IMPORTANT DATES AND DEADLINES:
Request for Party Status November 17. 2020 by 11:59 p.m.
Status Conference November 24 at 10:00 a.m.
Alternate Proposal December 2, 2020 by 11:59 p.m.
Prehearing Statement December 2, 2020 by 11:59 p.m.
Prehearing Conference December 21, 2020 at 1:00 p.m.
Rebuttal Statement December 28, 2020 by 11:59 p.m.
Colorado Regulation 8, Part B Asbestos Proposed Revisions
proposed revisions to Regulation 8, a discussion of what if the proposed regulation becomes regulation
PROPOSED REVISION – “The innermost room must be large enough to accommodate the cleaning of bagged debris and the largest sized debris, all while maintaining closed flaps.”
PROPOSED REVISION – I.B.124. Work Area — The addition of the words “An exterior work area may be established under the provisions of a variance request.”.
PROPOSED REVISION – I.B.69. Makeup Air Intake –The terms “a filtered, self-closing aperture” and “designed and Installed” imparts a concern as to what will the filter requirements will be and will there be some sort of additional mechanical requirements drafted by the Division in the form of a policy? The definition provided is vague and can be interpreted in the future to require elaborate filtering and expensive mechanically operated closure systems.
REQUIRED – The provided definition seeks to prevent a perceived problem causing the release of asbestos from a work area due to the loss of negative pressure inside. This is an occurrence which is extremely rare due to the existence of Americas modern electrical infrastructure. Additionally, the temporary loss of negative pressure does not indicate all work areas will automatically become positive pressure. What often happens is the work area becomes static allowing for the air to remain inside the work area as all the other engineering controls are still intact.
THINK ABOUT THIS!Industry practice already makes allowances for a simple inexpensive flap over this makeup air location which will self-close upon the loss of negative pressure. This form of requirement is overly burdensome and provides limited protection for a rare occurrence.