Asbestos

Encapsulation vs. Maintenance vs. Repair of Asbestos

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What is encapsulation?
I'm not removing any ACM, I'm encapsulating it. Do I still need to notify MDH?
What is maintenance?
During our yearly heating system inspection we identified several valves and connections that are leaking. In order to address these valves and connections we have to remove the asbestos-containing insulation. Do I still need to notify MDH?
What is repair?
I'm not removing any ACM, I'm conducting "patch and repair". Do I still need to notify MDH?

What is encapsulation?

Encapsulation is defined by Minnesota Rules, part 4620.3100, subpart 19 as:

"Treatment of asbestos-containing materials (ACM) with a sealant material that surrounds or embeds asbestos fibers in an adhesive matrix to prevent the release of fibers. A bridging encapsulant creates a membrane over the surface. A penetrating encapsulant penetrates the material and binds its components together."

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I'm not removing any ACM, I'm encapsulating it. Do I still need to notify MDH?

Yes. Encapsulation is defined as asbestos-related work (ARW). The Minnesota Department of Health (MDH) regulates ARW. Therefore MDH must be notified when the quantity of material to be impacted by ARW in a facility during the calendar year meets or exceeds:

  • 260 linear feet; or
  • 160 square feet; or
  • 35 cubic feet

If you are conducting encapsulation in a residence, the following quantities apply:

  • 10 linear feet; or
  • 6 square feet; or
  • 1 cubic foot

IMPORTANT: Residential amounts exclude roofing, siding, flooring and ceilings in residences with four or fewer dwelling units.

If it is predicted that these quantities will be exceeded, the encapsulation activities are regulated at the start of the year, not after these quantities are exceeded.

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What is maintenance?

Maintenance is defined by Minnesota Rules, part 4620.3100, subpart 25b:

"Encapsulation, enclosure, or removal of asbestos-containing material on or around a mechanical system or machinery to sustain the operating condition of the mechanical system or machinery."

Maintenance refers to the upkeep of the mechanical system itself, not the upkeep of the associated ACM.

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During our yearly heating system inspection we identified several valves and connections that are leaking. In order to address these valves and connections we have to remove the asbestos-containing insulation. Do I still need to notify MDH?

Yes. Maintenance activity is regulated when the amount of material to be encapsulated, enclosed, or removed in a facility during the calendar year meets or exceeds:

  • 260 linear feet; or
  • 160 square feet; or
  • 35 cubic feet

If you are conducting maintenance activity in a residence, the following quantities apply:

  • 10 linear feet; or
  • 6 square feet; or
  • 1 cubic foot

IMPORTANT: Residential amounts exclude roofing, siding, flooring and ceilings in residences with four or fewer dwelling units.

If it is predicted that these quantities will be exceeded, the maintenance activity is regulated at the start of the year, not after these quantities are exceeded.

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What is repair?

Repair is not defined in the Minnesota Asbestos Rules.

It is often referred to as "patch and repair" by people trained in the asbestos industry.

"Patch and repair" consists of applying encapsulant to ACM to return damaged, previously encapsulated ACM to an intact state to prevent fiber release. Insulation with an existing canvas or paper covering is considered previously encapsulated.

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I'm not removing any ACM, I'm conducting "patch and repair". Do I still need to notify MDH?

Yes. If damaged ACM must be addressed to make repairs, in the quantities specified under encapsulation, then this activity is regulated and the work must be notified.

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How do I find out more information?

For more information about asbestos, contact the Asbestos Program at MDH through the internet or by telephone at (651) 201-4620.

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Updated Wednesday, 03-Apr-2013 13:35:15 CDT