DOCUMENT RESUME

ED 326 981 EA 022 545

TITLE Managing Asbestos in Place: A Building Owner's Guideto Operations and Maintenance Programs forAsbestos-Containing Materials.

INSTITUTION Environmental Protection Agency, Washington, D. C.REPORT NO TS-799PUB DATE Jul 90NOTE 50p.

PUB TYPE Guides - Non-Classroom Use (055)

EDRS PRICE MF01/PCO2 Plus Postage.DESCRIPTORS *Asbestos; *Building Operation; Environmental

Standards; Facility Improvement; Federal Regulation;*Hazardous Materials; Maintenance; OccupationalSafety and Health; Operating Expenses; ProgramDevelopment

IDENTIFIERS *Environmental Protection Agency

ABSTRACTInstructions for building owners on the selection and

application of appropriate asbestos control and abatement actions arepresented in this guidebook. Chapter 1 offers background informationon the asbestos problem. Chapter 2 describes the purpose and scope ofan operations and maintenance (O&M) program. The third chapterdiscusses planning steps, including a survey and evaluation ofasbestos-containing materials and program implementation andmanagement, with a focus on cost. Work practices, recordkeepingsuggestions and requirements, and elements of an O&M program aredescribed in chapter 4. Chapter 5 offers training recommendations forworkers performing O&M activities, and the last chapter provides anoverview of federal, state, and local regulations. Appendices containa glossary, sample recordkeeping forms, organization charts,additional assistance contacts, respiratory protectionrecommendations, existing EPA guidance, and a sample list of suspectasbestos-containing materials. (16 references) (LMI)

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Contents

ACKNOWLEDGEMENTS v

FOREWORD vii

1. WHY IS ASBESTOS A PROBLEM?

Introduction and Overview 1

Background 2

Chapter Summary 4

2. WHAT IS AN O&M PROGRAM?

Purpose and Scope of an Operations and Maintenance Program 5

Purpose of O&M Program 5

Scope of an O&M Program 5

Chapter Summary 6

3. HOW DOES THE PROGRAM START?

Laying the Foundation for an Effective O&M Program 7The Asbestos Program Manager 7

Building Inspection and Assessment 7

Developing an O&M Program 8Implementing and Managing an O&M

Program 8Cost Considerations 9Selecting and Implementing Alternative Abatement Actions 9Chapter Summary 11

4. WHAT DOES AN O&M PROGRAM INCLUDE?

O&M Program Elements 12Informing Building Workers, Tenants, and Other Occupants 12ACM Surveillance Reinspection and Periodic Surveillance 14Supplement to Visual/Physical Evaluation 14Work Control/Permit System 15O&M Work Practices 16

Worker Protection Programs 17Basic O&M Procedures 18O&M Cleaning Practices 19

Procedures for Asbestos Fiber Release Episodes 20Recordkeeping 22Chapter Summary 22

5. WHAT O&M TRAINING IS NECESSARY?

TYpes of Training 23Chapter Summary 25

4 iii

6. WHAT REGULATIONS AFFECT ASBESTOS MANAGEMENT PROGRAMS INBUILDINGS, ESPECIALLY O&M PROGRAMS?

Federal, State, and Local Regulations Affecting O&M Programs 26OSHA Regulations & EPA Worker Protection Rule 26

Small-scale, Short-duration Projects 27EPA National Emission Standards for Hazardous Air Pollutants (NESHAP) Regulations 27

Notification 28Emissions Control and Waste Disposal 28

Resource Conservation and Recovery Act (RCRA); Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA, or "Superfund") 28Asbestos Hazard Emergency Response Act (AHERA) 28Asbestos Ban and Phaseout Rule 28Chapter Summary 29

APPENDIX A.

Glossary 30

APPENDIX B.

Sample Recordkeeping Forms 31

APPENDIX C.

Illustrative Organization Charts 35

APPENDIX D.

Additional Assistance (EPA, NESHAP, OSHA; Trailing) 37

APPENDIX E.

Respiratory Protection Recommendations 38

APPENDIX E

Existing EPA Guidance For ACM Control 39

APPENDIX G.

Sample List: Suspect Asbestos-Containing Materials 40

APPENDIX H.

References 40

DISCLAIMER

This document was prepared under contract to an agency of the United States Governintnt. Neither the United States Governmentnor any of their employees makes any warranty, expressed or imphed, oi assumes any legal liability for any third party's use of or theresults of such use of any information, product, or process discussed in this document. Mention or illustration of company or tradenames, or of commercial products does not constitute endorsement by the U.S. Environmental Protection Agency.

Iv

Acknowledgements

The time and effort that many individuals contributed to the development of this document isgratefally acknowledged by the U.S. Environmental Protection Agency (EPA). The material in thispublication represents EPA's approximately 11 years of experience in considering public input andfine tuning policies on managing asbestos-containing materials in buildings. This documentincorporates views expressed by safety and health professionals, property owners and managers,public officials, general industry representatives, workers, and the general public.

The primary EPA deve!oper and coordinator of the finaldocument was Dr. Robert Jordan of the TechnicalAssistance Section, Environmental Assistance Divi-sion, Office of Toxic Substances. Without Bob's con-stant oversight, combined with his technical knowledgeand concern that the document be representative ofstate-of-the-art asbestos management, this documentwould not have reached the public.

Joe Schechter, Chief of the Technical Assistance Sec-tion, managed the project and helped clarify and edit theGuide. Bob McNally, Chief of the Assistance ProgramsDevelopment Branch, was instrumental in the forma-tive period of the Guide's development and also devotedlong hours to its review. Other impoi tant contributionswithin the Environmental Assistance Division camefrom Tom Tillman and Dave Kling. Sylvia Thomasprovided necessary assistance in revisions of the earlydrafts. Esther Teppe: aad Jane Gurin helped review theGuide in its final revisions, to make sure the documentwas written in easy-to-understand language.

The original skT,rit whic, i provided the foundation for theproject was performed under a contract with BattelleMemorial Institute (No. 68-02-4294) by Dr. Dale Keyesand Dr. Jean Chesson, under the direction of EdieSterrett and Cindy Stroup of the EPA ExposureEvaluation Division. They prepared the first drafts ofthe document and were instrumental in establishing itsfinal format.

EPA staff also gratefully acknowledge the work of stafffrom the Georgia Tech Research Institute (GTRI).Through a cooperative agreement with EPA theyserved as the overall project coordinator and providedthoughtful technical guidance throughout this entireprocess. The GTRI team also developed several keysections of the Guide.

This publication was refined through a peer reviewmeeting held in October 1988 in Washington, DC, andby a series of comment periods provided through May1990. The following individuals gave their time andprovided comments:

John Biechman, Safe Buildings AllianceWolfgang Brandner, U.S. EPA Region VIIFrank Bull, Bull, Brown & Kilgo ArchitectsEva Clay, The Environmcntal InstituteWilliam Cobbs, U.S. General Services

AdministrationMark Demyanek, Georgia Tech Research

InstituteMichael Duffy Service Employees International

UnionPaul Fidducia, Winston and StrawnEugene Fisher, Association of Wall and Ceiling

IndustriesDouglas Greenaway, Consultant (f3rmerly,

Building Owners and Managers AssociationInternational)

David Harris, National Institute of BuildingSciences

Steve Hays, Gobbell Hays PartnersJoseph Hopkins, U.S. Department of EnagyDavid Mayer, Georgia Tech Research InstituteRichard Mendes, New York Cit5, Department of

Environmental ProtectionMichael Miles, Tishman Spyer PropertiesRoger Morse, ENTEK Environmental and

Technical Services, Inc.Robert Navratil, RREEF Funds, Construction

and EngineeringAnthony Restaino, US. EPA Region VR: -hard Roth, Social Security AdministrationSims Roy, U.S. EPA, Office of Air Quality

Planning and Standar&

6 V

Scott Schneider, Workers' Institute firOccupational Safib, and Health

Henry Singer, U.S. General ServicesAdministratim

Thomas Warren, Rose A.ssociates, Inc.

In additlon to these individuals, the EPA acknowledgesthe cont.. ibution of the Policy Dialogue Group on

Asbestos in Public and Commercial Buildings, whichmet several times during 1989-1990. The purpose ofthis multi-disciplinary group was to identify the prob-lems associated with asbestos in public and commercialbuildings and to develop policy recommendations forsolving these problems. Many comments rised by theDialogue Group in the area of asbestos managementwere incorporated into this document.

7

Foreword

In February 1988, the Administrator of the Environmental Protection Agency (EPA) recommendedto Congress that the Agency work during the next three years to enhance the nation's technicalcapability in asbestos by helping building owners better select and apply appropriate asbestos controland abatement actions in their buildings. The publication of this guidance document is EPA's mostextensive effort to date to carry out that recommendation. In fact, Managing Asbestos In Place isthe most comprehensive asbestos guide published by EPA since the Agency expanded and updatedGuidance filr Controlling Asbestos-Containing Materials in Buildings (also known as the PurpleBook) in June 1985. Based on the insights and recommendations of nationally recognized asbestosexperts, this new guide, along with a new operations and maintenance work practices manualexpected to be available in 1991, provides "state-of-the-art" instruction to building owners to helpthem successfully manage asbestos-containing materials in place.

Managing Asbestos in Place does not supplant the1985 Purple Book as EPA's principal asbestos guidancedocument. Rather, based on our experience since 1985,it expands and refines the Purple Book's guidance for aspecial operations and maintenance (O&M) program.In particular, the guide more strongly emphasizes theimportance cf in-place management. The guide's pur-pose is two-fold. First, it offers building owners themore detailed and up-to-date instruthey need tocarry out a successful O&M pro

r4. Second, it

informs building owners, lenders, and insurers that aproperly conducted O&M program can in many case:,be as appropriate an asbestos control strategy asremoval. Furthermore, in some cases, an O&M pro-gram is more appropriate than other asbestos controlstrategies, including removal.

Emphasizing the importance and effectiveness of agood O&M program is a critical element of EPA'sbroader effort to put the potential hazard and risk ofasbestos exposure in proper perspective. That effortcenters around communicating the following five facts,which EPA hopes will help calm the unwarranted fearsthat a number of people seem to have about the merepresence of asbestos in their buildings and discouragethe spontaneous decisions by some building owners toremove all asbestos-containing material regardless of itscondition.

FACT ONE: Although asbestos ishazardous, the risk of asbestos-relateddisease depends upon exposure toairborne asbestos fibers.

In other words, an individual must breathe asbestosfibers in order to incur any chance of developing an,A35estos-related disease. How many fibers a personmust bonthe to develop disease is uncertain. However,at very low exposure levels, the risk may be negligible orzero.

FACT TWO: Based upon available data,the average airborne asbestos levels inbuildings seem to be very low. Accordingly,the health risk to most building occupantsalso appears to be very low.

A 1987 EPA study found asbestos air levels in a smausegment of Federal buildings to be essentially the sameas levels outside these buildings. Based on that limiteddata, most building occupants (i.e., those unlikely todisturb asbestos containing building materials) appearto face only a very slight risk, if any, of developing anasbestos-related disease.

8vii

FACT THREE: Removal is often not abuilding owner's best course of action toreduce asbestos exposure. In fact, animproper removal can create a dangeroussituation where none previously existed.

By their nature, asbestos removals tend to elevate theairborne level of asbestos fibers. Unless all safeguardsare properly applied, a removal operation can actuallyincrease rather than decrease the risk of asbestos-related disease.

FACT FOUR: EPA only requires asbestosremoval in order to prevent significantpublic exposure to airborne asbestosfibers during building demolition orrenovation activities.

Asbestos removal before the wrecking ball swings intoaction is appropriate to protect public health. At othertimes, EPA believes that asbestos removal projects,unless well-designed and properly performed, canactually increase health risk.

FACT FIVE: EPA does recommend a pro-active, in-place management programwhenever asbestos-containing material isdiscovered.

As this guide will explain in some detail, in-placemanagement does not mean "do nothing." It meanshaving a program to ensure that the day-to-day manage-ment of the building is carried out in a manner thatminimizes release of asbestos fibers into the air, ander sures that when asbestos fibers are released, eitheraccidentally or intentionally, proper control and cleanupprocedures are implemented. As such, it may be all thatis necessary to control the release of asbestos fibers,until the asbestos-containing material in a building isscheduled to be disturbed by renovation or demolitionactivities.

9

Why Is Asbestos a Problem?Introduction: Asbestos in Buildings

This U.S. Environment3I Protection Agency (EPA) guide is primarily directed to owners andmanagers of office buildings, shopping centers, apartment buildings, hospitals, and similar facilitieswhich may contain asbestos materials. Managers of industrial plants and other types of structuresmay need to supplement this information with additional specialized guidance. This document givesbuilding owners, managers, workers, and other key building staff basic information on how to developand carry out high-quality operations and maintenance programs for managing asbestos in place tosafeguard the health of all building occupants. An operations and maintenance (O&M) program canbe defined as a formulated plan of training, cleaning, work practices, and surveillance to maintainasbestos-containing materials (ACM) in good condition.

In this document you will find the following information:

0 The objectives of an O&M program, and anindication of the scope of O&M activities(Chapter 2);

-0 Basic steps to take before starting an O&Mprogram, including an initial survey and evalua-tion of ACM (Chapter 3);

O How to implement and manage the program,including some basic cost considerations(Chapter 3);

O&M work practices that protect bothworkers and the general building environment(Chapter 4);

O Recordkeeping suggestions and requirements(a section Of Chapter 4);

0 Training recommendations and requirementsfor workers performing O&M activities (Chap-ter 5); and

O An overview of federal regulations, includingthose affecting O&M programs (Chapter 6).

In addition, the Appendices provide other useful infor-mation, including a glossary of useful terms, andcontacts for additional assistance.

Ho O&M There are steps which a buildingw

Fits Inowner can take to prevent as-bestos fiter releases or resuspen-

sion of already-released fibers, or control fiber releasesquickly and safely if they occur. O&M programs aredesigned to achieve both these goals. This guide'spurpose, therefore, is to inform building owners abouthow to develop, implement and manage effective O&Mprograms, and to encourage their use.

EPA recommends a pro-active, in-place managementprogram whenever asbestos is discovered. In manybuildings, a well-run O&M program may be all that isnecessary to control the release of asbestos fibers untilthe ACM in the building is abated through renovation ordemolition activities. Also, an emergency repair toequipment or building services, or an unexpectedincident such as ACM falling from a surface couldnecessitate a different control strategy. However, bar-ring such events, if ACM is properly managed, release ofasbestos fibers into the air is minimized. The exposureto asbestos fibers, and therefore the risk of asbestos-related disease, can be reduced to a negligible level forall building occupants.

An O&M program may also provide an effective, lesscostly alternative to wholesale removal operations.Some additional cost-related considerations are dis-cussed in Chapter 3.

The EPA National Emission Standards for Hazardous

1

1 0

An O&M programcan be definedas a formulatedplan of training,cleaning, workpractices, andsurveillanceto maintaina sbestos-

containingmaterials in

good condition.

I.

Air Pollutants (NESHAP) regulations on asbestos mayrequire ACM removal prior to renovation and/ordemolition projects, to prevent significant asbestosreleases into the air ( ee Chapter 6). Additionally,removal of some ACM in a building will be necessary ifthe material has been damaged beyond repair. However,at other times, removal is often not a building owner'sbest course of action to reduce asbestos exposure.(Extraneous factors for example, difficulty in obtain-ing insurance, or obtaining financing relative to a realestate transaction may actually represent the drivingforces in a decision to remove all ACM, rather than ahealth-based need for removal.) In fact, unless allsafeguards are properly applied by trained, experiencedindividuals, removing ACM can actually increase build-ing occupants' risk of asbestos-related disease.

Background

The AsbestosIssue

Asbestos fibers can cause se-rious health problems. If in-haled, they can cause diseases

which disrupt the normal functioning of the lungs.Three specific diseases asbestosis (a fibrous scarringof thelungs), lung cancer, and mesothelioma (a cancer ofthe lining of the chest or abdominal cavity) have beenlinked to asbestos exposure. These diseases do notdevelop immediately after inhalation of asbestos fibers;it may be 20 years or more before symptoms appear.

In general, as with cigarette smoking and the inhalationof tobacco smoke, the more asbestos fibers a personinhales, the greater the risk of developing an asbestos-related disease. Most of the cases of severe healthproblems resulting from asbestos exposure have beenexperienced by workers who held jobs in industries suchas shipbuilding, mining, milling, and fabricating, wherethey were exposed to very high levels of asbestos in theair, without benefit of the worker protections nowafforded by law. Many of these same workers were alsosmokers. These employees worked directly with as-bestos materials on a regular basis and, generally, forlong periods of time as part of their jobs. Additionally,there is an increasing concern for the health and safetyof construction, renovation, and building maintenancepersonnel, because of possible periodic exposure toelevated levels of asbestos fibers while performing theirjobs.

Whenever we discuss the risk posed by asbestos, wemust keep in mind that asbestos fibers can be foundnearly everywhere in our environment (usually at verylow levels). There is, at this time, insufficient informa-tion concerning health effects resulting from low-levelasbestos exposure, either from exposures in buildingsor from our environment. This makes it difficult toaccurately assess the magnitude of cancer risk forbuilding occupants, tenants, and building maintenanceand custodial workers. Although in general the risk is

likely to be negligible for occupants, health concernsremain, particularly for the building's custodial andmaintenance workers. Their jobs are likely to bringthem into close proximity to ACM, and may scimetimesrequire them to disturb the ACM in the performance ofmaintenance activities. For these workers in particular,a complete and effective O&M program can greatlyreduce asbestos exposure. This kin( of O&M programcan also minimize asbestos exposures for other buildingoccupants as well.

What isAsbestos?

The term "asbestos" describessix naturally occurring fibrousminerals found in certain types of

rock formations. Of that general group, the mineralschrysottle, amosite, and crocidolite have been mostcommonly used in building products. When mined andprocessed, asbestos is typically separated into very thinfibers. When these fibers are present in the air, they arenormally invisible to the naked eye. Asbestos fibers arecommonly mixed during processing with a materialwhich binds them together so that they can be used inmany different products. Because these fibers are sosmall and light, they may remain in the air for manyhours if they are released frum ACM in a building. Whenfibers are released into the air they may be Mhaled bypeople in the building.

Asbestos became a popular commercial product be-cause it is strong, won't burn, resists corrosion, andinsulates well. In the United States, its commercial usebegan in the early .1.900's and peaked in the period fromWorld War II into the 1970's. Under the Clean Air Act of1970 the EPA has been regulating many asbestos-containing materials which, by EPA definition, arematerials with more than 1 percent asbestos. TheOccupational Safety and Health Administration's(OSHA) asbestos construction standard in section K,"Communication of hazards to employees," specifieslabeling many materials containing 0.1% or moreasbestos. In the mid-1970's several major kinds ofasbestos materials, such as spray-applied insulation,fireproofmg, and acoustical surfacing material, werebanned by EPA because of growing concern abouthealth effects, particularly cancer, associated withexposures to such materials.

In July 1989, EPA promulgated the Asbestos Ban andPhasedown Rule. The rule applies to new productmanufacture, importation, and processing, and essen-tially bans almost all asbestos-containing products inthe United States by 1997. This rule does not requireremoval of ACM currently in place in buildings.

Where is AsbestosLikely to be Foundin Buildings?

In February 1988, theEPA released a reporttitled EPA Study of As-bestos-Containing Ma-

terials in Public Buildings: A Report to Congress. EPAfound that "friable" (easily crumbled) ACM can be

1 1

found in an estimated 700,000 public and commercialbuildings. About 500,000 of those bill' rings are believedto' contain at least some damaged asbestos, and someareas of significantly damaged ACM can be found in overhalf of them.

According to the EPA studs significantly damaged ACMis found primarily in building areas not generallyaccessible to the public, such as boiler and machineryrooms, where asbestos exposures generally would belimited to service and maintenance workers. FriableACM, if present in air plenums, can lead to distributionof the material throughout the building, thereby possi-bly exposing building occupants. ACM can also be foundin other building locations.

Asbestos in buildings has been commonly used forthermal insulation, fireproofing, and in various buildingmaterials, such as floor coverings and ceiling tile,cement pipe and sheeting, granular and corrugatedpaper pipe wrap, and acoustical and decorative treat-ment for ceilings and walls. it is found in pipeand boiler insulation and in spray-applied uses such asfireproofing or sound-deadening applications.

The amount of asbestos in these products varies widely(from approximately 1 percent to nf..arly 100 percent).The precise amount of asbestos in a product cannotalways be accurately determined from labels or byasking the manufacturer. Nor can positive identificationof asbestos be ascertained merely by visual examina-tion. Instead, a qualified laboratory must analyzerepresentative samples of the suspect material. Appen-dix G contains a sample list of some suspect materials.

When is Asbestosa Problem?

Intact and undisturbedasbestos materials donot pose a health risk.

The mere presence of asbestos in a building does notmean that the health of building occupants is endan-

_ .

gered. ACM which is in good condition, and is notsomehow damaged or disturbed, is not likely to releaseasbestos fibers into the a3r. When ACM is properlymanaged, release of asbestos fibers into the air isprevented or minimized, and the risk of asbestos-relateddisease can be reduced to a negligible level.

However, asbestos materials can become hazardouswhen, due to damage, disturbance, or detaiorationover time, they release fibers into building air. Underthese conditions, when ACM isdamaged or disturbedfor example, by maintenance repairs conducted withoutproper controls elevated airborne asbestos concen-trations can create a potential hazard for workers andother building occupants.

ACM which I. In poorphy sic,* condition.1.A.der a proper oper-ations and mainte-nance program, COILreedy* action wouldnormally preventdeterioration of theInsulation.

ACM with uoundstructural integrityon the exterior of adomestic hot watertank. Note that theinsulation jacketingis intact and thereis no evidence ofdisturbance.

12

This document, directed to owners and managers of office buildings and similar facilities, should helplay the groundwork for developing and implementing effective operations and maintenanceprograms.Major highlights in this section have focused on background information concerning asbestos andhave touched on the current asbestos-in-buildings situation. Important points to remember are thefollowing:

Inhalation of asbestos fibers has been shown tocause asbestosis, lung cancer and meso-thelioma. Much of our knowledge of thesehealth effects has come primarily from studiesof workers exposed routinely to very high levelsof asbestos in their jobs.

Information on health effects of low-levelasbestos exposure is ;ess certain; custodial/maintenance workers who sometimes disturbasbestos as part of their job would benefit fromproperly executed O&M programs.

Three of the six naturally occurring asbestosminerals, chrysotile, amosite, and crocidolite,have been most commonly used in buildingproducts.

Asbestos became a popular commercial prod-uct because of its strength, heat resistance,corrosion resistance, and thermal insulationproperties.

_,- Asbestos-containing materials (ACM) are reg-ulated by EPA, OSHA, and the ConsumerProduct Safety Commission (CPSC), and indi-vidual state and local agencies.

Friable ACM can be found in about 700,000public and commeitial buildings. Many areaswhere asbestos is found are not accessible tothe general public.

Some common uses of asbestos have includedpipe/boiler insulation, spray-applied fireproof-ing, floor and ceiling tile, cement pipe/sheetingand paper pipe wrap.

Positive identification of asbestos requireslaboratory analysis; information on labels orvisual examination only is not sufficient.

Intact, undisturbed materials generally do notpose a health risk; they may become hazardouswhen damaged, disturbed, or deteriorated overtime and release fibers into building air.

4

What Is an O&M Program?Purpose and Scope of an Operations andMaintenance Program

Purpose of O&M

The principal objective of an O&M program is to minimize exposure of all building occupants toasbestos fibers. lb accomplish this objective, an O&M program includes work practices to (1)

maintain ACM in good condition, (2) ensure proper cleanup of asbestos fibrs previously released,

(3) prevent further release of asbestos fibers, and (4) monitor,.the condition of ACM.

Scope of an O&M Program

An effective O&M program should address all types ofACM present in a building. ACM that may be managedas part of an O&M program in buildings can beclassified in one of the following categories:

1

2

3

Surfacing Material: Examples includeACM sprayed or troweled onto surfaces, suchas decorative plaster on ceilings or acousticalACM on the underside of concrete slabs ordecking, or fireproofing materials on struc-tural members.

Thermal System Insulation (TSI): Exam-ples include ACM applied to pipes, boilers,tanks, and ducts to prevent heat loss or gain,or condensation.

Miscellaneous ACM: Examples includeasbestos-containing ceiling or floor tiles, tex-tiles, and other components such as asbestos-cement panels, asbestos siding and roofingmaterials.

The O&M program, when developed and implementedin a particular facility, should include specific directionon how to deal with each of these gen6ea1 categories ofACM. Specified O&M work practices and proceduresshould be employed by trained personnel during build-ing cleaning, maintenance, renovation, and generaloperational activities that mry involve surfacing, ther-mal, or miscellaneous ACM. Some elaboration of O&Mwork practices and procedures is found in Chapter 4.

The O&M program can be divided into three types ofprojects:

0 those which ay e unlikely to involve any directcontact with ACM;

0 those which may cause accidental disturbanceot ACM;

0 those which involve relatively small distur-bances of ACM.

The first type may involve routine cleaning of shelvesand counter tops or other surfaces in a building(provided ACM debris is not present). Generally, such

An example of spray-applied surfacingACM on a mptal deckabove! suspendedceiling;

14

An example of as-bestos-containingthermal system insu-lation on pipes in abuilding's mechanical

activities would not be expected to disturb ACM. Thesecond type of project could include maintenance workabove a suspended ceiling in an area that may havesurfacing ACM overhead. The third type of projectsmall-scale, short-duration maintenance, repair, orinstallation projects involving minor disturbances ofACM includes activities such as inrtallation of newlight fixtures on or in an ACM ceiling. A single glovebagoperation to remove a small amount of ACM to repair apipe in a boiler room is another example of intentionalsmall-scale, short-duration disturbance.

-

An example of anrisbaitoieowtikfiaj

cement sheet product(miscellaneous ACM).

Larger projects involving more complex procedures forthe intentional removal of ACM are considered asbestosabatement projects. These require asbestos control andabatement pnocedures that are outside the scope of anO&M program. Before taking action, building ownersshould consult qualified professionals for advice andalternative solutions. Guidance for building owners onthe management of abatement projects is included inEPA's'Guidance for Controlling-Asbestos-ContainingMaterials in Buildings," June 1985, also known as the"PurPle Boole

for

The purpose of an Operations and MaintenanceProgram is to minimize exposure of all buildingoccupants to asbestos fibers. Through super-vised work practices, ACM can be managed inplace. Important points to remember are:

ACM can be classified into three categories:

O Surfacing Material

o Thermal System Insulation (TSI)

o Miscellaneous Material

O&M Programs can be divided into three types ofprojects:

o Unlikely to involve direct contact with ACM.

O Accidental disturbance of ACM.

O Small-scale, short-duration maintenance orrepair activity, which may involve intentionaldisturbance of ACM.

15

How Does the Program Start?Laying the Foundation for an Effective O&M Program

A comprehensive asbestos control program for a building should include these basic steps:

O Appoint an Asbestos Program Manager Pnddevelop an organizational policy.

) Conduct a physical and visual inspection of thebuilding and take bulk samples of suspectmaterials to determine if ACM is present,establish an ACM inventory, and assess theACM's condition and potential for disturbance.

0 If ACM is located, develop an O&M program,based on the inspection and assessment data.

Implement and manage the O&M programconscientiously.

0 Select and implement abatement actions otherthan O&M when necessary.

This chaptar provides information about each of thesebasic steps. In addition, see Appendix F for a chat t ofreferences outlining existing EPA guidance for each ofthese steps.

The Asbestos Program Manager

The position of Asbestos Program Manager (APM) isfrequently held by the building engineer, superinten-dent, facilities manager, or safety and health director. Ina small organization, the building owner may have thisrole. Regardless of who holds this position, EPA stressesthe need for the Asbestos Program Manager to beproperly qualified, through training and experience , andto be actively involved in all asbestos-control activities.EPA accreditation under the Asbestos Hazard Emer-gency Response Act (AHERA) or state certification as aBuilding Inspector/Management Planner would betypical of the requisite training.

If the person selected is not adequately prepared, he orshe should receive the training necef iry to develop andmanage an asbestos control program prior to beginning

the job. If for some reason this is not possible, thebuilding owner should strongly consider hiring a prop-erly trained, experienced, and credentialed outsideconsultant or firm to provide direction to the owner orthe Asbestos Program Manager.

In general, the Asbestos Program Manager should havethe authority to oversee all asbestos-related activities inthe building, including inspections, O&M activities, andother abatement actions. The Asbestos Program Man-ager will either train building workers in O&M tech-niques or ensure that such worker training takes place.In addition, he or she should oversee the custodial andmaintenance staffs, contractors, and outside servicevendors with regard to ". asbestos-related activities.

Building inspection andAssessment

To determine whether an asbestos control and manage-ment program should be implemented, the ownershould have an initial building inspection performed tolocate and assess the condition of all ACM in thebuilding. A trained, experienced and qualified inspector,who is able to perform the sampling of suspect ACM forlaboratory analysis, should conduct the inspection. If aninspection is not performed, then certain suspectmaterials should be assumed to contain asbestos, andtreated accordingly. (Refer to Appendix G for a samplelist of suspect ACM.)

EPA guidance on how to take "bulk" samples of suspectACM is contained in several publications (see AppendixEl) and from EPA Regional Asbestos Coordinators(listed in Appendix D).

Tne building inspection by a qualified professionalserves as the basis for establishing an effective overallplan for dealing with the asbestos in the building. Theinspector should advise the owner and the Asbestos

To determinewhether an

asbestos controland managementprogram shouldbe implemented,the owner should

have an initialbuilding

inspectionperformed to

locate and assessthe condition ofall ACM in the

building.

7

-

,

A properly trainedand protected build-ing inspector collect-ing a bulk sample ofsuspected asbestos-containing thermalsystem insulatkr,

Program Manager of hiSPedt ion findings.-Of course, theinspection may show that ACM is not present and thatan asbestos-control program is not required.

If ACM is found, the materiars characteristics, condi-tion, quantity, and location within the building, as well asbuilding use, will affect how the building owner shoulddeal with the ACM. For example, operations andmaintenance procedures may be appropriate and suffi-cient in a particular building forACM in good condition.But O&M procedures alone are not sufficient for ACMthat the inspector determines is significantly damaged,and may not be suffident for some types of ACMsituated in highly accessible areas; in these instances,some form of full scale abatement repair, encapsula-tion, enclosure, encasement, or removal will benecessary. Removal of the ACM may also be appropriatewhen performed in conjunction with major buildingrenovations, or as part of long-term building manage-ment policies (such as staged removal in conjunctionwith renovation over the life of the building, as coveredby the EPA NESHAP requirements for removal beforedemolition or renovation).

Developing an O&M Program

If ACM is found, the building owner should have anO&M program developed as soon as possible. Eitherthe Asbestos Program Manager or a qualified consult-

ant should develop the O&M program. The writtenO&M program should state clearly the O&M policiesand procedures for that building, identify and describethe administrative line of authority for that building, andshould clearly define the responsibilities of key partici-pants, such as the Asbestos Program Manager andcustodial and maintenance supervisors and staff. Thewritten O&M program should be available and under-stood by all participants involved in the managementand operations of the building.

In general, the O&M program developed for a particu-lar building should include the O&M program elementsdiscussed in the next chapter. However, the buildingowner should make sure that the O&M programdeveloped is site-specific and tailored for the building.The O&M program should take into account use,function, and design characteristics of a particularbuilding.

Implementing and Managingan O&M Program

A well-developed O&M program is ineffective unlessthe building owner is committed to implementing itproperly. The building owner should convey this com-mitment to key personnel involved in a building'smanagement and operations particularly the As-bestos Program Manager and custodial and mainte-nance supervisors and staff. The O&M program'ssuccess is contingent upon key personnel understand-ing the O&M program and committing themselves toimplementing it effectively.

lb le greatest extent possible, the building ownershould incorporate the O&M program into the existingsystem for managing a building's operations. Eachbuilding owner, therefore, will determine the appropri-ate organizational structure on a case-by-case basis.'No possible arrangements are suggested in Figures 1and 2 in Appendix C.

When managing an O&M program, the AsbestosProgram Manager should ciersee all asbestos-relatedactivities. In instances where a building owner hires acontractor to perform custodial and maintenance work,the Asbestos Program Manager should ensure that thecontractor is qualified to conduct work that may involveACM. Before hiring a contractor, the Asbestos ProgramManager should investigate to determine whether thecontractor's staff is qualified, trained and equipped todeal with O&M asbestos activities. Thoroughly check-ing the references of a contractor is a good recom-mended practice.

The Asbestos Program Manager should also monitorthe work performed in the building by other contrac-tors, such as electricians and plumbers, who mightinadvertently disturb ACM. Instituting a work permitsystem, as discussed in the next chapter, may preventaccidental disturbances of ACM. Under this system, a

17

contractor must receive a work permit from theAsbestos Program Manager before commencing work.At that time, the Asbestos Program Manager willinform the contractor whether the project could disturbACM and provide any special instructions to make surethe work is done properly. Communication between theAsbestos Program Manager and tenants occupying thebuilding is essential to prevent activities that mightcompromise the O&M program.

In addition, the Asbestos Program Manager shouldroutinely and frequently check the work being per-formed in the building by contractors and custodial andmaintenance staff to see if their work is disturbingACM. By maintaining close surveillance over theseactivities, the Asbestos Program Manager can helpensure that work which may disturb ACM is being donesafely. Tenants should be required (by legal agreementor understanding) to notify the building owner or theAsbestos Program Manager before conducting evensmall planned renovations. This would help preventbuilding tenants from unknowingly disturbing ACM. Forboth the work permit system and the renovationnotification requirement, clear and effective communi-cations to workers and tenants are crucial to the successof the O&M management program.

The Asbestos Program Manager should periodicallyreview the written O&M plan to determine whether itshould be updated. For example, if all ACM wereremoved from some areas of the building during a recentrenovation, or if some ACM was damaged, the O&Mprogram should be revised accordingly. The O&Mprogram should remain in effect as long as there is ACMpresent in the building.

Cost The costs associated with

Considerations implementing and manag-mg an O&M program may

vary significantly depending on the types of ACM,building-specific factors, actual O&M proceduresadopted, types of equipment used, and the useful life ofthe building. Owrws may find it more cost-effective tocontinue a well-supervised and managed O&M pro-gram than to incur the costs of immediate, large-scaleremoval. In addition to the direct costs of removal, othercosts related to ACM removal include moving buildingoccupants, arranging alternative space for buildingoccupants during the removal work, and restoring thebuilding after the removal is completed.

Clearly, many factors enter into the decision. Only byconducting a cost-effectiveness analysis of the long-term options (e.g., comparing (a) immediate removalwith (b) phased removal plus O&M with (c) removal justbefore demolition plus lifetime O&M) will owners betruly able to determine which option is most costeffective for their buildings. The prudent owner mayneed to consult one or more qualified consultants orfirms for advice, if such expertise does not exist withinthe owner's organization.

Selecting and ImplementingAlternative Abatement Actions

In some instances, due to the condition of ACM orupcoming building renovations, a building owner maydecide to take other abatement actions to deal withACM in the building. These response actions couldinclude encapsulation (covering the ACM with a sealantto prevent fiber release), enclosure (placing an air-tightbarrier around the ACM), encasement (covering theACM with a hard-setting sealing material), repair, orremoval of the ACM. Qualified, trained, and experi-enced contractors should be used for any of theseactions. EPA's Purple Book discusses most of thesealternatives in some detail. In general, repair, encap-sulation, enclosure, and encasement, are intended tohelp prevent the release of asbestos fibers. As aspects ofO&M, these techniques manage ACM in place. SeeAppendix F of this document for additional federalreference sources on asbestos response actions.

When determining which response alternative to select,the building owner and Asbestos Program Managermay consider seeking advice from qualified, independ-ent consultants with specific training and experience inasbestos management.

Asbestos consultants should have a background inengineering, architecture, industrial hygitn,-, safety, ora similar field. Experts who are Registered and/or withBoard Certified backgrc lads are recommended. Tohelp ensure that no "ccnflict of interest" exists,consultants should not be affiliated with the abatementcontractors who may be used on a recommended ACMcontrol project, nor with analytical laboratories whichperform sample analyses. As with other similar busi-ness decisions, building owners should interview sev-eral consultants and check references.

Renovations (including remodeling or redecorating) ofbuildings or replacement of utility system increases tilepotential for disturbing ACM. Before conducting anyrenovation or remodeling work, the building ownershould have the Asbestos Program Manager reviewasbestos inspection and assessment records to deter-mine where ACM may be located, visually reinspect thearea, and evaluate the likelihood that ACM will bedisturbed. Any suspect or assumed ACM that could bedisturbed during the renovation work should either beampled and analyzed to dete. mine whether it contains

asbestos, or the work should be carried out as if thematerials did contain asbestos. The Asbestos ProgramManager should also ensure that no new ACM isintroduced into the building as part of the renovationwork.

Removal of the ACM before renovation begins may benecessary in some instances. Removal is required by theAsbestos NESHAP regulations for projects whichwould break up more than a specified minimum amountof ACM; specifIcally, at least 160 square feet of surfacing

Renovations(including

remodeling orredecorating) of

buildings orreplacement ofutility systemsincreace thepotential for

disturbing ACM.

9

Asbestos-containingthermal system Insu-lation which has sus-tained significantdamage In a mechan-ical/boller room of abuilding.

_ -or miscellaneous material or at least 260 linear feet ofthermal system insulation (40 CFR 61.145-147). Build-ing owners and managers are encouraged to contacttheir state or local health or environmental departmentfor further clarification of these requirements (also, seeChapter 6 of this document). It is important to ensurethat new materials placed in the building do not containasbestos in order to _comply with the recent EPAAsbestos Ban and Phase Out rule (see Chapter 6).

In general, building owners should thoroughly considerany decision to remove ACM. atilf, encapsulation,encasement, enclosum, or repair may be viable alter-natives to removal. Building owners should assessthese in-place management techniques carefully beforedeciding to remove undamaged ACM.

Under certain circumstances, however, such as whensome ACM must be removed during building renova-tions, when the ACM has sustained a great deal ofdamage, or ACM disturbance will be difficult to manageproperly the building owner may decide to remove ACMin parts of the building.

When removal must occur, only qualified, trained andexperienced project designers and contractors shouldbe permitted to design and perform the work. Building

_

owners Might consider contacting lodal, state, andfederal asbestos regulatory agencies to see if prospec-tive contractors have received citations for violatingasbestos regulations in the past. In addition, if thebuilding owner and Asbestos Program Manager are notproperly qualified themselves, they should retain aqualified and independent project designer and a projectmonitor with_ training and_ experience in asbestosabatement to oversee and ensure that the asbestosabatement work is done safely When these precautionsare taken, asbestos removal is more likely to proceedsafely and effectively

Proper completion of the ACM remo: al is best evalu-ated by means of the analytical pmcedures usingtransmission electron microscopy (TEM) (These aredescribed in 40 CFR Part 763, Appendix A to SubpartE.) Clearance protoals for statistically comparingasbestos fiber levels inside the work area with outsidelevels are available. If the measured levels inside are netstatistically higher than the average airborne asbestosconcentration measured outside the abatement area,the cleanup is considered successful, and the space isjudged ready for reoccupancy. (Fbr reference, seeAppendix H, U.S. EPA "Guidelines for Conducting theAHERA TEM Clearance Test . ...")

19

Laying the foundation for a comprehensive asbestos control program for a building includes somebasic steps. Important points contained in this discussion are the following:

An Asbestos Program Manager needs to beproperly qualified through training and experi-ence, and be actively involved in all asbestoscontrol and disturbance activities.

An Asbestos Program Manager should haveauthority to oversee and to direct custodial/maintenance staff and contractors with regardto all asbestos-related activities.

) An initial building inspection should be per-formed by a trained, qualified, experiencedinspector to locate and assess the condition ofall ACM in the building.

The inspection results serve as the basis forestablishing an O&M program. O&M pro-cedures may not be sufficient for certain ACMthat is significantly damaged or in highlyaccessible areas.

An Asbestos Program Manager or qualifiedconsultant should develop the written O&Mprogram that is site-specific and tailored forindividual buildings. The O&M programshould take into account use, function anddesign characteristics of a building.

0 The success of any O&M program lies in thecommitment by the building owner to imple-ment it properly.

`,..._.JWhen outside contractors are used for as-bestos-related activities, their references andtraining should be thoroughly checked andtheir subsequent work monitored.

0 Periodically review written O&M programs.

, M,....., Altf natives or control options that may be

implemented under an O&M program include:

repairencapsulationenclosureencasementremoval (minor)

0 Removal of ACM before renovations may benecessary in some instances. (See NESHAPand State/Local regulations discussion inChapter 6.)

The successof any O&M

programdepends on thebuilding owner'scommitment to

implement itproperly.

11

If staff arenot adequately

trained, the O&Mprogram will not

be effective.

12

What Does an O&M ProgramInclude?O&M Program Elements

To achieve its objectives, an O&M program should include seven elements. Although these shouldappear in any O&M program, the extent of each will vary from program to program depending onthe building type, the type of ACM present, and the ACM's location and physical condition. Forexample, if only nonfriable ACM is present, minimal notification might be needed, and custodial ormaintenance staff would most likely have fewer work practices to be followed. If friable ACM ispresent, a more detailed O&M program should be prepared and followed. Each of the first sixelements listed below is described in this chapter to provide an illustration of a basic O&M program.The seventh program element, training of the Asbestos Program Manager and custodial andmaintenance staff, is very important. If staff are not adequately trained, the O&M program will notbe effective. Chapter 5 is devoted exclusively to O&M training topics.

A successful O&M program should include the follow-ing elements:

Notification: A program to tell workers,tenants, and building occupants where ACM islocated, and how and why to avoid disturbingthe ACM. All persons affected should beproperly informed.

_ Surveillance: Regular ACM surveillance tonote, assess, and document any changes in theACM's condition.

-,' Controls: Work control/permit system toccntrol activities which might disturb ACM.

Work Practices: O&M work practices toavoid or minimize fiber release during activitiesaffecting ACM.

Recordkeeping: To document O&M activ-ities.

C Worker Protection: Medical and respiratoryprotection programs, as applicable.

'Raining: Asbestos Program Manager, andcustodial and maintenance staff training.

informing Building Workers,Tenants, and Other Occupants

Building owners should inform building workers, occu-pants, and tenants about the location and physicalcondition of the ACM that they might disturb, and stressthe need to avoid disturbing the material. Occupantsshould be notified for two reasons; (1) building occu-pants should be informed of any potential hazard in theirvicinity; and (2) informed persons are less likely tounknowingly disturb the material and cause fibers to bereleased into the air.

Building owners can inform occupants about thepresence of ACM by distributing written notices,posting signs or labels in a central location whereaffected occupants can see them, and holding aware-ness or information sessions. The methods used maydepend on the type and location of the ACM, and on thenumber of people affected. Some states and localitieshave "right-to-know" laws which may require that alloccupants, workers, and visitors in buildings with ACMbe informed that asbestos is present.

In service and maintenance areas (such as boilerrooms), signs such as "Caution Asbestos Do NotDisturb" placed directly adjacent to thermal systeminsulation ACM will alert and remind maintenance

2 1

workers not to inadvertently disturb the ACM. In mostcases, all boilers, pipes, and other equipment with ACMin service areas where damage may occur should haveprominent warning signs placed next to the ACM. As analternative, color coding can be used to identify theACM in certain situations provided that all potentiallyinvolved parties understand the coding system.

Information sessions reinforce and clarify writtennotices and signs, and provide an opportunity to answerquestions. All employees and tenants or tenant repre-sentatives likely to disturb ACM should be included inthe notification program on a continuing basis. Buildingowners should inform new employees about the pres-ence of ACM before they begin work. Owners shouldprovide additional signs and information sessions inlanguages other than English where a significantnumber of workers, occupants, or visitors do not speakEnglish. It may be necessary to make special provisionsfor illiterate workers, such as providing clear verbalinformation or signs, about potential hazards of disturb-ing ACK and showing them where ACM is located.

The specific information given to types of buildingoccupants will vary For example, since service workerscarry out certain tasks that office workers or tenants donot perform, they should receive additional informa-tion. Most important, O&M workers should receive thetraining necessary for them Iv perform their taskssafely.

Whatever its form, the information given to buildingoccupants and workers should contain the followingpoints to the extent they reflect building conditions:

O ACM has been found in the building and islocated in areas whe. e the material could bedisturbed.

O The condition of the ACM, and the responsewhich is appropriate for that condition.

O Asbestos only presents a health hazard whenfibers become airborne and are inhaled. Themere presence of ACM does not represent ahealth hazard.

O The ACM is found in the following locations(e.g., ceilings in Rooms 101 and G-323, walls inthe lobby, above suspended ceilings in the firstfloor corridor, on columns in the main entry, onpipes in the boiler room).

O Do not disturb the ACM (e.g., do not pushfurniture against the ACM, do not damageTSD.

O Report any evidence of disturbance or damageof ACM to (name, location, and phone numberof Asbestos Program Manager).

C) Report any &1St or debris that might comefrom the ACM or suspect ACM, any change inthe condition of the ACM, or any improperaction (relative to ACM) of building personnelto (name, location, and phone number ofAsbestos Program Manager).

O Cleaning and maintenance personnel are tak-ing special precautions during their work toproperly clean up any asbestos debris and toguard against disturbing ACM.

O All ACM is inspected periodically and addi-tional measures will be taken if needed toprotect the health of building occupants.

Routine maintenanceactivities can causedisturbance of ACM Ifworkers are not prop-erly trained in opera-tions and mainte-nonce procedures.Here, a worker care-lessly contacts ACM,possibly damaging it.

It is important to undertake an honest and openapproach to the ACM notification procedure. Ownersshould strive to establish clear lines of communicationwith all building occupants regarding asbestos issues.People who are informed of the presence, location andcondition of ACM in a building where they work or live,who understand that the mere presence of ACM is notnecessarily hazardous to them, and who accept thatACM can often be managed effectively in place, can be

2 2

An example of anasbestos caution signpieced directly on asection 0 asbestos-containing duct insu-lation. Signs such asthis help to nsurethat workers will notinadvertently disturbACM.

Visual reinspectionsof asbestos materialsat regular intervalscan detect changes inmaterial condition.Here, surfacing ACMhas delaminated froma coiling In a building;O&M routines cankeep small problemsfrom becoming blgproblems.

very helpful to the owner in eliminating or reducinghysteria on the part of other less informed buildingoccupants. On the other hand, if occupants suspect thebuilding owner is not being honest about asbestosactivities in the building, that owner's credibility may bequestioned and the situation can become far moredifficult to manage. If and when asbestos incidentsoccun it is especially important for the building ownerto deal with occupantl and contractors openly andhonestly, for that is the best way to maintain occupant/tenant confidence in both the owner and the building'sasbestos ptogram.

ACM Surveillance

Reinspection andPeriodit: Surveillance

A visual reinspectionof all ACM should beconducted at regular

intervals as part of the O&M program. Combined withongoing reports of changes in the condition of the ACMmade by service workers, the reinspections should helpensure that any ACM damage or deterioration will bedetected and corrective action taken.

According to recent EPA regulations covering schools(the Asbestos Hazarcl Emergency Response Act,"AHERA"), an accredited inspector must reinspectschool buildings at least once every three years toreassess the condition of ACM. The AHERA regula-tions for schools also require a routine surveillancecheck of ACM every six months to monitor the ACM'scondition. The AHERA Rule permits this surveillanceto be conducted by a trained school custodian ormaintenance worker. While these intervals are men-tioned here as a guide, they may also be appropriate forother buildings. The Asbestos Program Managershould establish appropriate intervals, based on consul-tation with the building owner and any other qualifiedprofessionals involved in the O&M program.

EPA recommends a visual and physical evaluation ofACM during the reinspections to note the ACM'scurrent condition and physical characteristics. Throughthis reinspection, it is possible to determine both therelative degree of damage end assess the hIcelihood offuture fiber release. Maintenance of a set of visualrecords (photos or video tape) of the ACM over time canbe of great value during reinspections.

Some asbestos consultants recommend examining set-tled dust for accumulations of asbestos fibers as anothersurveillance tool in an O&M program. While nouniversally accepted standardized protocols currentlyexist for sampling and analysis of settled dust, positiveresults (i.e., ACM is present in the dust) may indicatethe need for special cleaning of the affected area, orother action. Because the results of this testing aredifficult to interpret and evaluate at this time, buildingowners should carefully consider the appropriateness ofthis testing to their situation.

Supplement toVisual/PhysicalEvaluation

As part of an O&M pro-gram, a carefully designedair monitoring program todetect airborne asbestos fi-

bers in the building may provide useful supplementalinformation when conducted along with a comprehen-sive visual and physical ACM inspecuon and reinspec-tion program. If the ACM is currently in good condition,increases in airborne asbestos fiber levels at some latertime may provide an early warning of deterioration ordisturbance of the material. In that way, supplementalair monitoring can be a useful management tool. If anowner chooses to use air monitoring in an "earlywarning" context, a knowledgeable and experiencedindividual should be consulted to design a propersampling strategy Appendix H contains a reference to auseful guide to monitoring airborne asbestos, which canbe consulted for further discussion of this subject.

If supplemental air monitoring is done, a baselineairborne asbestos fiber level should be established soonafter the O&M program is initiated: Representative,multiple air samples should be collected throughout thcbuilding during periods of normal building operation.This should be done over a long eno 4h period of time tobe representative of existing conditions, in order. toadequately characterize prevailing fiber levels in thebuilding. This air monitoring should supplement, notteNace, physical and visual inspection. Visual inspec-tion can recognize situations and anticipate futureexposure (e.g., worsening water damage), whereas airmonitoring can only detect a problem after it hasoccurred, and fibers have been released.

Note that the collection of air samples for supplemen-tary evaluation should not use aggressive air samplingmethods. Aggressive sampling methods, in which air isdeliberately disturbed or agitated by use of a leaf bloweror fans, should be used at the completion of an asbestosremoval project when the building or area is tmoc-

23

cupied, not for routine monitoring.

The most accurate and preferred method of analysis ofair samples collected under an O&M program wouldrequire the use of transmission electron microscopy(TEM). Phase contrast microscopy (PCM), which iscommonly used for personal air sample analysis and as ascreening tool for area air monitoring, cannot distin-guish between asbestos fibers and other kinds of fiberswhich may be present in the air. PCM analysis alsocannot detect thin asbestos fibers, and does not countshort fibers. TEM analysis is approximately ten timesmore expensive than PCM analysis. However, the moreaccurate information on actual levels of airborneasbestos fibers should be more beneficial to the buildingowner who elects to use supplemental air monitoring inthe asbestos management program. TEM analysis ismost reliably performed by laboratories accredited bythe National Institute for Standards and Technology(NIST; see Appendix D for telephone number), and whofollow EPA's quality assurance guidelines. (Appendix H,U.S. EPA, Dec. 1989, wfransmission Electron Micro-scopy Asbestos Laboratories: Quality AssuranceGuidelines.")

Selection of a reliable and experienced air monitoringfirm and analytical laboratory is important, if thebuilding owner elects to conduct supplemental airmonitoring under the O&M program. A consultantknowledgeable in air sampling and analysis protocolscan be contacted for recommendations if the buildingowner or Asbestos Program Manager has limitedknowledge in this area.

Periodic air monitoring, conducted simultaneously withthe visual reinspections or surveillance, would then beused to see if asbestos levels have changed relative to thebaseline. Some building owners may wish to presentcurrent air monitoring results to building occupants inaddition to information regarding the physical reinspec-dons. Although this supplemental use of air monitoringas part of an O&M program may provide usefulinformation, it is likely to be very expensive, particularlyif the more accurate and recommended TEM analysis isused. Use of only a small number of measurements ormeasurements taken only at one time may be mislead-ing (i.e., overestimate or underestimate of fiber levels),and can lead to inappropriate decisions.

It should be noted that some of the exposures of personsto airborne asbestos fibers in buildings may result fromepisodic events, such as repair work or the accidentaldisturbance of the ACM or of ACM debris by mainte-nance activities inside the building. Air monitoring maynot be done frequently enough to include such episodicevents; this can lead to a misleading interpretation of airsampling results. In particular, air sampling may under-estimate the exposure of O&M workers and buildingoccupants. A good reference sourcebook for additionalinformation on air sampling and analysis for asbestosfibers is "A Guide to Monitoring Airborne Asbestos inBuildings" (see Appendix H).

Work Control/Permit System

The O&M program should include a system to controlall work that could disturb ACM. Some building ownershave had success using a "work permit" program, whichrequires the person requesting the work to submit a JobRequest Form to the Asbestos Program Manager(Appendix B, Form 2) before any maintenance work isbegun. The form gives the time and location of therequested wort, the type of maintenance needed, andavailable information about any ACM in the vicinity ofthe requested work. The contratior or other personauthorized to perform the work should be identified onthe work request.

Upon receiving a pre-work Job Request Form, theAsbestos Program Manager should take the followingsteps:

1

2

3

Refer to written records, building plans andspecifications, and any building ACM inspec-tion reports to determine whether ACM ispresent in the area where work will occur. IfACM is present, but it is not anticipated thatthe material will be disturbed, the AsbestosProgram Manager should note the presenceof the ACM on the permit form and provideadditional instruction on the importance ofnot disturbing the ACM.

If ACM is both present and likely to bedisturbed, the Asbestos Program Manager ora designated supervisor qualified by tainingor experience, should visit the site anddetermine what work practices should beinstituted to minimize the release of asbestosfibers during the maintenance activity.

This determination should be recorded on theMaintenance Work Authorization Form (seeexample in Appendix B, Form 3), which isthen sent to the in-house maintenance super-visor or to the maintenance contractor toauthorize the work.

4 The Asbestos Program Manager shouldmake sure that a copy of both the request andthe authorization forms (if granted) are placedin the permanent file.

24

An exampl of amaintenanc workerconducting activitiesnear a friablasbestos-containingceiling. Under aproper permittingsystem, the buildingAsbestos ProgramManager wouldevaluat andauthorize projectssuch as this prior tobeginning work.

15

It is importantto undertake anhonest and openapproach in ACM

notification.

16

5

6

7

8

Where the task is not covered by previouslyapproved standard work practices, the As-bestos Program Manager should make surethat the appropriate work practices andprotective measures are used for the job.

For all jobs where contact with ACM is likely,the Asbestos Program Manager or a desig-nated supervisor qualified by training orexpuience should visit the work site whenthe work begins to see that the job is beingperformed properly. For lengthy jobs wheredisturbance of ACM is intended or likely,periodic inspections should be made for theduration of the project.

The Asbestos Program Manager's observa-tions should be provided on an Evaluation ofWork Form (see Appendix B, Form 4). Anydeviation from standard and approved workpractices should be recorded immediately onthis form and the practices should be imme-diately corrected and reported to the AsbestosProgram Manager

Upon completion of the work, a copy of theevaluation form should be placed in thepermanent asbestos file for the building.

Building owners should consider using asbestos O&Mwork control forms similar to those which already maybe in use for non-ACM work in their facilities, orexpanding the existing forms to include the content ofthe request , approval, and evaluation forms illustrated inAppendix B.

The O&M management system should also addresswork conducted by outside contractors. Many buildingowners contract for at least some custodial and mainte-nance services. A building's asbestos work control/permit system, as described above, should also covercontract work.

At a minimum, contracts with service trades orabatement companies should include the followingprovisions to ensure that the servVe or abatementworkers can and will follow appropriate work practices:

Proof that the contractor's workers have beenproperly notified about ACM in the owner'sbuilding and that they are properly trained andaccredited (if necessary) to work with ACM.

Copies of respiratory protection, medical sur-veillance, and worker training documentationas required by OSHA, EPA and/or state regula-tory agencies.

r) Notification to building tenants and visitorsthat abatement activity is underway (per-formed by owner).

4,;

, Written work practices must be submitted bythe vendor or contractor for approval ormodification by the Asbestos Program Man-ager. The vendor or contractor should thenagree to abide by the work practices as finallyaccepted by the Asbestos Program Manager.

Assurance that the contractor will use properwork area isolation techniques, proper equip-ment, and sound waste disposal practices.

Historical air monitoring data for representa-tive examples of the contractor's previousprojects, with emphasis on projects similar tothose likely to be encuuntered in the building.

Provisions for inspections of the area by theowner's representative to ensure that the areais acceptable for re-entry of occupants/ten-ants.

A resume for each abatement contractor/supervisor or maintenance crew chief, knownas the "competent person" in the OSHAstandard and EPA Worker Protection Rule.

Criteria to be used for determining successfulcompletion of the work (i.e., visual inspectionsand air monitoring).

Any other information deemed necessary bythe owner's legal counsel.

Notification to EPA (and other appropriateagencies) if the abatement project is largeenough (see Chapter 6).

O&M Work Practices

1

The O&M program focuses on a special set ofwork practices for the custodial, maintenance,and construction staff. The nature and extentof any special work practices should be tailoredto the likelihood that the ACM will be disturbedand that fibers will be released. In general, fourbroad categories of O&M work practices arerecognized:

Worker Protection Programs Thesework practices help ensure custodial andmaintenance staff are adequately protectedfrom asbestos exposure.

2 Basic O&M Procedures Basic pro-cedures are used to perform routine custodialand maintenance tasks that may involve ACM.

3 Special O&M Cleaning TechniquesSpecial techniques to clean up asbestos fiberson a routine basis.

eLt7-4; 0;I

A Procedures for Asbestos Fiber Refease-* Episodes If moderate to relatively large

amounts of ACM are disturbed, the buildingowner should use these procedures to addressthe hazard.

A brief synopsis of worker protection anclIAM workpractices follows. (Note: A more detailed, technicallyoriented O&M "woth practices" manual specificallyaddressing topics such as work practices, workerpmtection, and specOc information on how to conyout O&M plans, is being developed, with publicationexpected in 1991.)

A worker protectionWorker Protection program includes engi-Programs neering controls, per-

sonal exposure monitoring, medical surveillance, andpersonal protection. While engineering controls are thepreferred method of worker protection, there are fewengineering control options available for O&M work.This section discusses two key aspects of personalprotection; use of respiratory protection and protectiveclothing for workers in an asbestos O&M program.According to OSHA regulations (see Chapter 6), awritten respiratory protection program is necessarywhenever an O&M program specifies that serviceworkers wear respirators, or where respirators aremade available to employees. OSHA regu., ions alsorequire a respirator program whenever workers areexposed, or are likely to be exposed, to fiber levels aboveOSHA's "permissible exposure limits" such as the8-hour time weighted average (TWA) limit or the 30-minute "excursion limit" (EL). The 8-hour TWA limitand the EL are described in more detail in Chapter 6. Inaddition, OSHA requires workers to wear specialprotective clothing under the same circumstances.

Respiratory Protection/Worker Protection Pro-grams The selection of approved respirators, suitablefor the hazards to which the worker is exposed, is onlyone aspect of a complete respiratory protection pro-gram. Other elements include written operating pro-cedures for respirator use; outlining personnel respon-sibilities for respirator cleaning, storage, and repair;medical examination of workers for respirator use;training in proper respirator use and limitations;respirator fit testing; respirator cleaning and care; andwork-site supervision. All of these are described indetail in the OSHA respirator standard, 29 CFR1910.134. The O&M respirator program can be admin-istered by the facility safety and health manager or theAsbestos Program Manager, if properly qualified.

Proper respiratory protection is an integral part of allcustodial and maintenance activities involving potentialexposure to asbestos. When in doubt about exposureduring a certain work operation, building owners shouldprovide respiratory protection to custodial and mainte-nance workers. OSHA specifies general types of

_

respirators for protection against airborne asbestosduring "construction" activities, which include abate-ment, renovation, maintenance, repair, and remodeling.

Personal air sampling is not the same as area airmonitoring. Personal air sampling (required by OSHA)is designed to measure an individual worker's exposureto fibers while the worker is conducting tasks that maydisturb ACM. The sampling device is worn by theworker and positioned so that it samples air in theworker breathing zone. In contrast, area (or ambient)air sampling is conducted to get an estimate of thenumbers of airborne asbestos fibers present in abuilding. It is used as an assessment tool in evaluatingthe potential hazard posed by asbestos to all buildingoccupants. (See the previous discussion of area airmonitoring on page 14.)

When adequate c2re is taken to prevent or minimize andcontrol fiber release, routine, small-scale/short-dura-tion maintenance or custodial tasks are not likely togenerate high levels of airborne asbestos compared tolarge asbestos removal prOects; and respirators whichfilter breathing air may be used. OSHA, EPA, andNIOSH are on record as not recommendingsingle use, disposable paper dust masks for useagainst asbestos; in fact, OSHA has disallowedtheir use against airborne asbestos fibers.

The options that may be used include:

0 A half-face or full facepiece, negative pressure,air-purifying respirator with replaceable high-efficiency filters.

Pictured below atedifferent examples ofairpurifying, negativepressure respiratorsequipped with high-efficiency cartridgeswhich can be used toprotect workersagainst asbestosexposer*. On the leftars mtamples of half-mask facepisces*quipped with high.fficiency cartridges,and on tbe right areexamples of fullfacellemr, high'eflicemmy masks.

_

, -----_--,-_

9

0 A half or full facepiece powered air-purifYingrespirator (PAPR) with replaceable high-effi-ciency filters. This has a battery powered pumpwhich assists breathing and provides positiveprea,ure in the facepiece.

-

Pictured above aretwo different types ofpowered air-purifyingrespirators (PAPR's)equipped with high-efficiency filters. Onthe left is an exampleof a tight fitting, fullfaceplece PAPP, andon the right is anexample of a loose-fitting helmet stylePAPR.

18

Under the OSHA standards for asbestos, any employeerequired to wear a negative pressure respirator canrequest a powered air-purifying respirator, and theemployer is required to provide a fully functional andapproved unit, provided it will afford the worker at leastequal protection.

Currently, only respirators approved by NIOSH and theMine Safety and Health Administration (MSHA) arepermitted for use. If they are air-purifying respirators,the filtration device(s) must be rated as "high-effi-ciency"

Selecting the most appropriate respirator for eachO&M task requires knowledge of the levels of airborneasbestos fibers and other possible air contaminantsgenerated by the task or likely to be present where thetask is performed. This knowledge is best gainedthrough personal air monitoring conducted duringworker performance of the actual task. (Obviously theworkers must have respiratory protection while thisinitial personal air sampling is carried out.) In fact,OSHA and EPA require air monitoring under certaincircumstances (see Chapter 6). To learn more about thedifferent types of respirators available and the degree ofprotection they provide, see Appendix E. Owr .- 3 mayalso wish to contact the nearest OSHA offic, , a localtrained and qualified industrial hygienist (preferablyCertified), or an occupational health professional formore information on respirators. The expertise of thesespecialists should be used to ensure proper selection, fittesting, and training of workers in respirator use.

Building owners and other facility managers may not befamiliar with some of the terms used in discussions ofrespirators, airborne fiber levels, and related topics.

Appendix E contains more information on these topics,and gives the minimum EPA-recommended levels ofrespiratory protection to be provided during typicalO&M tasks.

For additional information on respirator programs,respirator types, and respirator use, the building owneror Asbestos Program Manager may want to use thefollowing references:

O "Respiratory Protection: An Employer's Man-ual," NIOSH, October 1978;

0 "A Guide to Respiratory Protection for theAsbestos Abatement Industry," EPA/NIOSH,1986;

O OSHA respirator standard (29 CFR1910.134);

O OSHA asbestos regulations (29 CFR1910.1001 and 1926.58);

O "Occupational Exposure Sampling StrategyManul," NIOSH #77-173, January 1977.

O "Respirator Decision Logic," NIOSH, May1987; and

O "NIOSH Guide to Industrial Respiratory Pro-tection," September 1, 1987.

Protective Clothing/Worker Protection Pro-grams In addition to the use of respirators, some O&Mprocedures may require workers to wear protectiveclothing. Most often, protective clothing is disposableand consists of coveralls, a head cover, and foot coversmade of a synthetic fabric which does not allow asbestosfibers to pass through. This type of clothing prevents.mrkers' regular clothing from becoming contaminatedwith asbestos fibers. Contaminated clothing could betaken home, creating a possible risk to the worker'sfamily members.

OSHA and EPA regulations require workers to wearprotective clothing whenever they are exposed, or likelyto be exposed, to fiber levels above OSHA's permissiblelevels (see Chapter 6). It is important that workers beproperly trained in the use, removal and disposal ofprotective clothing after use. All O&M activities maynot require the use of protective clothing. It is importantfor the Asbestos Program Manager to assess this needon a case-by-case basis.

Basic O&M Basic O&M procedures to mini-

Procedures mize and/or contain asbestos fi-bers may include wet methods,

use of mini-enclosures, use of portable power toolsequipped with special local ventilation rtcachments, andavoidance of certain activities, such as sawing, sanding,

o 74,

and drilling ACM. Maintenance activities can be dividedinto three categories with regard to their potential fordisturbing ACM:

1 Those which are unlikely to involve any directdisturbance of ACM; for example, cleaningshelves or counter tops with a damp cloth.

2 Those which may cause accidental distur-bance of ACM; for example, working on afixture near a ceiling with surfacing ACM.

2 Those which involve intentional small-scalemanipulation or disturbance of ACM; forexample, removing a small segment of TSIACM to repair a pipe leak.

The O&M program suld include work practices foreach type of ACM that is present in the building(surfacing, TSI, and miscellaneous) as well as for eachtype and category of maintenance activity performed(e.g., general cleaning, electrical work, plumbing).

Special work practices such as wet wiping, areaisolation, and HEPA vacuuming, and the use of personalprotective equipment such as respirators and protectiveclothing, may be needed where disturbance of ACM islikely The need for these practices varies with thesituation. For example, removing fight fixtures locatednear surfacing ACM may disturb the material and mightinvolve the use of special cleaning, possibly areaisolation, and respiratory protection. Periodic emptyingof a trazh can near heavily encapsulated asbestos-containing plaster may not disturb the material at all, sono special work practices would generally be necessaryThese work practices and procedures are intended toensure that disturbance of any ACM during O&Mactivities should be minimized, or carried out undercontrolled conditions when the disturbance is requiredby the nature of a specific O&M task.

In addition, ACM may readily release asbestos fibersinto the air when certain mechanical operations areperformed directly on it. For example, fiber releases canoccur when workers are drilling, cutting, sanding,breaking, or sawing vinyl asbctos floor tile.

The action of drilling, cutting, abrading, sanding,chipping, breaking, or sawing is the critical factor here,since it is likely to cause a release of fibers. Maintenanceor repair operations involving those actions should beeliminated or carefully controlled with basic O&Mprocedures in order to prevent or minimize asbestosfiber release.

Certain activities that occur in the vicinity of ACM canalso cause &nage which may result in asbestos fiberrelease. For example, maintenance and custodial staffmay damage ACM accidentally with broom handles,ladders, and fork lifts while performing other tasks.Activities performed in the vicinity of ACM shouldalways be performed cautiously to prevent fiber release.

'lb summarize, ff in doubt about the possibility ofdisturbing ACM during maintenance activities, ade-quate precautions should be taken to minimize fiberrelease; these will protect workers as well as thebuilding environment Basic O&M procedures, includ-ing use of wet methods and specially equipped tools,should be used to protect building occupants.

O&M cleaning Special cleaning practices

Practices are appropriate for a buildingwith exposed surfacing or

thermal system insulation ACM, especially if the ACMis friable. If gradual deterioration or damage of ACM hasoccurred or is occurring, asbestos-containing uust ordebris could be present. If the building inspection hasdetermined that asbestos-containing dust or debris ispresent in some areas, then the O&M program shouldinclude special cleaning practices to collect residualasbestos dust. Routinely cleaning floors using wetmethods is an example of one such practice. Custodialand maintenance workers in the course of normal workcan also identify and report areas which are in need ofspecial cleaning or repair. Special cleaning techniquesshould suPplement, not replace, rePair or abatementactions Pr damaged, friable ACM. The cleaningprogram should include an initial cleaning followed, asneeded, by subsequent periodic or episodic cleanings.

Building owners and custodial and maintenance staffshould ensure that special O&M cleaning is donecorrectly. Proper cleaning is impor.ant for two reasons:

O The use of improper techniques to dean upasbestos debris caused by previous deteriora-tion or damage may result in widespreadcontamination, and potentially increase air-borne asbestos fiber levels in the building.

O Improper cleaning may cause damage to theACM, thus releasing more airborne asbestosfibers.

Proper O&M cleaning will involve the use of wetcleaning or wet-wiping practices to pick up asbestosfibers. Dry sweeping or dusting can result in asbestosfibers being re-suspended into the building's air andtherefore should not be used. Once wet cloths, rags, ormops have been used to pick up asbestos fibers, theyshould be properly discarded as asbestos waste whilestill wet. They should not be allowed to dry out, sincethe collected fibers might be released at some later timewhen disturbed. The use of special vacuum cleaners,connonly referred to as HEPA vacuums, may bepreferable to wet cleaning in certain situations. Thesevacuums are equipped with filters designed to removevery small particles or fibers such as asbestos byfiltering those particles from the air passing through thevacuum. Since the exhaust air from an ordinary vacuumcleaner is not filtered sufficiently, it is possible for tinyasbestos fibers to pass through the filter and back intothe building ain

28

If in doubt aboutthe possibilityof disturbingACM duringmaintenance

activities,adequate

precautionsshould be taken

to minimizefiber release.

19

tTff

Specialprocedures are

generally neededto minimize the

spread of fibers inthe building after

asbestos fiberrelease occurs.

Here, a worker usesa NEPA vacuum(backpack type) toclean ACM debrisfrom one of severalcarpeted areas in aroom where surfacingmaterial had fallen.

It is important for O&M workers to use caution whenemptying HEPA vacuums and changing the filters.Exposures could result from such activities. Workersshould move the HEPA vacuum to a physically isolatedarea of the facility and put on proper personal protectiveequipment before emptying the dust and debris intoproperly labeled, sealed, and leak-tight containers fordisposal as asbestos-containing waste. When custodialworkers do not work with ACM, trained maintenanceworkers can be used to empty the HEPA vacuums andchange their filters. Decisions regarding special clean-ing practices should be based on the building inspectionand ACM assessment data, including the potential forACM disturbance. hi general, the building would notneed special O&M cleaning when the building containsonly nonfriable (not easily crumbled) ACM; ACM whichhas been encapsulated, encased, or enclosed behind air-tight barriers; or ACM known to be undamaged/undisturbed since the last special cleaning. Flirther-more, where ACM is confined to a single room or area,special cleaning of just that area rather than other partsof the building may be sufficient.

If ACM has been released onto a carpeted area of abuilding, it may not always be possible to adequatelyclean the carpeted area. "Steam" cleaning and HEPAvacuuming methods are sometimes employed for thispurpose. A preliminary study carried out by EPA in1989 showed that hot water vacuums were moreeffective in carpet cleaning than HEPA vacuums, underthe test conditions. Flirther field studies are planned toconfirm these findings.

For carpets, successful cleaning will likely depend onfactors such as the amount of ACM released onto thecarpet, how long the situation has existed, traffic overthe area, as well as the structure and composition of thecarpet itself. It is prudent to evaluate individualsituations on a case-by-case basis. The AsbestosProgram Manager should consider the need for workersengaged in cleaning asbestos fiber-contaminated car-pets to wear proper respiratory proteion. It may alsobe prudent to arrange for this typc of cleaning to bedone after normal working hours or when the facility isless occupied. Additionally, it may be more cost effectiveto properly dispose of contaminated carpets and otherfabrics as asbestos-containing waste if a permanentasbestos control option is being undertaken in thebuilding.

Where the ACM is damaged and located in an "airplenum" where fibers can be transported by theheating, ventilation, or air conditioning (HVAC) systemthroughout the building special cleaning practicesmay be extended to the entire building, including theHVAC system itself.

Procedures forAsbestos FiberRelease Episodes

Special procedures aregenerally needed to min-imize the spread of fibersthroughout the building

after asbestos fiber releases occur, such as the partialcollapse of an ACM ceiling or wall. These proceduresare needed whether the ACM disturbance is intentionalor unintentional. lb provide building owners with someguidance, under EPA regulations for schools a "majorfiber release" is defined as one involving more thanthree square or linear feet of ACM. The procedures tobe followed will vary according to the site of the majorrelease episode, the amount of ACM affected, theextent of fiber release from the ACM, the relationship ofthe release area to the air handling systems, andwhether the release site is accessible to buildingoccupants. Depending on the severity of the episode,asbestos abatement consultants and contractors may beneeded to develop a strategy for conducting the clean-up operations.

In general, for major fiber releases, the area should beisolated by closing doors andjor erecting temporarybarriers to restrict airflow as well as access to the site.Signs should be posted as necessary immediatelyoutside the fiber release site to prevent persons notinvolved in the cleanup operation from inadvertentlyentering the area. If asbestos fibers could enter theHVAC system, the system should be modified to preventfiber entry, or should be shut down and sealed off. Thefinal step should be to employ thorough cleanupprocedures to properly control the ACM, a careful visualinspection, and final clearance air monitoring te verifysatisfactory cleanup.

Similar procedures can be used for much smaller fiberrelease events; where the amount of ACM is on the

29fa_

order of three square or linear feet or less. The HEMvacuuming, wet wiping, and worker protection pro-cedures outlined in this guidance document, as well aswetting ACM wastes and properly placing them in anappropriate leak-tight container (such as a properlylabeled, 6-mil-thick plastic bag), are examples of some ofthe procedures which could be used for both major andminor fiber releases.

It is important to recognize that different levels oftraining are needed for workers involved with fiberrelease episodes. A major release will generally require"asbestos abatement worker training," rather than the

degree of training considered adequate for O&Mworkers.

EPA suggests that building owners and AsbestosProgram Managers consult with state and local regula-tory officials before establishing formal training pro-cedures for each type of situation.

The following table should be useful in determiningwhen to apply certain O&M wo: k practices in buildings.The table illustrates the O&M work practices thatshould be used by custodial and maintenance staff,depending on the likelihood of ACM disturbance.

. V

A ,10 .

s

Likelihood of ACM Disturbance

Accidental Disturbance DisturbanceContact Unlikely Possible Intended or Likely

),

,

Need Pre-Work Approval from AsbestosProgram Manager

Review by ProgramManager

Special Scheduling or Access Control No Yes yes

Supervision Needed No Initial, At Least Yes

HVAC System Modification None As Needed' Shut Down'

Area Containment

Respiratory Protection

None

...

Available For Use

Drop Cloths, Mini-enclosures

,

yes2

.

Protective Clothing

,

Use of Wet Methods

None

. .

No

Review by Asbestos ProgramManager

As Needed

Yes

.1

,

Yes

Use of HEPA Vacuum Available For Use Available For Use As Needed

1) In the area where work takes place2) TYpe of containment may vary For example. smallscale, shortduration tasks may no. , equire full containment.

2130

EPA recommendsthat buildingowners makeavailable all

written elementsof the O&M

program to thebuilding's O&Mstaff as well asto tenants andother building

occupants.

Recordkeeping

All the building asbestos management documentsdiscussed in this Guide (inspection and assessmentreports, O&M program plan, work practices andprocedures, respirator use procedures, fiber releasereports, application for maintenance work and workapproval forms, evaluations of work affecting ACM, andreinspections/surveillance of ACM) should be stored inpermanent files. In addition, for employees engaged inasbestos-related work, federal regulations (see Chapter6) require that employers retain:

O Personal air sampling records, for at least 30years. Personal air samples are those collectedin the worker's breathing zone during perform-ance of work involving asbestos exposures.

O objective data used to qualify for exemptionsfrom OSHA's initial monitoring requirementsfor the duration of the exemption.

O medical records for each employee subject tothe medical surveillance program for theduration of their employment plus 30 years.

0 all employee training records for one yearbeyond the last date of each worker's employ-ment.

In addition, OSHA requires that employers provide toeach employee their record of exposure and medicalsurveillance under the Records Access Standard (29CFR 1910.20) and the Hazard Communication Standard(29 CFR 1910.1200). See the OSHA Construction Rule(29 CFR 1926.58) or the EPA Worker Protection Rule(40 CFR 763 Subpart G) for more details of recordkeep-ing requirements.

EPA recommends that building owners make availableall written elements of the O&M program to thebuilding's O&M staff as well as to tenants and otherbuilding occupants, if applicable. Building owners arealso encouraged to consult with their legal counselconcerrjng appropriate recordkeeping strategies as astandard part of their O&M programs. Additionally,state and local regulations may also require additionalrecordkeeping procedures.

Although the elements discussed in this chapter should appear in any O&M program, the extent towhich each applies will vary depending on the building type, the type of ACM present, and the ACM'slocation and physical condition. To achieve its objectives an O&M program should include thefollowing:

O A notification program to inform buildingoccupant,, workers, and tenants about thelocation of ACM and how to avoid disturbingACM.

O Periodic surveillance and reinspection of ACMat regular intervals by trained workers orproperly trained inspectors. Air monitoring todetect airborne asbestos fibers in the buildingmay provide useful supplemental informationwhen conducted along with a comprehensivevisual and physical ACM inspection/ reinspec-tion program. Air samples are most accuratelyanalyzed using transmission electron micro-scopy (TEM).

O A "work control/permit" system, which somebuilding owners have used st. xessfully tocontrol work that could disturb ACM. ThissYstem requires the person requesting work tosubmit a Job Request Form to the AsbestosProgram Manager before any work is begun.

O O&M work practices to avoid or minimize fiberrelease during activities affecting ACM.

O Recordkeeping. OSHA and EPA have specificrequirements for workers exposed to asbestos.

31

What O&M 'Raining IsNecessary?'types of 'Damning

'Raining of custodial and maintenance workers is one of the keys to a successful O&M program. Ifbuilding owners do not emphasize the importance of well-trained custodial and maintenancepersonnel, asbestos O&M tasks may not be performed properly. This could result in higher levels ofasbestos fibers in the building air and an increased risk faced by both building workers and occupants.

OSHA and EPA require a worker training program forall employees exposed to fiber levels (either measuredor anticipated) at or above the action level (0.1 f/cc,8-hour time-weighted average the TWA) and/or theexcursion limit (1.0 f/cc, 30-minute TWAsee Chapter6). According to the EPA regulations governing schools,all school staff custodial and maintenance Nkrorkers whoconduct any activities that will result in the disturbanceof ACM must receive 16 hours of O&M training. Somestates and municipalities may also have specific trainingrequirements for workers who may be exposed toasbestos, or who work in a building with ACM present.

With proper training, custodial and maintenance staffcan successfully deal with ACM in place, and greatlyreduce the release of asbestos fibers. 'Braining sessionsshould provide basic information on how to deal with alltypes of maintenance activities involving ACM. How-ever, building owners should also recognize that O&Mworkers in the field often encounter unusual, "non-textbook" situations. As a result, training shouldprovide key concepts of asbiistos hazard control. If theseconcepts are dearly understood by workers and theirsupervisors, workers can develop techniques to address

a specific problem in the field. Building owners whoneed to provide O&M training to their custodial andmaintenance staff should contact an EPA environmentalassistance center (see Appendix D) or equally qualifiedtraining organization for more information.

At least three levels of maintenance worker training canbe identified:

LEVEL 1: AWARENESS TRAINING. For custo-dians involved in cleaning and simple main-tenance tasks where ACM may be acciden-tally disturbed.

For example, fixing a light fixture in a ceiling coveredwith surfacing ACM. Such training may range from twoto eight hours, and may include such topics as:

Background information on asbestos.Health effects of asbestos.Worker protection programs.Locations of ACM in the building.Recognition of ACM damage and deterioration.The O&M program for that building.Proper response to fiber release episodes.

32

'Raining ofcustodial andmaintenance

workers isone of thekeys to a

successfulO&M

program.

23

A properly protectedand trained workerconducts a giovebagremoval Job on a sec-tion of thermal sys-tem insulation. Undera propar operationsand maintenance pro-gram, any worker in-volved in such activ-ities would have level1 and 2 training.

This lean exampleof a large-scaleasbestos removalproject (note missingscaffold safety rails).Such projects are wellbeyond the scope ofan P ILA program. TheEPA NESHAP regula-tions require that as-bestos materials beremoved from build-ings prior to demoli-tion or renovationwhen the asbestoswill be disturbed.

24

LEVEL 2: SPECIAL O&M TRAINING. Formaintenance workers involved In generalmaintenance and asbestos material repairtasks.

For example, a repair or removal of a small section ofdamaged TSI, or the installation of electrical conduit inan air plenum containing ACM or ACM debris. Suchtraining generally involves at least 16 hours. This level oftraining uswilly involves more detailed discussions ofthe topics included in Level 1 training as well as:

Federal, state, and local asbestos regulations.Proper asbestos-related work practices.Descriptions of the proper methods of handlingACM, including waste handling and disposal.Respirator use, care, and fit-testing.Protective clothing donning, use, and handling.Hands-on exercises for techniques such asglovebag work and HEPA vacuum use andmaintenance.Appropriate and proper worker decontaminationprocedures.

LEVEL 3: ABATEMENT WORKER TRAINING.For workers who may conduct asbestosabatement

For example, conducting a removal job, constructing anenclosure, or encapsulating a surface containing ACM.This work involves direct, intentional contact withACM. The recognized "abatement worker" trainingcourses approved by EPA or states, under the EPAAHERA model accreditation plan for schools, whichinvolve 24 to 32 hours of training, would fulfill this levelof training.

If this level of training is provided to in-house staff, itmay save time and money in the long run to use theseindividuals to perform such activities. This level oftraining is much more involved than Levels 1 and 2,although it should include some of the same elements(e.g., health effects of asbestos). It will typically includea variety of specialized topics, such as:

Pre-asbestos abatement work activities.Work area preparation.Establishing decontamination units.Personal protection, including respirator selec-tion, use, fit-testing, and protective clothing.Worker decontamination procedures.Safety considerations in the abatement workarea.A series of practical hands-on exercises.Proper handling and disposal of ACM wastes.

The Asbestos Program Manager should consider con-ducting the training program for Levels 1 and 2 if he orshe has sufficient specific asbestos knowledge andtraining. If the Asbestos Program Manager does notconduct the training, the building owner should hire anoutside consultant or send workers to an appropriateO&M training course. A trained (preferably Certified)industrial hygienist or equally qualified safety and healthprofessional should conduct the training on respiratoruse and fit-testing. Ahealth professional should conductthe training on health effects.

OSHA or EPA Regional Offices, as well as state and localagencies and professional associations, may be able tosuggest courses or direct you to listings of trainingproviders for each of the three levels. Appendix Dprovides the addresses and/or phone numbers forOSHA, EPA, and EPA-sponsored training providers.

Where custodial and maintenance services are per-formed by a service company under contract, or wheresome installation or repairs are performed by em-ployees of trade or craft contractors and subcontrac-tors, those workers may need to have training at level 1,2, or 3 as appropriate for their work. The AsbestosProgram Manager or building owner should verify thatthese employees receive appropriate training beforethey begin anY work.

33

-4

In summary, good training is crucial to the success of anO&M program. Strong support for O&M training bythe building owner should convince custodial and

maintenance workers that following the appropriatework procedures is critical to protecting their ownhealth as well as the health of other building occupants.

Properly trained custodial and maintenance workers are critical to a successful O&M program. Thefollowing items are highlighted training requirements:

O OSHA and EPA require worker training Pro-gram for all employees exposed to fiber levelsat or above the action level (0.1 f/cc, 8-hr. TWA)and/or the excursion limit (1.0 f/cc, 30-minuteTWA see Chapter 6).

O Some states and municipalities may havespecific worker training requirements.

O At least three levels of maintenance workertraining can be identified:

Level 1 Awareness training for workersinvolved in activities where ACM may beaccidentally disturbed. May range from 2-8hours.

Level 2 Special O&M training for mainte-nance workers involved in general maintenanceand incidental ACM repair tasks. At least 16hours.

Level 3 Abatement worker tralning forworkers who may conduct asbestos abatement.This work involves direct, intentional contactwith ACM. "Abatement worker" trainingcourses that involve 24 to 32 hours of trainingfulfill this level of training.

34

Strong supportby the building

owner canconvince workers

that followingappropriate

procedures iscritical to

protecting theirown health as

well as the healthof other building

occupants.

25

Building ownersare governed by avariety of federal,state, and local

regulations whichinfluence the way

they must dealwith ACM in

their facilities.

26

What Regulations AffectAsbestos ManagementPrograms in Buildings,Especially O&M Programs?Federal, State, and Local Regulations AffectingO&M Programs

Building owners are governed by a variety of federal, state, and local regulations which influence theway they must deal with ACM in their facilities. Some of these regulations, particularly at the stateand local level, may change frequently Building owners should contact their state and localgovernn.ent agencies, in addition to organizations such as the National Conference of StateLegislatures (NCSL), the National Institute of Building Sciences (NIBS), or EPA environmentalassistance centers, for updated information on these requirements. (Appendix D lists phone numbersfor these organizations.)

OSHA Regulationsand the U.S.EPA WorkerProtection Rule

There are several im-portant OccupationalSafety and Health Ad-ministration (OSHA)and EPA regulations

that are designed to protect workers. They are summa-rized here, as guidance. OSHA has specific require-ments concerning worker protection and proceduresased to control ACM. These include the OSHAconstruction industry standard for asbestos (29 CFR1926.58), which applies to O&M work, and the generalindustry asbestos standard (29 CFR 1910.1001). State-delegated OSHA plans, as well as local jurisdictions,may impose additional requirements.

For most operations and maintenance activities inbuilding areas where only non-friable ACM is present orwhere friable ACM is in good condition, applicableOSHA permissible exposure limits are not likely to beexceeded. However, it is possible that some O&Mactivities will disturb ACM to such an extent that theOSHA limits are exceeded, unless good work practicesare followed.

The OSHA standards generally cover private sectorworkers, and public sector employees in states whichhave an OSHA state plan. Public sector employees, suchas city or county government employees, or certainschool employees, who are not already sulsject to a stateOSHA plan are coveted by the EPA "Worker ProtectionRule" (Federal Register: February 25, 1987; 40 CFR763 Subpart G, Asbestos Abatement Projects; WorkerProtection, Final Rule). Note: As this document goes toPrets, OSHA is considering a substantial number ofchanges to its regulations.

The OSHA standards and the EPA Worker ProtectionRule require employers to address a number of itemswhich are triggered by exposure of employees toacbestos fibers. Exposure is discussed in terms of fibersper cubic centimeter (cc) of air. A cc is a volumeapproximately equivalent to that of a sugar cube.

1kvo main provisions of the regulations fall into thegeneral category of "Permissible Exposure Limits(PELs)" to akborne asbestos fibers. They are:

35

2

8-Hour Time-weighted average limit(TWA)0.2 fiber per cubic centimeter (f/cc)of air based on an 8-hour time-weightedaverage (TWA) mmpling period. This is themaximum level of airborne asbestos, onaverage, that any employee may be exposed toover an 8-hour period (normal work shift).Excursion limit (EL) 1.0 f/cc as averagedover a sampling period of 30 minutes.

These levels trigger mandatory requirements, whichinclude the use of respirators and protective clothing,the establishment of "regulated areas," the posting ofdanger signs as well as the use of engineering controlsand specific work practices.

OSHA regulations also establish an 'Action Lever! 0.1f/cc for an 8-hour TWA. Employee training is requiredonce the action level of 0.1 f/cc and/or the "ExcursionLimit" is reached. This training must include topicsspecified by the OSHA rules. If an employee is exposedat or above the action level for a period of 30 days ormore in a calendar year, medical surveillance is requiredaccording to the OSHA construction industry asbestosstandard.

OSHA also requires medical examinations under its"General Industry Standard" for any employee exposedto fiber levels in the air at or above the WHA "actionlevel" (0.1 f/cc) and/or the "excursion limit" (1.0 f/cc). Inboth cases the action level and excursion limit theOSHA medical examination requirement applies if theexposure occurs for at least one day per year.

The OSHA "Construction Industry Standard" (29 CFR1926.58) for asbestos, is generally applicable fc: theworkers who carry out the kinds of work discussed inthis O&M guidance document. The OSHA construc-tion industry asbestos standard applies to demolitionand asbestos removal or encapsulation projects, as wellas to repair maintenance, alteration, or renovation ifACM is involved. ACM spills or emergency clean-upactions are also covered by Ws regulation.

According to those regulations, participation in amedical surveillance program is required for anyemployee who is required to wear a negative pressure,air-purifying respirator. Preplacement, annual, andtermination physical exams are also required for theseemployees. However, a termination exam is onlynecessary under the construction industry standard(which applies to custodial and mdmtenance employees)if a physician recommends it. While not mandatory EPAand NIOSH recommend physical examinations, includ-ing cardiac and pulmonary tests, for any employeerequired to wear a respirator by the building owner.These tests determine whether workers will be undulystressed or uncomfortable when using a respirator.

Additional requirements of the OSHA asbestos stand-ards, such as the use of air filtration systems and hygienefacilities, involve procedures which are most applicableto large-scale asbestos abatement projects. However,

these rules also include a number of recommendationsfor procedures which might be appropriate for a varietyof O&M programs for buildings.

"Appendix G" which is spe-cified as a non-mandatory

Short-duration section to the OSHA reguia-Projects tion 29 CFR 1926.58, may

become mandatory under certain circumstances where"small-scale, short-duration" asbestos projects areconducted. These projects are not precisely defined interms of either size or duration, although their natureand scope are illustrated by examples presented in thetext of the regulation. Properly trained mthntenanceworkers may conduct these projects. Examples mayinclude removing small sections of pipe insulation orcovering for pipe repair, replacing valves, installingelectrical conduits, or patching or removing smallsections of drywall. OSHA issued a clarification of thedefinition of a "small-scale, short-duration" (SS/SD)project in a September 1987 asbestos directive. Thedirective focuses on intent, stating that in SS/SDprojects, the removal of ACM is not the primary goal ofthe job. If the purpose of a small-scale, short-durationproject is maintenance, repair, or renovation of theequipment or surface behind the ACMnot abatementof ACMthen the appendix provisions may apply. If theintent of the work is abatement of the ACM, then thefull-scale abatement control requirements apply.

In any event, this appendix section of the OSHAconstruction standard outlines requirements for the useof certain engineering and work practice controls suchas glovebags, mini-enclosures, and special vacuumingtechniques. Similar information on these proceduresmay be found in the EPA's AHERA regulations forschools. (See final AHERA rule, Appendix B, for SS/SDprojects.)

EPA's rules concern-U.S. EPA Nationaling the application,Emission Standards

for Hazardous Air removal, and disposal

Pollutants (NESHAP) of ACM, as well(40 CFR 61 Subpart M) as manufacturing,

spraying and fabri-cating of ACM, were issued under the asbestosNESHAP. The asbest. NESHAP regulation governsasbestos demolition and renovation projects in allfacilities. The NESHAP rule usually requires owners oroperators to have all friable ACM removed before abuilding is demolished, and may require its removalbefore a renovation. For renovation projects wherefriable ACM will be disturbed, the NESHAP rule mayrequire appropriate work practices or procedures forthe control of emissions. It is prudent to note that anyACM which may become friable poses a potentialhazard that should be addressed. The building ownershould consider that in many instances, the removal offriable ACM prior to demolition could be less expensivethan removals while the building is still occupied andbeing used. Some revisions to the current NESHAPrule are anticipated by the end of 1990.

36

In general,applicable OSHA

permissibleexposure limitsare not likely tobe exceeded for

most O&Mactivities in

building areaswhere only non-friable ACM is

present or wherefriable ACM is ingood condition.

27

Depending onproject size, EPAor the state mustbe notified before

a building isdemolished or

renovated.

28

NotificationEPA or the state (if the state has been delegatedauthority under NESHAP) must be notified before abuilding is demolished or renovated. The followinginformation is required on the NESHAP notice:

1 Name and address of the building owner ormanager;

2 Description and location of the building;

Estimate of the approximate amount of friableACM present in the facility;

Scheduled starting and completion dates ofACM removal;

Nature of planned demolition or renovationand method(s) to be used;

3

4

5

7

Procedures to be used to comply with therequirements of the regulation; and

Name, address, and location of the disposalsite where the friable asbestos waste materialwill be deposited.

The notification requirements do not apply if a buildingowner plans renovation ^rojects which will disturb lessthan the NESHAP limits of 160 square feet of friableACM on facility components or 260 linear feet of friableACM on pipes (quantities involved over a one-yearperiod). For renovation operations in which the amountof ACM equals or exceeds the NESHAP limits, notifica-tion is required as soon as possible.

Emissions Controland Waste DisposalThe NESHAP asbestos rule prohibits visible emissionsto the outside air by requiring emission control pro-cedures and appropriate work practices during collec-tion, packaging, transportation or disposal of friableACM waste. All ACM must be kept wet until sealed in aleak-tight container that includes the appropriate label.The following table provides a simplified reference forbuilding owners regarding the key existing NESHAPrequirements.

Resource Conservationand Recovery ActRegulations (RCRA);and ComprehensiveEnvironmental Response,Compensation, andLiability Act Regulations(CERCLA, or "Superfund")

Under ex-panded au-thority ofRCRA, a fewstates haveclassifiedasbestos-con-taining wasteas a hazardous

waste, and require stringent handling, manifesting, anddisposal procedures. In those cases, the state hazardous

waste agency should be contacted before disposing ofasbestos for approved disposal methods and re-cordir,*ping requirements, and for a list of approveddisposal sites.

Pliable asbestos is also included as a hazardous sub-stance under EPA's CERCLA regulations. The owner ormanager of a facility (e.g., building, installation, vessel,landfill) may have some reporting requirements. Checkwith your EPA Regional Office for further information.(See Appendix D for telephone numbers.)

The AsbestosHazard EmergencyResponse ActRegulations (AHERA) Emergency Re-

sponse Act of 1986 (AHERA). The AHERAregulatoryrequirements deal only with public and private elemen-tary and secondaty school building& The regulationsrequire schools to conduct inspections, develop com-prehensive asbestos management plans, and selectasbestos response actions to deal with asbestos hazards.The AHERA rules do not require schools to removeACM.

In October 1987,EPA issued final reg-ulations to carry outthe Asbestos Hazard

A key element of the AHERA regulations requiresschools to develop an O&M program if friable ACM ispresent. The AHERA O&M requirements aLso covernon-friable ACM which is about to become friable. Forexample, drilling through an ACM wall will likely resultin friable ACM. Under the AHERA O&M provisions,schools must carry out specific O&M procedures whichprovide for the clean-up of any ACM releases and helpensure the general safety of school maintenance andcustodial workers, as well as all other school buildingoccupants. The AHERA regulation's O&M require-ments mandate that schools employ apecific workpractices including wet wiping, HEPA vacuuming,proper waste disposal procedures, and specific trainingfor custodial and inaintenatiee einPloyea Wilds:Atkin-buildings with ACM.

U.S. EPAAsbestos Banand Phaseout Rule

Bans on some uses andapplications of asbestosunder the Clean Air Actwere briefly described

in Chapter 1. In July 1989, under the Tbxic SubstancesControl Act (TSCA), EPA promulgated an Asbestos Banand Phaseout Rule. The complete rule was published inthe Federal Register on July 12, 1989.

Beginning in 1990 and taking effect in three stages, therule prohibits the importation, manufacture, and proc-essing of 94 percent of all remaining asbestos productsin the United States over a period of seven years.

37

Demolition Renovation

AMOUNT*(in 1 yr.)

--260 Init.or ?..- 160 sq. ft.

<260 Init.or <160 sq.ft.

..-260 In ft.or ?-.- 160 sq. ft

<260 In. ft.<160 sq. ft.

NOTIFICATION YES YES YESNOT

REQUIRED

HOW FAR IN ADVANCE* 10 DM'S 20 DAYSAS SOON

AS POSSIBLENOT REQUIRED

EMISSION CONTROLS(Work Practices)

yEs NOTREQUIRED

YESNOT

REQUIRED

DISPOSALSTANDARD

YESNOT

REQUIREDYES

NOTREQUIRED

*May be changed on promulgation of Revised NESHAP Rule m 1990

A variety of federal, state, and local regulations govern the way building owners must deal with ACMin their facilities. State and local regulations may be more stringent than federal standards and oftenchange rapidly. Building owners should periodically check with the appropriate Federal, State, andlocal authorities to determine whether any new asbestos regulations have been developed or whethercurrent regulations have been amended. Specific federal regulations that may affect asbestos-relatedtasks and/or workers are highlighted here:

0 OSHA Construction Industry Standard forAsbestos (29 CFR 1926.58).

0 OSHA General Industry Standard for Asbestos(29 CFR 1910.1001).

0 OSHA Respiratory Protection Standard(29 CFR 1910.134).

0 EPA Worker Protection Rule (40 CFR 763Subpart G).

O EPA National Emission Standards for Haz-ardous Air Pollutants (NESHAP) (40 CFR 61Subpart M).

O EPA Asbestos Hazard Emergency ResponseAct (AHERA) Regulations (40 CFR 763 Sub-part E).

O EPA Asbestos Ban and Phaseout Rule (40 CFR763 Subpart I).

38

Appendix A.

Giossary of Terms

ACM Asbestos-Containing Material. Any material containing more than one percent asbestos.

Asbestos Program Manager A building owner or designated representative who supervises all aspects of the facilityasbestos management and control program.

Air Plenum Any space used to convey air in a building or structure. The space above a suspended ceilingis often used as an air plenum.

Asbestos Abatement Procedures to control fiber release from asbestos-containing materials in a building or toremove it entirely. These may involve removal, encapsulation, repair, enclosure,encasement, and operations and maintenance programs.

Delamination Separation of one layer from another.

EPA US. Environmental Protection Agency

Friable Asbestos Any materials that contain greater than one percent asbestos, and which can be crumbled,pulverized, or reduced to powder by hand pressure. This may also include previously non-friable material which becomes broken or damaged by mechanical force.

Glovebag

HEPA Filter

Industrial Hygienist

Medical Surveillance

Miscellaneous ACM

NESHAP

NIOSH

Personal Air Samples

Prevalent Level Samples

Surfacing ACM

TSI

TWA

A polyethylene or polyvinyl chloride bag-like enclosure affixed around an asbestos-containing source (most often, TSI) so that the material may be removed while minimizingrelease of airborne fibers to the surrounding atmosphere.

High-Efficiency Particulate Air Filter. Such filters are rated to trap at least 99.97% of allparticles 0.3 microns in diameter or larger.

A professional qualified by education, training, and experience to anticipate, recognize,evaluate and develop controls for occupational health hazards.

A periodic comprehensive review of a worker's health status. The required elements of anacceptable medical surveillance program are listed in the Occupational Safety and HealthAdministration standards for asbestos.

Interior asbestos-containing building material on strurtural components, structuralmembers or fixtures, such as floor and ceiling tiles; does not include surfacing material orthermal system insulation.

National Emission Standard for Hazardous Air Pollutants EIA Rules under the Clean AirAct.

The National Institute for Occupational Safety and Health, which was established by theOccupational Safety and Health Act of 1970. Primary fiinctions of NIOSH are to conductresearch, issue technical information, and test and certify respirators.

An air sample taken with a sampling pump directly attached to the worker with thecollecting filter and cassette placed in the worker's breathing zone. These samples arerequired by the OSHA asbestos standards and the EPA Worker Protection Rule.

Air samples taken under normal conditions (also known as ambient background samples).

Asbestos-containing material that is sprayed-on, troweled-on or otherwise applied tosurfaces, such as acoustical plaster on ceilings and fireproofing materials on structuralmembers, or other materials on surfaces for aooustical, fireproofing, or other purposes.

Thermal system insulation asbestos-containing material applied to pipes, fittings,boilers, breeching, tanks, ducts or other interior structural components to prevent heatloss or gain or water condensation.

Time-weighted Average. In air sampling, this refers to the average air concentration ofcontaminants during a particular sampling period.

r) (t) 0

'''-f

Appendix B.

Sample Recordkeeping Forms

Form 1. A sample form for recording information during ACM reassessment.

Reinspection of Asbestos-Containing Materials

Location of asbestos-containing material (address, building, room, or general description):

'type of asbestos-containIng materlal(s):1. Sprayed- or troweled-on ceilmgs or walls2. Sprayed- or troweled-on structural members3. Insulation on pipes, tanks, or boiler4. Other (describe):

Abatement Status:

1. The material has been encapsulated ___, enclosed ______ neither _____, removed......._

Assessment:

1. Evidence of physical damage:

2. Evidence of water damage.

3. Evidence of delamination or other damage.

4. Degree of accessibility of the material.

5. Degree of activity near the material.

6. Location in an air plenum, air shaft, or airstreanr

7. Other observations (including the condition of the encapsulant or enclosure, if any).

**Recommended Action:

Signed. Date.(evaluator)

40 31

Form 2. A sample application form for maintenance work approval.

Job Request Form for Maintenance Work

Name. Date.

Telephone No Job Request No.

Requested starting date. Anticipated finish date.

Address, building, and room number(s) (or description of area) where work is to be performed:

Description of work:

Description of any asbestos-containing material that might be affected, if known (include location and type):

Name and telephone number of requestor:

Name and telephone number of supervisor:

Submit this application to:

(The Asbestos Pmgram Manager)

NOTE: An application must be submitted for all maintenance work whether or not asbestos-containing material might beaffected. An authorization must then be received before any work can proceed.

Granted (Job Request No.With conditions*Denied

)

*Conditions:

32

1

Form 3. A sample maintenance work authorization form.

Maintenance Work Authorization Form

AUTHORIZATION

Authorization is given to proceed with the following maintenance work:

No

PRESENCE OF ASBESTOSCONTAINING MATERIALS_ Asbestos-containing materials are not present in the vicinity of the maintenance work._ ACM is present, but its disturbance is not anticipated; however, if conditions clu...ge, the Asbestos Program Manager

will re-evaluate the work request prior to proceeding._ ACM is present, and may be disturbed.

Work Practices if Asbestos-Containing Materials Are Present

The following work practices shall be employed to avoid or minimize disturbing asbestos:*

Personal Protection if Asbostos-Cont::;ning Materials Are Present**

The following equipment/clothes shall be used/worn during the work to protect workers:

(manuals on personal protection can be referenced)

Special Practices and/or Equipment Required:

Signed: Date.(Asbestos Program Manager)

4233

34

Form 4. A sample work evaluation form

Evaluation of Work Affecting Asbestos-Containing Materials

This evaluation covers the following maintenance work:

Location of workd (address, building, room number(s), or general description):

Date(s) of work.

Description of work.

Work approval form number

Evaluation of work practices employed to minimize disturbance of asbestos:

Evaluation of work practices employed to contain released fibers and to clean up the work area:

Evaluation of equipment and procedures used to protect workers:

Personal air monitoring results; (in-house worker or contract?)

Worker name Results.

Worker name Results:

Handling or storage of ACM waste.

Signed: Date.(Asbestos Program Manager)

4 3

Appendix C.

Illustrative Organization Charts

Figure 1. A sample organization for a building owner witha large in-house management staff. Shaded boxes indicateoutside assistance.

Owners and Managers Who Employ an Extensive In-house Management Staff

IN-HOUSE STAFF (FIGURE 1)

Asbestos Program Manager: Has authority and overallresponsibility for the asbestos control program. May developthe O&M program. Coordinat.t. s all activities. May alsoadminister the respiratory protection program.

Physical Plant Manager: (may also be the AsbestosProgram Manager) Participates in establislung work practicesfor cleaning and maintenance activities, and in trainingcustodial and maintenance staff to use them. Assists inimplementing the O&M program and in conducting periodicreinspections of the ACM. Ensures that outside contractorsfollow O&M procedures.

Communications Person: (Public Affairs Officer, Nurse,Physician, Industrial Hygienist) Assists in preparation anddistribution of information about ACM in the building. Personshould be a good speaker and communk... )r.

Recordkeeping Person: (Executive Assistant, Secretary)Responsible for maintaining records.

OUTSIDE ASSISTANCE

EPA Regional Asbestos Coordinato; NESHAP COor-dinator and State/Local Government Advisors: Pro-vide general guidance and answer specific questions.

OSHA Regional Office: May be helpful in answeringquestions about existing regulations, and providing guidancefor worker protection.

Asbestos Consultant(s)*: (Industrial Hygienists, HealthProfessionals, Architects, Engineers, and others) May assist invarious aspects of the asbestos O&M program, including itsdevelopment and implementation. May also conduct materialinspections and provide work practice recommendations.

Lawyer: Provides advice on legal requirements (such as lawsand statutes) and liability aspects of the program.

Asbestos Contractor*: May provide services for ACMabatement and for building decontamination following a fiberrelease episode.

*It is important for owners and Asbestos Program Manager's toconsider potential "conflict of interest" issues pertaining to thosepersons or firms used to sample, inspect, assess, analyze, recom-mend response actions, design response actions, and conductasbestos response actions.

4435

P2-

Figure 2. A sampk organization for owners of buildingswhere services are provided by contract. Shaded boxesindicate outside assistance.

Owners and Managers Who Contract For Services

IN-HOUSE STAFF (FIGURE 2)

Asbestos Program Manager: Has overall responsibilityfor the asbestos control program. May develop and implementthe O&M program. Establishes training and experience re-quirements for contractor's workers. Supervises and enforceswork practices with assistance of work crew supervisors.Conducts periodic reinspections and responsible for rec-ordkeeping. This person should be properly trained in O&Mprogram development and implementation (see Chapter 5).

OUTSIDE ASSISTANCE

EPA Regional Asbestos Coordinator and State/LocalGovernment Advisors: Provide general guidance andanswer specific questions.

OSHA Regional Office: May be helpful in answeringquestions about existing regulations and providing guidancefor worker protection.

Asbestos Consultant(s)*: (Industrial Hygienists, HealthProfessionals, Architects, Engineers, and others) May assistAsbestos Program Manager in various aspects of the asbestosO&M program, including development and implementation.May also conduct the inspection and provide work practicesrecommendations.

Lawyer: Provides advice on legal requirements (laws andstatutes) and liability aspects of the program.

Asbestos Contractor*: May provide services for ACMabatement and building decontamination following a fiberrelease episode.

*It is important for owners and Asbestos Program Manager's toconsider potential "conflict of interest" issues pertaining to thosepersons or firms used to sample, inspect, assess, analyv-, recom-mend response actions, design response actions, and conductasbestos response actions.

4 5

APPENDIX D.

Additional Assistance and TraininV

EPA REGIONAL CONTACTS

Additional assistance can be obtained from your U.S.EPA Regional Asbestos Coordinators, NESHAP Re-gional Coordinators, and OSHA Regional Offices. Theirtelephone numbers are listed below:

EPA Region I: (CT,ME,MA,NH,RI,VT)

Asbestos Coordinator (617) 565-3835NESHAP Coordinator (617) 565-3265

EPA Region II: (NJ,NY,PR,VI)

Asbestos Coordinator (201) 321-6671NESHAP Coordinator (212) 264-6770

EPA Region III: (DE,DC,MD,PA,VA,WV)

Asbestos Coordinator (215) 597-3160NESHAP Coordinator (215) 597-6550

EPA Region IV: (AL,FL,GA,KY,MS,NC,SC,TN)

Asbestos Coordinator (404) 347-5014NESHAP Coordinator (404) 347-2904

EPA Region V: (IL,IN,MLMN,OH,WI)

Asbestos Coordinator (312) 886-6003NESHAP Coordinator (312) 353-2088

EPA Region VI: (AR,LA,NM,OK,TX)

Asbestos Coordinator (214) 655-7244NESHAP Coordinator (214) 655-7229

EPA Region VII: (IA,KS,MO,NE)

Asbestos Coordinator (913) 551-7020NESHAP Coordinator (913) 551-7020

EPA Region VIII: (CO,MT,ND,SD,UT,WY)

Asbestos Coordinator (303) 293-1442NESHAP Coordinator (303) 294-7685

EPA Region IX: (AZ,CA,HI,NV,AS,GU)

Asbestos Coordinator (415) 556-5406NESHAP Coordinator (415) 556-5526

EPA Region X: (AK,ID,OR,WA)

Asbestos Coordinator (206) 442-4762NESHAP Coordinator (206) 442-1757

OSHA REGIONAL OFFICES

Region I Boston, MA: (617) 223-6710Region II New York, NY: (212) 944-3432Region IIIPhiladelphia, PA: (215) 5964201Region IVAtlanta, GA: (404) 347-3573Region V Chicago, IL: (312) 353-2220Region VI Dallas, TX: (214) 767 4731

Region VII Kansas City, MO: (816) 374-5861Region VIII Denver, CO: (303) 844-3061Region IXSat, Francisco, CA: (415) 995-5672Region X Seattle, WA: (206) 442-5930

Toxic Substances Control Act (TSCA)Assistance Hotline

Copies of the EPA Guidance Documents, Technical Bulletins,and other publications cited here can be obtained by calling theTSCA Assistance Hotline, in Washington, D.C., at: (202)554-1404.

Approved 'Raining Centers

Certain training centers and satelhte centers were initiallyfunded by EPA to develop asbestos training courses. They, andother training providers approved by EPA or states, offercourses for professionals such as asbestos inspectors andmanagement planners involved with ACM detection andcontrol, for asbestos abatement project designers, projectsupervisors and abatement workers, and others. In general,qualified professionals trained as inspectors and asbestosmanagement planners would be good choices to design anO&M plan. Original training centers are located at thefollowing saes:

Georgia Institute of TechnologyGTRI/EDL/ESTD29 O'Keefe BuildingAtlanta, GA 30332(404) 894-3806

University of KansasAsbestos Training Center6600 College Blvd. Suite 315Overland Park, KS 66211(913) 491-0181

Pacific AsbestosInformation CenterUniversity CA/Extension2223 Fulton St.Berkeley, CA 94720(415) 643-7143

Tufts UniversityCurtis HallAsbestos Information Center474 Boston AvenueMedford, MA 02155(617) 381-3531

University of Illinois at ChicagoMidwest Asbestos Information CenterBox 6998Chicago, IL 60680(31) 996-6904

Additional training providers are listed in the Federal Registeron a regular basis. Call (202) 554-1404 for information. Inaddition, information on how to receive a copy of an O&MCourse produced by an EPA contractor may be obtained at thesame number.

OTHER ORGANIZATIONS

National Conference of State Legislatures (NCSL)Denver, CO (303) 623-7800

National Institute of Building Sciences (NIBS),Washington, D.C. (202) 289-7800

American Board of Industrial Hygiene (ABIH).Lansing, MI (517) 321-2638

National Institute for Standards and Technology (NIST),Gaithersburg, MD (contact for lab accreditation)(301) 975-4016

4 637

APPENDIX E:

Respiratory ProtectionRecommendations

EPA recommends that the following guidelines be followed forrespiratory protection during various custodial and mainte-nance tasks. These guidelines are Issued to cover tasks that donot always create routine fiber levels high enough to triggeiOSHA respiratory protection requirements. Therefore, build-ing owners should note they go beyond OSHA requirements.

Routine maintenance where contact withACM is unlikely. No respiratory protection re-quired. (Air-purifymg respirator with high-efficiencyfilters should be available if needed; half-face or fullfacepiece).

Routine maintenance where there is reason-able likelihood of ACM disturbance. Air-purify-ing respirator w h high-efficiency filters (half-face orfull facepiece).

Maintenance or repair involving intentionalsmall-scale disturbance of ACM. Powered air-purifying respirator with high-efficiency filters, or air-purifying respirator with high-efficiency filters (half-face or full facepiece). If glove bags are used to containthe ACM during disturbance, either half-face or fullfacepiece air-purifying respirators with high-effi-ciency filters may be used.

Any O&M activity requiring sawing, cutting,drilling, abrading, grinding, or sanding ACM.(NOTE: specially equipped tools with local exhaustventilation should be used for these activities. See 29CFR 1910.) Powered air-purifying respirator withhigh-efficiency filters, or full faceoiecc, air-purifyingrespirator equipped with high-efficiency filters shouldbe used.

Cleanup after a minor asbestos fiber release.Air-purifying respirator with lugh-efficicticy filters(half-face or full facepiece).

Cleanup after a major asbestos fiber release.Air-supplied respirators, either the "Type airlinerespirator equipped with a backup high-efficiencyfilter or SCBA (Self-Contained Breathing Apparatus).

The U.S. EPA, in collaboration with NIOSH, has issued aguidance document. "A Guide to Respiratory Protection forthe Asbestos Abatement Industry" which recommends levelsof respiratory protection for those engaged in large-scaleasbestos abatement projects that are beyond routine O&Mprocedures. Air-supplied self-contained, and "type C" airlinerespirators are the focus of the EPA/NIOSH document. Theserespirators allow workers to breathe fresh air supplied throughhoses and face masks, and are generally used only by asbestosabatement workers engaged in large-scale asbestos removalprojects. They are usually not considered either practical ornecessary for most custodial and maintenance jobs.

38

An industrial hygienist or envircnmzmal/occwationaiprofessional should assist workers with respirator selectionand fitting, and train them in respirator use. Fit-testing (whichmeans determining whether a particular brand and size ofrespirator properly fits an individual worker) is essential, sincerespirators which leak at the face seal provide significantly lessprotection. OSHA requires fit-testing initially and every sixmonths for employees required to wear a negative pressurerespirator for protection against asbestos, or for individualsexposed at or above the OSHA-specified limits.

A respirator's effectiveness is also influenced by how it ishandled, cleaned, and stored. Custodial and maintenance staffshould clean their respirators after each u! and disinfect theirrespirators at the end of a day's use. This ..nproves comfort,and also reduces the chances of skin irritation or infection.After cleaning the respirator, custodial and maintenance staffshould place the respirator (with the worker's name) in a cleanand sanitary location and store the unit in a secure place forfuture use. Respirators should be visually inspected by the userbefore and after each use, during cleaning and at least monthlywhen not in use. Inspection records should be maintainedaccordingly. When the respirator's high-efficiency filters arediscarded, they should be disposed of as asbestos waste.

APPENDIX F

Existing q3A nuidnnna fnr rnril qtap That a imilding Owner May Taketo Control ACM

Action

Appoint Asbestos ProgramManager and Develop anOrganizational Policy.

Inspect the facility to determineif ACM is present. Take bulksamples of suspect ACM andassess the material's condition.

Establish an O&M program.

Implement and ConscientiouslyManage the O&M Program;Assess the Potential forExposure to Asbestos and SelectResponse Actions.

Select and ImplementAbatement Actions Other ThanO&M When Necessary

Existing EPA Guidance/Regulations*

"Guidance for Controlling Asbestos-Containing Materials in Buildings" ("Purple Book")EPA publication number: 560/5-85-024

"Guidance for Controlling Asbestos-Containing Materials in Buildings" ("Purple Book",chapter 2) EPA publication number: 560/5-85-024

"Simplified Sampling Scheme for Surfacing Materials" ("Pink Book") EPA publicationnumber: 560/5-85-030a

"Asbestos-Containing Materials in Schools; Final Rule and Notice" (Asbestos HazardEmergency Resmnse Act. or AHERA). Federal Reguter October 30, 1987. (sections763.85 to 763.88)

Model training course materials for accrediting asbestos building inspectors in accordancewith AHERA (inspection/assessment materials).

"Purple Book", Chapter 3

AHERA regulations, sections 763.91 and 763.92

EPA Guidance for Service and Maintenance Personnel. EPA publication number560/5-85-018

"Purple Book", Chapter 4

Model training course materials for accrediting asbestos management planners inaccorclance with AHERA (assessment materials).

AHERA regulations, section 763.88 and 793.92

"Purple Book", Chapter 6

AHERA regulations. section 763.93 (including 763.85 through 763.92)

AHERA regulation, appendix A; Determining Completion of Response Actions-Methods.

"Abatement of Asbestos-Containing Pipe Insulation" U.S. EPA; Asbestos-in-BuildingsTechnical Bulletin 1986-2.

U.S. EPA National Emission Standards for Hazardous Air Pollutants (NESIIAP)Regulations (40 CFR 61)

Model training course materials for accrediting asbestos management planners inaccordance with AHERA (assessment materials).

*Most of these guidance materials are available through EPA's TSCA Assistance Hotline, at (202) 554-1404,

4 839

APPENDIX G:

Sample List of Suspect AshectnQxtnntninin- Materiale

Cement PipesCement WallboardCement SidingAsphalt Floor TileVinyl Floor TileVinyl Sheet FlooringFlooring BackingConstruction Mastics (floor tile, carpet, ceiling tile. etc.)Acoustical PlasterDecorative PlasterTextured Paints/CoatingsCeiling Tiles and Lay-in PanelsSpray-Applied InsulationBlown-in InsulationFireproofing MaterialsTaping Compounds (thermal)Packing Materials (for wall/floor penetrations)High Temperature GasketsLaboratory Hoods/Table TopsLaboratory GlovesFire BlanketsFire CurtainsElevator Equipment Panels

Elevator Brake ShoesHVAC Duct InsulationBoiler InsulationBreeching InsulationDuctwork Flexible Fabric ConnectionsCooling TowersPipe Insulation (corrugated air-cell, block. etc.)Heating and Electrical DuctsElectrical Panel PartitionsElectrical ClothElectric Wiring InsulationChalkboardsRoofing ShinglesRoofing FeltBase FlashingThermal Paper ProductsFire DoorsCaulking/PuttiesAdhesivesWallboardJoint CompoundsVinyl Wall CoveringsSpackling Compounds

NOTE: This list does not int.'ude every produLt/matenal that may i.untain astestus It is intended as a general guide to ShUV. hiLh types ofmaterials may contain asbestos.

APPENDIX H:

References

USEPA. 1984. U.S. Environmental Protection Agency. Na-tional Emusion Standards far Hazardous Air Pollutants.40CFR 61. April 5, 1984.

USEPA. 1985. US. Environmental Protection Agency. Meas-uring airborne asbestos following an abatement action.Washington DC: USEPA. EPA 600/4-85-049. ("Silver Book")

USEPA. 1985. U.S. Environmental Protection Agency. As-bestos in buildings: Simplified sampling scheme for surfacingmaterials. Washington DC: USEPA. EPA 560/5-85-030A.("Pink Book")

USEPA. 1985 U.S. Environmental Protection Agency. Guid-ance for controlling asbestos-con;aining materials in build-ings. Washington DC: EPA 560/5-85-024. ("Purple Book")

USEPA. 1985. US. Environmental Prozection Agency. As-bestos in buildings: Guidance for service and maintenancepersonnel. Washington DC: EPA 560/5-85-018. ("CustodialPamphlet")

USEPA. 1986. US. Environmental Protection Agency. Abate-»tent of asbestos-containing piPe insulation. Washington DC:Technical Bulletin No. 1986-2.

USEPA. 1986. US. Environmental Protection Agency. Aguide to respiratory protection for the asbestos abatementindustry. Washington DC: EPA 560/OPTS-86-001.

40

USEPA. 1987. Asbestos Abatenient Projects; Worker Protec-tion, Final Rule. 40 CFR 763. February 1987.

USEPA. 1987. U.S. Environmental Protection Agency. As-bestos-Containing Materials in Schools; Final Rule andNotice. 40 CFR 763. Federal RegWer, October 30, 1987.

USEPA. 1988. EPA Study of Asbestos-Containing Materialsin Public Buildings: A Report to Congress. February, 1988.

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