1 ASBESTOS MANAGEMENT PROGRAM University of New Brunswick Fredericton Campus Project No Jacques Whitford 2008
2 PROJECT NO REPORT TO University of New Brunswick Fredericton Campus 767 King s College Road Fredericton, New Brunswick E3B 5A3 FOR Asbestos Management Program ON UNB Fredericton June 25, 2008 Jacques Whitford 711 Woodstock Road Fredericton, NB E3B 5N8 Phone: Fax:
3 UNBF Asbestos Management Plan Page iii June 2008 Table of Contents 1.0 INTRODUCTION & OBJECTIVES UNB FREDERICTON ASBESTOS MANAGEMENT POLICY Foreword Mandate Scope Objectives Asbestos Steering Committee Implementation LEGISLATION Background and Regulatory Requirements ROLES AND RESPONSIBILITIES Senior University Administration Human Resources and Organizational Development University Asbestos Steering Committee Director of Physical Plant Managers Asbestos Management Program Coordinator Forepersons/Supervisors Joint Health and Safety Committee, Department of Physical Plant Safety Committee or Health and Safety Representative Facility Workers Physical Plant Project and Site Coordinators Consultants Outside Contractors Certified Asbestos Abatement Contractors Faculty, Staff and Students ASBESTOS BACKGROUND INFORMATION Health Effects of Asbestos Exposure Examples of Asbestos Containing Building Materials Hazards of Asbestos in Buildings ASBESTOS CONTAINING MATERIALS AT THE UNIVERSITY OF NEW BRUNSWICK FREDERICTON EVALUATION OF ASBESTOS CONTAINING MATERIALS AND ACTIONS FOR CONTROL Assessment of Condition Spray Applied Fireproofing, Insulation, and Textured Finishes (Friable) Other Friable Asbestos Containing Material Non Friable and Potentially Friable Materials Asbestos Containing Material Debris Debris from Friable ACM... 18
4 UNBF Asbestos Management Plan Page iv June Debris from Damaged Non Friable ACM Evaluation of Accessibility Action Matrix and Action Descriptions Action Matrix Action Descriptions REASSESSMENT INSPECTIONS OF ASBESTOS CONTAINING MATERIALS NOTIFICATION Contractors/Subcontractors Workplace Health, Safety and Compensation Commission Labeling WORKER TRAINING AND INSTRUCTION CLASSIFICATION OF TYPES OF ASBESTOS WORK Class 1 or Low Risk Asbestos Related Work Class 2 or Moderate Risk Asbestos Related Work Class 3 or High Risk Asbestos Related Work Glovebag Work Procedure Emergency Procedures Air Monitoring WORK PROCEDURES FOR WORKING WITH ASBESTOS Identification of Work that May Involve Asbestos Normal Maintenance and Small Projects Large Project Work Work Practices Worker Protection Program Respiratory Protection Protective Clothing Basic Procedures Special Cleaning Techniques Prohibited Activities Procedures for Asbestos Fibre Release Episodes Minor Episodes Major Episodes RECORD KEEPING...39 List of Tables Table 5.1 Friable and Non Friable ACMs Table 7.1 Action Matrix Table List of Appendices
5 UNBF Asbestos Management Plan Page v June 2008 APPENDIX A APPENDIX B APPENDIX C APPENDIX D APPENDIX E APPENDIX F APPENDIX G APPENDIX H APPENDIX I APPENDIX J APPENDIX K APPENDIX L APPENDIX M Legislation Contact Information for Workplace Parties Asbestos Work Notice Form and Contractor Asbestos Awareness Form Completed Work Notice Forms and Contractor Asbestos Awareness Forms UNB Fredericton Facilities Known or Suspected to Contain Asbestos Procedures for Collecting Bulk Asbestos Samples UNB Fredericton Mechanical Rooms Cleared for Entry Example Reassessment Schedule ACM Reassessment Inspection Form Completed ACM Reassessment Inspection Forms List of Employees Trained In Asbestos Awareness Asbestos Warning Signs Safe Work Procedure for Emergency Entry Into Areas Potentially Contaminated with Asbestos Fibres
6 UNBF Asbestos Management Plan Page 1 June INTRODUCTION & OBJECTIVES Jacques Whitford Limited (Jacques Whitford) was retained by the University of New Brunswick Fredericton (UNB) to update its Asbestos Management Program (AMP). UNB has updated the Asbestos Management Program to minimize risk and establish control measures for confirmed and suspected asbestos containing materials (ACMs) that are and/or may be present within buildings at the Fredericton Campus. This document is the property of the University of New Brunswick and cannot be reproduced or adapted without the express written consent of Jacques Whitford Limited and the University of New Brunswick. A Review Committee was established to aid in the development of this document, including representatives of the Environmental Health and Safety Office and Physical Plant Department. It is considered to be a living document that will be modified and improved as is required to maintain a safe and healthy working environment at the University. The objective of the AMP, which addresses both friable and non friable ACMs, is to: Provide procedures to track and maintain an inventory of confirmed and suspected ACMs throughout each building; Provide tools to inform personnel and building occupants within each facility of the locations of any confirmed or suspected ACMs that may be encountered while performing their required duties; Provide procedures to monitor the condition of confirmed or suspected ACMs through visual assessment at each building; Provide procedures to enable the University to respond quickly and effectively to any changes in the condition of confirmed or suspected ACMs and properly maintain or repair any damaged confirmed or suspected ACMs that may be encountered in the future; Provide procedures to prevent accidental disturbance of confirmed or suspected ACMs by controlling access to these materials wherever possible and by establishing measures and safe work procedures for activities that may disturb confirmed or suspected ACMs at each building; and Provide compliance criteria to meet applicable legislation and regulations. Building maintenance, internal and external servicers, such as ITS staff, Aliant service technicians and controls technicians, security personnel and management personnel at the campus should become familiar with sections of this AMP that are relevant to their work. The program should provide guidance to the building personnel as well as contractors hired by UNB, when working near confirmed or suspected ACMs. The program should also provide enough general information to enable workers to recognize the hazards, understand the risks, and respond accordingly to disturbed/damaged asbestoscontaining materials in the workplace. This AMP was developed to be in accordance with current applicable statues and regulations in New Brunswick. It will be customized, maintained and updated by UNB s employees to reflect actual site conditions for each building to which the AMP applies. Furthermore, applicable provincial regulations must be followed during ACM removal/repair at each building utilizing this AMP.
7 UNBF Asbestos Management Plan Page 2 June 2008 To help support this AMP, a comprehensive inventory of asbestos containing materials (entitled Asbestos Containing Material Inventory) has been prepared. It is accessible in both hard copy and in database form.
8 UNBF Asbestos Management Plan Page 3 June UNB FREDERICTON ASBESTOS MANAGEMENT POLICY 2.1 Foreword The University of New Brunswick (Fredericton) is committed to promoting the health, safety and wellbeing of its employees, students, visitors and contractors (UNB Safety Policy No. 7800). Asbestos, a fibrous material commonly used in building materials prior to 1980 because of its heatresistant, chemical resistant and insulating properties, continues to be present in a number of University buildings, in the form of insulation around piping and mechanical equipment, thermal and acoustic boards, plasters, asbestos cement products, and floor and ceiling tiles. 2.2 Mandate Recognizing the hazards that may arise when asbestos fibres become airborne, as a result of disturbance or deterioration, the University is committed to the strict management of asbestoscontaining materials in University buildings, and activities that may disturb such materials. The University has the responsibility to ensure that stringent controls are in place to prevent the potential exposure of individuals to harmful levels of asbestos. 2.3 Scope This Policy applies to all buildings and structures owned by the University of New Brunswick Fredericton, to all employees and students of the University, to occupants of University buildings, and to external organizations who may come in contact with or disturb asbestos containing materials in University buildings. 2.4 Objectives The University is committed to achieving the following objectives: To exercise due diligence in protecting University employees from the potential health risks associated with hazardous exposure to airborne asbestos fibres; To provide a safe and healthy work and study environment for employees, students, contractors and visitors, in accordance with the University's Health and Safety Policy; To comply with the legislated requirements outlined under the Code of Practice for Working with Materials Containing Asbestos in New Brunswick (Regulation dated March 19, 1992); and To comply with the University's Asbestos Management Program. The University will manage asbestos hazards based on prioritization and assessment of risk. Priority for asbestos removal will be assigned as follows: Asbestos containing materials will be removed prior to any demolition or renovation activity which may result in their disturbance.
9 UNBF Asbestos Management Plan Page 4 June 2008 Friable asbestos containing materials which have been damaged to the extent that repair measures are not expected to effectively maintain the material in good condition are to be removed. Consideration shall be given to the proactive removal of friable asbestos containing materials during major renovation projects, or during any major asbestos removal work. Friable asbestos containing materials which can easily be disturbed during routine maintenance activity should be removed. 2.5 Asbestos Steering Committee The University will maintain an Asbestos Steering Committee (ASC) whose mandate is to monitor the university s activities related to the identification and management of health and safety issues related to asbestos containing materials located on the campus. The ASC will focus on ensuring that the University has an effective and clearly communicated plan for managing asbestos on campus, and that the plan is followed by both management and employees in an efficient and effective manner. As an oversight group, the ASC will examine the overall Asbestos Management Program including but not limited to several areas of interest such as training, communication and the health assessment of employees. It will report to Vice President Fredericton (Academic) and Vice President (Finance and Corporate Services) and make recommendations on issues brought forth by its members to ensure a safe and healthy environment for all the University s employees and students. Further information on the ASC, including its current members, can be viewed on the Physical Plant website at 2.6 Implementation The University will establish an Asbestos Management Program which will outline a comprehensive system to actively manage and stringently control all asbestos containing materials in University buildings, and all activities that may disturb such materials, including maintenance, alteration, and repair operations. The Program will define and communicate the responsibilities of workplace parties involved in its development, administration and implementation. In keeping with the University's Health and Safety Policy, individuals who fail to meet their obligations as outlined in the Program, may, depending on the circumstances, face appropriate disciplinary actions. Any disciplinary action will uphold provisions of existing collective agreements. The Program may be amended from time to time by University administration in consultation with appropriate staff and faculty representatives, provided it remains consistent with the Policy.
10 UNBF Asbestos Management Plan Page 5 June LEGISLATION The following section outlines the relevant legislation in the province of New Brunswick that is applicable to managing asbestos in the workplace. This AMP is written to meet or exceed the requirements of this legislation. 3.1 Background and Regulatory Requirements The Code of Practice for Working with Materials Containing Asbestos in New Brunswick (Regulation dated March 19, 1992 enforced under the Occupational Health and Safety Act O.C ) requires that an assessment of the workplace for the presence of all asbestos materials be performed, and if asbestos materials are present, an asbestos management program is to be developed in writing and maintained for as long as asbestos materials remain. The Code of Practice requires controls on all work around both friable and non friable materials. The Regulation specifically requires that prior to the demolition or partial demolition of a building, all affected asbestos materials must be removed. A building owner can leave the asbestos materials in place, provided that all disturbances of the materials follow the prescribed procedures. The New Brunswick Code of Practice classifies asbestos related work into three different classes (Class 1, 2, and 3) depending on the degree of risk of exposure to asbestos, and the controls required to minimize exposure to acceptable levels. Class 3 (major removal work) has the potential for high exposure to airborne asbestos, and Class 1 has the lowest potential for fibre release (i.e. work on nonfriable products). Clearance air monitoring is compulsory for all Class 3 projects, except for outdoor projects. The Code of Practice also requires training in the hazards of asbestos exposure, asbestos work practices and the use of personal protective equipment, for all workers who may be involved with Class 1, 2 or 3 asbestos work operations. Full implementation of the Asbestos Management Program provides compliance with the above requirements. A full copy of the New Brunswick Regulation is provided in Appendix A.
11 UNBF Asbestos Management Plan Page 6 June ROLES AND RESPONSIBILITIES The success of the AMP is dependent on the implementation of roles and responsibilities by workplace parties. Key workplace parties include, but are not limited to: Senior University Administration; Human Resource and Organizational Development (HROD); University Asbestos Steering Committee; Director of Physical Plant; Managers; Asbestos Management Program Coordinator; Supervisors and Forepersons; Joint Health and Safety Committee, Department of Physical Plant Safety Committee and Health and Safety Representatives; Physical Plant Workers and Project Coordinators; Consultants and Contractors; and Faculty, staff, students, visitors. See Appendix B for Contact Information for selected Workplace Parties. 4.1 Senior University Administration Senior University Administration is responsible for: ensuring the Director of the Physical Plant is implementing the Asbestos Management Program at UNB Fredericton in a timely and effective manner; ensuring funding is allocated in annual budgets and adequate resources are available for the implementation of the Asbestos Management Program at UNB Fredericton; and directing that an external audit be undertaken and reviewing annual external audit findings of the overall program and authorising corrective actions. 4.2 Human Resources and Organizational Development Human Resources and Organizational Development are responsible for: supporting the requirements of the Asbestos Management Program; and retaining indefinitely in employee files any medical, Work Safe NB forms, respiratory fit test records, worker training records and personal air sampling results received from the Asbestos Management Program Coordinator. 4.3 University Asbestos Steering Committee University Asbestos Steering Committee is responsible for:
12 UNBF Asbestos Management Plan Page 7 June 2008 monitoring activities related to the management of asbestos containing materials located on campus. 4.4 Director of Physical Plant The Director of Physical Plant is responsible for: ensuring that the AMP is being followed and that its requirements are being implemented by the Asbestos Management Program Coordinator; ensuring that workplaces that are within his/her area of responsibility and authority, are complying with legislative requirements in the Province of New Brunswick that are applicable to managing asbestos in the workplace; appointing a qualified employee as the Asbestos Management Program Coordinator; monitoring that the Asbestos Management Program Coordinator is carrying out his/her responsibilities; ensuring that Physical Plant managers support the requirements of this program and support the Asbestos Management Program Coordinator; identifying financial requirement for asbestos related work in annual maintenance budgets for asbestos building materials sampling, reassessment inspections, training, safety equipment and contracting out asbestos abatement work; identifying financial requirement for asbestos related work in annual project budgets for asbestos building material sampling, contracting out asbestos abatement project work and the monitoring of asbestos abatement work by outside consultants (where required); rescinding a stop work order after the Asbestos Management Program Coordinator is satisfied that control measures and safe work practises for asbestos related activities as described in this AMP have been satisfied; and liaising, on behalf of the university, with regulatory bodies on matters related to asbestos management. 4.5 Managers Managers are responsible for; supporting the requirements of this program and supporting the Asbestos Management Program Coordinator; ensuring that his/her staff comply with the AMP and have the necessary training to do so; assisting the Director of the Physical Plant in financial requirements for asbestos related work in annual budgets; following the agreed to procedures for the initiation of work, ensuring that any required asbestos abatement work is completed for his/her projects according to the AMP; ensuring his/her staff inform the Asbestos Management Program Coordinator of all planned removals/repairs regarding ACMs; ensuring his/her staff notify the AMP Coordinator of any hazardous occurrences involving asbestos related work;
13 UNBF Asbestos Management Plan Page 8 June 2008 ensuring asbestos related work is overseen, coordinated and conducted by qualified personnel in corporation with AMP Coordinator; and coordinating with the Asbestos Management Program Coordinator asbestos related instruction and training programs. 4.6 Asbestos Management Program Coordinator The Asbestos Management Program Coordinator is responsible for: reporting to the Project Manager; special reporting to the Director for stop work orders; implementing the requirements of the asbestos management program on the UNB Fredericton Campus; issuing a stop work order to any University employee or outside contractor where asbestos related procedures and safety precautions outlined in worker training courses, the Code of Practice for Working with Materials Containing Asbestos in New Brunswick and this AMP are being contravened; Providing immediate notification to: o the Director of the Physical Plant of any hazardous occurrence or stop work order for further investigation and action as per the provisions of this AMP; and o the relevant Physical Plant Manager of any hazardous occurrence involving asbestosrelated work. reporting to the Director to rescind a stop work order once control measures and safe work practises for asbestos related activities as described in this AMP have been satisfied in response to a stop work order ; responding to questions and requests for asbestos related information; arranging for asbestos building materials assessments; maintaining an asbestos inventory; conducting or arranging reassessment inspections and ensuring that the record (i.e. inventory) of asbestos building materials is updated at least once in a 12 month period (6 months for the service tunnels) or whenever the owner becomes aware of new information relating to the inventory; oversee and coordinate asbestos abatement work, including determining whether the work is Class 1, 2 or 3 type work, using outside consultants (where necessary) and certified asbestos abatement contractors; determining whether properly trained UNB staff or certified asbestos abatement contractors will perform Class 1 asbestos related work where required; ensuring Asbestos Work Notice Forms (Appendix C) are completed for all asbestos related work and records maintained in Appendix D; maintaining a record of all signed Contractor Asbestos Awareness Forms in Appendix D; coordinating air testing (for airborne asbestos fibres) where required; when practable, relaying results of post abatement clearance air sample(s) to the client/occupant/worker.
14 UNBF Asbestos Management Plan Page 9 June 2008 monitoring site maintenance worker s compliance with the asbestos management program and providing performance updates to the Director of the Physical Plant, all with the assistance of supervisors/forepersons and site coordinators; coordinating with Physical Plant managers training requirements for Physical Plant staff; maintaining and updating the AMP as needed to maintain an up to date document; preparing and issuing notification letters, s, postings, and signs regarding the existence of ACMs, planned asbestos abatement work, and other related correspondence; ensuring certified asbestos abatement contractors perform Class 2 or 3 asbestos related work notifies in writing an officer with the Work Safe NB; informing forepersons and workers of the information contained in the most up to date inventory if they are to be near work that is in close proximity to ACMs or they may disturb it; maintaining and updating all records related to asbestos management including worker training records, as well as respiratory fit test records and personal air sampling results (where applicable) and forwarding these records to Human Resources and Organizational Development for retention in employee files; reviewing (on request), project and maintenance work requirements against the Asbestos Containing Material Inventory (if applicable) to determine the possibility of disturbing the ACM, and classifying the work based on the approved criteria; providing assistance in purchasing respiratory equipment and other asbestos work related equipment (if required); coordinating fit testing and maintaining respiratory equipment and other asbestos work related equipment. with the assistance of supervisors/forepersons and site coordinators, ensuring the storage, transportation, and disposal of any asbestos waste generated during asbestos related activities conducted by site personnel or contractors is completed in accordance with provincial requirements; and reporting and documenting asbestos related incidents or emergencies. 4.7 Forepersons/Supervisors Forepersons/Supervisors of asbestos related work are responsible for: recognizing hazards associated with potential ACMs in their workplace and ensuring they do not disturb potential ACMs. If unsure, they should contact the Asbestos Management Program Coordinator; assisting their staff in determining if potential ACMs are present in their workplace area by consulting the Asbestos Containing Material Inventory; confirming that staff and contractors are aware of their requirements under the asbestos management program and are following standard operating procedures and safety precautions related to asbestos work; confirming that site personnel or contractors under their control have stored, transported and disposed of any asbestos waste generated during asbestos activities in accordance with provincial requirements;
15 UNBF Asbestos Management Plan Page 10 June 2008 ensuring that workers have been provided with the required training to conduct the work safely; ensuring that appropriate personal protective equipment (PPE), tools, and clothing required to complete the work are provided; ensuring that required equipment to conduct the work is on site before commencing; ensuring that the appropriate procedures for the work are followed and implemented; coordinate with Asbestos Management Program Coordinator to ensure that procedures for inspection and air monitoring are implemented based on the applicable classification of type of asbestos work indicated in this document and the specific requirements of the legislation; immediately notifying the Asbestos Management Program Coordinator of any hazardous occurrences involving asbestos related work; when practable relaying results of post abatement clearance air sample(s) to the worker. Results are to be obtained from the Asbestos Management Program Coordinator; ensuring all outside contractors performing work under their control have completed a Contractor Asbestos Awareness Form and submitted this form to the Asbestos Management Program Coordinator; and remaining current with the AMP and training in related asbestos requirements. 4.8 Joint Health and Safety Committee, Department of Physical Plant Safety Committee or Health and Safety Representative The Joint Health and Safety Committee or the Health and Safety Representative is responsible for: participating in hazard investigations to ascertain the risk associated with asbestos related work requirements; monitoring the workplace to ensure that the legislative and AMP requirements are being addressed; reviewing clearance air testing results provided by the Asbestos Management Program Coordinator as required; participating in training and undertaking a review of training requirements for asbestos related work on a frequency determined by the committee; and reporting immediately, specific workplace complaints related to asbestos management to the Asbestos Management Program Coordinator and provide follow up as required. 4.9 Facility Workers Physical Plant and Residence Life, Campus and Conference Services (RLCCS) Workers are responsible for: recognizing hazards associated with potential ACMs in their workplace and ensuring they do not disturb potential ACMs. If unsure they should contact their foreperson, immediate supervisor or the Asbestos Management Program Coordinator if their foreperson or immediate supervisor is not available; applying the appropriate practices, procedures, and equipment for the type of asbestos related work being undertaken;
16 UNBF Asbestos Management Plan Page 11 June 2008 in the absence of forepersons / supervisors, ensuring all outside contractors performing work under their control have completed a Contractor Asbestos Awareness Form and submitted this form to the Asbestos Management Program Coordinator; wearing, utilizing, and maintaining the assigned PPE, clothing, and tools; attending and participating in worker instruction and training sessions; and reporting immediately to their forepersons/supervisor and, in his/her absence, the Asbestos Management Program Coordinator all hazards, as well as known or suspected conditions or activities that are in violation of approved practices or procedures and that may cause a hazardous occurrence Physical Plant Project and Site Coordinators Physical Plant Project and Site Coordinators are responsible for: ensuring information regarding the possible presence of asbestos containing materials is made available in the areas of all planned projects from the foreperson or the Asbestos Management Program Coordinator; informing the Asbestos Management Program Coordinator of all planned removals/repairs regarding ACMs; ensuring asbestos related work is overseen and conducted by qualified personnel; monitoring construction activities to ensure adherence to the asbestos work procedures as described in this AMP; ensuring that all contractors performing work under their control have completed a Contractor Asbestos Awareness Form and have submitted this form to the Asbestos Management Program Coordinator prior to commencement of work; identifying financial requirement for asbestos related work in project budgets for asbestos building material sampling, contracting out asbestos abatement project work and the monitoring of asbestos abatement work by outside consultants (where required); and attendance and participation in asbestos related instruction and training programs Consultants Consultant responsibilities may include the following: performing annual audit and reporting of findings to Senior Administration; assisting with and/or developing a respiratory protection program; selecting and evaluating safety equipment; collecting suspected asbestos containing materials samples; collecting air clearance samples; monitoring abatement work including filling out the Asbestos Work Notice Forms (Appendix C), preparing written reports summarizing abatement work completed and the results of air monitoring test and submitting these documents to the Asbestos Management Program Coordinator; and conducting training.