HBA staff and members met with Metro staff again on March 20th regarding Metro’s new asbestos disposal requirements which take effect on April 1. HBA continues to work with Metro to refine and clarify the requirements, and ensure consistency in how they are enforced, and promote dialogue between Metro staff and HBA members.
On March 20, Metro representatives attended a roundtable with HBA members and staff regarding implementation of DEQ’s new asbestos requirements at Metro’s two transfer stations – these additional requirements will take effect April 1, 2017. To illustrate the importance of compliance, DEQ Recently put out notice that it has issued a $28,800 civil penalty in our region for mishandling asbestos containing material. You can find a link to this notice and Metro’s asbestos handling information at the end of this article.
During the meeting, we received clarification regarding required paperwork at the transfer stations. While the Metro paperwork needs to be completed every time, the lab work analysis only needs to be done once and can be used for the duration of a project. The current required form does not include any project duration document so for now, the lab work from a specific work site can last an open-ended amount of time. Metro suggests you duplicate your paperwork if you know you’ll be doing multiple loads from the same work site.
Metro informed attendees that they are working to ensure they have correct information on-site for the contract workers at the transfer stations and are making a concerted effort for greater consistency among employees on enforcement. They have also further refined the list of suspect asbestos containing materials (ACM). Materials that are confirmed to have asbestos in them through lab analysis can be taken to the Hillsboro Landfill or the Wasco County Landfill in The Dalles. HBA membership provided feedback that it would be helpful for Metro to distribute documents to all contractors who may dump waste at Metro’s transfer stations that provide a distinction on what materials will need to be taken to alternate dumping facilities.
The requirement stands that listed suspect ACM from construction prior to January 1, 2004 will need to be tested and post-2004 materials won’t be. No additional documentation is needed other than checking the box on the construction and demolition waste acceptance form.
HBA membership and staff provided feedback to Metro that some sort of pamphlet or brochure that includes photos of ACM would be very helpful in both Metro training their staff, and our members training theirs. It would ensure everybody was on the same page regarding materials and would help make the process smoother, especially for contract or non-English speaking employees. Metro and HBA members are working together in creating this educational document.
Metro is actively working to disseminate the updated information within our industry and HBA is helping to facilitate that as much as possible. Portland Metro and the HBA are partnering to alert contractors about the upcoming rules changes through HBA contacts at the Oregon Construction Contractors Board (CCB). The CCB has indicated they will include information on the new set of rules in their upcoming newsletter that goes out to contractors registered with the CCB.
Metro staff will be included on a panel titled “Deconstruct & Dump! Inside Metro’s New Asbestos Dumping Laws” at HBA’s BuildRight Conference – at 10:45am on April 19 at the Kennedy School. HBA staff will continue to work with Metro and members on implementation of these new regulations and will be participating in DEQ’s Asbestos 2017 Rulemaking Advisory Committee.