Planning for Tenant Improvements
Renovations are costly but if you’re not aware of the Hazardous Materials within your building prior to your project commencement you may find yourself encountering much larger challenges that lead to project delays, fines, and even lawsuits.
Managing Hazardous Material issues such as asbestos, lead, indoor-air-quality problems and abatement activities can be a difficult task. Building owners and managers have numerous notification requirements. Under OSHA regulations, building owners and managers are required to provide tenants, contractors and maintenance personnel with proper notification regarding the presence and location of asbestos containing materials in the building. The EPA has enacted numerous regulations designed to protect children from exposure to lead. New regulations and standards have been adopted surrounding Silica dust monitoring and Polychlorinated biphenyl (PCB) containing materials as well.
If you have a planned Tenant Improvement or renovation project here are some important preventative steps you can take to reduce risk of exposure to harmful hazardous materials.
Environmental Project Planning Considerations
- Define project scope.
- Review project impacts against known environmental conditions and determine if environmental information addresses all known site conditions, if not arrange for a survey. A review of site conditions related to project impacts to building materials should be preformed during this process.
- Asbestos sampling should be conducted for all materials – fireproofing, ceilings, wall materials, flooring, roofing, exterior siding, mechanical systems, etc. Any detectable asbestos concentration triggers OSHA required procedures. There is NO exemption for small quantities.
- Lead sampling should be conducted for all paint disturbance, especially loose & peeling paints, ceramic tile, soundproof sheeting, caulkings, structural steel primers, etc. Any detectable lead concentration triggers OSHA required procedures during disturbance. There is NO exemption for small quantities.
- Identify Universal Wastes in project area – florescent/mercury vapor light tubes, PCB light ballasts, mercury HVAC switches, refrigerants, etc.
- Identify other conditions that may become issues during the project – mold, evidence of water leaks, bird or rodent droppings, etc.
- If asbestos, lead, or other environmental issue will be encountered, review project to determine alternate scopes to avoid impact. If alternates are not available, begin integrating an abatement design into the overall project scope, budget and schedule. Most abatement will occur after hours and/or on weekends.
- Issue appropriate environmental notifications to architects/engineers/consultants, GC, trades and occupants. Notification to the GC and trades should be issued at the bid walk or announcement of the project.
- Coordinate environmental scope and resources (Consultant & abatement contractor) with occupant business needs, building operations and construction activities. Allow for notification and permitting to regulatory agencies (typically 10 working days prior to the start of activities).
- Begin project. Air sampling will typically be collected on most environmental projects. Air sampling is a primary method of documenting a safe work environment during the abatement activities and a final means to allow engineering controls to be removed. Air sampling results should be forwarded to any trades and occupants entering the removal area after abatement.
- Obtain a project closeout package that includes the following items:
- Project dates, hours, parties involved, etc.
- Scope of work (used to update the building’s environmental inventory), including procedures, change conditions and any materials that were not able to be removed, or newly discovered materials and their status
- Waste manifests and recycling documentation
- Daily inspection reports, etc.
- Worker documentation
- Worker, perimeter and post remediation (clearance) air sampling results.