Asbestos regulations, 296-62 Part I-1 WAC, are overseen by the Washington State Department of Labor and Industries. In coordination with Labor and Industries, the following guidelines have been developed for assistance while conducting clandestine drug lab decontamination projects.
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Clandestine drug lab (CDL) decontamination work plans shall include a section addressing the presence or absence of asbestos in the structures to be decontaminated or demolished.
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Building owners must make an assessment to determine if asbestos is present and may potentially be disturbed during decontamination or demolition. The building owner must provide an asbestos report to the contractor prior to any construction work. The report will typically be a Good Faith Survey, by a certified Asbestos Hazard Emergency Response Act (AHERA) building inspector.
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To assist in making a determination as to whether or not an AHERA inspection is required, a distinction needs to be made between construction and custodial projects. Construction projects include work where the building materials are removed or potentially damaged by the work. Custodial projects include work where building contents are removed and resilient surfaces are cleaned without being damaged.
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CDL decontamination construction projects require an AHERA inspection since it is reasonable to assume that asbestos will possibly by disturbed during construction activities. If the building owner has documentation, such as a previous survey or construction records, they may use these to prepare their report, but need to check that the documents are current. An AHERA inspection is not required if the building owner assumes that materials contain asbestos and have them handled as asbestos.
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CDL decontamination custodial projects typically do not require an AHERA inspection since it is reasonable to assume that asbestos would not be disturbed by custodial activities. However, if it were determined that custodial work may disturb the building material, it would then be considered a construction activity. An example of this is custodial activities on popcorn ceilings could disturb the building material. Also consider that the CDL contractor may encounter suspect asbestos-containing building material debris and require the building owner to survey the materials before proceeding with work. Providing a survey prior to work can prevent such delays.
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Demolition projects require an assessment, a Good Faith Survey, by a certified AHERA building inspector to determine if asbestos is present and will be disturbed during demolition.
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Asbestos-containing material that will be disturbed during decontamination or demotion requires abatement by a Certified Asbestos Contractor.
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Asbestos-containing materials that will not be disturbed during decontamination do not require remediation by a Certified Asbestos Contractor. A CDL contractor may perform the necessary decontamination work.
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It is generally recommended that asbestos cleanup be conducted after initial or final stages of CDL decontamination have been completed to minimize CDL related hazards in the asbestos work area. However, actual procedures and timing will be determined on a case-to-case basis.
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Asbestos work can generally be subcontracted to a Certified Asbestos Contractor who is not CDL certified when the following conditions can be met. The asbestos abatement contractors must:
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Be briefed on the CDL risks and hazards specific to the site to ensure worker safety and correct PPE selection. The CDL contractor may require additional PPE for the asbestos workers.
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Work only in those areas where asbestos abatement work is conducted.
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Only perform tasks specific to the asbestos abatement unless their workers are CDL certified.
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Take into account contaminants from the drug lab when disposing of asbestos materials.
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Building owners and CDL contractors must abide by Labor and Industries asbestos regulations. Refer to Chapter 296-62 WAC, Part I-1 and Chapter 296-65 WAC.
Learn more about asbestos.