Asbestos O & M

UNIVERSITY OF UTAH
Revised May 2001

ASBESTOS OPERATIONS AND MAINTENANCE PROGRAM

PURPOSE/SCOPE

This program has been developed to provide guidance and assistance to University custodial, telecommunications, and maintenance staff and others concerned with the presence of asbestos and asbestos containing materials in University buildings. This information is intended to establish actions to be taken during maintenance, telecommunications, and renovation activities in order to prevent asbestos from becoming an airborne hazard.

Under current policy, operations involving either asbestos abatement or disturbance of asbestos materials must not be performed by maintenance, telecommunications, or custodial personnel. Under this plan, operations in which any asbestos material is drilled, cut, abraded, sanded, chipped, broken, crushed, sawed, or made friable are not allowed. Materials which must be so treated must have the asbestos abated, or be handled, by a licensed abatement firm. Contact the Environmental, Health and Safety office at 581-6590 for assistance when abatement or special handling of asbestos materials is needed.

INTRODUCTION

It has been estimated that asbestos was used in excess of 3,000 building products. The issue is made more confusing by the fact that in many cases the same material or same type of material manufactured at different times might or might not contain asbestos. At the University, materials which may contain asbestos can include the following. This list is not all inclusive.

Materials made with transite (cement asbestos) including roof and exterior shingles, siding, and pipe,
Vinyl and asphalt flooring (linoleum or tile), and the cove base, including the backing and mastics,
Acoustic texturing, decorative wall and ceiling plaster, paints (rare), spackles, coatings, and wallboard mud,
Ceiling tiles, and lay-in panels,
Thermal system insulation, including spray-applied, blown-in, boiler, breeching, and pipe insulation,
Fireproofing materials, including blankets, curtains, counter tops, gloves, electrical wiring insulation, and cloth,
Roofing materials, including tars, and underlayments,
HVAC ductwork flexible fabric connections and insulation,
Packing materials, gaskets, felts, caulking, putties, joint compounds, and adhesives.
Laboratory countertops, sinks, and the lining of laboratory fume hoods

Asbestos may be found in other items not covered on this list.

DEFINITIONS

ACM - Asbestos containing material. Any material containing more than 1% asbestos
Competent Person - One who is capable of identifying existing asbestos hazards in the workplace and selecting the appropriate control strategy for asbestos exposure and who has the authority to take prompt corrective measures to eliminate them.
Negative Exposure Assessment - A demonstration by means of analytical sampling and assessment that employee exposure during an operation is expected to be consistently below OSHA permissible exposure limits.
NESHAP - National Emissions Standards for Hazardous Air Pollutants. NESHAP-size projects are at least 260 linear feet of friable asbestos on pipes or 160 square feet of friable asbestos on other surfaces, or at least 35 cubic feet of friable asbestos on components not previously measured.
OSHA - Occupational Safety and Health Administration.
PACM - Presumed asbestos containing material. Thermal system insulation and surfacing material found in buildings constructed no later than 1980. Asphalt and vinyl flooring material installed no later than 1980 must also be considered as asbestos containing unless the employer determines them to be asbestos free. NOTE: This is an OSHA rule. Utah State regulations require the asbestos content of materials which will be distrubed to be determined prior to work taking place, regardless of the date of construction.
Regulated area - A demarcated area where the airborne concentrations of asbestos exceed, or there is a reasonable possibility they may exceed, the permissible exposure limits.

INVENTORY

No work activity which involves the disturbance of suspect materials may be performed until those materials have been tested to see if they contain asbestos.

At the present time, a comprehensive inventory of all materials in each University building has not been made. Surveys which have been completed are maintained by the Environmental Health and Safety office. Contact EHS at 581-6590 before work is started to determine if the necessary samples have been taken, or if it is necessary to collect samples for analysis. Material must not be disturbed until a determination is made whether or not asbestos is present.

HAZARD POTENTIAL

From a regulatory standpoint, asbestos is called by six different names, each describing a different mineral form: chrysotile, amosite, crocidolite, tremolite, anthophyllite, and actionolite. Asbestos was used in products because of its strength, resistance to heat and chemical attack, and durability. The percent of asbestos found in a material can vary widely. The only way to adequately determine if a material contains asbestos is by laboratory analysis. OSHA defines "asbestos containing material" (ACM) as any material containing more than one percent asbestos.

Asbestos fibers are a hazard by inhalation, causing a variety of lung diseases and cancers. The risk is related to the extent to which asbestos fibers become airborne and are inhaled. Airborne asbestos fibers which are harmful to the body are so small that it is not possible to tell if unsafe airborne levels exist by simple visual observation. For this reason, all reasonable steps possible must be taken to prevent the fibers from becoming airborne, and established procedures must be followed. Generally this involves the same methods which would be used to keep any dust from becoming airborne.

The risk from asbestos is partially related to its degree of "friability." The term friable means that the dry material can be crumbled, pulverized or reduced to powder by hand pressure. Obviously the more friable a material is, the greater the potential for the release of dust; e.g., floor tiles are not considered friable; acoustical ceiling texturing and ceiling tiles are friable.

RESPONSIBILITIES

--Subcontractors

Particular care must be taken before allowing outside contractors to work on or near asbestos containing materials. All contractors must be provided with information about the location of known or suspected asbestos containing material(s) in the building. Project Managers must require evidence that the contractor is familiar with the O&M program, has experience working around asbestos containing materials, and has adequately trained workers. Only workers with the necessary training, state certifications, and company license may actually abate or disturb asbestos materials.

PROHIBITED ACTIVITIES

Custodial, telecommunications, and maintenance staff must ensure that their activities do not damage or further disturb asbestos containing materials. Custodial, telecommunication, maintenance staff, and building occupants are instructed:

not to drill holes into asbestos containing material,
not to hang pictures or plants on structures covered with asbestos containing materials,
not to sand asbestos containing floor tiles, hard board panels or other non-friable materials,
not to damage asbestos containing materials while moving furniture or other objects,
not to install curtains, drapes, or dividers in such a way that they damage asbestos containing materials,
not to dust floors, ceilings, moldings or other surfaces in an asbestos containing environment with a dry brush or sweep with a broom,
not to use an ordinary vacuum to clean up asbestos containing debris,
not to use compressed air to remove asbestos, or materials containing asbestos,
not to remove ventilation system filters dry,
not to shake ventilation system filters,
not to perform any other task which would cause the airborne release of asbestos fibers.

When any work near or on asbestos containing materials will result in the material being disturbed, qualified asbestos abatement contractors should be considered for the work.

PERIODIC SURVEILLANCE
Periodic review of the condition of asbestos materials is essential to ensure that the program is addressing the needs of the occupants of the building, custodial, telecommunications, maintenance staff, and outside contractors. Maintenance, telecommunications, and custodial personnel are asked to be alert for any damage to known asbestos containing materials, and report this damage to EHS so that corrective actions can be taken. This would include:

Evidence of physical damage;
Evidence of water damage;
Evidence of delamination or other deterioration;
Degree of accessibility of the material; and,
Degree of activity near the material;

If damage is noted immediately notify your supervisor or Environmental Health and Safety at 1-6590. Do not let a potentially unsafe condition go unreported.

Applicable regulations and guidelines

Regulatory agencies which address the handling and removal of asbestos include:
The State of Utah (Department of Environmental Quality Utah Air Conservation Rules)
OSHA (Construction [1926.1101] and General Industry [1910.1001] standards)
EPA (NESHAP, AHERA, Model Accreditation, Worker protection)

A detailed review of these regulations is beyond the scope of this summary reference. The regulations are complicated, and the full text documents should be referenced for a complete understandng of what is required. Portions of the OSHA regulations are summarized below.

OSHA REQUIREMENTS

There are two OSHA standards which apply to work around asbestos at the University:

The General Industry Standard (1910.1001).
The Construction Standard (1926.1101).

The regulations and accompanying requirements are different, depending upon the work done. Asbestos abatement work, and maintenance work which involves the deliberate disturbance of asbestos is covered by the Construction Standard.

--OSHA Work Categories

The following definitions from the OSHA construction standard are important to understanding the University O&M policy. This O&M policy addresses only Class IV work, and work as addressed in the General Industry Standard. Class I, II, and III work is beyond the scope of work recognized or authorized in this document.

"Class I asbestos work" means activities involving the removal of TSI and surfacing ACM and PACM.
"Class II asbestos work" means activities involving the removal of ACM which is not thermal system insulation or surfacing material. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics.
"Class III asbestos work" means repair and maintenance operations, where "ACM", including TSI and surfacing ACM and PACM, is likely to be disturbed.
OSHA has clarified this definition as follows: Class III asbestos work is defined as repair and maintenance activities involving intentional disturbance disturbance of ACM/PACM. Class III is limited to incidental cutting away of small amounts (less than a single standard waste bag) of ACM/PACM, for example to access an electrical box for repair, or repair a valve.
"Class IV asbestos work" means maintenance and custodial activities during which employees contact but do not disturb ACM or PACM and activities to clean up dust, waste and debris resulting from Class I, II, and III activities.
OSHA has clarified this definition as follows: Class IV work is defined as maintenance and custodial activities during which employees contact ACM and PACM and activities to clean up waste and debris containing ACM and PACM. This includes dusting surfaces, vacuuming carpets, mopping floors, cleaning up ACM or PACM materials from thermal system insulation or surfacing ACM/PACM. Incidental disturbance could include activities such as changing a battery in a smoke detector attached to a ceiling containing ACM or PACM; polishing floors containing asbestos, and changing a light bulb in a fixture attached to an asbestos containing ceiling.

--Permissible exposure limits

Both OSHA regulations establish two permissible limits for asbestos: an eight hour time weighted average of 0.1 fibers/cc, and a thirty minute excursion limit of 1.0 fibers cc. The purpose of the excursion limit is to evaluate brief work operations which generate higher dust levels for short periods of time. The daily average limit of 0.1 fibers/cc cannot be exceeded, in any case, however. These limits are not definite "safe" and "unsafe" values, but regulatory guidelines. All workers should take prudent steps to prevent the generation of asbestos dusts, and avoid the inhalation of fibers to the extent possible.

WORK PRACTICES AND OSHA

Specific requirements mandated by OSHA for Class IV work from the construction standard, as well as housekeeping work from the General Industry Standard, are summarized in the following main sections. The full text of the OSHA standard should referenced for complete details. Environmental Health and Safety can be consulted for further information.

CONSTRUCTION STANDARD (29CFR 1926.1101)

--Class IV work requirements. The following work practices are specific for Class IV work (Maintenance and Custodial Activities). Other classes of work are not covered in this document

Competent person: For Class IV jobs, on-site inspections shall be made at intervals sufficient to assess whether conditions have changed, and at any reasonable time at employee request.
Methods of compliance: The employer shall use the following engineering controls and work practices in all operations covered by this section, regardless of the levels of exposure:

Vacuum cleaners: Vacuum cleaners equipped with HEPA filters to collect all debris and dust containing ACM and PACM, except in the case of roofing material.

Wet methods: Wet methods, or wetting agents, to control employee exposures during asbestos...cleanup, except where employers demonstrate that the use of wet methods is infeasible due to for example, the creation of electrical hazards, equipment malfunction, and, in roofing as explained in the standard.

Prompt clean-up: Prompt clean-up and disposal of wastes and debris contaminated with asbestos in leak-tight containers.

Prohibitions: The following work practices and engineering controls shall not be used for work related to asbestos or for work which disturbs ACM or PACM, regardless of measured levels of asbestos exposure or the results of initial exposure assessments:

Compressed air: Compressed air used to remove asbestos, or materials containing asbestos, unless the compressed air is used in conjunction with an enclosed ventilation system designed to capture the dust cloud created by the compressed air.

Dry sweeping: Dry sweeping, shoveling or other dry clean-up of dust and debris containing ACM and PACM.

Employee rotation: Employee rotation as a means of reducing employee exposure to asbestos.

Respirators: Respirators will be worn during Class IV work performed within regulated areas where employees performing other work are required to wear respirators. This basicially means if there is exposure in excess of the permissible exposure limits.
Training: Training for employees performing Class IV operations shall be consistent with EPA requirements for training of local education agency maintenance and custodial staff as set forth at 40 CFR 763.92(a)(1). Such a course shall include available information concerning the locations of thermal system insulation and surfacing ACM/PACM, and asbestos-containing flooring material, or flooring material where the absence of asbestos has not yet been certified; and instruction in recognition of damage, deterioration, and delamination of asbestos containing building materials. Such course shall take at least 2 hours.

--Housekeeping:

Vacuuming. Where vacuuming methods are selected, HEPA filtered vacuuming equipment must be used. The equipment shall be used and emptied in a manner that minimizes the reentry of asbestos into the workplace.
Waste disposal. Asbestos waste, scrap, debris, bags, containers, equipment, and contaminated clothing consigned for disposal shall be collected and disposed of in sealed, labeled, impermeable bags or other closed, labeled, impermeable containers except in roofing operations (as specified).
Flooring. Care of asbestos-containing flooring material.

(i) All vinyl and asphalt flooring material shall be maintained in accordance with this paragraph unless the building/facility owner demonstrates, that the flooring does not contain asbestos.
(ii) Sanding of flooring material is prohibited.
(iii) Stripping of finishes shall be conducted using low abrasion pads at speeds lower than 300 rpm and wet methods.
(iv) Burnishing or dry buffing may be performed only on flooring which has sufficient finish so that the pad cannot contact the flooring material.

Waste disposal. Waste and debris and accompanying dust in an area containing accessible thermal system insulation or surfacing ACM/PACM or visibly deteriorated ACM:

(i) shall not be dusted or swept dry, or vacuumed without using a HEPA filter;
(ii) shall be promptly cleaned up and disposed of in leak tight containers.

--Competent person: For Class IV jobs, on-site inspections shall be made at intervals sufficient to assess whether conditions have changed, and at any reasonable time at employee request.

GENERAL INDUSTRY STANDARD (29CFR1910.1001)

--Housekeeping Requirements

Although houskeeping has been addressed in the above section, the OSHA General Industry Standard has a specific section (k) on this activity. The requirements follow:

(1) All surfaces shall be maintained as free as practicable of ACM waste and debris and accompanying dust.

(2) All spills and sudden releases of material containing asbestos shall be cleaned up as soon as possible.

(3) Surfaces contaminated with asbestos may not be cleaned by the use of compressed air.

(4) Vacuuming. HEPA-filtered vacuuming equipment shall be used for vacuuming asbestos containing waste and debris. The equipment shall be used and emptied in a manner which minimizes the reentry of asbestos into the workplace.

(5) Shoveling, dry sweeping and dry clean-up of asbestos may be used only where vacuuming and/or wet cleaning are not feasible.

(6) Waste disposal. Waste, scrap, debris, bags, containers, equipment,and clothing contaminated with asbestos consigned for disposal, shall be collected, recycled and disposed of in sealed impermeable bags, or other closed, impermeable containers.

(7) Care of asbestos-containing flooring material.

(i) Sanding of asbestos-containing floor material is prohibited.
(ii) Stripping of finishes shall be conducted using low abrasion pads at speeds lower than 300 rpm and wet methods.
(iii) Burnishing or dry buffing may be performed only on asbestos-containing flooring which has sufficient finish so that the pad cannot contact the asbestos-containing material.

(8) Waste and debris and accompanying dust in an areas containing accessible ACM and/or PACM or visibly deteriorated ACM, shall not be dusted or swept dry, or vacuumed without using a HEPA filter.