Asbestos Management Program

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1 Asbestos Management Program Concordia University Environmental Health and Safety Updated: December 2009 Lina Filacchione, Manager, Industrial Hygiene and Prevention EHS-DOC-014 v.3

2 TABLE OF CONTENTS INTRODUCTION...4 SCOPE...4 DEFINITIONS...6 HEALTH RISKS...7 CONCORDIA BUILDINGS...8 ASBESTOS PROGRAM RESPONSIBILITIES...8 INDUSTRIAL HYGIENE MANAGER...9 FACILITIES MANAGEMENT...9 PROJECT MANAGEMENT SERVICES EMPLOYEES CONTRACTORS CSST CATEGORIES OF ASBESTOS WORK BASED UPON RISK TYPE 1 - LOW RISK TYPE 2 - MODERATE RISK TYPE 3 MODERATELY HIGH RISK TYPE 4 - HIGH RISK GUIDELINES/ PROCEDURES GENERAL PROHIBITIONS FOR ALL TYPES OF ASBESTOS WORK GENERAL REQUIREMENTS FOR ALL TYPES OF ASBESTOS WORK EMPLOYER OBLIGATIONS TYPE 1 (LOW RISK) WORK TYPE - 2 (MODERATE RISK) WORK TYPE - 3 (MODERATELY HIGH RISK) WORK TYPE - 4 (HIGH RISK) WORK SPECIFICATIONS FOR CONSULTANTS MONITORING FOR HIGH RISK ASBESTOS REMOVAL PERSONAL PROTECTION RESPIRATOR PROTECTION PROTECTIVE CLOTHING WASTE REMOVAL EHS-DOC-014 v.3 2

3 EDUCATION/TRAINING LEVEL 1: AWARENESS TRAINING LEVEL 2: SPECIAL TRAINING LEVEL 3: ABATEMENT WORKER TRAINING PERIODIC INSPECTION AND AIR MONITORING RECORD KEEPING APPENDIX A: CONSTRUCTION DATES AND ACM INFORMATION FOR CONCORDIA BUILDINGS APPENDIX B: ASBESTOS PERMIT FORM APPENDIX C: MODERATE RISK WORK PROCEDURES FOR ASBESTOS CONTAINING MATERIAL APPENDIX D: LIST OF SAMPLING LOCATIONS AND PROCEDURES EHS-DOC-014 v.3 3

4 INTRODUCTION According to regulations, asbestos is defined as the fibrous form of mineral silicates belonging to rock forming minerals of the serpentine group, that is, chrysotile, and the amphibole group, that is, actinolite, amosite, anthophyllite, crocidolite, tremolite, or any mixture containing one or more of these minerals. The mineral is described as resistant and even indestructible, since it tolerates abrasion, the corrosive effect of chemical products and very high temperatures (flames). In addition to its qualities as a thermal and electrical insulating material, asbestos is relatively cheap. Once the fibres have been extracted, the product can be marketed without having to undergo a sophisticated transformation process. Asbestos came to be widely used during World War II, and in 1950, Underwriters Laboratories approved it as a fireproofing material. From 1950 to the present day, it has been used in a variety of applications: in car brakes, as fireproofing in construction, as a thermal insulation, etc. During the 1970 s, its use began to wane because of potential health hazards related to asbestos-containing materials (ACM). Its use was banned in SCOPE The objective of this program is to ensure that asbestos-containing material in University buildings is managed such that the health of maintenance workers and building occupants is safeguarded. This program applies to all buildings and structures owned by Concordia University, to all employees and students of the University and to external organisations including contractors hired by the University who may come into contact with or disturb asbestos containing material in University buildings. Quebec has developed stringent guidelines with respect to friable asbestos-containing materials in buildings. This is outlined in the "Safety Code for the construction industry" (S-2.1, r.6). The asbestos management program documented here is intended to meet the requirements of this regulation. To conform to Quebec Legislation and general recognized standards of practice, the procedures outlined in the program are to be followed by Concordia University supervisors, employees, and contractors performing any type of work on asbestos containing materials. EHS-DOC-014 v.3 4

5 The basic elements of the management program are: 1. An initial asbestos survey to identify and record the locations and conditions of all friable asbestos containing material (ACM). Available at Environmental Health and Safety. 2. The preparation of a survey report detailing results from the survey and providing recommendations for remedial action to comply with the Quebec regulations. Available at Environmental Health and Safety. 3. The provision of appropriate procedures for all asbestos-related work that may disturb ACM. 4. Notification of all workers or building occupants that ACM is present so that they can adopt safe work procedures to protect themselves or other occupants of the building. 5. Training and education of workers who may come into contact with ACM. 6. Personal protection for all workers who come in contact with ACM. 7. Inspections and air monitoring at the workplace to ensure that asbestos is being contained in the workplace. 8. Specific criteria for determining abatement completion, control and monitoring of external contractors performing work that may disturb friable ACM. 9. The maintenance of records of all asbestos-related work with ACM. 10. The provision for auditing the implementation and effectiveness of the program. 11. Communication of this program and of asbestos-related work taking place in University buildings to joint health and safety committees and to other persons who may be affected by the work. EHS-DOC-014 v.3 5

6 DEFINITIONS Asbestos Asbestos is a generic term describing a number of naturally occurring, fibrous, hydrated mineral silicates that differ in chemical composition and are suitable for use as noncombustible, non-conducting and chemically resistant materials. Different types of asbestos that may be found in buildings are chrysotile, amosite, crocidolite, tremolite, actinolite or anthophyllite. Asbestos-Containing Material Any material found to contain 0.1% or greater content of asbestos, as determined by Polarized Light Microscopy. Friable Friable material means material that when dry can be crumbled, pulverized or powdered by hand pressure, and includes such material that is crumbled, pulverized, or powdered. Three types of friable asbestos commonly used in buildings are: Sprayed fibrous fireproofing Decorative or acoustic texture coatings Thermal pipe insulation Non-Friable Generally, non-friable materials cannot be easily crumbled, pulverized or powdered by hand pressure. Common types of non-friable material include: Vinyl floor tiles Asbestos cement products Acoustic tiles Gaskets Seals Plaster Type 1 work Low risk work involving asbestos containing materials. Type 2 work Moderate risk work involving asbestos containing materials. Type 3 work Moderately high risk work involving asbestos containing materials. Type 4 work High risk work involving asbestos containing materials. EHS-DOC-014 v.3 6

7 HEALTH RISKS Inhalation of asbestos fibres can cause serious health problems. These fibres may remain in the air for many hours if they are released from asbestos containing material (ACM) in a building. When fibres are released into the air, people in the building may be exposed. Inhalation of asbestos fibres may cause diseases that disrupt the normal functioning of the lungs. Three specific diseases have been linked with exposure to asbestos: Asbestosis (a fibrous scarring of the lungs) Lung cancer Mesothelioma (cancer of the lining of the chest cavity) In most cases, these diseases have been associated with heavy exposure over many years. However, mesothelioma may result from shorter exposures to specific types of asbestos, namely crocidolite and amosite (referred to as the amphibole group). These are less frequently found in Canadian buildings than is the more common and less hazardous chrysotile, which was mined in Quebec. Friable ACM presents the greatest hazard to workers. Friable means material that when dry can be crumbled, pulverized or powdered by hand pressure. Three types of friable material commonly used in buildings are: Sprayed fibrous fireproofing Decorative or acoustic texture coatings Thermal pipe, boiler/furnace insulation Workers with a history of smoking are at increased risk of developing lung cancer than are non-smokers. This is mainly because smoking impairs the lungs ability to clear fibres and other foreign materials. Asbestos fibres, which are ingested (swallowed) or which meet the skin cause no particular harm. It is when fibres are inhaled into the lungs that they can cause disease. The presence of asbestos in buildings does not necessarily constitute a health risk to either maintenance workers or other building occupants. It is only when the fibres become airborne that they may become hazardous through inhalation or breathing them into the lungs. Once in the lungs, they cause a biochemical reaction in certain individuals, which may result in disease. It is for this reason that regulations identifying the type and location of asbestos in buildings, controlling the production and dissemination of fibres and the training of workers have been developed. Work with asbestos can be performed safely providing that measures are taken to control the production and spread of asbestos dust and to protect the workers from breathing the fibres. EHS-DOC-014 v.3 7

8 CONCORDIA BUILDINGS The use of asbestos insulation in buildings was banned in Quebec in the early 70's. In buildings constructed after this date, asbestos is not usually found except in vinyl flooring, tiles, seals and gaskets and in special applications. The potential risk in these cases is the release of fibres, which may occur during the installation or removal, cutting, sawing or shaping of these products. The Visual Arts Building, Vanier Library and the Concert Hall fall into this category. In older buildings like the Administration Building at Loyola, and the older Annexes on the SGW Campus, asbestos will normally only be found on pipe and furnace insulation and in the building products described above. Asbestos fireproofing insulation was not often used before There are, however, Concordia buildings, which do contain asbestos insulation, usually on supporting beams in walls, and ceilings where it was applied as fireproofing. At SGW, the Hall Building contains asbestos insulation. At Loyola, it is found in parts of the Athletic Complex. A list of University owned buildings, with their construction dates, and possible asbestos containing materials can be found in Appendix A. Any building constructed prior to 1985, is considered as having materials that potentially contain asbestos. It is important to know where asbestos is present so that control measures can be taken to prevent the release of fibres into the air during routine maintenance and renovation work, which may expose both the workers and other building occupants. In 1990, the Quebec Government issued new regulations for work with asbestos products, which are included in the Safety Code for the Construction Industry S-2.1, r.6, article In 1999, modifications were made to this code, with respect to work liable to emit asbestos fibres. The University is now obliged to follow these regulations whenever any work is being performed either by its own employees or by contractors. Ideally, all friable ACM should be eventually removed from all University owned buildings. However, budgetary constraints are such that, presently, friable ACM is removed only when major renovations are done. ASBESTOS PROGRAM RESPONSIBILITIES To effectively manage ACM and prevent asbestos exposures, the Asbestos Management Program requires participation by all members of the University community. The overall responsibility for implementing this program is shared between Environmental Health and Safety, Facilities Management, and any department liable to work near asbestos containing material. The following summarizes the key duties and responsibilities. EHS-DOC-014 v.3 8

9 Industrial Hygiene Manager The asbestos program manager will be the Industrial Hygiene Manager from Environmental Health and Safety and will have the following responsibilities within the asbestos management program. Oversees workplace inspections and prepares/updates the survey report. Monitors all asbestos-related activities in the buildings including operation and maintenance activities and other abatement actions. Provides technical advice to Facilities Management and other University personnel and makes recommendations regarding the identification of asbestos, the health hazards and the control measures related to asbestos. Coordinates ongoing asbestos training and education programs. Evaluates on an ongoing basis the effectiveness of the asbestos management program and recommends changes to the program as appropriate. Conducts and oversees inspections at regular intervals to determine the condition of the ACM and to prepare a report indicating the results. Monitors Custodial and Maintenance personnel, and outside contractors with regard to all asbestos-related activities through periodic site visits to ensure proper work practices. Reviews specifications for outside contractors working in areas where ACM is present. Maintains records of all Type 2, 3, 4 work carried out. Has final authorization in determining level of risk, based on type of work to be carried out, in case of disagreement. Facilities Operations Facilities Operations, through its Managers, Property Managers, Supervisors, Group Leaders and other employees, may authorize, contract or conduct work that may disturb asbestos containing material. The Property Managers and Supervisors have the following responsibilities: To review all maintenance, repairs and renovation work to determine whether friable asbestos-containing materials are present and might be disturbed by such activities. To classify all asbestos work under his/her jurisdiction as Type 1, 2, 3, 4, in consultation with Environmental, Health and Safety, as needed. EHS-DOC-014 v.3 9

10 To be responsible for all asbestos work (Type 1, 2, 3, 4) performed by his/her employees or by external individuals contracted to do the work, and to ensure that all such work is conducted in accordance with the Asbestos Management Program by regular monitoring of the progress of the work and regular site inspections. To ensure that employees who must perform work on or may disturb ACM have been provided with proper training and education, and PPE, and have been fit-tested for the respirator they have been assigned. Ensure that Contractors comply with the current Asbestos Management Program when working near ACM. To advise the asbestos program manager of all Type 2, 3, 4 asbestos work for which he/she is responsible by filling out the Asbestos permit form. See Appendix B. To respond to reports of asbestos damage or disturbance, and to ensure that appropriate cleanup and abatement are completed in a timely manner. Upon assigning work, supervisors shall call on the means at their disposal (Asbestos Inventory or by contacting Environmental Health and Safety) to determine whether there are ACM near that work. *In emergency situations where the presence of asbestos cannot be assessed prior to commencement of the work, employees shall employ the practices prescribed for working near asbestos, assuming Type 2 risk (as stated in the present document). If the there is any doubt of whether the work area contains asbestos, the supervisor should contact Environmental Health and Safety, which will have to conduct sampling of the materials. The cost of sampling will be at the expense of the department undertaking the work. If it turns out that there are asbestos-containing materials in the contemplated workplace, supervisors are responsible to determine the level of risk (1, 2, 3, 4). See section titled Categories of Asbestos Work Based upon Risk for definitions of different risk levels. If in doubt about risk level, supervisors shall consult Environmental Health and Safety. Work entailing a low to moderate risk (see Employer Obligations-Type 1, 2 ) Upon assigning work, supervisors shall advise employees of occupational risks, appropriate safe work practices, and the protective equipment required for the level of risk at hand (low to moderate). Work entailing a moderately high or high risk (see Employer Obligations-Type 3, 4 ) Must be performed by specialized contractors. Employees or supervisors shall in no case undertake such work. Once work has commenced, supervisors are responsible for ensuring that employees are wearing the appropriate personal protective equipment and are using the safe work practices and techniques prescribed for the level of risk at hand. EHS-DOC-014 v.3 10

11 Project Management Services Project Managers have the following responsibilities: Prior to starting work, determine if asbestos is present in or around the work to be carried out. If the there is any doubt of whether the work area contains asbestos, the Environmental Health and Safety office will have to conduct sampling of the materials. The cost of sampling will be at the expense of the department undertaking the work. To advise contractors of the presence of all ACM prior to commencing the work. To be responsible for all asbestos work (Type 1, 2, 3, 4) performed by external individuals contracted to do the work, and to ensure that all such work is conducted in accordance with the Asbestos Management Program by regular monitoring of the progress of the work and regular site inspections. Ensure that the CSST is notified of all Type 4 operations before the work commences. To advise the asbestos program manager of all Type 2, 3, 4 asbestos work for which he/she is responsible by filling out the Asbestos permit form. See Appendix B. Ensure that asbestos removal be carried out by Contractors who have demonstrated competency in this field.. When ACM is not being removed as part of the project, Project Managers must advise Contractors of the presence of ACM near the work to be carried out. When asbestos removal is part of the project, ensure that inspection/air monitoring reports are given to the Industrial Hygiene Manager in a timely manner. Ensure that new materials used in renovations comply with Quebec s definition of an asbestos containing material (0.1% or greater). Employees This section applies to any University employee who may disturb or come into contact with ACM, through their regular work activities. Employees have the following responsibilities: Prior to starting work, employees are responsible to determine if asbestos is present in or around the work to be carried out (by verifying with their supervisors or Environmental Health and Safety). Follow the asbestos procedures (as outlined in the present asbestos management program). Carefully plan and complete work to avoid damaging asbestos. Immediately report any suspected asbestos exposure or damaged asbestos in the work area to their supervisor. EHS-DOC-014 v.3 11

12 Attend required training necessary to perform work activities. Do not store materials against asbestos containing materials or damage asbestos while moving furniture or other objects. Do not eat, drink, smoke or store food in areas containing friable asbestos containing materials. Contractors Contractors have the following responsibilities: Must comply with the University s current Asbestos Management Program when working near ACM. Immediately report any suspected asbestos exposure or damaged asbestos in the work area to the Project Manager or Security. CSST At anytime, CSST inspectors may inspect areas on University premises that contain ACM, to ensure compliance with applicable regulations. An inspector may stop work or shut down a construction site if applicable regulations are not respected. May require results of air monitoring performed in areas recognized as high priority for removal (from the asbestos inventory). EHS-DOC-014 v.3 12

13 CATEGORIES OF ASBESTOS WORK BASED UPON RISK TYPE 1 - LOW RISK These include the following: 1. Installation or removal of manufactured goods containing asbestos: vinyl tiles, acoustic tiles, gaskets, seals, and asbestos cement products (non-friable); as long as the material remains Non-friable throughout the work. 2. Sawing, cutting, shaping or drilling of the products mentioned above with a hand tool or power tool fitted with a dust collection device equipped with a High Efficiency Particulate Filter (HEPA filter). 3. Removal of drywall installed with asbestos joint filling compounds. TYPE 2 - MODERATE RISK 1. The total or partial removal of false ceilings where friable materials containing asbestos may be found, where the volume of debris on top of the ceiling tiles is less than 0.03 cubic meters. 2. Enclosure of friable material containing asbestos except by the sprayed application of a sealant. 3. Removal of friable asbestos material (chrysotile only) where the work area can be sealed from the workers breathing area such as work in a glove bag for the removal of pipe lagging. 4. All work which is susceptible to emit asbestos dust not classified as low or high risk. 5. The manipulation or removal of friable materials containing asbestos where the volume of debris does not exceed 0.03 cubic meters for each minor renovation or regular work specific to the area. See Appendix C for detailed Type 2 work procedures. TYPE 3 MODERATELY HIGH RISK 1. The manipulation or removal of friable materials containing asbestos where the volume of debris is greater than 0.03 cubic meters and does not exceed 0.3 cubic meters for each minor renovation or regular work specific to the area. TYPE 4 - HIGH RISK 1. The manipulation or removal of friable materials containing asbestos where the volume of debris exceeds 0.3 cubic meters for each renovation or regular work specific to the EHS-DOC-014 v.3 13

14 area. 2. Cleaning or removal of ventilation systems, including rigid ducts, in buildings where insulation contains asbestos applied by spraying. 3. Enclosure (encapsulation) of friable material by spray application of a sealant. 4. Repair, alteration or demolition of kilns, boilers or similar devices made partially or completely of refractory materials containing asbestos. 5. Use of power tools to cut manufactured goods containing asbestos (see Type 1, #1), not equipped with a dust collection device fitted with a HEPA filter. 6. Removal or handling of friable asbestos material containing amosite or crocidolite, were the volume of debris is greater than 0.03 cubic meters. 7. The total or partial removal of false ceilings where friable materials containing asbestos may be found, where the volume of debris on top of the ceiling tiles is greater than 0.03 cubic meters. GUIDELINES/ PROCEDURES The appropriate guidelines and procedures for work with ACM are found in the Quebec Regulation Respecting the Quality of the Work Environment c.s-2.1, r and in the Quebec Safety Code for the Construction Industry c.s-2.1, r.6 GENERAL PROHIBITIONS FOR ALL TYPES OF ASBESTOS WORK 1. Spray application of asbestos material is prohibited. 2. Use of compressed air is prohibited except when necessary to operate a respirator. 3. Smoking, eating, drinking or chewing any substance is prohibited during work procedures. EHS-DOC-014 v.3 14

15 GENERAL REQUIREMENTS FOR ALL TYPES OF ASBESTOS WORK 1. All workers must be trained and informed of the risks before undertaking any asbestos related work. This training must be documented. The training and information program must contain at least: General obligations of the employer Worker rights and obligations Effects of asbestos on health Applicable standards and the sampling to be carried out Protective devices and equipment Tasks to be carried out and equipment to be used Safe working methods and procedures Prevention and verification methods 2. All buildings containing asbestos must be surveyed and these survey results are to be made available to the workers and the Health and Safety Committee. 3. The employer shall determine the types of asbestos present in the materials before undertaking work liable to generate asbestos dust. 4. Before undertaking any work that is likely to release asbestos fibres, all furniture must be removed from the area or protected by an airtight film. 5. Friable material must be kept thoroughly wetted throughout the work except where this procedure may constitute a danger that cannot be eliminated, such as work in an electrical room. 6. Residue from materials containing asbestos must be removed quickly, either with a HEPA vacuum cleaner or by wetting thoroughly before removal. Residue must then be placed in an airtight container. 7. Upon completion of the work, where non-disposable drop sheets are used, these sheets must be cleaned with a HEPA vacuum. Drop sheets intended for disposal must first be wetted and folded before disposal. The work area and the area around it must be cleaned with a HEPA vacuum or by damp wiping surfaces. 8. All containers containing asbestos must be labelled with a permanently fixed label bearing the following indications. MATERIAL CONTAINS ASBESTOS TOXIC BY INHALATION KEEP CONTAINER TIGHTLY CLOSED DO NOT BREATHE THE DUST 9. Workers must wear approved safety shoes fitted with soles, which do not slip on wet surfaces. EHS-DOC-014 v.3 15

16 EMPLOYER OBLIGATIONS TYPE 1 (LOW RISK) WORK In low risk work areas, the employer must ensure that employees wear respirators that satisfy either of the following: 1. It is specified in the Guide des appareils de protection respiratoire utilisés au Québec, published by the Institut de recherche Robert-Sauvé en santé et en sécurité du travail. 2. The respirator is certified to be an FFP2 type in accordance with EN-149 Standard. The equipment shall be selected, adjusted, used and cared for in accordance with CSA Standard Z TYPE - 2 (MODERATE RISK) WORK See Appendix C for detailed Type 2 work procedures. On a construction site where moderate-risk work is being carried out, the employer must ensure that: 1. Any worker in the area must wear a reusable respirator fitted with a HEPA filter as specified in the Guide des appareils de protection respiratoire utilisés au Québec, published by the Institut de recherche Robert-Sauvé en santé et en sécurité du travail. This equipment shall be selected, adjusted, used and cared for in accordance with CSA Standard Z Disposable clothing must be changed each day and used clothing disposed of at the end of every shift by sealing it in a yellow waste bag. 3. Workers may not wear or carry their clothing outside the work area or the clothes locker room. 4. During work to enclose friable asbestos material, the work area must be isolated with materials impervious to asbestos fibres. 5. When removing a false ceiling for gaining access to a work area where friable material containing asbestos is found, the work area must be isolated with materials impervious to asbestos fibres and the ventilation system must be protected from contamination. 6. A sign with the following specifications must be posted at the entrance to each work area; yellow in colour, 500mm x 350mm with block writing as specified below: ASBESTOS 50 mm DANGER 40 mm DO NOT BREATHE THE DUST 15mm PROTECTIVE EQUIPMENT COMPULSORY 15mm NO ADMITTANCE WITHOUT AUTHORIZATION 15mm EHS-DOC-014 v.3 16

17 INHALING ASBESTOS DUST MAY BE HARMFUL TO YOUR HEALTH 10mm TYPE - 3 (MODERATELY HIGH RISK) WORK An employer handling or removing friable materials containing asbestos whose volume of debris exceeds 0.03 cubic metres without exceeding 0.3 cubic metres, for each minor renovation or specific regular maintenance work, shall fulfill the following obligations: 1. The employer must ensure disposable protective clothing is made available. The respirator used is the same as is used for Type 2 work. 2. The employer must isolate the work area from the rest of the building and supply it with a ventilation system equipped with a HEPA filter. 3. The employer must put in place a procedure for decontaminating prior to leaving the work area: The work area is cleaned by a wetting procedure or with a HEPA vacuum. After removal of protective clothing, the respirator and protective hard-hat are cleaned by wetting. The employee washes parts of his/her body that were exposed to dust that may have contained asbestos. TYPE - 4 (HIGH RISK) WORK A University employee shall never carry out type 4 work. 1. Workers must wear a powered air purifying continuous-flow, half-face or full-face piece or a supplied air continuous-flow half or full face piece, if working with power tools not fitted with a HEPA vacuum dust collecting system or when working with asbestos materials (other than chrysotile) that has been thoroughly wetted. 2. When working with asbestos material, which cannot be wetted, workers must wear a continuous flow positive pressure respirator fitted with a hood rather than with a mask. 3. Before work begins, the contractor must, together with the employer concerned, identify in writing and make available to the workers: The equipment and tools necessary to carry out the work and the measures to be taken in order to install, use, maintain, protect and move them. The hazards associated with the work to be carried out. The health and safety measures to be taken in accordance with the work to be carried out. EHS-DOC-014 v.3 17

18 The types of asbestos and other contaminants, which may be encountered while performing the work. The individual and common devices and equipment to be used. The measures to be taken in case of emergency, which must include the location of emergency exits. 4. At least once a day the employer must take a reading of the concentration of airborne respirable asbestos fibres in the work area in accordance with section 13 of the Regulation Respecting the Quality of the Work Environment. Upon completion of the work, it is prohibited to dismantle the airtight enclosure or to remove the airtight drop-sheet before the concentration of airborne respirable fibres drops to less than 0.01 f/cc air. 5. Other measures to be taken by the employer even when using an outside contractor to perform asbestos work include isolation of the work area to prevent building contamination, which can be achieved by the following: At the beginning and end of each shift, ensure that the airtight containment is in good condition. Air vents of the building ventilation system must be sealed off from the work area before the work begins and kept sealed during the work. Materials containing asbestos must be wetted before and during removal work unless this procedure constitutes a danger, which cannot be eliminated by another means. A locker area must be provided in a separate room and a shower located between the locker room and the work area must be provided. The work area and work clothes locker room must be sealed from the rest of the building with an airtight enclosure, which must have exhaust ventilation equipped with a HEPA filter. The ventilation system must provide at least 4 air exchanges per hour and put the area under a negative pressure between and KPa. EHS-DOC-014 v.3 18

19 SPECIFICATIONS FOR CONSULTANTS MONITORING FOR HIGH RISK ASBESTOS REMOVAL The minimum requirements for inspections and air monitoring for high-risk sites are outlined in the Safety Code for the Construction Industry (S-2.1, r.6). At Concordia, the consultants performing the air monitoring and inspections of the site must abide by the following procedures: 1. A thorough inspection must be performed once the enclosure is constructed, prior to the start of any contaminated work. This also includes a background air sample. No work can begin until the consultant has given their approval. 2. Daily air monitoring (to be analysed by PCM) must be performed during contaminated work both inside and outside the enclosure. 3. Daily inspections of the work site (during contaminated work) must be performed. This includes that the enclosures are in good condition; the negative pressure is adequate (between and Kpa) as well as ensuring that the proper work practices (outlined in the construction code) are carried out by the contractors performing the removal. If any of these conditions are not met, the consultant may cease work until the repairs or modifications are complete. 4. Daily inspection reports must be submitted before the start of the next workday and must include the results of the air monitoring. These reports must be given to the Concordia Project Manager and the asbestos program manager. 5. Upon completion of work, it is prohibited to dismantle the airtight enclosure until a final visual inspection is performed and a final clearance test is taken and analysed by PCM. The report from the final clearance test must also be submitted as soon as possible after the clearance test to the aforementioned persons. The air concentration of airborne respirable asbestos must be less than 0.01 fibres per cubic centimeter of air. A total of litres of air must be sampled. If, at any time, the University Community is at risk due to the work being performed, the asbestos program manager has the right to halt the work performed by the contractor until such time as the situation is rectified. Note: These specifications are those that are adopted whenever a high-risk asbestos removal is performed through Project Management Services. The same procedures apply regardless of which department is contracting the work. Environmental Health and Safety (EHS) will ensure that daily inspection and air monitoring reports are made available to the Central Advisory Health and Safety Committee as well as Area Health and Safety Committees, if requested. EHS-DOC-014 v.3 19

20 PERSONAL PROTECTION Respirator Protection The regulations state that only respirators specified in the Guide des appareils de protection respiratoire utilisés au Québec, published by the Institut de recherche Robert-Sauvé en santé et en sécurité du travail are required for all levels of asbestos work. Respirators must be selected, fitted, used and maintained according to the CSA standard Z The requirements of respirator protection are as follows: Only half-face and full-face HEPA respirators are approved for all types of asbestos work. Respirators approved for asbestos exposure are required for low and moderate risk work. The selection of approved respirators, suitable for the hazard to which the worker is exposed is only one aspect of a complete respiratory protection program. Other elements include written operating procedures for respirator use; outlining personal responsibilities for respirator cleaning, storage and repair; training in proper respirator use and limitations; respirator fit testing; respirator cleaning and care and work site supervision. Proper respiratory protection is an integral component of all custodial and maintenance activities involving potential exposure to asbestos. When in doubt about exposure during a work operation, custodial and maintenance workers should be provided with respiratory protection. Protective Clothing In addition to the use of respirators, some procedures require workers to wear protective clothing. Usually, protective clothing is disposable and consists of coveralls, a head cover and foot covers made of a synthetic fabric that does not allow fibres to pass through. This type of clothing prevents worker s regular clothing from becoming contaminated with asbestos fibres. Contaminated clothing should not be taken home, as this might pose a risk to the worker s family members. It is important that workers be properly trained in the use, removal and disposal or protective clothing after use. WASTE REMOVAL Procedures for handling dust and waste containing asbestos after clean up or removal should be performed at regular and frequent intervals as the work proceeds. The following procedures should be practised. All ACM waste should be removed rapidly from the workplace All waste should be placed in a sealed plastic bag or barrel A label must be placed on the container indicating the following: - MATERIAL CONTAINS ASBESTOS EHS-DOC-014 v.3 20

21 - TOXIC BY INHALATION - KEEP CONTAINER TIGHTLY CLOSED - DO NOT BREATHE THE DUST EDUCATION/TRAINING The control of asbestos exposure can be achieved by following the procedures prescribed by the regulations. However, these procedures are only as effective as the person carrying them out. It is therefore essential that before a worker undertakes work liable to emit asbestos dust, he/she is trained and informed of the risks, prevention methods and safe working methods. The training and information program is outlined in the Quebec Safety Code for the Construction Industry c.s-2.1, r.6. Different levels of training may be necessary for different groups of workers. Three levels may be identified: Level 1: Awareness Training This training is for any employee, who during the course of their work, may come into contact with ACM or may contract work near ACM. Topics should include: The employer s general obligations Health effects of asbestos The standards applicable and the sampling to be carried out The worker s rights and obligations Locations of ACM in buildings Recognition of ACM damage and deterioration Individual and common protective devices and equipment The tasks to be carried out and the equipment and tools to be used Safe working methods and procedures Prevention and verification methods Level 2: Special Training This training is for maintenance workers involved in general maintenance and asbestos material repair tasks and for any worker whose duties include having to access ceiling space where friable asbestos containing material is present. Specific examples include: repair or removal of a small section of damaged thermal insulation, removal of ceiling tiles (constructing an enclosure), or plumbers removing piping. The level of training usually involves more detailed discussions of the topics included in level 1 training as well as the following: Asbestos regulations Descriptions of the proper methods of handling ACM, including waste handling and disposal EHS-DOC-014 v.3 21

22 Respirator use, care and fit testing Protective clothing use and handling Hands-on exercises for techniques such as glove bag work and HEPA vacuum use and maintenance Appropriate and proper worker decontamination procedures Level 3: Abatement Worker Training This applies to workers who may conduct asbestos abatement. For example, conducting a removal job, or encapsulating surface ACM. This work involves direct, intentional contact with ACM. Outside contractors will perform this work; thus, training for level 3 is not a priority for this program and is the responsibility of the contractor. Frequency of training All new employees must be trained as soon as possible. Supervisors are responsible for ensuring that employees, who have not been trained, do not disturb or come in contact with ACM. All employees must receive refresher courses every 2 years. PERIODIC INSPECTION AND AIR MONITORING A visual inspection of all ACM will be conducted at regular intervals as part of the asbestos management program. Combined with ongoing reports of changes in the condition of the ACM made by maintenance workers, the re-inspection should help ensure that any ACM damage or deterioration will be detected and corrective action taken. The buildings must be re-inspected by a qualified individual, as determined by the asbestos program manager, once every 2 years to reassess the condition of the ACM. A routine check every year to monitor the condition of the ACM can be carried out by trained maintenance personnel. If any modifications are made to Concordia buildings, re-inspection should follow immediately. Copies of these inspections reports shall be kept at Environmental Health and Safety. Through re-inspection, it is possible to determine both the relative degree of damage and assess the likelihood of future fibre releases. The use of visual records (photographs) of the ACM over time can be of great value during re-inspections. Environmental Health and Safety shall conduct air monitoring of areas identified as being high risk (i.e. potential for employee exposure is high) annually. A list of the current areas being monitored can be found in Appendix D, along with air monitoring procedures. These areas will have to be reassessed after visual inspections are carried out. EHS-DOC-014 v.3 22

23 RECORD KEEPING All the asbestos management documents should be stored in permanent files. These include: Survey reports, including results of bulk sample analysis Notification statements Documentation of worker training Inspection and air monitoring reports Periodic reassessment reports Copies will be made available to any building occupant upon request. APPENDIX A: CONSTRUCTION DATES AND ACM INFORMATION FOR CONCORDIA BUILDINGS Owned buildings SGW Year of Possible ACM* construction EV 2005 none FB 1990 none GM 1965 Gypsum (joints), ceiling tiles, vinyl tiles GN Gypsum (joints), plaster, ceiling H 1966 Gypsum (joints), plaster, ceiling LB 1992 none MB 2009 none SB 1970 Gypsum (joints), plaster, ceiling TD 1903 Gypsum (joints), plaster, ceiling VA Unknown 1980 (renovated) Stucco, gypsum (joints), plaster, ceiling Inventory information Partial friable & non-friable inventory available. Partial non-friable inventory available. Friable chrysotile asbestos on ceiling beams (sub-basement-10 th floor +mechanical rooms) Partial non-friable inventory available. Owned annexes SGW Year of Possible ACM* construction B Unknown Gypsum (joints), plaster, ceiling 1985 (restored) BC 1904 Gypsum (joints), plaster, ceiling Inventory information Partial non-friable inventory available. EHS-DOC-014 v.3 23

24 CI 1885 Gypsum (joints), plaster, ceiling D 1900 Gypsum (joints), plaster, ceiling EN (restored) Gypsum (joints), plaster, ceiling FA 1910 Gypsum (joints), plaster, ceiling K 1900 Gypsum (joints), plaster, ceiling M 1889 Gypsum (joints), plaster, ceiling MI 1900 Gypsum (joints), plaster, ceiling MU 1900 Gypsum (joints), plaster, ceiling P 1875 Gypsum (joints), plaster, ceiling PR 1875 Gypsum (joints), plaster, ceiling Q 1875 Gypsum (joints), plaster, ceiling R 1875 Gypsum (joints), plaster, ceiling Gypsum (joints), plaster, ceiling RR (renovated) S 1885 Gypsum (joints), plaster, ceiling T 1875 Gypsum (joints), plaster, ceiling V 1875 Gypsum (joints), plaster, ceiling X 1875 Gypsum (joints), plaster, ceiling Z 1875 Gypsum (joints), plaster, ceiling Some plaster sampling done. (March 2009) Some plaster sampling done. (Fall 2008) Owned buildings Loyola Year of Possible ACM* construction AD 1927 Gypsum (joints), plaster, ceiling tiles, vinyl tiles CC Gypsum (joints), plaster, ceiling tiles, vinyl tiles CJ 2005 none FC 1933 Gypsum (joints), plaster, ceiling tiles, vinyl tiles Inventory information Partial non-friable inventory available. EHS-DOC-014 v.3 24

25 1963 Gypsum (joints), plaster, ceiling tiles, vinyl tiles Partial non-friable inventory available. JR ±1960 Gypsum (joints), plaster, ceiling tiles, Partial non-friable inventory available. vinyl tiles PA 1964 Gypsum (joints), plaster, ceiling tiles, Partial non-friable inventory available. vinyl tiles PB 1964 Friable amosite asbestos on ceiling beams. PE 1964 Gypsum (joints), plaster, ceiling tiles, Partial non-friable inventory available. vinyl tiles PG 1964 Gypsum (joints), plaster, ceiling tiles, vinyl tiles PS 1923 Gypsum (joints), plaster, ceiling tiles, vinyl tiles PT 1990 none PY ± (restored) None, due to level of renovation in 1993 RF 1916 Gypsum (joints), plaster, ceiling tiles, vinyl tiles SC 1973 Gypsum (joints), plaster, ceiling tiles, vinyl tiles SP 2003 none VE 1989 none VL 1989 none Owned annexes Loyola Partial non-friable inventory available. Friable amosite asbestos (65%) on ceiling beams. Partial non-friable inventory available. HA- HB- HC Year of Possible ACM* construction BB- ±1940 Gypsum (joints), plaster, ceiling tiles, BH 1991 vinyl tiles (restored) TA 1923 Gypsum (joints), plaster, ceiling tiles, vinyl tiles Inventory information *In addition, to the above possible ACM, all University mechanical rooms, pipe shafts, confined spaces, tunnels usually contain friable ACM in the form of insulation and pipe covering material. Some of this inventory is available at EHS. EHS-DOC-014 v.3 25

26 APPENDIX B: ASBESTOS PERMIT FORM This form is to be filled out by any individual assigning or contracting Moderate or Moderately High risk work involving asbestos containing material. All Concordia employees or Contractors performing this type of work must have taken the appropriate training in asbestos awareness. Note: this permit is valid for one task only. Please indicate if task will extend beyond one day. This form is to be sent to the Environmental Health and Safety Task Information: Building/floor/room #: Date: Time: - Description of work: Will portable enclosure be used? Yes No Authorized personnel: Will the task be performed by: Concordia employee External Contractor? (Fill out appropriate section below) Concordia Employee information: Supervisor name: - Employees assigned to task: Supervisor signature: Employee(s) Signature: Contractor information: EHS-DOC-014 v.3 26

27 Name of company: Contact name and phone #: Items required prior to starting the task: Half-face respirator with HEPA cartridges Tyvek suit Yellow waste bag Asbestos signage Amended water in spray bottle Disposable rags HEPA vacuum Checklist for Type 2 or Moderate Risk Work The following checklist should be used to ensure all requirements as set forth by the Asbestos Management Program document for Type 2 or Moderate Risk work have been complied with before, during and following any asbestos disturbance. All non-essential equipment and personnel have been removed from the established work area. The area affected by the work has been isolated from adjoining areas of the building and the required signage has been posted identifying the site as an Asbestos Work Area. Personal protective equipment will be donned prior to entering the work area. Required tools, equipment and waste bags have been located within the established work area. HVAC systems, vents and diffusers within the Asbestos Work Area have been shutdown or otherwise isolated. Suitable wash facilities (any area with a sink) have been located immediately adjacent to or near the established work area. Thoroughly wet all asbestos-containing materials to be disturbed. Maintain established work area free of accumulated waste, dust or debris. All material removed shall be placed directly into a yellow asbestos waste bag as the work progresses. If using portable enclosure, the established procedure has been followed. EHS-DOC-014 v.3 27

28 EHS-DOC-014 v.3 28

29 APPENDIX C: MODERATE RISK WORK PROCEDURES FOR ASBESTOS CONTAINING MATERIAL These procedures are to be followed by maintenance staff or contract persons performing the following work on friable asbestos materials: 1. Removal of any part of a false ceiling, if ACM fireproofing or mechanical insulation is present. Note: High-risk work procedures are required if the amount of debris above the ceiling tile is greater than 0.03 m 3. To determine the level of risk, an enclosure must be built using moderate risk work procedures. The supervisor or employee should gently lift one side of the tile or access panel, to inspect for asbestos debris and determine the amount, if any. High-risk work shall not be undertaken by any University employee. The area must first be cleaned by an outside contractor; after which employees can employ moderate work procedures to perform the necessary work. 2. The manipulation or removal of friable materials containing asbestos where the volume of debris does not exceed 0.03 cubic meters for each minor renovation or regular work specific to the area. 3. Enclosure of friable material containing asbestos except by the sprayed application of a sealant. 4. Removal of friable asbestos material (chrysotile only) where the work area can be sealed from the workers breathing area such as work in a glove bag for the removal of pipe lagging. 5. Removal of vinyl sheet flooring with an asbestos-containing backing felt. Equipment Equipment required for work must be on site before proceeding. Vacuum: A HEPA filter vacuum, equipped with brushes, fittings, etc. Personal protective equipment: o Workers within the work area shall wear approved respirators. o Respirators and filters will be provided by the employer, and individually assigned to workers. o Respirators shall be a half-face piece respirator with high efficiency (HEPA) filters. o Respirators must be kept in position throughout the entire time the worker is in the area of the work from the first disturbance of the ceiling tile or asbestos material until the final cleaning of the area and bagging of waste is complete. o Filters must be changed after 24-hours of wear, or sooner if breathing resistance increases. EHS-DOC-014 v.3 29

30 o Employees must have been fit-tested prior to any work. Fit testing is only required once to determine the size of the respirator for the employee. o No person using a respirator shall have facial hair that affects the seal between the respirator and the face. o All workers shall wear disposable coveralls (Tyvek) with attached elasticised hood. Coveralls should be worn with the hood in place at all times. o Coveralls may be vacuumed or wet wiped clean for re-use, for a maximum of 8 hours cumulative wear. Suit and head cover shall remain in place until worker leaves work area or the enclosure is dismantled. o Boot covers or dedicated boots are required if footwear cannot be effectively cleaned by wet wiping or vacuuming. Other equipment: o Plastic sheeting (6mm polyethylene) - to erect a total enclosure or to serve as drop sheet o Wood framing or clips to support polyethylene sheeting, as appropriate to work area o Tape to fasten plastic enclosure to ceiling or to tape drop sheet to floor o Labelled asbestos waste bag (6mm) for all asbestos waste, disposable suit, plastic sheeting for disposal, etc. o Pump sprayer containing amended water o Asbestos warning signs o Equipment necessary to perform work in question Other Protective Measures Do not eat, drink or smoke in the work area. On completing clean up of work area, use vacuum or wet cloth to clean hands, face, respirator and boots. Remove protective equipment and proceed to nearest washroom to wash exposed skin on hands and face. Scheduling of Work Ideally, work should be scheduled when occupants are absent. If work above ceiling is required on an emergency basis when area is occupied, have Facilities supervisor or Security advise occupants to vacate area until work is complete and clearance is given to return. EHS-DOC-014 v.3 30

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