Buyer Beware: Managing EHS Aspects of Facilities

EHS professionals should be on the front line in assuring that the purchase and renovation of buildings hold no health and safety booby traps.

The purchase and development of a building or property is often conducted without thoroughly evaluating environmental, health and safety (EHS) concerns. Assessing facility-related EHS issues can reduce the potential for unforeseen costs, scheduling delays and potential exposures to environmental contaminants. Properly managing the EHS aspects of a facility can also add considerable value to buildings and properties.

Regulatory requirements and best practices relating to EHS management throughout a property's life-cycle are examined in this article. These elements include:

  • "Due diligence" when acquiring a property
  • Renovation or demolition of a property
  • New construction
  • Operations and management of existing properties
  • Facility decommissioning, and
  • Site remediation

Pre-Purchase Due Diligence

An environmental site assessment (ESA) should be performed prior to purchase. ESAs should be conducted in accordance with ASTM standard E 1527-00 and performed by a qualified environmental professional. ESAs are the most common tool for evaluating a site's history and potential environmental liability.

Phase I ESAs involve non-intrusive investigative techniques to identify current and past (historical) use at the subject property, and the potential effects of that use on the subject and adjoining properties. If a Phase I assessment indicates a potential environmental concern, a Phase II ESA should be conducted to further define the extent of the identified concern (this generally involves intrusive environmental sampling techniques).

Properly conducted ESAs enable corporate managers, borrowers, investors and lenders to fulfill due diligence requirements for all types of properties and transactions (before purchase, sale, development, refinancing or foreclosure). The importance of this information is related to how it affects the property's value. Properties that have a "clean bill of health" are worth more than properties with environmental impairments.

In addition to standard ESAs, many purchasers and lending institutions require additional building investigations as part of due diligence, including:

  • Indoor environmental quality (IEQ) assessments,
  • Mold evaluations,
  • Asbestos surveys, and
  • Lead investigations.

The results of these investigations can also have a dramatic effect on property values. Generally, these pre-purchase inspections are non-destructive and include a complete walk-through of the building to identify visible signs of water incursion or mold growth, accessible suspect asbestos-containing material (ACM), and deteriorated suspect lead-containing paint (LCP).

Pre-purchase inspections may also include observing maintenance procedures and schedules as well as reviewing available historical documents. Limited sampling may be performed; however, assessments performed as part of due diligence are generally not adequate for renovation or demolition.

Operations and Maintenance

If regulated materials are present in a building (such as ACM, LCP, contaminated drinking water, etc.), a written Operations and Maintenance (O&M) program should be developed to reduce EHS liabilities and control costs.

O&M programs should include survey information identifying regulated building materials as well as descriptions concerning the location, extent and condition of the materials. They should also outline standard operating procedures for maintaining these materials, such as:

  • Maintenance schedules
  • Inspection schedules
  • Personnel training requirements
  • Handling procedures, and
  • Emergency response procedures

O&M programs should be continuously updated to reflect current site conditions. Depending on the size and complexity of a site, the building owner or manager should consider incorporating the use of computer-based technologies (such as databases and geographical information systems) to more efficiently implement and sustain the O&M program.

Building Demolition and Facility Decommissioning

When building demolition is planned, a number of environmental issues must be addressed. In many industrial and manufacturing facilities, process and production equipment must be decommissioned. This requires a thorough understanding of the processes, including knowledge of all raw materials, intermediates, finished products and waste streams.

Prior to building demolition, buildings should be surveyed for building materials that may require removal or special handling procedures. These include:

  • ACM,
  • LCP,
  • Mold,
  • PCB-containing electrical components,
  • Mercury-containing light tubes, switches, and thermostats,
  • Underground storage tanks (USTs),
  • Aboveground storage tanks (ASTs),
  • Refrigerants, and
  • Other remaining miscellaneous chemicals/products.

Surveys for some of these regulated building materials require qualified EHS personnel who are licensed to perform this type of work. Accreditations, certifications and other requirements for performing asbestos and lead inspections are specified by federal, state and local regulations.

A pre-demolition survey is usually destructive and requires sampling of suspect materials. Accredited building inspectors should perform asbestos surveys (additional state licensing may be required). The asbestos survey should identify the presence, location and quantity of ACM in the building. The age of the building does not preclude it from survey requirements. Asbestos is still present in some building materials that are currently on the market (e.g., roofing materials).

A pre-demolition lead survey should include identification of LCP. The presence of LCP should be communicated to contractors bidding on the demolition or performing work in the structure (including salvage contractors).

Generally, fluorescent light fixtures should be inspected for ballasts and tubes. Inspectors should look for labeling on the ballasts. If the ballast does not have a label indicating "No-PCBs," then the ballast is assumed to contain PCBs. Inspectors should also look for staining associated with older ballasts, which may require disposal prior to demolition. An overall count of potential PCB-containing ballasts (including observed leaking units) and the quantity of mercury-containing light tubes and thermostats should be reported. These materials must be removed prior to building demolition and either recycled or disposed of in accordance with federal, state and local regulations.

Following the completion of the building materials survey, the owner should contract with a qualified EHS consultant to develop abatement or remediation bid documents, including contract documents, technical specifications and drawings. These documents should be clear and concise. They should also follow industry standards such as those developed by the Construction Standards Institute (CSI). This approach allows owners to obtain "apples-to-apples" bids from various contractors, which can improve quality and control project costs.

During remediation, a qualified EHS professional should provide oversight to ensure compliance with applicable regulations and contract documents. At the completion of the project, clearance inspections and sampling should be conducted, as necessary.

Project records should be used to document the procedures followed (they should be retained by the owner). This documentation is helpful when the property is ready to be sold.

Building Renovation

If structures are scheduled for renovation, similar surveys should be performed. In the case of renovation, it is crucial for EHS professionals to understand the complete scope of the project. They should attend design meetings in order to completely understand how the renovation will impact all areas of the building. If the EHS professional is included in the early stages of the planning and design process, significant schedule delays and material impacts can be minimized. For example, if the electrical engineer for the project indicates that new conduit must be installed above the ceiling, the EHS professional can recommend preferred areas for the conduit to be installed (in order to minimize impacts to ACM).

The cost of removing materials such as asbestos is often lower during renovation, since interior demolition may increase the accessibility of the ACM. EHS professionals should review the short-term and long-term costs of leaving regulated building materials in place. When these materials remain in place, an O&M program should be developed and implemented.

Site Remediation

Soil and groundwater remediation may be necessary prior to site redevelopment. Underground storage tanks and/or contaminated soil may need to be removed. Risk assessment methodologies may allow some level of contamination to remain underground. Because of this, excavation activities associated with site redevelopment may trigger additional remediation requirements.

Properly conducted ESAs will help identify these issues and assist in developing the appropriate regulatory strategy that can be the cornerstone of significant cost savings. Property owners and developers need to have a clear understanding of these issues before appropriate cleanup criteria and procedures are determined.

Clear documentation of site remediation activities and active O&M programs can help increase the property's value when it is sold.

New Building Design and Construction

During the design process for a new building, a review of the design should be performed to address EHS concerns. Indoor environmental quality (IEQ) issues (including the selection of finishing materials, furnishings and HVAC systems) should be reviewed. Selection and use of "green" building products can help minimize odor complaints and other IEQ concerns.

During construction, periodic inspections of porous building materials that are being installed should be performed (especially for moisture content). The use of mold-contaminated lumber and other building materials can result in significant IEQ issues. The building envelope (i.e., windows, doors, wall systems and roofing) should also be inspected during construction.

Conclusion

The redevelopment of properties often involves planning and integration of environmental remediation activities. EHS professionals can assist developers, redevelopment agencies and owners, as well as facility operators, in mitigating the environmental impacts that often go hand in hand with these efforts.

Understanding and managing EHS-related issues throughout the life of a property facilitates compliance with regulations, reduces potential liabilities and leverages property values.

Nicole Gladu is manager, Occupational Health and Safety, for the Portland Regional Office of Clayton Group Services. She has more than 13 years of experience in environmental health and safety. As an EPA Asbestos Hazard Emergency Response Act (AHERA)-certified building Inspector, management planner, and project designer, she specializes in managing projects involving asbestos-containing materials (ACM) and lead-based paint (LBP) for public- and private-sector clients.

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