Asbestos NESHAP Clarification of Joint Compound Analysis and Other Multi-layered Materials.

The US Environmental Protection Agency (EPA), recently issued a clarification to the final rule National Emissions Standard for Asbestos (NESHAP) Standard, 40 CFR 61, regarding analysis of multi-layered systems (Federal Register/Vol. 59/Wednesday, January 5, 1994). The portion of the clarification pertaining to joint compound/wallboard is stated as follows:

"When joint compound, and/or tape is applied to wallboard it becomes an integral part of the wallboard and in effect becomes one material forming a wall system. Therefore, where a demolition or renovation impacts such a wall system, a composite analysis of the wall system (percent of asbestos in the joint compound, tape and wallboard) should be conducted. If the analysis shows an asbestos content of greater than one percent and at least 160 square feet of the wall system is involved in the demolition or renovation activities (whether planned or unplanned, during a calendar year), then the activities should be subject to the asbestos NESHAP."

The intent of the clarification is for guidance and does not replace the existing asbestos NESHAP. The clarification discusses other multi-layered materials, as well. These materials include plaster/ stucco systems and add-on materials (e.g. sprayed-on materials, paint, ceiling or wall texture, etc.). When these materials contain two or more distinct layers or materials, each layer should be treated separately and the results reported by layer (discrete stratum). a copy of the clarification is attached to this fact sheet. The recommended sampling scheme for friable surfacing material is found in the EPA document, "Asbestos in Buildings: Simplified Sampling Scheme for Friable Surfacing Materials," also known as the "Pink Book". For further information contact Mr. Chris Oh at (703) 308-8732, or Mr. Jeffrey Ken Knight at (703) 308-8728.