CDS Regulatory Compliance & Environmental Impact 3 — Questions and Answers
Question 1: During selective demolition, crews find friable asbestos pipe insulation in a non-residential building. Under OSHA 29 CFR 1926.1101, workers performing this removal must be classified as performing which class of asbestos work?
- Class I (Correct answer)
- Class II
- Class III
- Class IV
Correct answer: Class I
Class I asbestos work involves the removal of thermal system insulation (TSI) and surfacing ACM, which carries the highest exposure risk under OSHA regulations.
Question 2: What is the OSHA permissible exposure limit (PEL) for asbestos fibers averaged over an 8-hour time-weighted average (TWA)?
- 0.1 fiber per cubic centimeter of air (Correct answer)
- 1.0 fiber per cubic centimeter of air
- 0.5 fiber per cubic centimeter of air
- 2.0 fibers per cubic centimeter of air
Correct answer: 0.1 fiber per cubic centimeter of air
OSHA's PEL for asbestos is 0.1 fiber per cubic centimeter of air as an 8-hour TWA for construction workers.
Question 3: Which document must accompany hazardous waste shipments from a demolition site to ensure regulatory compliance from the generator to the disposal facility?
- Bill of lading
- Uniform Hazardous Waste Manifest (Correct answer)
- SWPPP record
- Safety Data Sheet (SDS)
Correct answer: Uniform Hazardous Waste Manifest
The Uniform Hazardous Waste Manifest is the required cradle-to-grave tracking document for all hazardous waste shipments under RCRA.
Question 4: A demolition supervisor must ensure that lead-based paint (LBP) notifications are provided to workers before work begins on a pre-1978 residential structure. This requirement is primarily mandated by which EPA rule?
- Lead and Copper Rule
- Renovation, Repair and Painting (RRP) Rule (Correct answer)
- Lead NESHAP
- Residential Lead-Based Paint Hazard Reduction Act
Correct answer: Renovation, Repair and Painting (RRP) Rule
EPA's RRP Rule requires certified firms and renovators to follow specific work practices and provide lead hazard information before working on pre-1978 housing.
Question 5: Under the Emergency Planning and Community Right-to-Know Act (EPCRA), facilities must report releases of extremely hazardous substances that exceed reportable quantities to which entity FIRST?
- EPA regional office
- State emergency response commission (SERC) and local emergency planning committee (LEPC) (Correct answer)
- OSHA area office
- Local fire department
Correct answer: State emergency response commission (SERC) and local emergency planning committee (LEPC)
EPCRA Section 304 requires immediate notification of the SERC and LEPC for releases of extremely hazardous substances exceeding reportable quantities.
Question 6: What is the primary regulatory purpose of requiring a demolition contractor to submit a written asbestos inspection report prior to beginning demolition?
- To satisfy OSHA recordkeeping requirements only
- To comply with NESHAP and ensure proper identification and handling of ACM before demolition begins (Correct answer)
- To obtain a building permit from the local authority
- To document worker training certifications
Correct answer: To comply with NESHAP and ensure proper identification and handling of ACM before demolition begins
NESHAP requires a thorough asbestos inspection prior to demolition to identify all ACM so it can be properly abated before the building is torn down.
Question 7: Which of the following best describes the regulatory status of 'universal waste' such as fluorescent lamps and batteries found during building demolition?
- They are exempt from all hazardous waste requirements
- They are subject to streamlined RCRA hazardous waste regulations with simpler management requirements (Correct answer)
- They must be managed identically to listed hazardous waste
- They are classified as solid waste only and require no special handling
Correct answer: They are subject to streamlined RCRA hazardous waste regulations with simpler management requirements
Universal waste rules under RCRA provide a simplified regulatory framework for common hazardous waste items like batteries, pesticides, and mercury-containing equipment.
CDS Regulatory Compliance & Environmental Impact 3
During selective demolition, crews find friable asbestos pipe insulation in a non-residential building.
Under OSHA 29 CFR 1926.1101, workers performing this removal must be classified as performing which class of asbestos work?