i.e. several layers of floor tile/mastic or two layers of plaster (brown and white), etc.).

8 Collect and carefully place sample into the sample bag.

Seal the sample bag, label with a unique sample number, record on appropriate forms and chain-of-custody (COC). Also indicate quantity, condition and homogeneous areas on forms and COC.

Clean up all settled dust generated using wet wipes and clean cutting tools with a new disposable wipe. Dispose of gloves, plastic collection sheet and wipes after each sample is collected.

11 Repair of Sampling Site?

12 Repeat steps for each sample.

D-3

Thermal System Insulation (TSI)

Introduction Thermal System Insulation (TSI) materials are described as materials applied to pipes, fittings, boilers, breeching, tanks, ducts, or other structural components to prevent heat loss or gain, or water condensation, or for other purposes (i.e., pipe insulation, elbow/fitting mud, block insulation, air duct wrap/insulation, etc.). Do not collect samples from any homogeneous area where the inspector determines that the TSI is fiberglass, foam glass, rubber, or other non- ACM. The table below will be used to determine the appropriate number of samples to collect.

Samples shall be collected in a randomly distributed manner.

Number of Samples

Bulk Sample Collection for TSI Materials Homogenous Area # samples

TSI in General 3

Less than six (6) linear or square feet of patched TSI 1

Elbows, fittings & cementitious material

Sufficient number to determine whether the material is ACM

Sampling Procedures

Step Action 1 Don all required PPE

2 Gather sampling tools and place in sampling kit/toolbox.

3 Secure the space/compartment from entry of unprotected personnel

4 Identify the bulk ACM sampling site following a statistically random manner that is representative of the homogeneous area.

5 Place clean plastic sheeting under the area to be sampled to protect floor/deck and collect sample if dropped. NOTE: Use new plastic sheeting between samples

6 Utilize the spray bottle to adequately wet the sample area using amended water.

7 Using the core sampling tool and a new core sampling tube, press the core sampler directly down to the substrate, twist and pull the core sample out and invert the sample being careful to not lose any sample

8 Carefully place the core sampler into the original plastic sleeve, seal the end of the sleeve with the included plug and place in a separate sample bag (double-bag).

9 Seal the sample bag, label with a unique sample number, record on appropriate forms and chain-of-custody (COC). Also indicate quantity, condition and homogeneous areas on forms and COC.

10 Clean up all settled dust generated using wet wipes and clean cutting tools with a new disposable wipe. Dispose of gloves, plastic collection sheet and wipes after each sample is collected.

11 Repair of Sampling Site?

D-4

Miscellaneous Materials

Introduction Miscellaneous materials are described as materials that are not surfacing or TSI but applied to structural components (i.e., flooring, roofing, ceiling tiles, transite panels, drywall, taping/joint compound, mastic, exterior siding, etc.). Samples shall be collected in a randomly distributed manner.

Number of Samples Bulk Sample Collection for Miscellaneous Materials

Homogenous Area # samples

Miscellaneous Materials At least one sample (Recommend 3 samples)

Sampling Procedures

Step Action 1 Don all required PPE

2 Gather sampling tools and place in sampling kit/toolbox.

3 Secure the space/compartment from entry of unprotected personnel

4 Identify the bulk ACM sampling site following a statistically random manner that is representative of the homogeneous area.

5 Place clean plastic sheeting under the area to be sampled to protect floor/deck and collect sample if dropped. NOTE: Use new plastic sheeting between samples

6 Utilize the spray bottle to adequately wet the sample area using amended water.

7 Cut or scrape the approximate (1) square inch (in2) or one (1) cubic inch (in3) area directly off the substrate using sampling tools. Be sure to remove and separate all layers of suspect ACM, if several layers are identified (i.e. several layers of floor tile/mastic).

8 Carefully place the core sampler into the original plastic sleeve, seal the end of the sleeve with the included plug and place in a separate sample bag (double-bag).

9 Seal the sample bag, label with a unique sample number, record on appropriate forms and chain-of-custody (COC). Also indicate quantity, condition and homogeneous areas on forms and COC.

10 Clean up all settled dust generated using wet wipes and clean cutting tools with a new disposable wipe. Dispose of gloves, plastic collection sheet and wipes after each sample is collected.

11 Repair of Sampling Site?

D-5

HCN ID: 1 RAC: 3

Reference: 29 CFR 1910.1001(j)(3)(i)

Location: ADMIN

Monitoring Item: INSPECTION AND INVENTORY. Unit adequately identified the presence, location, and quantity of all known or suspected asbestos-containing materials (ACM). Documentation reflecting aforementioned is maintained and current.

NOTE: An accredited inspector must conduct asbestos inspections in most structures. In many states, the inspector must have a state license.

Finding(s): Asbestos containing flooring (i.e, floor tile and mastic) on first floor hallways/passageways of Matthew E. Schlimme Coast Guard Industrial Facility.

Corrective Actions: Update unit asbestos inventory to include 12"x12" white w/multicolor dot floor tiles and black mastic installed on first floor hallways/passageways of Matthew E. Schlimme Coast Guard Industrial Facility.

Checklist #: ASB-02

Date Completed: _________________________

Third Party Monitored

HCN ID: 2 RAC: 3

Reference: Safety and Environmental Health Manual, COMDTINST M5100.47(series), Ch 12.C.5.j

Location: ADMIN

Monitoring Item: TRAINING. Unit provides initial asbestos awareness training to inform personnel (including housekeeping) of all asbestos-containing materials in their respective work areas. Annual refresher training is provided appropriate to their work assignments.

Training material is available for review and records are maintained in TMT for at least one year past employee's employment.

NOTE: Refer to Asbestos Management TTP, CGTTP 4-11.1(series) for guidance on awareness training.

Finding(s): No TMT record of asbestos awareness training for unit personnel.

Corrective Actions: Provide notification and annual asbestos awareness training to personnel who perform housekeeping operations in areas where asbestos containing material (ACM) is present on the following topics:

- Health effects and hazards of asbestos;

- Locations, signs of damage and deterioration of ACM and presumed ACM;

- Proper response to asbestos fiber release episodes; and

- Housekeeping standards.

Checklist #: ASB-03

Date Completed: _________________________

Third Party Monitored

Appendix E:Hazardous Condition Management System Discrepancies (All)

IPD ST LOUIS (31-52065)Unit Name: Visit Date: 8/25/2022

HCN ID: 3 RAC: 3

Reference: Safety and Environmental Health Manual, COMDTINST M5100.47(series), Ch 12.B.8 and 12.C.6.a

Location: Bldg. 17

Monitoring Item: PERIODIC SURVEILLANCE. Unit visually inspects all workspaces known to contain ACM for damaged and/or friable material, and report damaged suspect or confirmed immediately.

NOTE 1: Refer to the Asbestos Management TTP, CGTTP 4-11.1(series) for guidance on visual inspections. There are no federally specified qualifications for conducting periodic surveillance.

Finding(s): Asbestos containing flooring (i.e., floor tile and mastic) on first floor hallways/passageways of Matthew E. Schlimme Coast Guard Industrial Facility.

Corrective Actions: Implement operations and maintenance plans to include routine inspections, monitoring procedures, and control measures to ensure ACM is not disturbed and maintained in good condition.

Checklist #: ASB-06

Date Completed: _________________________

Unit Monitored

Hazardous Condition Management System Discrepancies (All)

IPD ST LOUIS (31-52065)Unit Name: Visit Date: 8/25/2022

E-2