Unregulated Disposal of Asbestos Contaminated Shower Water Effluent: A Question of Public Health Risk
Kaplan, David E., Journal of Environmental Health
The disposal of specific toxic wastes and other hazardous substances into a public sewer or storm drain system is prohibited, and regulatory compliance is achieved through a combination of federal, state and local statutes. The plethora of materials includes waste oils, industrial chemicals, heavy metals, solvents, and just about anything else that poses a risk to public health. Unfortunately, it appears that a seemingly innocuous and often overlooked substance, asbestos, is unregulated when it comes to the disposal of waste shower water generated within an asbestos abatement decontamination facility. Perhaps this is in part due to the general understanding that cause-effect associated illness is long-term, rather than immediate, which helps create the illusion that asbestos is not of the same magnitude of danger as those prohibited substances. Many regulatory authorities, including Massachusetts, consider asbestos as a special rather than hazardous waste when it is time for disposal.
Standard work practices in asbestos abatement require proper personal hygiene and decontamination, which are performed in a typical decontamination facility as described by the U.S. Occupational Safety and Health Administration (OSHA), 1926.58 (J)(2)(iii), (1)--specifically, the removal of contaminated worksuits and showering prior to entering the "clean room." This procedure is required to minimize fibers leaving the worksite and contaminating those outside.
Contaminated clothing, equipment and tools which may be re-used are cleaned in the "dirty room," while personal protective equipment such as respirators are wet-wiped and eventually washed in the shower area to remove residual fibers. Assuming that waste shower water does indeed contain asbestos fibers, contractors generally pass this water through a 5.0 micron filter before disposal into a public system or a holding tank for future disposal in an approved landfill. The logic of this practice is commendable since it can help minimize water contamination. However, it appears that there are no federal regulations specifically requiring the filtration of waste shower water generated within a decontamination facility. This practice probably results from interpreting broadly OSHA's 1926.58, Appendix F, or believing that the U.S. Environmental Protection Agency (EPA) has a regulation which may apply to this very specific form of environmental water pollution. Perhaps such regulations do not exist at the federal level because the health effects of asbestos in water have so far been incompletely ascertained (2).
To say, quantitatively, just what poses a health risk from asbestos-tainted water may remain unanswerable for some time. Many studies of domestic water supplies have been conducted since asbestos was first reported in the 1973-1974 Lake Superior study (3). This early study of asbestos in the drinking water supply of Duluth, Minnesota, verified the existence of asbestos mineral fibers in concentrations which ranged from approximately 20 x 106 fibers/liter of water (5 to 30 micrograms of asbestos fiber per liter of water). An upper limit of fiber concentration did not appear to be clearly established.
The study attributed the concentrations to a mining operation that discharged its waste products to the bottom currents of Lake Superior. Other investigations in Kentucky, Washington and Pennsylvania have detected asbestos contamination in the water supplies from a variety of sources.
Whether ingestion of asbestos fibers, either by food or water, will have adverse health effects is unclear. None of these studies attempts to quantify safe limits of ingestion. Unlike occupational exposure which causes asbestosis, mesothelioma, other lung ailments, and also poses an increased risk for cancer, no one really knows the health risk of drinking fiber-contaminated water.
It seems unlikely that shower water from asbestos abatement projects would contribute significantly higher concentrations of fibers to a public water supply, given the dilution factor in the volume of water. …