Colorado College Asbestos Management Program

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1 Introduction: Asbestos is a mineral used in building and heating applications for its great tolerance to heat, which makes it both a remarkable thermal insulator and a good fireproofing agent. Asbestos appears in buildings in five major forms, all similar in chemistry but different in crystal structure. Asbestos is a proven carcinogen when inhaled; causing diseases like emphysemalike asbestosis, mesothelioma and lung cancer. As a result, Federal and state governments have created regulations limiting its use and providing for the safety and well-being of the public and workers involved with asbestos handling, installation, maintenance and removal operations. Building materials ranging from insulation to fireproofing to floor tiles, as in Vinyl-Asbestos Tiles, might contain asbestos. Colorado College has extensive survey data that identifies asbestos containing materials in many areas on campus. In some areas, the college knows the composition and asbestos content of building materials. These building products are "asbestos-containing materials," or ACM. In many cases, the college may not know the actual composition of certain building materials that, historically, contain asbestos, like roofs, old pipe insulation and floor tiles. These materials are "presumed asbestos-containing materials," or PACM. Because PACM may contain asbestos, the college treats them as ACM without determining its asbestos content, in most cases. In other cases, like plaster, window putty and sheet-rock, the prevalence of asbestos is much rarer, but still a concern. These materials are also PACM, until sampling and analysis determines their actual asbestos content. Asbestos-containing materials are of two kinds friable or non-friable. Friable materials are those which can produce airborne asbestos fibers upon crushing with hand pressure. In general, materials that are more fragile are more friable. Some conditions, like demolition, cause non-friable materials to release fibers. Working near non-friable ACM without disturbing it is substantially different than working directly on non-friable ACM, where the risk of releasing asbestos fibers is greater. Management in Place: It is the practice of the College to maintain friable asbestos in good condition, until damage, renovation or demolition necessitates its removal. Management in place requires that ACM and PACM be controlled as follows: Maintenance of friable ACM/PACM in good condition, Proper clean-up of asbestos fibers previously released, Prevention of further release of asbestos fibers Monitoring of the condition of asbestos-containing materials. ACM or PACM in any damaged condition requires prompt assessment and may require removal, enclosure, encapsulation, repair, and/or isolation of the area pending such action. ACM/PACM assessments are performed by the EH&S office in Facilities Services. V - 1

2 Locations: Asbestos was common in construction between 1930 and Consequently, maintenance workers should expect it to exist in many building materials. Examples of ACM include, but are not limited to: acoustic plaster, sprayed-on fireproofing, pipe, boiler and other thermal system insulation, wrapping and tape on forced air ducts (heating and exhaust), gaskets in furnaces and boilers, and Ceiling tiles. Binder in plaster, joint compounds, wall board and surface texturing in/on walls and ceilings, Binder in composite (vinyl) tiles and glues on floors and baseboards, Binder in glazing putty on windows, Backing on sheet flooring materials, Fabric core and backing of some membrane and built-up roofing systems, Insulation on electrical wiring, Transite wall panels, and Siding on exteriors. The primary difference between these materials is friability, or the ease with which asbestos fibers become airborne. Fiber release depends on condition of the material and work methods some work methods make non-friable materials release fibers. It is important to evaluate both the materials in the work area and the work methods used on or near those materials to determine asbestos risk. Training: The Environmental Health & Safety office in Facilities Services will provide training, as required by regulations or other factors, to housekeeping, maintenance and technical staff. Training will include, but not be limited to: Health effects of asbestos exposure Locations of asbestos in campus buildings Recognition of asbestos damage Response to asbestos damage Identification of Asbestos Containing Materials: The asbestos content of most PACM cannot be accurately determined without analysis specific for asbestos. Some materials, however, are historically very likely to contain asbestos: Pipe and boiler insulation and gaskets Wall materials Flooring materials Window Putty Transite exteriors and wallboard Sprayed-on and troweled-on ceilings It is the policy and practice of the College to presume that all building V - 2

3 materials likely to contain asbestos are asbestos containing until proven otherwise by analytical testing. Facilities Services has survey information pertaining to asbestos-containing building materials, including individual samples of many buildings. This survey information is available from the Environmental Health & Safety office in Facilities Services. Facilities Services will re-validate its campus-wide asbestos survey from time to time, as required by conditions, projects and regulatory obligation. Reporting Asbestos Concerns: It is the practice of Facilities Services to manage asbestos in place, in keeping with Environmental Protection Agency guidance. This approach requires prompt reporting, assessment and correction of asbestos concerns. Additionally, maintenance, renovation and demolition work that is likely to impact ACM or PACM must not impact these materials in any way that is likely to release asbestos fibers into the air. To report concerns with damaged, friable ACM and PACM (reporting asbestos emergencies): Stop work in the area. Quickly report the damaged material, its location and condition to the Environmental Health & Safety Manager (x6678) and to the Work Order Desk in Facilities Services (x6876). Stay near the area until contacted by EH&S and/or Facilities Services to locate and identify the concern. To receive an assessment of work methods and asbestos risk in maintenance, renovation or demolition work area: Contact EH&S (x6678) and report the location, expected scope of work and work methods. Do not perform destructive work until EH&S assesses the materials, area and work methods. Work Procedures: Efficiently using asbestos work procedures depends on understanding where asbestos exists or might exist. In many spaces on campus, the college knows that asbestos is not present. Refer to the campus-wide asbestos inventory, available from shop supervisors and from the Environmental Health & Safety office, in Facilities Services. Many campus work tasks near asbestos do not require specific training and equipment. Generally, these are: Working in Maintenance Tunnels, Chases and Mechanical Rooms: Asbestos may be present in mechanical rooms and tunnels as pipe and boiler insulation. Generally, asbestos insulation will have a canvas cover to protect it from casual damage. Asbestoscontaining insulation may be so marked, as will asbestos-free insulation. If insulation is not marked or labeled, refer to the campus-wide asbestos inventory or presume the material to contain asbestos. V - 3

4 Evaluate the condition of any rigid insulation. If there are breaks, rips or tears in the surface of the insulation, do no further work in the area. Contact the Environmental Health & Safety office. Do not work in the area until the Environmental Health & Safety office has cleared the area for safe work. If the insulation appears to be in good condition or the area has been cleared for safe work by the Environmental Health & Safety office in Facilities Services, continue with the work, ensuring that asbestos is not damaged, hit, disturbed, drilled, broken or prodded in any way. Working on Walls, Floors and Ceilings Asbestos may be present in walls, floors and ceilings. Before any work begins that affects the structure of wall, floor and/or ceiling systems, refer to the campus-wide asbestos inventory or contact the Environmental Health & Safety office. If the wall, floor or ceiling materials are presumed asbestoscontaining materials (PACM), do no work in the area that involves cutting, cracking, hammering, drilling or sawing until the asbestos content of the material has been evaluated by the Environmental Health & Safety office. If the wall, floor or ceiling materials are ACM, do no work in the area that involves cutting, cracking, hammering, drilling or sawing until the work method has been reviewed and approved by the Environmental Health & Safety office. If the wall, floor or ceiling materials do not contain asbestos, either according to the campus-wide asbestos inventory or laboratory analysis of PACM, proceed with the work in a safe manner. Working above Suspended Ceiling Tiles (Armstrong Hall) Carefully remove one ceiling tile near the work area, minimizing dust generation. Look on ceilings or beams for gray material with a wooly appearance. This material is asbestos. Look around under beams and ceilings treated with this gray material for clumps on suspended ceiling tiles or light fixtures. Look on the beams and ceiling for damage to the sprayed-on material. If clumps of fallen sprayed-on material are visible, do no further work in the area and report the concern to the Environmental Health & Safety office in Facilities Services immediately. If you can not see clumps of fallen sprayed-on material, or if the Environmental Health & Safety office in Facilities Services has cleared the area for work, continue with the work. Be certain that you do not damage, hit, disturb, drill, break or prod the sprayed on material in any way. In the event that asbestos-containing materials and/or presumed asbestoscontaining materials receive damage, report the damage immediately as an asbestos emergency (see above). Occupational Safety and Health Administration (OSHA) requires that work that damages asbestos be performed either under a containment or by trained personnel after a Negative Exposure Assessment (NEA) has been performed, to V - 4

5 verify that workers are not subjected to unacceptable levels of airborne asbestos fibers. The NEA is the only way to verify that work that affects asbestos is safe, without taking other substantial precautions, such as containment, ventilation and/or wet methods. The Environmental Health & Safety office in Facilities Services performs and keeps records of NEAs for campus maintenance and construction activities. In some cases, EH&S will need to repeat a NEA before the work can happen again. This will depend on work methods and the asbestos-containing material involved. Asbestos Removal and Repair Procedures: Employees or contractors who perform removal or repair of asbestos will be trained in such removal or repair, in accordance with all applicable local, state and federal regulations (49 CFR , 49 CFR , 49 CFR , 40 CFR 61, Colorado Regulation 8, etc.). All employees and contractors performing removal or repair will wear personal protective equipment, as required by all applicable local, state and federal regulations. All employees or contractors who perform any work procedures directly involving asbestos will exert the utmost effort to reduce fiber release and to protect workers and members of the campus community. All contracted asbestos repair or the Environmental Health & Safety office in Facilities Services will manage removal operations. Copies of all applicable asbestos regulations are available in the Environmental Health & Safety office in Facilities Services. V - 5