Click the following link to view the PDF of this paper: Incidental Disturbances of Asbestos-Containing Material (ACM)

Andrew S. Amell
Senior Project Manager
Atlantic Testing Laboratories

An incidental disturbance of suspect or known asbestos-containing material (ACM) can unintentionally occur during renovation and/or demolition activities that are performed at construction sites. Historical incidental disturbances, resultant to natural deterioration of an ACM, can also exist at a project site and be discovered in a designated construction area prior to commencement of work activities. Whether an identified ACM could be disturbed during a project or has been historically disturbed, appropriate engineering controls must be implemented for abatement of the disturbed ACM. New York State’s regulations for management of building materials that contain identified or presumed ACM are specified in the New York State Department of Labor (NYSDOL) Industrial Code Rule 56 (Part 56 of Title 12 of the Official Compilation of Codes, Rules and Regulations of the State of New York, cited as 12 NYCRR Part 56). 12 NYCRR Part 56 requires identification of ACM whenever all or parts of a building or structure will be demolished, renovated, remodeled, or repaired.

Loose Fill Vermiculite from a Concrete Masonry Unit (CMU) Wall.

An incidental disturbance, as defined in 12 NYCRR Part 56, is the unintentional disturbance of ACM, presumed asbestos-containing material (PACM), or asbestos material. An incidental disturbance condition is characterized by ACM that is no longer intact and where loose asbestos-containing debris is present, regardless of the cause or source of disturbance. Protocols described in 12 NYCRR Part 56-11.2 (Emergency Projects) must be followed upon discovery of an incidental disturbance that is an imminent danger to the health and safety of the public or an asbestos related risk to the health and safety of the public from the release of airborne asbestos fibers. Access to the affected area of concern (AOC) must be restricted to prevent the public from entering and accessing the AOC, and an assessment must be conducted to determine the extent of the contamination. Additionally, the local NYSDOL Asbestos Control Bureau must be notified of the discovery and given the opportunity to request additional information of the occurrence and how it is going to be addressed.     An incidental disturbance assessment typically incorporates three primary components to document and determine the extent of the AOC. These components include a visual assessment, bulk sampling and analysis, and static air sampling and analysis. A visual assessment is always performed and, depending on the type and location of the disturbance, the bulk sampling and static air sampling may be subsequently performed. The visual assessment and bulk sampling must be conducted by a NYSDOL certified Asbestos Building Inspector, and the static air sampling must be conducted by a NYSDOL certified Air Sampling Technician. The process begins with the visual assessment to determine and delineate the discernible extent of the debris field within the AOC. Bulk samples of dust/debris can then be collected at different horizontal surface locations. These are often impacted floor surfaces where bulk debris samples will be collected in different directions, to confirm or further evaluate the extent of the AOC via analytical data. These bulk sample locations are typically positioned in cardinal directions outward (i.e., North, South, East, West) from the impacted areas. In some cases, bulk samples are collected at elevated surfaces to determine if the height of a required cleanup area can be limited. Bulk samples may also be collected at doorways/openings. This can achieve confinement of an AOC to a certain room or space that can be easily enclosed without the need for construction of temporary barriers. Finally, depending on the location and occupancy status of the building, static air samples may be collected within and/or adjacent to the AOC to evaluate the potential for airborne contamination.

Disturbance of Pipe Thermal System Insulation (TSI) within a crawlspace.


The data collected during an incidental disturbance assessment are used to determine the square footage of the AOC where presumed asbestos contamination will be addressed, in addition to any repair or removal required for the ACM that was the source of the contamination. Currently, 12 NYCRR Part 56-11.2 (Emergency Projects) provides corrective actions for the clean-up of an incidental disturbance of less than 10 square feet of the AOC. Incidental disturbances identified with an area of 10 square feet or greater must be addressed via a NYSDOL approved Site-Specific Variance (SSV) to detail the procedures of the clean-up. The NYSDOL SSV must be prepared and submitted by a NYSDOL certified Asbestos Project Designer. The square footage associated with the disturbance is the overall area affected with asbestos-containing debris and not only the amount of disturbed ACM prior to damage. For example, if 1 square foot of ACM becomes damaged with debris dispersed over a floor surface of 20 square feet, the AOC is identified as 20 square feet and subject to cleanup via a SSV.

ATL, a WBE certified company, has specialized seismographs and qualified personnel to perform vibration monitoring, as well as licensed Professional Engineers experienced in performing building condition surveys.

For more information, contact Andrew Amell at 315-699-5281, info@atlantictesting.com, or visit www.AtlanticTesting.com.

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