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Guide to Handling Fugitive Dust from
Construction Projects
AGC OF WASHINGTON EDUCATION FOUNDATION
(
www.constructionfoundation.org
)
and the
FUGITIVE DUST TASK FORCE,
Seattle, Washington, 1997
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Updated and edited for the Internet by:
www.sheetflow.com
February 2009
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2.0 INTRODUCTION
Fugitive Dust is particulate matter that is suspend
ed in the air by wind or human
activities and does not come out of a stack.
Air quality regulations require the use of control
techniques to minimize Fugitive
Dust emissions. The goal is to eliminate visible a
irborne Fugitive Dust.
Therefore, state and local regulatory agencies expe
ct that as many of these control
techniques be employed as necessary to achieve this
goal.
2.1 Reasons for Fugitive Dust Control
Fugitive Dust from construction projects is regulat
ed by the Washington State air
quality laws for several reasons:
1.
Fugitive Dust can become a nuisance to neighbors by
depositing on their
property;
2.
Inhaling Fugitive Dust particles can cause respirat
ory diseases;
3.
Fugitive Dust can be a direct safety hazard.
2.2 Purpose of Brochure
This brochure is designed as a guide to provide pra
ctical examples of suggested
best management practices necessary to comply with
air quality regulations
involved in the construction process.
While Fugitive Dust can be created from a variety o
f activities, such as
agricultural activities, this brochure will focus o
n Fugitive Dust that is created by
construction activities. Air pollution from debris
burning, plant operations, rock
crushing and abrasive blasting, sometimes associate
d with construction activities,
and are dealt with in other regulations and publica
tions. For additional
information on the subject, the web sites of local
air quality agencies are listed in
the back of this brochure.
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3.0 WHY FUGITIVE DUST IS A PROBLEM
3.1 Nuisance
It is unlawful in the state of Washington to cause
or allow air contaminant
emissions in sufficient quantities and of such char
acteristics and duration that it
unreasonably interferes with enjoyment of life and
property.
3.2 Safety
Fugitive Dust from construction can reduce visibili
ty on roadways and highways,
resulting in traffic accidents.
3.3 Health
Fugitive Dust can also have significant health effe
cts if it is inhaled in large
amounts, or if dust contains crystalline silica, as
bestos fibers, heavy metals or
disease spores. Very small particles can be inhale
d deep into lungs and are a
particular health threat for the young, the old, an
d those with chronic respiratory
problems.
3.4 Construction
Fugitive Dust can be created directly from the acti
vities involved in construction,
such as moving soils or demolishing structures. Fu
gitive Dust can also be
generated by disturbing residual soils or materials
that have been left behind by
construction activities. For example, vehicles can
generate Fugitive Dust from
dirt on roadways that was tracked out as mud from c
onstruction sites.
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4.0 PRE-CONSTRUCTION PLANNING
Fugitive Dust control planning is a partnership bet
ween the owner, general
contractor, subcontractors and any other party whos
e activities during the project
may lead to the generation of Fugitive Dust. This
partnership extends to legal
responsibilities as well in that all parties can be
held liable for non-compliance
and subsequent regulatory actions, including moneta
ry penalties.
Incorporating Fugitive Dust control measures in the
plans and specifications of
the project can help ensure that the participants i
n the construction partnership
avoid violations of Fugitive Dust regulations. Ear
ly planning can also help
owners and project designers to “level the playing
field” in the competitive bid
process and avoid change orders.
4.1 Fugitive Dust Control Plan
A Fugitive Dust control plan might include:
1.
Identification of all Fugitive Dust Sources.
2.
A description of the Fugitive Dust control method(s
) to be used for each
source.
3.
A schedule, rate of application, calculations or so
me other means of
identifying how often, how much and when the contro
l method is to be
used.
4.
Provisions for monitoring and recordkeeping.
5.
A backup plan in case the first control plan does n
ot work or is inadequate.
6.
The name and phone number of the person responsible
for making sure the
plan is implemented and who can be contacted in the
event of a Fugitive
Dust complaint.
7.
Back-up or company phone number.
8.
Map or drawing of the site.
9.
Source and availability of materials such as water.
Weather, equipment and site conditions will require
that field personnel make on
the spot, common sense changes in order to address
the intent of the regulations.
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4.2 Inspection Checklist
Incorporating a simple inspection checklist during
the daily report process helps
make the tasks of Fugitive Dust control more routin
e. A checklist system reduces
paperwork, acts as a job reminder, and serves as a
record of efforts to minimize
Fugitive Dust problems. Categories that might be i
ncluded in the checklist are:
1.
Date
2.
Time
3.
Preventative measures
4.
Frequency of control measures application
5.
Weather conditions
6.
Comments
REMEMBER:
Fugitive Dust controls are only effective when they
are monitored and managed
through frequent inspections and maintenance of con
trol measures.
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5.0 SITE-SPECIFIC DESIGN CONSIDERATIONS
The specifics and level of complexity of each Fugit
ive Dust control plan will
depend on a number of factors that are specific to
each project. Consider the
following:
5.1 Cost of Alternatives
Several factors must be taken into consideration wh
en weighing various
alternatives. Cost considerations include:
1.
Unit cost,
2.
Total project cost,
3.
Acquisition cost,
4.
Maintenance cost,
5.
Cost of non-compliance,
6.
Capital cost, and the
7.
Cost of time waiting for product or application.
While one method may not be cost effective for larg
e projects because the unit
cost is high, it may be cost effective for small pr
ojects because the acquisition
cost is low.
5.2 Environmental Constraints
Water application is one of the best short term met
hods for controlling Fugitive
Dust. However, water runoff containing mud and sil
t can cause damage to
streams and other resources. A Fugitive Dust plan
should be considered in
conjunction with the overall Temporary Erosion and
Sediment Control (TESC)
plan. The Department of Ecology can be contacted f
or even more specific
information.
5.3 Location
The proximity of the project to populated areas may
dictate more controls, due to
anticipated impacts, than a project in a remote loc
ation. Wildlife habitats and
wetlands may also be affected by Fugitive Dust.
5.4 Project Size and Duration
The marketplace will not practically allow for the
same rigors of control to be
applied on all projects. For example, a land clear
ing project involving several
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acres or a major excavation project may call for tr
uck wheel washing facilities,
while this may not be practical for clearing a resi
dential lot. A project lasting
several months may call for more durable measures w
here one lasting several
days may rely solely on water.
5.5 Public Relations
Adopting a “good neighbor policy” by including a la
rge sign with the company or
job site phone number may help to make sure that lo
cal complaints are phoned
directly to the site, rather than to the regulators
. Controversial projects, or
projects that do not have a high level of community
support, are oftentimes under
more scrutiny. Care should be given to choosing no
t only the technically correct,
but aesthetically correct solutions.
5.6 Risk to Others (Sensitive Populations)
Fugitive Dust can have particularly adverse health
impacts on young children, the
elderly, and persons with respiratory problems. Th
us, additional control
Measures would be expected for a project near a hos
pital, nursing home, day care
facility, school, etc.
5.7 Site Conditions
Topography and soil type can make a difference in t
he control of Fugitive Dust.
Rocks and sand may be less dusty than hardpan, silt
s and clays. Hills, trees and
shrubbery can serve as natural windbreaks; however,
these are not control
measures and do not meet the requirements of air po
llution regulations. Soils that
are disturbed on tops of hills or on wide open flat
surfaces are more affected by
wind.
5.8 Weather
Moisture, in the form of rain and humidity, are nat
ural dust suppressants.
However, extremely rainy conditions can carry soil,
in the form of mud, to other
areas where it can dry and become a Fugitive Dust h
azard. Wind can intensify
Fugitive Dust problems.
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6.0 COMMON FUGITIVE DUST MANAGEMENT PRACTICES
The following is a list of commonly employed Fugiti
ve Dust management
practices for various dust sources. The best manag
ement practices for a particular
project should be selected based upon site-specific
considerations.
6.1 Graders and Scrapers
1.
Use water truck or sprinklers to moisten soils befo
re grading.
2.
Minimize areas of clearing and grubbing to a manage
able size.
3.
Minimize timeframes between Fugitive Dust-creating
activities and final
solutions (ex., roadway excavation and paving).
4.
Avoid activity during high winds.
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6.2 Front-End Loaders and Backhoes
1.
Use water truck to keep soils moist.
2.
Use water sprays (e.g. garden hose) when dumping so
ils into haul trucks.
3.
Minimize drop height.
4.
Avoid activity during high winds.
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6.3 Haul Trucks
1.
Wet loads with garden hose.
2.
Ensure adequate freeboard.
3.
Cover loads.
4.
Reduce speed on unpaved haul roads to less than 15
mph.
5.
Surface haul roads with gravel.
6.
Pave haul roads.
7.
Pave exit aprons.
8.
Surface exit aprons with quarry spalls (aka “rip ra
p”).
9.
Brush off mud from wheels, wheel wells, running boa
rds and tail gates.
10.
Wash wheels and inner fender wells immediately prio
r to exiting (note:
this control may require installation of a sediment
ation basin).
11.
Use street sweeper to remove trackout from paved ro
adways (note:
sweepers should be periodically checked to insure t
hat the water storage
tank is full and spray nozzles are in good working
order).
12.
Flush streets with water (note: this control may re
quire the installation of a
sedimentation basin).
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6.4 Demolitions
1.
Use water sprays (e.g., fire hoses) before, during
and after use of wrecking
ball or bulldozer.
2.
Avoid activity during high winds.
6.5 Renovations
1.
Use chutes and covered dumpsters for lowering dusty
materials (e.g.’
sheetrock) from multi-story buildings.
2.
Avoid activity during high winds.
6.6 Storage Piles
1.
Use sprinklers to keep piles moist.
2.
Use tarps to cover piles.
3.
Use soil stabilizers.
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7.0 DESCRIPTIONS OF BEST MANAGEMENT PRACTICES
Fugitive Dust emissions can be prevented and reduce
d in four basic ways:
1.
Limiting the creation or presence of dust-sized par
ticles.
2.
Reducing wind speed at ground level.
3.
Binding dust particles together.
4.
Capturing and removing Fugitive Dust from its sourc
es.
These Fugitive Dust control measures are not mutual
ly exclusive. Most situations
require the use of two or more of these methods in
combination for any particular
situation, and several methods will be employed to
handle the variety of situations
that make up a particular job.
7.1 Coverings – Fabric/other for Erosion Control
Fabrics and plastics for covering piles of soils an
d debris can be an effective
means to reduce Fugitive Dust. However, these mate
rials can be costly and are
subject to degradation from the sun, weather, and h
uman contact. Straw and hay
can also be used to cover exposed soil areas, altho
ugh they can be disturbed by
wind and track though.
7.2 Dust Suppressants – Chemical
There are many types and brands of Chemical Dust Su
ppressants which work by
binding lighter particles. Chemical Suppressants m
ay be applied as a surface
treatment to “seal” the top of an area, or may be a
pplied using an admix method
that blends the project with the top few inches of
the surface material.
Examples of these products include, but are not lim
ited to:
1.
Hydrolyzed starch derivatives,
2.
Calcium chloride,
3.
Magnesium chloride,
4.
Lignin derivatives,
5.
Tree resin emulsions, and
6.
Synthetic polymer emulsions.
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Other products, and properties of products, can be
found in the Department of
Ecology’s
“Techniques for Dust Prevention and Suppression”
( Ref.1, page 24),
as well as from many vendors.
USED OIL CAUTION:
It is important to note that used oil may
NOT
be used as a dust suppressant.
RCW 70.95-I
(apps.leg.wa.gov/RCW/default.aspx?cite=70.95I0) sp
ecifically
prohibits the use of used oil as dust suppressant,
and is referenced in the
“Applicable Washington Regulations” section of this
brochure.
7.3 Erosion Controls
Plants, bushes, trees, earthen banks and rock walls
provide natural, and more
permanent, windbreaks. Other erosion control measu
res, such as wood or porous
fences can be installed for temporary measures. Be
cause enclosures and wind
screens can be costly the feasibility of using this
type of control must be
determined on a case-by-case method.
7.4 Filter Fabric around Catch Basin
Filter fabric around a catch basin is used to colle
ct sediment from muddy water
run-off. Sediment, when left to dry, can cause Fug
itive Dust emissions.
Sediment collected in filtering systems must be dea
lt with on a regular basis.
Treating mud with flocculants, or “mucking out” cat
ch basins, are two methods to
deal with the residual debris.
7.5 Flocculating Agent
This is a method using a chemical agent to bind soi
l particles suspended in water
so that when the material dries it does not become
airborne. This method might
be used after a sediment catch basin is no longer n
eeded, but before water-
suspended soil can be dealt with in a more permanen
t way.
7.6 Minimize Disrupted Surface Area
A conscious effort, especially during sitework and/
or demolition, to disrupt only
those areas that absolutely need to be cleared in o
rder to accomplish a project can
provide a variety of benefits. Vegetation left in
place during sitework reduces the
area subject to wind erosion. In addition, minimiz
ing the disrupted surface area
can also reduce the size of the project, potentiall
y reducing the types and cost of
Fugitive Dust control. Disturbing natural soils cr
usts in some geographical areas,
such as Central and Eastern Washington, may unneces
sarily create Fugitive Dust
situations. Limiting vehicle access points to and
routes within a project help to
reduce these disruptions.
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7.7 Paving
This is a more permanent solution to Fugitive Dust
control, suitable for longer
duration projects or situations. High cost is the
major drawback to paving.
Paving may be an appropriate solution for access ro
ads to large development
projects, where the road can eventually be incorpor
ated in the overall plan for the
area. Another appropriate use of paving might be “
maintenance” projects such as
parking lots and staging areas, where gravel cover
is not adequate for Fugitive
Dust control or erosion.
David S. Jenkins - Port of Seattle
7.8 Stabilized Construction Entrance (Quarry Spalls
)
These are buffer areas that minimize the amount of
material tracked on to a
trafficked road surface, sometimes called “rock ent
rances”. These buffer areas
consist of very large aggregate, usually 4” to 8” c
rushed quarry rock, which jars
particles free from wheels and undercarriage, as ve
hicles travel over the quarry
spalls. This aggregate is sometimes laid over a fa
bric road carpet to increase
effectiveness.
7.9 Schedule Work
Rescheduling work around especially windy days can
potentially be one of the
least expensive and easiest Fugitive Dust control m
easures. This can also be a
totally impractical option if work crews are idle a
nd/or this is a project with
significant time constraints. It is also unreasona
ble to expect to discontinue work
in geographical areas that are prone to high and co
ntinuous winds. However,
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limited use of rescheduling in extreme weather cond
itions might be appropriate.
The high profile aspects of certain projects and po
pulation exposed should be
taken into consideration when scheduling especially
Fugitive Dust producing
work. Evenings and weekends are possible alternati
ves for scheduling work in
business and school locations; while mid-day may be
more appropriate for
residential areas because people are more likely to
be away from home.
7.10 Speed Reduction
High vehicle speeds increase the amount of Fugitive
Dust created from unpaved
roads and lots. Reducing the speed of a vehicle fr
om 45 to 35 miles per hour can
reduce emissions by up to 22 percent according to a
Washington State
Department of Ecology study ( Ref. 2, page 24). Ho
wever, no more than 5 to 15
miles per hour is recommended for most conditions.
Speed bumps are a
commonly used method to ensure speed reduction. In
cases where speed
reduction cannot effectively reduce Fugitive Dust,
it may be necessary to divert
traffic.
7.11 Street Sweepers
Street sweepers are often used in conjunction with
water. Some sweepers have a
spray as well as brushes. However, sweepers can sp
read mud when there is a lot
of wetness. Some sweepers, for parking lots and sm
aller jobs, actually have
vacuum systems to trap Fugitive Dust. Dry sweeping
is discouraged, especially in
very dry climate conditions, because it causes dust
particles to become airborne.
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7.12 Vehicle Spillage
Covers for haul trucks help to prevent soils and ot
her materials from being
dropped on roads. However, covering loads is not r
equired by state law if six
inches of freeboard is maintained within the bed of
the truck. Vehicles driving
over dirt and other debris tracked onto roads can c
ause significant Fugitive Dust
emissions. Reducing the drop height for loading eq
uipment, wet suppression, and
wind guards are effective ways of minimizing the Fu
gitive Dust created during
loading operations.
7.13 Water Spray
Water spray, whether it is through a simple hose fo
r small projects, or a water
truck for large projects, is an effective way to ke
ep Fugitive Dust under control.
Misting systems and sprinklers are mechanisms that
can be employed to deliver
continuous wetness. However, there are several con
straints in using water. Water
can be very costly for larger projects in compariso
n to other methods. Heavy
watering can also create mud, run-off, and environm
ental problems.
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7.14 Wheel Wash
A wheel wash is a method to remove mud and dirt fro
m wheels by driving
through a shallow trench filled with water or onto
an area where the wheel wells
and undercarriage can be hosed down. Care should b
e taken to keep the trench
deep enough so that it is effective, but not so dee
p that it interferes with the
mechanical operations of the vehicles. The trench
may be lined with asphalt to
ease maintenance in removing collected silt. A whe
el wash can be used in
conjunction with brooms or hoses to remove dirt fro
m other areas of vehicles.
Wheel washes must have a containment area to take c
are of the run-off.
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7.15 Vehicle Scrape
This is an alternative to a wheel wash when water d
isposal, or other
environmental constraints, are present. Establishi
ng a specific area where
compact dirt or mud is removed from ledges of dump
trucks, wheel wells, hitches,
tires, and other confined areas, will reduce track
out.
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8.0 APPLICABLE WASHINGTON REGULATIONS
It is important to make sure that your Fugitive Dus
t control practices comply with
federal, state and local laws. The following is a
list of some of the regulations
that apply; however contact your local Air Pollutio
n Control Agency, County
Health Department and/or Public Works Department to
find out the specific
requirements for the area in which your project is
located.
Local Air Pollution Control Agency Regulations:
Contact your local air pollution control agency for
the specific regulations
appropriate to the location of your project. These
agencies and their web sites are
listed on the last page of this brochure.
Chapter 70.94 RCW – Washington Clean Air Act
and
Chapter 173-400 W
ashington Administrative Code (W
AC)
(http://apps.leg.wa.gov/RCW/dispo.aspx?cite=70.94)
(http://apps.leg.wa.gov/WAC/default.aspx?cite=173-
400):
These statutes require owners and operators of Fugi
tive Dust sources to prevent
Fugitive Dust from becoming airborne and to maintai
n and operate sources to
minimize emissions.
Chapter 70.95-I RCW – Used Oil Recycling:
(http://(apps.leg.wa.gov/RCW/default.aspx?cite=70.
95I)
This law prohibits the use of used oil as a dust su
ppressant. Used oil includes any
oil that has been refined from crude oil, used, and
as a result of such use, is
contaminated by physical or chemical impurities. I
f you plan to use a chemical
suppressant, verify that it does not contain any us
ed oil as an ingredient. Also, be
certain that if the product contains fuel oil ingre
dients that the fuel oil does not
contain used oil.
Chapter 46.61.655 RCW – Dropping Load, Other Materi
als – Covering:
( http://apps.leg.wa.gov/rcw/default.aspx?cite=46.
61.655)
This regulation prohibits the discharge of debris f
rom vehicles and prescribes
minimum loading standards in lieu of covering truck
beds.
Chapter 90.48 RCW – Water Pollution Control:
(http://apps.leg.wa.gov/RCW/default.aspx?cite=90.4
)
Section .080 prohibits the discharge of any materia
l into surface or ground waters
that could cause pollution as defined in WAC 173-20
0-020(22). If your site is
near surface or ground water, use dust control meas
ures that have zero or minimal
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aquatic impact. If you decide to use a chemical du
st suppressant, select a product
with no aquatic toxicity.
Chapter 70.105 RCW – Hazardous Waste Management:
(http://apps.leg.wa.gov/RCW/default.aspx?cite=70.1
05)
This statute prohibits the disposal to the ground o
f any dangerous (hazardous)
waste. If you are planning to use a chemical dust
suppressant, make sure it does
not contain any dangerous waste ingredients.
Chapter 70.105D RCW – Hazardous Waste Cleanup – Mod
el Toxics Control
Act (MTCA):
(http://apps.leg.wa.gov/RCW/default.aspx?cite=70.1
05D)
This law requires the identification and cleanup of
hazardous sites. The
Department of Ecology can investigate reports of re
leases or the presence of
hazardous substances. If a hazardous product is us
ed as a dust suppressant and
Ecology later receives a complaint of contamination
, a site assessment may be
conducted.
Chapter 90.03 RCW – Surface Water Code and Chapter
90.44 RCW
Regulations of Public Ground Water (wells):
(http://apps.leg.wa.gov/RCW/default.aspx?cite=90.0
3)
This regulation requires a water right permit for a
ll surface water withdrawal and
for any water from a well that will exceed 5,000 ga
llons per day. If you plan to
use water, and have questions about, call the Depar
tment of Ecology’s Water
Resources Program.
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9.0 LOCAL AIR POLLUTION CONTROL AUTHORITIES
Department of Ecology – East Region
(
www.ecy.wa.gov/programs/air/airhome.html
)
Counties: Ferry, Stevens, Pend Oreille, Lincoln, G
rant, Adams, Whitman,
Franklin, Walla Walla, Columbia, Garfield, Asotin
Olympic Region Clean Air Agency
(
www.orcaa.org
)
Counties: Clallam, Jefferson, Grays Harbor, Pacifi
c, Thurston, Mason
Spokane Regional Clean Air Agency
(
www.spokanecleanair.org
)
County: Spokane
Northwest Clean Air Agency
(
www.spokanecleanair.org
)
Counties: Island, Whatcom, Skagit
Puget Sound Clean Air Agency
(
www.pscleanair.org
)
Counties: Snohomish, King, Pierce, Kitsap
Benton Clean Air Agency
(
www.bcaa.ne
)
County: Benton
Southwest Clean Air Agency
(
www.swcleanair.org
)
Counties: Lewis, Cowlitz, Clark, Skamania, Wahkiak
um
Department of Ecology – Northwest Region
(www.ecy.wa.gov/programs/air/airhome.html)
Yakima Regional Clean Air Agency
(
www.yakimacleanair.org
)
County: Yakima
Department of Ecology – Central Region
(
www.ecy.wa.gov/programs/air/airhome.html
)
Counties: Okanogan, Chelan, Douglas, Kittitas, Kli
ckitat
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10.0 PARTICIPATING ASSOCIATIONS
Asphalt Paving Association of Washington, Inc.
(www.asphaltwa.com/index.htm)
Associated Builder & Contractors of Western Washing
ton
(www.asphaltwa.com/index.htm)
Associated Builder & Contractors Inland Pacific Cha
pter
(www.ipcabc.org)
Associated General Contractors Inland Northwest Cha
pter
`
(www.nwagc.org)
Associated General Contractors of Washington
(www.agcwa.com)
Building Industry Association of Washington
(www.biaw.com/DesktopDefault.aspx)
Building Industry Association of Whatcom County
(www.biawc.com)
Central Washington Home Builders Association
(www.biawc.com)
Master Builders Assoc. of King and Snohomish Counti
es
(www.mba-ks.com/index.cfm)
Tri-City Construction Council
(www.tricityplancenter.com)
11.0 REFERENCES
1. Benedict, Mark-“Techniques for Dust Prevention a
nd Suppression”,
Washington State Dept. of Ecology, (Current Versio
n)
(
www.ecy.wa.gov/biblio/96433.html
)
2. "Guidelines for Cost Effective Use and Applicati
on of Dust Palliatives" published
Roads and Transportation Association of Canada. O
ctober 1986. A summary of
this report was published in the January, 1990
Public Works
magazine.