Planning Is Key to Avoiding Expensive Mistakes
Commercial buildings have a defined life-cycle. At some point, most existing structures will be demolished for a new use, renovated as a part of an expansion or change, or occasionally damaged or destroyed by disaster (fire, earthquake, hurricane, tornado, flood, etc.).
As construction technology has advanced, building materials have changed and become more specialized. Engineered materials and steel have replaced wood, fluorescent lamps have replaced the light bulb, and a vast number of products – both man-made and naturally-occurring – have found uses in buildings to meet specific design needs. Many of these products were created to solve problems or satisfy needs; but often little thought was given to the impacts and problems that these “answers” may themselves create.
Building Materials as Hazardous Waste?
Poly-Chlorinated Biphenyls (PCBs) are a perfect example of this dilemma. PCBs are oils that are stable and have excellent dielectric and heat-dissipation properties. For this reason, they found widespread use after 1929 in electric-power transformers and light ballasts. Later, they were added to window caulk and cable to make them more flexible. Not until the 1970s was there any understanding of the potential environmental issues created by these persistent materials that bioaccumulate in living organisms (stability can have a down-side) and have toxic and mutagenic effects.
In time, some of the problems created by the industrial age began to be realized – among them the improper disposal of building materials that are hazardous to humans and/or the environment. Over the years a number of laws and regulations have been enacted to help deter such now-illegal disposal. Failure to comply can lead to some major, unanticipated expenses. HETI was recently involved in a case where a commercial entity in the process of building renovation failed to test mastic, which was holding a brick facing on, for the presence of asbestos. The mistake was caught after two roll-offs of brick were mixed into a much larger pile at a recycling facility resulting in over $500,000 in disposal costs to the entity…since the entire pile had to be treated as asbestos waste.
Another example is lead-based paint (LBP). It does not need to be removed prior to building demolition under current federal and most state regulations; but the owner is required to notify the renovation/demolition contractor that LBP may be present if the building’s painted surfaces are not surveyed and sampled. Additional notification is also required by the facility receiving potential LBP waste.
Disposing of Building Demolition Waste
When considering building demolition or renovation, state and/or federal hazardous waste regulations must be considered … and the following types of materials in the building may need to be disposed of as hazardous or regulated waste after removal:
♦ roofing shingles and tarpaper (asbestos) ♦ asbestos ceiling or floor tiles ♦ mastic containing asbestos ♦ lamps, thermostats, and “silent” light switches (mercury) ♦ lighting ballasts (PCBs or DEHP) ♦ batteries from exit signs (nickel-cadmium, nickel metal hydride and lead acid) ♦ wet-type transformers (PCBs) ♦ emergency lights and smoke alarms (radioactive materials such as Americium) ♦ paints (chemicals) ♦ window caulk (potential PCBs and asbestos) ♦ lead pipes, roof vent flashings and lead pig tails ♦ refrigeration units [chlorinated fluorocarbons (CFCs) or ammonia] ♦ elevator reservoirs (hydraulic oils, PCBs) ♦ fluorescent light tubes and metal halide lighting (mercury vapor) ♦ product piping (chemicals and oils) ♦ fire-doors (asbestos) ♦ rubber gymnasium floors (mercury) ♦ forklift charging stations (lead) ♦ thermal system insulation on older boilers and heaters (asbestos) ♦ other miscellaneous materials
Many states now require that pre-demolition/renovation surveys be conducted for hazardous materials as part of the planning process. These surveys should be performed by qualified experienced individuals to identify, remove and segregate hazardous and regulated materials from entering the demolition waste stream. Even if a particular state does not have such a requirement, HETI strongly urges that such a survey be performed to limit liability and costs to correct improper disposal. This is one area where a dollar of prevention can save a thousand dollars of cure.
HETI…Helping Manage Risk
Through our risk management consulting practice, we offer a technical staff of experienced safety professionals with proven capabilities to deal with a full range of risk control issues, including construction safety and quality assurance.
HETI consultants help identify safety and quality assurance concerns prior to each phase of a construction project; have experience with complex projects (such as tunnels, bridges, roads, light rail, airports, environmental remediation, high-rise buildings, habitation construction, and industrial facilities); have diverse experience with wrap-ups, both OCIP and CCIP; and assist in implementing hazard controls before the project starts.