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WRD 23.30 Page 2 <br /> III. Interpretive Guidance <br /> A. How do the building survey requirements of WAC 296-62-07721 apply to joint <br /> compound? <br /> 1. Sampling for joint compound. Owners and employers can generally rely upon <br /> full-depth samples of wallboard systems containing joint compound collected <br /> during building inspections. <br /> For general demolition and other work dealing with the wallboard system as a <br /> whole,building surveys using samples representing the full depth of wallboard <br /> material meet the good faith survey requirements. Where sample results identify <br /> trace or less than one percent asbestos for the wallboard system, some basic <br /> requirements of the asbestos standard will apply but the work will not be <br /> considered an "asbestos abatement project" under the definitions of the standard. <br /> However, full-depth samples are not sufficient for wallboard systems where <br /> surfacing materials are present or where work will specifically disturb joint <br /> compound. <br /> Building inspectors must examine wall systems in sufficient detail to identify <br /> extensive patching or application of surfacing layers on walls (as per the EPA <br /> AHERA inspection protocols for identification of surfacing materials in 40 CFR <br /> 763 Part E). These applications are considered to be "surfacing materials" under <br /> the standard,although similar plaster products may be used for joint compound. <br /> Surfacing materials have been associated with extensive asbestos exposure and <br /> have more stringent handling requirements than most other materials(see the <br /> OSHA preamble to the 1994 rulemaking for additional discussion). <br /> Where work practices will selectively disturb joint compound, a full depth sample <br /> may not represent the workplace hazard. For example, sanding or scraping a wall <br /> may specifically disturb the joint compound and create dust and debris composed <br /> primarily of joint compound. Building inspectors must assess the work to be <br /> conducted and sample the materials representative of the hazard presented by the <br /> work. This may be accomplished using individual samples of different layers or <br /> having layers within samples analyzed separately. WISHA enforcement staff <br /> may elect to collect samples of dust or debris from the workplace or sample <br /> specific materials to make an assessment of the hazard represented by these <br /> materials. The specific work activity associated with the sample must be <br /> documented. <br /> --policy continues on next page— <br />