INFORMATION BULLETIN

           A NUMERICAL DEFINITION OF "MINOR REMOVAL" OF 
               FRIABLE MATERIAL CONTAINING ASBESTOS

Produced by:
Construction Health and Safety Program,
Ontario Ministry of Labour.
ISBN 0-7778-4892-9

BACKGROUND:  TYPE 1, TYPE 2 AND TYPE 3 ASBESTOS OPERATIONS

Under the Regulation respecting Asbestos on Construction Projects 
and Buildings and Repair Operations (R.R.O. 838, section 9), 
asbestos operations are classified according to the level of the 
asbestos hazard they present.  A low risk operation is Type 1, a 
medium risk operation is Type 2 and a high risk operation is Type 
3.  They type of operation determines many of the requirements 
that apply to if, for example with regard to notification, 
medical surveillance, record keeping, work procedures, etc. 

Under the regulation the minor removal or minor disturbance of 
friable material containing asbestos is a Type 2 operation 
(R.R.O. 838, section 9 (1)(b)(ii)).

A NUMERICAL DEFINITION

The Ministry of Labour has recognized the need for a precise and 
clear numerical definition of minor removal operations to achieve 
consistency in applying the regulation.  The ministry therefore 
recommends the following definition:

     The minor removal of material containing asbestos means the 
     removal of nine square feet or less of wet friable material.  
     (This includes, but is not limited to, mechanical insulation 
     and sprayed-on fireproofing insulation.)  However, the 
     length of pipe in a minor removal operation must never 
     exceed 21 linear feet, even if less than nine square feet of 
     materials is involved. 

     This definition does not apply when two or more operations 
     are to be performed at the same time or one after another. 

This definition provides a clear distinction between Type 2 minor 
removal operations and Type 3 operations.  It has been accepted 
and used by many in industry and the ministry in the last few 
years and has become standard industry practice.

To apply this definition to lengths of pipe, see Table 1 (page 
2). 

PROPOSED AMENDMENTS TO THE REGULATION

Proposed amendments to R.R.O. 833 now being considered will 
include a precise numerical definition.  The ministry recommends 
that the definition stated above be used as a guideline until 
these proposed amendments take effect.

MEASURES AND PROCEDURES FOR TYPE 2 OPERATIONS

The minor removal or disturbance of friable material containing 
asbestos must be carried out following the measures and 
procedures prescribed for Type 2 operations in the regulation.  
Among others, these include:

     - the use of non-powered air-purifying respirators, 
     - the use of personal protective clothing, including full 
       body coveralls, 
     - enclosure of the work area,
     - the use of HEPA (high efficiency particulate aerosol) 
       filter vacuuming or damp wiping to remove dust that 
       contains asbestos from contaminated surfaces and personal 
       protective equipment and clothing, 
     - wetting of the insulation,
     - bagging and disposing of asbestos waste, and
     - washing of hands and face.

The use of amended water to wet the insulation thoroughly before 
starting to remove it is very important for controlling the 
spread of asbestos fibres into the work area and onto surfaces, 
including personal protective equipment.

APPLICATIONS FOR A GLOVE BAG VARIANCE

Type 2 removals do not require a variance for a glove bag to be 
used in the operation.  The glove bag is an enclosure as defined 
for Type 2 operations.  Type 3 operations do require a variance 
for a glove bag to be used.  Thus the definition of "minor 
removal" and the Table below can be used in deciding whether it 
is necessary to apply for a glove bag variance.

TABLE 1: LENGTHS OF INSULATED PIPE EQUIVALENT TO NINE SQUARE FEET

Table 1 may be used as a guide in applying the definition of 
"minor removal" given above to insulated pipe.  It states what 
lengths of pipe correspond to the maximum allowable nine square 
feet of insulation for various diameters of pipe.  For example, 
if a pipe has an outside diameter of eight inches, then the 
maximum length of pipe for a minor removal is 4.5 feet.

Table 1:

Measure the outside diameter of the insulated pipe in inches.  If 
it is:
-----------------------------------------------------------------
 1.6     2     4    6    8   10   12   14   16-20   22-26   26-30 
-----------------------------------------------------------------
then the maximum allowable length of pipe in linear feet is:
-----------------------------------------------------------------
21.0   17.0  9.0   6.0  4.5  3.5  3.0  2.5   2.0     1.5     1.0
-----------------------------------------------------------------

Besides the table, there is a simple formula for finding the 
maximum allowable length for a given pipe.  Divide 34.4 by the 
pipe's outside diameter in inches.  For example, for pipe with an 
outside diameter of ten inches, the maximum length allowed for a 
minor removal operation is 34.4 divided by ten, which gives a 
rounded answer of 3.5 feet of pipe.  (However, the formula does 
not apply to pipes with a diameter under 1.6 inches, because the 
definition states that the length of pipe in a minor removal 
operation can never exceed 21 linear feet.)

The equation underlying the Table and the formula is:

Area = Length x Perimeter [Perimeter = pi x Diameter in inches/12] 

FOR MORE INFORMATION

This Information Bulletin should be used together with the 
regulation (R.R.O. 838).  For a copy of the Occupational Health 
and Safety Act or regulation, call your nearest ministry office 
or the ministry's Publication Section at (416) 326-7731 or (toll-
free in Ontario) 1-800-268-8013, extension 6-7731.

For further information, please contact the Construction Health 
and Safety Program at your nearest Ministry of Labour office.