2014 Conference on Monitoring and Surveillance of #Asbestos-Related Diseases. This presentation points out the transposition of European requirements in the French regulation and the two systems will be put in parallel throughout. The goal is also to describe the consequences of the French regulatory evolutions and their applications in workplace area.

1. Asbestos: recommendations for checking compliance
with the OEL
A.Romero-Hariot, C.Eypert-Blaison, R.Vincent
Our job: making yours safer
Espoo, FINLAND – 13 February 2014

2. Background
 The checking of the asbestos OEL is based on a common European
regulation
 European Directive 2009/148/EC (ex-2003/18/CE) on the protection of workers
from the risks related to exposure to asbestos at work (Articles 7 and 8)
 Transposed in the French Labor code regulations (R.4412-94 and following)
and several decrees
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0.1 F.cm-3, reference time of one hour,
PCM method
1 July 2012 1 July 2015
100 F.L-1, reference time of
8 hours , ATEM method
2009 2011
10 F.L-1,
8-h, ATEM
Regulations are based on nature of
asbestos (friable or non-friable asbestos)
Regulations are based on the level of dust
generated by the process

3. European / French regulations
 European Directive 2009/148/EC - Article 7 (1)
 Depending on the results of the initial risk assessment, and in order to
ensure compliance with the limit value laid down in Article 8,
measurement of asbestos fibers in the air at the workplace shall be
carried out regularly
 French regulations
> Initial risk assessment can be based on values known from previous evaluations, for
example experience from ATEM study, INRS databases like FIBREX or SCOLA, or other
studies …
> Compliance with the limit value is based on the asbestos fiber concentration generated
around the face of the worker when he is working on asbestos-containing material (ACM)
> Measurement shall be carried out regularly
• For ACM removal activity:
– The initial risk assessment requires a “work test” on the workplace for each worksite type
(i.e. combination of ACM and technique of removal)
– The level of concentration previously measured is checked three times a year per worksite
type
• For maintenance or other processes that may expose workers to asbestos (“Sporadic exposure”
in the meaning of the European directive)
– The initial risk assessment doesn’t necessarily require a “Work test”
– There is no specification on the number of checks
– Employers must nevertheless check OEL
– INRS recommends checking OEL a minimum of once a year per process
3
©A.Romero-Hariot/INRS
© A.Romero-Hariot / INRS

4. European / French regulations
 European Directive 2009/148/EC - Article 7 (2)
 Sampling must be representative of the personal exposure of the
worker to dust arising from asbestos or materials containing asbestos
 French regulations
> Dust arising from asbestos or ACM is measured in the air around the face of the worker
• Individual sampling, 30 cm maximum around the nose of the worker, each process is evaluated
• The dust level concentration is classified according to 3 levels:
> If asbestos concentration is higher than level 3, the technique must not be used because
the existing personal protective equipment cannot guarantee the protection of worker
under the OEL value
 INRS recommends performing 3 personal samplings and classifying the
dust level based on the highest value 4
1
• Asbestos concentration is under OEL value
• i.e. < 100 f.L-1 until 1 July 2015, < 10 f.L-1 from 1 July 2015
2
• Asbestos concentration is above the OEL value and below 60 times the OEL value
• i.e. between 100 and 6,000 f.L-1 until 1 July 2015, and between 10 and 600 f.L-1 after this date
3
• Asbestos concentration is above 60 times the the OEL value and below 250 times the OEL value
• i.e. between 6,000 and 25,000 f.L-1 until 1 July 2015, and between 600 and 2,500 f.L-1 after this date

5. European / French regulations
 European Directive 2009/148/EC - Article 7 (2)
 Sampling must be representative of the personal exposure of the worker
to dust arising from asbestos or materials containing asbestos
 French regulations
> Individual sampling during work situation for each process (i.e. ACM-Technique combination)
> When the worker wears a respiratory protective device, the assigned respiratory
protection factor is taken into account to calculate his exposure
5
Dust level Respiratory protective device, if dust level > 5 f.L-1 Assigned protection
factor (APF) - INRS
1st level FFP3 (only for maintenance and less than 15 mins)
Half mask with P3 filters or P3 cartridges
Full mask with P3 filters or P3 cartridges
TH3P
TM2P
TM3P
10
10 (Half mask)
30 (Full mask)
40
20
60
2nd level TM3P (160 L.min-1 flow rate)
Supplied Air Respirator (SAR) with continuous flow rate (300 L.min-1 flow rate)
Pressure-demand Supplied Air Respirator (SAR) (300 L.min-1 flow rate)
60
250
250
3rd level Supplied Air Respirator (SAR) with continuous flow rate (300 L.min-1 flow rate)
Pressure-demand Supplied Air Respirator (SAR) (300 L.min-1 flow rate)
Dustprof ventilated clothing (Nuclear clothing)
250
250
Undetermined

6. European / French regulations
 European Directive 2009/148/EC – Art. 7 (3) & Art. 7 (4)
 Sampling shall be carried out after consultation of the workers and/or their
representatives within the undertaking or establishment
 Sampling shall be carried out by suitably qualified personnel. The samples
taken shall be subsequently analysed, in accordance with paragraph 6, in
laboratories equipped for fiber counting
 French regulations
> Workers are consulted through their representatives (CHSCT)
> The sampling strategy, the sampling and the analysis are defined and conducted by an
accredited body, with the employer’s assistance
> The sampling strategy is submitted to the occupational physician
> Head quality and Laboratory responsible of the organism follow a specific training in
accordance with the accreditation requirement (COFRAC)
> ATEM indirect method for counting asbestos fibers according to the French standard NF X 43-
050 (1996) is applied
 Although analysis may be entrusted to a different laboratory, INRS
recommends that the entire evaluation (strategy – sampling – analysis) be
performed by the same body in order to minimize errors at each step of the
evaluation 6

7. European / French regulations
 European Directive 2009/148/EC – Art. 7 (5)
 The duration of sampling must be such that representative exposure can be
established for an 8-hour reference period (one shift) by means of
measurements or time-weighted calculation
 French regulations
> A non-stop shift when wearing respiratory protective equipement cannot exceed 2hours 30mins,
and the total time wearing the equipment cannot exceed 6 hours a day
> The reference period for checking OEL compliance is 8 hours
> Either the measurements (successive sampling when possible) or the time-weighted calculation
based on the pre-evaluated dust level, can be used to check the OEL compliance
> Determination of sampling duration is based on recommendations in:
• the French guideline GA X 46-033 (2012) corresponding to the ISO 16000-7 standard “Indoor air – part 7:
Sampling strategy for determination of airborne asbestos fiber concentrations”
• the French standard XP X 43-269 (2012) “Air quality — Workplace atmospheres — Sampling on membrane
filters for the determination of the fiber number concentration by microscopic techniques: phase contrast
optical microscopy, scanning electron microscopy analysis and transmission electron microscopy analysis —
Counting by phase contrast optical microscopy”
 INRS recommends taking into account an analytical sensitivity of 1 f.L-1 for
very low dust situations in order to be able to compare the result with the OEL
at 10 f.L-1 entering into force 1 July 2015; i.e., a minimum of 1hour 10mins sampling is
required if two filters are sampled simultaneously at a 3 L.min-1 flow rate, and if these two
filters are fully processed together to give one single result 7
© C.Eypert-Blaison / INRS

8. European / French regulations
8
© C.Eypert-Blaison INRS
 European Directive 2009/148/EC – Art. 7 (6) & Art 7 (7)
 Fiber counting shall be carried out wherever possible by phase-
contrast microscope (PCM) in accordance with the method
recommended in 1997 by the World Health Organization (WHO) or
any other method giving equivalent results
 For the purpose of measuring asbestos in the air, as referred to in
paragraph 1, only fibers with a length of more than 5
micrometres, a breadth of less than 3 µm and a length/
breadth ratio greater than 3:1 shall be taken into consideration
 French regulation
> PCM doesn’t count only asbestos fibers, and doesn’t take into account the
thinnest of them
> PCM underestimates the number of asbestos fibers compared to ATEM
• ATEM method has been adopted since July 2012
> WHO size criteria takes into account (L > 5 µm, D < 3 µm, L/D > 3)
> The French standard NF X 43-050 (1996) “Air quality – Determination of
asbestos fibers concentration by transmission electron microscopy – Indirect
method” has been adopted
> A minimum of 4 grid openings and a maximum of 60 grid openings are observed
for the counting or 100 asbestos fibers

9. European / French regulations
 European Directive 2009/148/EC – Art. 8
 Employers shall ensure that no worker is exposed to an airborne concentration
of asbestos in excess of 0.1 fibers per cm3 as an 8-hour time-weighted
average (TWA)
 French regulations
> 100 f.L-1 8-hour TWA until 1 July 2015, 10 f.L-1 after this date
> Example for checking OEL, based on previous evaluation of each process
http://www.inrs.fr/accueil/produits/mediatheque/doc/publications.html?refINRS=NT%201
9
© A.Romero-Hariot / INRS
Schedule
Duration
of working
phase
Process
concerned
Dust level
of the pre-
evaluated
process
Type of
respiratory
protective
device
worn
Assigned
protection
factor of
respiratory
device
9:00 a.m –
11:00 a.m
2 hours P1: grinding
plaster 24,000 f.L-1
Presure-
demand
SAR
250
11:00 a.m –
12:30 p.m
1,5 hours lunch - None -
12:30 p.m –
15:00 p.m.
2,5 hours P2: scraping
vinyl floor tiles
with a spatula
574 f.L-1
TM3P
60
8-hour TWA
=
2x (24000/250)
+ 8
2,5x (574/60)
=
27 f.L-1
This result is consistent with
the OEL in force but will not
be effective 1July 2015

10. Titre de la présentation04/07/2014 10
Thank you for your attention
Our job: making yours safer
www.inrs.fr