Articles / Press Releases


Summary Of EPA And OSHA Requirements For Handling -Containing Roofing Material




REQUIREMENTS OLD OSHA STANDARD NEW OSHA STANDARD
CLASS II WORK
NEW OSHA STANDARD - INTACT INCIDENTALS EPA INTERPRETIVE RULE
Permissible Exposure limits (PEL's) 0.2 f/cc, 8hr. TWA
1.0 f/cc, 30-minute excursion limit
0.1 f/cc action level
0.1 f/cc 8 hr. TWA 1.0 f/cc 30-minute excursion limit no action level Not applicable (N/A) Doesn't establish PEL's, only regulates friable ACRM
Exposure Assessment No Yes, competent person may make negative exposure assessment (NEA), based on NRCA's data provided material is intact and standard is complied with No No
Air Monitoring Historical data exemption No, if NEA produced No No
HEPA Vacuums No Only when roof cutter is used on aggregate-surfaced roof with roof area > 5580 ft, or material is not intact No Only when roof cutter is used on aggregate-surfaced roof with roof are > 5580ft, or material is friable
Wet Methods No Only when roof cutter is used or material is not intact No Only when roof cutter is used and roof area > 5580 Ft., or material is friable
Bagging/Wrapping No Only the dust dispersed from a roof cutter, or when material is not intact No Only the dust dispersed from a roof cutter, where roof area > 5580 ft. or material is friable
Lowering Material by Hand, Crane, Hoist or Enclosed (dust-tight) chute No Yes Yes Only the dust dispersed from a roof cutter, where roof area > 5580 ft. or material is friable
Roof Cutter Adaptations (misting into shroud, HEPA vacuuming or wet wiping) No Yes No Yes
Roof Level Air Intakes Isolated or Shut Down No Yes No No
Respirators & Protective Clothing No No, if NEA provided No No
Smoking Prohibition Yes Yes No No;
Notification -Removal No No to OSHA, Yes to employees, building owner and other employers on site No Yes to EPA, but only if roof cutter used on roof area > 5580Ft.
Notification - Installation No N/A products no longer manufactured Only if products are labeled according to (K)(7) No
Worker Training No Yes, 8 hours annually for authorized persons Yes, no time minimums stipulated No
Supervisor Training No Yes, EPA Supervisor course or equivalent for "competent person" Competent persons must be "knowledgeable", which may or may not require training. Yes, but only when roof cutter is used or material is friable
Medical Surveillance No Yes, if worker is on Class II jobs for 30 or more days per year No No
Record Keeping Limited Yes, for data, training and medical surveillance Yes, but only for installation Limited
Exemptions: Square Foot No Limited, conditional exemption where work area < 25 ft Limited, conditional exemption where work area < 25 ft 160 Ft for friable material; 5580 ft when roof cutter is used
Residential Dwellings of Four units or less No No No Yes

Translate Site

Kanopy Reflective Roof Maintenance Solutions
  • Reduce Energy Use
  • Lowers Peak Energy Use, reducing energy costs year-round
  • Helps the environment, reduces "Heat Island Effect"
  • Extend the life of the roof
  • Reduces waste. Helps avoid roof tear-off.
  • Economic compared to roof replacement
  • Eliminates interior building operation disruption