Material Transport

Since heavy equipment is often used to move and segregate demolition debris, questions have been raised concerning the effect of such transport particularly on Category I nonfriable ACM.

Category I

If Category I nonfriable ACM is transported across a demolition site in the bucket of a top loader, backhoe, hydraulic excavator or other similar vehicle, it is not considered RACM since it is not subjected to sanding, grinding, cutting or abrading during this activity.

Use of bulldozers, on the other hand, is expected to have a greater impact on Category I materials. However, EPA has stated that "...if the bulldozer is moving the debris or picking it up to be put in a vehicle and inadvertently runs over Category I material, then it is not subject to the NESHAP standard" (see Appendix I).

Consequently, the moving of debris by bulldozers, whether by carrying it in a bucket or pushing it along the ground does not in itself cause Category I nonfriable ACM to become RACM.

Category II

Category II nonfriable ACM subjected to sanding, grinding, cutting or abrading during collection and transport is considered RACM and thus subject to the asbestos NESHAP.

Courtesy of The EPA