Asbestos Protocol

Revised May 2001

PURPOSE/SCOPE

This program outlines the University of Utah asbestos management procedure. The program is designed to provide guidance to University faculty, staff, students, contractors, consultants, and visitors in order to minimize and/or eliminate the possibility of exposure to airborne asbestos fibers.

The Asbestos Protocol covers the identification, maintenance, and removal, of regulated asbestos containing material in University facilities. It sets the requirements for public warning, building occupant notification, and employee training.

This protocol does not provide guidance for University operations in leased spaces. Until guidance is developed, contact the Director of Research Park who is the University's leasing agent.

DEFINITIONS:

ACM - Asbestos containing material. Any material containing more than 1% asbestos.

Class I Asbestos Work - Means activities involving the removal of thermal system insulation (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.

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.

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.

Contracting Department - For the purposes of this procedure, any department that contracts to have work done in University owned buildings and facilities; e.g., Campus Design and Construction, Plant Operations, Telecommunications, Hospital Facilities and Engineering, University Student Apartments, etc.

Friable asbestos - Material containing at least one percent asbestos which, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

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 those which involve 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 it to be not asbestos-containing. NOTE: This is an OSHA rule. Utah State regulations require the asbestos content of materials which will be disturbed to be determined prior to work taking place, regardless of the date of construction.

Regulated area - An area established by the empLoyer to demarcate areas where Class I, II, and III asbestos work is conducted, and any adjoining areas where debris and waste from such asbestos work accumulate; and a work area within which airborne concentrations of asbestos exceed, or there is a reasonable possibility they may exceed, the permissible exposure limits.

PROTOCOL

There is no thorough inventory of the buildings on campus, although the Divison of Facilities, Construction and Management(DFCM) is paying to have some buildings surveyed. New state regulations require the following:

"...the operator shall ensure that the structure or facility to be demolished or renovated is inspected for ACM by an inspector certified under the provisions of R307-801-6. An asbestos survey report shall be generated according to the provisions of R307-801-10. The operator shall make the asbestos survey report available on site to all persons who have access to the site for the duration of the renovation or demolition activities, and to the executive secretary upon request."

Although buildings constructed in the past two decades are not as likely to have asbestos materials, ALL projects are suspect unless the area has been tested. The Division of Air Quality takes the position that building materials may contain asbestos unless proven otherwise. EHS can help with this determination, depending upon the size of the project.

Operations in which any asbestos material is drilled, cut, abraded, sanded, chipped, broken, crushed, or sawed are not allowed.

Identification of ACM and PACM must be made by a state accredited inspector. Suspect materials must be tested for asbestos content prior to disturbing for any reason. Samples must be collected by a State accredited inspector. Samples must be analyzed by a NVLAP (National Voluntary Laboratory Accreditation Program) accredited laboratory.

There is currently no University asbestos abatement team. When work will result in the disturbance of asbestos containing materials, the materials should be removed by a state licensed asbestos abatement contractor, meeting University insurance requirements, prior to the work taking place. A recommended list of contractors is available from Purchasing and EHS.

All NESHAP-size abatement projects should be coordinated with the assistance of the University Environmental Health and Safety (EHS) department or a private industrial hygiene consulting firm.

Maintenance, telecommunications, and custodial activities where the limited disturbance of small quantities of ACM is incidental and unavoidable will be performed as outlined in the University Asbestos Operations and Maintenance Program.

All contractors (e.g., general, electrical, mechanical, etc.) must be informed of the University's posture regarding asbestos, including identification of known ACM locations.

RESPONSIBILITIES

Building Occupants

Follow procedures as outlined above.
Report any loose or damaged ACM or PACM to EHS.

Contracting Departments

Prepare bidding documents to ensure compliance with applicable asbestos regulations including advanced notification in accordance with State of Utah Department of Environmental Quality regulations.
Contract with Department of Environmental Quality licensed abatement contractors who also meet the University's insurance requirements. Variations in practice must be coordinated with EHS.
Ensure that any bulk samples that are collected are done so by a Department of Air Quality accredited inspector. Provide all results to EHS.
Provide appropriate communications to contractors, contract employees, and building occupants regarding the presence and removal of ACM and PACM.

Environmental Health and Safety

Coordinate the Asbestos Program. Develop and maintain a database.
Provide industrial hygiene consultation and service. Relay requirements to University supervisors and managers.
Collect bulk and air samples for analysis as requested or required, as feasible.

Maintenance, Telecommunications, and Custodial Supervisors

Ensure employees receive training on possible location of asbestos containing materials, hazards, and procedures for reporting incidents. Document training which should be conducted with all new personnel and annually thereafter.
Report asbestos incidents to EHS for follow-up.
Report any loose or damaged ACM or PACM to EHS.

Maintenance, Telecommunications, and Custodial Personnel

Perform duties as trained,
Report any loose or damaged ACM or PACM to EHS.

REFERENCES

Environmental Protection Agency, 40 CFR Part 61, National Emission Standards for Hazardous Air Pollutants

National Institute of Building Sciences, Asbestos Operations and Maintenance Work Practices Guidance Manual, 2nd Edition

Occuaptional Safety and Health Administration, 29 CFR Part 1910.1001 and 1910.1101

State of Utah Department of Environmental Quality, Utah Air Conservation Rules, R307-1-8

University of Utah, PPM 2-73, Environmental Health and Safety Policy

CONTACTS

Ms. Michele Johnson, Assistant Director, Environmental Health and Safety, University of Utah, 125 S. Fort Douglas Blvd. #605, SLC, UT 84113, (801) 581-6590

Mr. Jeff Throckmorton, Senior Industrial Hygienist, Environmental Health and Safety, University of Utah,125 S. Fort Douglas Blvd. #605, SLC, UT 84113, (801) 581-6590

Mr. Ben Datillo, State of Utah, Department of Environmental Quality, Division of Air Quality, 1950 W. North Temple, SLC, UT 84114-4820, (801) 536-4000

Ms. Tori Burns, Senior Industrial Hygienist, Industrial Commission of Utah, Occupational Safety and Health Division, 160 E. 300 South, 3rd Floor, P.O. Box 146650, SLC, UT 84114-6650, (801) 530-6901