8.1 Air Monitoring: Personal Sampling, Area Sampling During Abatement & PCM vs. TEM Analysis
Key Takeaways
- OSHA's mandatory Appendix A method collects breathing-zone samples on mixed cellulose ester filters in a 25-mm cassette with a 50-mm electrically conductive extension cowl, at 0.5-2.5 L/min.
- On New Jersey subcode projects, the AST collects at least three area samples per 8-hour shift: one in the decontamination clean room and two adjacent to the work area (N.J.A.C. 5:23-8.21(b)).
- Results must not exceed 0.01 f/cc outside the containment barrier or 0.02 f/cc inside the clean room; exceedances trigger immediate corrective action and reports within 24 hours.
- Pumps are calibrated with a primary standard before initial sampling and rechecked with at least a secondary standard before and after each sample (N.J.A.C. 5:23-8.21(a)4).
- PCM laboratories must participate in the AIHA proficiency program with 24-hour maximum turnaround; TEM laboratories must be NIST-NVLAP accredited with 72-hour maximum turnaround.
8.1 Air Monitoring During Asbestos Abatement
Quick Answer: Personal samples measure worker exposure against OSHA's 0.1 f/cc TWA and 1.0 f/cc excursion limits. They are collected in the breathing zone on 25-mm mixed cellulose ester filters at 0.5-2.5 L/min and analyzed by phase contrast microscopy (PCM). Area samples on New Jersey subcode projects are collected by the AST: at least three per 8-hour shift, with one in the clean room and two adjacent to the work area. Results must not exceed 0.01 f/cc outside containment or 0.02 f/cc in the clean room. Clearance samples come after clean-up (Section 8.3). PCM counts all fibers of countable size. TEM identifies asbestos specifically.
Three Kinds of Air Sampling
| Type | Who Collects | Purpose | Standard |
|---|---|---|---|
| Personal (breathing zone) | Contractor or its industrial hygienist | Worker exposure, respirator selection, NEA data | 29 CFR 1926.1101(f) and Appendix A |
| Area (during abatement) | AST on subcode projects; project monitor elsewhere | Detect fiber escape from the enclosure or decon unit | N.J.A.C. 5:23-8.21(b); 8.19(c)4 |
| Clearance (post-abatement) | AST or project monitor | Decide whether barriers can come down and the area can be reoccupied | N.J.A.C. 5:23-8.21(c)-(g); 12:120-4.7(c); 40 CFR 763.90(i) |
Some projects also collect baseline samples before work begins to document existing conditions. They are useful when a later area result is questioned, but the subcode's area-sampling limits are fixed numbers, not "above baseline."
Personal Sampling (OSHA Appendices A and B to 1926.1101)
- Filter and cassette: A mixed cellulose ester (MCE) filter designated for asbestos counting, in the preferred 25-mm cassette with an open-faced 50-mm electrically conductive extension cowl. The non-mandatory Appendix B procedure specifies a 0.4 to 1.2 micrometer pore size. A 37-mm cassette requires written justification.
- Flow rate: Mandatory Appendix A sets 0.5 to 2.5 L/min for the 25-mm cassette. Aim for a filter loading of 100 to 1,300 fibers per square millimeter. If the filter darkens or shows loose dust, start a second sample.
- Position: The open-face cassette is clipped to the collar or lapel, open side down, about 10 cm (4 inches) from the nose and mouth.
- Volumes: Appendix B suggests a minimum of 25 L for TWA samples and 48 L for 30-minute excursion-limit samples, with lower maximum volumes in dusty removal environments to avoid overloading.
- Calibration: Calibrate each pump before and after sampling with a representative cassette in line, using a primary standard such as a bubble burette or electronic flow calibrator.
- Representativeness: Samples must represent the full-shift and 30-minute exposures of each employee in each work area. For short-term samples, target the tasks most likely to exceed the excursion limit, such as gross removal and bag-out.
Results are reported in fibers per cubic centimeter (f/cc). Employees must be notified within 5 working days after the employer receives the results.
Area Sampling During Abatement on Subcode Projects
Unoccupied Buildings (N.J.A.C. 5:23-8.21(b)1)
- At least three samples per 8-hour shift: one at the beginning of the shift, one every four hours thereafter, and one at the end of the contractor's workday.
- Locations:
- One stationary sample inside the clean room of the decontamination unit.
- Two samples adjacent to the work area, but remote from the decon entrance. Rooms next to critical barriers and the work area get preference.
- Limits: Results must not show more than 0.01 f/cc outside the containment barrier or more than 0.02 f/cc inside the clean room.
- If a limit is exceeded: The AST immediately directs corrective action and gives a verbal report within 24 hours to the contractor, owner, and project designer. Written notice follows, with a copy to the enforcing agency and DCA within three business days of receiving the results (N.J.A.C. 5:23-8.10(d)6).
Occupied Buildings (N.J.A.C. 5:23-8.19(c)4-5)
- At a minimum, collect one sample at the beginning of each shift, one every four hours, and one at the end of the workday for every 10,000 square feet of occupied space next to the work area. Place them where fiber migration is most likely.
- Add samples at work-area entrances, at interior spaces supplying make-up air, and in stairwells, shafts, elevators, plenums, and in-service ducts passing through the work area.
- Collect at least one sample inside the work area during each shift. That result does not trigger the contingency plan.
- On-site analysis, or results within four hours, by an analyst listed in the AIHA Asbestos Analyst Registry (or equivalent), using NIOSH 7400.
- 10% of samples are re-analyzed at a laboratory within 24 hours for quality control.
- Daily occupancy is allowed only if every sample is 0.010 f/cc or less by PCM. Above that, the contingency plan applies:
- Investigate the engineering controls.
- Take a second PCM sample, which may be split. If it is 0.010 f/cc or less, the contingency ends.
- If it is still above 0.010 f/cc, either clean and retest by PCM, or analyze the split by TEM. If TEM also exceeds 0.010 f/cc, cleaning is required, including wet wiping and misting the air.
- If results are not at or below 0.010 f/cc within 24 hours of the first high result, evacuate the building.
- A written chain of custody for samples is part of the ASCM's approved plan.
Pumps, Laboratories, and Turnaround
| Requirement | New Jersey Subcode Rule (N.J.A.C. 5:23-8.21(a)) |
|---|---|
| Who samples | The AST performs all subcode air sampling |
| Pump calibration | Primary standard before initial sampling; at least a secondary standard before and after each sample; periodic primary recalibration; calibration records kept in the daily log |
| PCM laboratories | Enrolled in the AIHA Proficiency Analytical Testing program or an equivalent; use NIOSH 7400; 24-hour maximum turnaround |
| TEM laboratories | NIST-NVLAP accredited; use the AHERA TEM method (Appendix A to 40 CFR 763 Subpart E); 72-hour maximum turnaround |
| ASCM laboratory independence | The laboratory may have no economic relationship with the abatement contractor (N.J.A.C. 5:23-8.11(d)) |
PCM vs. TEM
| Feature | Phase Contrast Microscopy (PCM) | Transmission Electron Microscopy (TEM) |
|---|---|---|
| Method | NIOSH 7400 (OSHA Appendix A is similar) | AHERA TEM method (Appendix A to Subpart E); NIOSH 7402 is used to identify fibers on PCM filters |
| What it counts | All fibers longer than 5 micrometers with a length-to-width ratio of at least 3:1 | Asbestos structures, identified by morphology, electron diffraction, and X-ray analysis |
| Asbestos specific? | No. Counts fiberglass, cellulose, gypsum, and other fibers | Yes |
| Smallest fibers seen | About 0.25 micrometer wide | Much thinner fibrils |
| Speed and cost | Fast and inexpensive; can be done on site | Slower and more expensive; accredited laboratory |
| Typical use | Personal samples; area samples during abatement; small-project or glovebag clearance | Most subcode clearance; AHERA school clearance above 160 sq ft / 260 lin ft; resolving questionable PCM results |
Because PCM cannot tell asbestos from other fibers, a high PCM result during drywall demolition next door might not be asbestos. TEM (for example, NIOSH 7402 analysis of the same filter, or the occupied-building split-sample procedure) can resolve that question. Until it is resolved, treat the high PCM result as a warning and investigate the containment.
Exam Traps
- Clean room versus outside containment: The limit is 0.02 f/cc in the clean room and 0.01 f/cc outside containment.
- Sampling frequency: Beginning of shift, every four hours, and end of day, the same schedule as the pressure checks.
- Cassette position: Open face down, about 10 cm from the nose and mouth.
- PCM is not asbestos-specific.
- Who samples on subcode jobs: the AST, employed by the ASCM, which the owner hires. The contractor still does its own OSHA personal monitoring.
Scenario
On an unoccupied-school subcode project, the AST's mid-shift sample in the decon clean room reads 0.024 f/cc, above the 0.02 f/cc clean-room limit. The adjacent-room samples read 0.004 and 0.006 f/cc.
- The AST immediately directs corrective action. Inspection finds a shower-to-clean-room curtain taped open to run a hose, and a clean room that was not wet-wiped.
- The contractor restores the three-layer curtained doorway, wet-wipes and HEPA-vacuums the clean room, and verifies the pressure differential.
- The AST gives the verbal report within 24 hours to the contractor, owner, and project designer, and sends the written report to them, the enforcing agency, and DCA within three business days of receiving the result.
- Follow-up samples in the clean room must be at or below 0.02 f/cc.
On a New Jersey subcode project in an unoccupied building, where must the AST place the minimum area samples during each 8-hour abatement shift?
What area-sample limits apply during abatement under N.J.A.C. 5:23-8.21(b)1?
Why might a high PCM area result near an active drywall demolition job not prove that asbestos is escaping containment?