3 3. INTRODUCTION

SThe asbestos decontamination requirements for Building 17 are regulated by the Occupational Safety and Health Administration (OSHA) under the Code of Federal Regulations (CFR) parts 1910 and 1926, which govern general industry and construction exposure and surveillance standards. These regulations provided a basis for determining proper personal protection and acceptable exposure risk for staff working in the building and a baseline for the development of testing and clearance standards for releasing artifacts from the containment after decontamination was completed.

Asbestos abatement work for the construction industry is divided into four classes of hazard severity based on the level of activity and the type of building material being removed or disturbed. Decontamination of objects is not specifically defined by OSHA standards but could be interpreted as between Class III (disturbance of asbestos materials in the repair or maintenance of an area or item) and Class IV (maintenance cleaning). These classifications also relate to different levels of training and engineering control measures. Although the decontamination work involved the removal of friable fibers from object surfaces, the volume of delaminating insulation material in the building and the potential for elevated ambient air contamination levels warranted more protective measures. As the Smithsonian Institution generally approaches personal protection in hazardous situations conservatively, NMAH required its staff to take the more stringent Class III training classes and wear respirators with a higher protection factor (powered air-purifying respirators). This requirement entailed additional staff training time and costs to certify personnel to enter the containment, and increased equipment costs, as powered air-purifying respirators cost significantly more than the respirators used in less hazardous asbestos work. Additionally, staff costs were affected by this decision, as increased staffing was necessary to complete a daily rotation of three-hour shifts. The shifts were divided largely because of the strain of wearing full protective gear for long periods of time in a non-climate- controlled environment.