To facilitate LSPs, PRPs and interested parties in understanding and responding to the practice changes and obligations associated with the regulation of asbestos and asbestos containing debris in soil under the Massachusetts Contingency Plan, the LSPA Loss Prevention and New Practices Committees have assembled relevant and useful information here.
The LSPA has provided and will continue to provide information to the LSPA membership regarding the regulation of asbestos in soil under the MCP. Available presentations and communications can be found here. This area of the website will be updated as new communications are made.
April 2004 LSPA Membership Meeting Presentation - LSPA Response to the Regulation of Asbestos in Soil Under the MCP by Wesley Stimpson
June
2004 LSPA News - New Practice Area for LSP Contained in the Wave
Two Changes by Wesley E. Stimpson
July/August
2005 LSPA News - Managing Asbestos In Soil Under The
MCP by Robert C. Atwood
January 2005 LSPA Membership Meeting Presentation - Managing Asbestos in Soil Under The MCP – New LSP Practices Coming in 2005 by Robert Atwood
October
2005 LSPA News - Evaluating Risk from Asbestos
in Soil Under the MCP by Lisa Bailey
February
2006 LSPA News - Pending Changes to the MCP - Dealing With Asbestos
In Soil by Robert Atwood
June 2007 LSPA Membership Meeting Presentation - Managing Asbestos in Soil. Under the MCP by Robert Atwood, William Swanson and Paul Locke
The most current version of the AIS regulation change package, which includes changes to the MCP, Bureau of Waste Prevention Regulations and Solid Waste Regulations, can be found here:
Public Comment Draft
LSPA Comments on Draft AIS Regulations dated May 31, 2007
Various analytical methods are available to determine the presence and nature of asbestos containing debris and fibers in soil. Unlike other OHM regulated under the MCP there is no one test method available to determine notification obligations, nature and extent and evaluate risk and clean up goals. The more commonly used methods can be found here.
MassDEP Summary
of Methods (excluding MassDEP sieve)
MassDEP Draft Sieve Method
EPA Region I Protocol
PLM
Berman Elutriator
The LSPA has been in contact with the Massachusetts Department of Occupational Safety (DOS) and OSHA. Information provided to them concerning the obligation that an LSP firms may face when AIS is regulated under the MCP can be found here:
LSPA Letter to DOS dated February 21, 2006
DOS Letter to LSPA dated July 17, 2006
LSPA Letter to DOS dated February 17,
2007
OSHA Meeting Memo dated December 29, 2006
While no state is proposing to regulate asbestos in soil in the same manner as Massachusetts, the following states do have policies and procedures that they expect to be followed if asbestos and asbestos debris is encountered during construction or at a know waste disposal area: