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Head Tight Schedule for Province-Wide Asbestos Inventory

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					Head: Tight Schedule for Province-Wide Asbestos Inventory
Intensified Scrutiny of Non-Friable Materials Brings New Costs

By Barbara Carss

Workers in full HAZMAT gear turned a recent energy retrofit into a delicate
communications exercise for property managers with Peel Region’s non-profit housing
corporation, Peel Living. The $1.2-million project to convert an electrically heated, 140-
unit seniors’ housing complex to central natural gas heating began just after Ontario’s
new asbestos Regulation under the Occupational Health & Safety Act came into effect in
November 2005. This compelled more stringent than anticipated controls for the work,
which involved drilling through flooring and ceilings that contain asbestos.
    “It stalled our project and it created all kinds of confusion. It increased costs. There
were delays. There was a lot of communication required to address the residents’
concerns and concerns from their family members,” recounts Glen O’Brecht, director of
property management, Peel Region. “Asbestos is a loaded word. No matter how well you
explain it, not everyone gets it. It’s a very emotional term.”
    The new Regulation will drive up costs for diligence, maintenance,
retrofits/renovations and demolition in many situations.
    The previous version of the Regulation, which dated back to the 1980s, focused
primarily on what are known as friable forms of asbestos that can become airborne and
inhaled, whereas the new Regulation mandates greater scrutiny and precautions for so-
called non-friable products in which asbestos fibres are embedded and immobile. This
encompasses items and materials that can be found in almost any building constructed
before 1990, including vinyl asbestos floor tiles, flooring glue, ceiling stipple, drywall
joint filling compound, roofing membranes and transite cement. Indeed, transite cement
products such as piping used as rainwater leaders have never been banned and are still
being installed today.
    Most conditions of O. Reg 278/05 came into effect in November 2005, but it gave
owners of commercial, industrial, institutional and multi-residential buildings with four
or more units a two-year window to complete a compulsory survey and management plan
for all building materials that contain asbestos. As the Nov. 1, 2007 deadline for
completing these surveys and plans draws nearer, industry specialists report that
compliance levels are still low – in part because of a limited pool of professionals to carry
out the work, and in part due to ignorance.
    “In practice, you can imagine the impossibility of surveying every single building in
Ontario in a two-year period,” says Don Pinchin, president, Pinchin Environmental Inc.,
one of the most active consulting firms in the field. “There’s also the fact that many
building owners are totally unaware of this.”

PRACTICAL CHALLENGES
The experts emphasize that the previous asbestos Regulation did need to be updated. It
was out of sync with Ontario’s occupational exposure limit (OEL) for asbestos, which, in
2000, had been reduced below the level stated in the Regulation. Nor did it recognize
new technologies and procedures for asbestos abatement and management that had been
developed in the 20-year interim since the Regulation was introduced.
    Yet, many of the same experts maintain that some of the new stipulations are
overzealous. In particular, they question why certain non-friable products have now been
designated for “Type 2” removal procedures that are more complex and costly than the
handling practices that were formerly allowed. Pinchin argues, for example, that vinyl
asbestos floor tiles break cleanly and abatement can be carried out effectively with the
less onerous “Type 1” precautions, while drywall joint filling compound contains such
trace amounts of asbestos as to pose negligible risk.
    “Drywall joint filling compound is going to be a nightmare,” observes Corrado
Maltese, senior manager, Occupational Health & Safety, with the Toronto Catholic
District School Board (TCDSB). “The joint filling compound is something that wasn’t
really a concern previously. Now, if we need to nail something in the wall – even
something as simple as that – we need to know if we’re going to be disturbing asbestos.”
    Since sections of drywall are often replaced during building renovations, walls can
become a patchwork of drywall vintages that make it difficult to gauge where joint filling
compound containing asbestos – which was formally banned in 1986 – might be. This is
one of the reasons the cost of asbestos management surveys is rising. “The level of effort
to distinguish what is and isn’t asbestos drywall has significantly increased,” says Jason
McGonigle, health and safety group manager with the environmental consulting firm,
Golder Associates.
    Previously, even if building owners voluntarily opted to identify the non-friable
sources of asbestos on the premises, they typically relied on an environmental
consultant’s professional judgement to deduce its location. Although the former
Regulation did require scientific sampling for friable asbestos, the new Regulation is
more comprehensive. “It really has tripled the number of samples we’re taking,” Pinchin
says.

NOTIFICATION RESPONSIBILITY
Nov. 1, 2007 is also the deadline for notifying occupiers of a building of the presence of
asbestos on the premises. Building owners must notify residents and/or commercial
tenants in writing, and, in turn, these occupiers must inform employees, contractors
and/or visitors who could potentially encounter and disturb asbestos.
     In the commercial and institutional sectors, information about asbestos is now
typically made available through joint health and safety councils and other associated
policies. At the TCDSB, for example, everyone who works on one of the Board’s
properties is required to read the posted notifications of where asbestos exists, then sign a
form to confirm that he or she is aware of the asbestos and will handle it only in
accordance with regulated procedures. “Every time a contractor comes into one of our
buildings this is required,” Maltese explains.
     Since 1990, the asbestos survey for each school property is made available to the
public in the school’s main office, but Board officials still haven’t determined if they will
have to send written notification to students and their parents/guardians in order to
comply with the new Regulation. “We feel that the students are not going to be disturbing
it [asbestos]. They’re not authorized to hang art and they don’t have access to boiler
rooms or other spaces where asbestos can be found,” Maltese says.
COST REPERCUSSIONS
More stringent controls for handling non-friable materials are already increasing
renovation/retrofit and demolition costs. The new Regulation also introduces training
requirements for workers and supervisors on “Type 3” abatement jobs, involving friable
materials, which could affect project budgets.
    As of November 2007, workers will have to prove that they have successfully
completed a 16-hour classroom course (or recognized equivalent) and exam, and
employers will be responsible for ensuring workers have the necessary training.
Consultants foresee employee retention challenges that could create delays and/or work
stoppages.
    “Most owners can’t even conceive of the amount of turnover they are going to have
[on their jobsites] because the work is very unpleasant,” Pinchin advises. “I think it is
likely going to push up the wage rates that these jobs are paid.”
    Increased abatement costs could cause particular upheaval in the health care sector as
hospitals across Ontario are in the midst of multi-year capital programs for which budgets
were allocated prior to the new Regulation coming into effect. Construction workers
frequently uncover unexpected surprises within sprawling buildings that have typically
been added to over the course of several decades and eras of engineering and construction
practices.
    “We have no less than seven different wings here – the original one being built in
1925, and it’s still functional,” notes J.J. Knott, director of plant operations at the Norfolk
General Hospital and a member of the board of directors of the Canadian Healthcare
Engineering Society (CHES). Many of the hospital expansion projects also involve the
demolition of older structures to make way for new facilities.
    “We set aside large chunks of money to take care of abatement, specifically asbestos,
but those pockets are suddenly going to need to be deeper,” Knott says. “I hope that the
Ministry [of Public Infrastructure Renewal] is sympathetic when it looks at those
numbers.”
    Budgeters may also start re-crunching the numbers for energy retrofits and other
upgrades. In Peel Region, O’Brecht calculates that the long-term savings from energy
management improvements in the aging non-profit housing stock should still
significantly outweigh the extra costs for Type 2 asbestos removal, but the new
requirements will complicate future projects.
    In the recent retrofit at the seniors’ apartment tower, workers had to drill through
asbestos vinyl floor tiles and asbestos ceiling stipple to make way for the piping and fan
coils that were to replace electric baseboard heaters. Residents spent time in the
building’s recreation lounge while construction occurred in their units.
    “We are in the midst of big capital renovation work. We have about 13 buildings that
operate on electric baseboards,” O’Brecht notes. “It [the Regulation] will increase the
project costs; it will add additional steps to the work; and, certainly, there is a resident
impact. If the payback was less, but we triggered the highest level of hazardous material
handling requirements, I think we would have to reassess the costs and benefits.”

				
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