ASBESTOS MANAGEMENT PROGRAM

Transcription

1 ASBESTOS MANAGEMENT PROGRAM Rvised2014

2 Table of Contents PURPOSE AND SCOPE... 2 REFERENCES... 2 DEFINITIONS... 2 ATTACHMENTS... 3 RESPONSIBILITIES... 3 TRAINING... 4 INTERNAL ASBESTOS MANAGEMENT PROGRAM... 5 CONTRACTOR ASBESTOS NOTIFICATIONS AND ABATEMENT WORK ACTIVITES... 9 Appendix A: Facilities Management Asbestos Containing Ceiling List Appendix B: ISU Asbestos Team Job Summary Form 1

3 PURPOSE AND SCOPE The purpose of Illinois State University s (ISU) Asbestos Management Program is to provide processes and procedures designed to protect the campus community from the hazards associated with exposure to asbestos. No health risks exist if asbestos containing material (ACM) is not disturbed. If ACM necessitates removal or clean-up, it will be effectively and safely managed through strict compliance with the procedures and controls outlined in this Program. This Program applies to the entire Illinois State University Campus and facilities owned, operated, or managed by the University. REFERENCES 29 CFR Asbestos 29 CFR Asbestos Illinois Department of Public Health (IDPH) Title (p) 2.4 Illinois Environmental Protection Agency (IEPA) 40 CFR 763(E) DEFINITIONS Asbestos: a naturally occurring fibrous mineral which is mined from the earth as one of many varieties including chrysotile, amosite, crocidolite, tremolite, anthrophyllite and actinolite. It is different from other minerals in that its crystals form long, thin, needle like fibers. Its high tensile strength, resistance to heat and chemicals make it an ideal binder in certain building materials. Asbestos Containing Materials (ACM): any building material containing greater than 1 percent asbestos. The Environmental Protection Agency identifies 3 basic categories of ACBM: Thermal System Insulation, such as pipe cover, pipe fitting cover, tank cover, boiler cover; Surfacing Materials, such as spray-on fire proofing, troweled on or spray-on acoustic treatments; Miscellaneous, such as floor tile, mastic, ceiling tile, roofing, transite. Class III Work: repair and maintenance operations, where ACM, including Thermal System Insulation and surfacing ACM and PACM, is likely to be disturbed. Class IV Work: maintenance and custodial activities during which employees contact but do not disturb ACM or PACM and activities to clean up dust, waste and debris resulting from Class I, II and III activities. Competent Person: one who is capable of identifying existing asbestos hazards in the workplace and selecting the appropriate control strategy for asbestos exposure, and who has the authority to take prompt corrective measures to eliminate them. In addition, for Class I and Class II work, one who is specially trained in a training course which meets the criteria of EPA's Model Accreditation Plan (40 CFR 763) for supervisor, or its equivalent and, for Class III and Class IV work, who is trained in a manner consistent with EPA requirements for training of local education agency maintenance and custodial staff as set forth in 40 CFR (a)(2). Disturbance: activities that disrupt the matrix of ACM or PACM, crumble or pulverize ACM or PACM, or generate visible debris from ACM or PACM. Disturbance includes cutting away small amounts of ACM and PACM, no greater than the amount which can be contained in one standard sized glove bag or waste bag in order to access a building component. In no event shall the amount of ACM or PACM so disturbed exceed that which can be contained in one glove bag or waste bag which shall not exceed 60 inches in length and width. 2

4 Excursion Limit: 1.0 fiber per cubic centimeter of air as averaged over a sampling period of thirty (30) minutes. Fiber: a particulate form of asbestos 5 micrometers or longer with a lengh-to-diameter ratio of at least 3 to 1. Friable: ACM that can be crumbled, pulverized, or reduced to powder by the pressure of an ordinary human hand. Glovebag: not more than a 60 x 60 inch impervious plastic bag-like enclosure affixed around an asbestoscontaining material, with glove-like appendages through which material and tools may be handled. High-Efficiency Particulate Air (HEPA): a filter capable of trapping and retaining at least percent of 0.3 micrometer diameter mono-disperse particles Negative Exposure Assessment: a demonstration by the employer that an emploee s exposure during an operation is expected to be blelow the Permissable Exposure Level. Permisable Exposure Level (PEL): a legal limit in the United States for exposure of an employee to a chemical substance or physical agent, usually expressed in parts per million and as a time-weighted average. Presumed Asbestos Containing Material (PACM): thermal system insulation and sufacing material found in building construction no later than Regulated Area: an area established by the employer to demarcate areas where Class I, II, and III asbestos work is conducted, and any adjoining area where debris and waste from such asbestos work accumulate; and a work area within which airborne concentrations of asbestos, exceed or there is a reasonable possibility they may exceed the permissible exposure limit. Thermal System Insulation (TSI): ACM applied to pipes, fittings, boilers, breeching, tanks, ducts, or other structural components to prevent heat loss or gain. ATTACHMENTS Faciltities Management Asbestos Ceiling Tile List List of ISU Asbestos Team Members ISU Asbestos Team Jub Summary form RESPONSIBILITIES Environmental Health and Safety is responsible for: Maintaining the Illinois State University Asbestos Program and related initiatives/documents including oversight of the University Asbestos Team Carrying out duties as the Responsible Person for the University as it pertains to the (K-12) Laboratory Schools Asbestos Management Plan Serving as the Authority Having Jurisdiction with regard to all asbestos work planned or conducted at the University Maintaining a composite list of types of ACM materials that can be found in buildings on campus Maintaining the list of buildings/rooms with asbestos ceiling tiles Collecting samples of bulk asbestos materials for analysis at an accredited laboratory 3

5 Serving as the University contact for contractors requesting information on the locations and amounts of asbestos containing materials on campus Maintaining a list of pre-approved asbestos abatement contractors/consultants for each fiscal year. Providing Class IV asbestos training to ISU designated departmental personnel Notifying the Illinois Department of Public Health (IDPA) regarding planned asbestos work or asbestos releases that meet designated thresholds established by the IDPH or Environmental Protection Agency. Facilites Planning is responsible for: Ensuring that contractors are aware of the ISU Asbestos Program as it applies to their scope of work and reviewing contractor program requirements at pre-bid meetings and pre-construction meetings Ensuring that the Asbestos Program Manager or EHS designee are included in the planning of project and renovation work that involves disturbance or removal of building materials which may be suspect to contain asbestos in order to ensure that asbestos containing materials are identified and managed Facilities Management/Office of Energy Management /Housing Services is responsible for: Ensuring that Building Service Workers, Trade Shop Personnel, Heating Plant Personnel, Building Mechanics and Building Operation Engineers receive the annual asbestos awareness training provided by EHS. Ensuring that the Asbestos Program Manager or EHS designee are included in the planning of projects and renovation work that involve disturbance or removal of building materials which are known or suspected to contain asbestos in order to ensure that asbestos containing materials are identified and managed. University Purchasing is responsible for: Pre-approving asbestos contractors and consultants who may preform work at the University. Including language in all bid and contract documents, advising contractors of the presence of ACM in identified buildings at Illinois State University. TRAINING All ISU Asbestos Team members involved in Class III work receive initial Asbestos Abatment Contractor/ Supervisor training consistent with EPA 40 CFR 763 subpart E, Appendix C. Such a course includes classroom and hands-on training and is 40 hours in length. Annual 8-hour refresher training is required thereafter. [Training is provided by an EPA/IDPH accredited trainer using an EPA/IDPH approved training curriculum.] All personnel involved in Class IV (e.g. Facilities Management and Office of Energy Management craft personnel) work are required to successfully complete training consistent with EPA requirements for training of local education agency maintenance and custodial staff as set forth at 40 CFR (a)(1). Such course shall take at least 2 hours. Facilities Planning Project Management and Facilities Management Supervisors are required to attend an Asbestos Management training program provided by the University Asbestos Coordinator prior to undertaking their roles in planning, coordinating or overseeing work activities on campus. 4

6 INTERNAL ASBESTOS MANAGEMENT PROGRAM Identifcation of ACM in Campus Facilities Many of the buildings on campus have asbestos containing material in one form or another. Such materials include floor tile/mastic, ceiling tile, acoustic ceilings, cement board (transite), spray-on fireproofing, and thermal system insulation. EHS has completed inspections on most campus buildings and facilities to identify materials that contain asbestos, and their respective locations. This is an on-going process and all Asbestos Facilities Inspections are maintained in EHS. Results of the inspections are utilized in planning and conducting maintenance, renovation and construction work to ensure that ACM is not disturbed; or if necessary, is managed in a controlled manner ensuring no exposure to employees or building occupants. Locations of asbestos containing ceilings are identified in Appendix A, Asbestos Containing Ceiling List. This list is updated annually by the University Asbestos Program Coordinator (APC). Hard copies of this list are provided to Building Service Worker (BSW) supervision, and posted in BSW closets across campus. The list is also provided to all Supervisory staff to dissiminate to their groups including, Heating Plant, Craft Trades, and Housing Maintenance personnel. The purpose for this list is to make staff continualy aware of the location of asbestos containing ceilings. Should a water leak or other incident result in damage to asbestos ceilings, they will be handled per the requirements outlined in Class IV asbestos work training. Identification of Asbestos in the Unversity Laboratory Schools is contained in the Asbestos Management Plan, specifically developed for each school. Managing ACM Facilities Work on Campus Facilities Management Supervision is trained on the types of ACM present within campus facilities. Prior to beginning any work which has the potential to disrupt ACM, the APC is to be consulted to confirm the existence of ACM and ensure appropriate precautions are taken. If the work activity is designed to involve the disturbance of ACM, the APC shall be consulted to schedule such work to be completed by the University Abestos Team or be contracted to an approved asbestos abatement contractor. Note: The basis for this determination is the type and amount of ACM that will be disturbed. The APC will oversee all work performed involving ACM by the University Asbestos Team. The University Asbestos Team The APC is responsible for managing the ISU Asbestos Team. This team is comprised of members from Energy Management, Facilities Trades, University Housing, and Campus Dining Services. Team members are licensed by the Illinois Department of Public Health as Asbestos Workers but are trained to a higher level as Asbestos Contractor/Supervisors. EHS maintains the list of Asbestos Team members with contact information. The team is utilized for abatement and ACM clean-up acitivties that fall within Illinois Department of Public Health definition of Operation and Maintenance. This includes any asbestos removal or clean-up activites involving less than 3 square or 3 linear feet of Thermal Systeme Insulation or Surfacing ACM, and as categorized by OSHA as Class lll or IV asbestos 5

7 work. This also includes asbestos floor tile removal using intact methods with no restriction to the amount removed. Training is provided as outlined in Section 6.0. Team members will be be medically qualified prior to undertaking any Class III or IV work activities. Medical qualifications are administered by Student Health Services, under the supervision of a licensed physician. Standard protocol for medical qualifications include the completion of a medical questionnaire (prescribed by OSHA), a pulmonary function test, and a physical examination directed to the pulmonary and gastrointestinal systems,including a chest roentenogram to be administered at the discretion of the physician. Based on the results of the medical questionnaire, the physician may require more frequent or additional follow-up examinations/testing. Note: The asbestos questionnaire will be completed and reviewed annually. Although not required, the physical examinations, including chest roentenograms, will be offered to employees every three years unless the physician requests an exam on a more frequent basis. Following the annual medical qualification, the examining physician shall provide a written opinion to the APC, to include the following information: The Physician s opinion as to whether the employee has any detected medical conditions that wold place the employee at an increased risk of material health impairment from exposure to asbestos Any recommended limitations on the employee or on the use of personal protective equipment such as respirators A statement that the employee has been informed by the physician of the results of the medical examination and of any medical conditions that may result from asbestos exposure A statement that the employee has been informed by the physician of the increased risk of lung cancer attributable to the combined effect of smoking and asbestos exposure Work Practices The APC shall provide a copy of the physician s written opinion to the affected employee within 30 days of its receipt. All team members are given annual respirator fit tests conducted by EHS using a TSI Porta Count quantitative fit test unit. The APC will assign all asbestos work to asbestos team members and review the work plan prior to the start of work. The APC will oversee operations, as deemed warranted by the APC or requested by team members. The APC is responsible for coordinating communications with building occupants regarding the asbestos work, to the degree warranted based on the impact of the work on the occupants of the facility. Personal air monitoring and negative exposure assessments will be conducted to identify any potential exposures to ACM by members of the team. The APC will coordinate/oversee all monitoring as it relates to the Asbestos Team. Asbestos team members will complete an In House Asbesots Team Job Summary upon completion of each job (Appendix B). All team members are provided training on the use of air monitoring equipment provided by the University for this purpose as part of the annual Contractor/Supervisor refresher class. Class III and IV work shall be conducted in a regulated area. ISU team members are required to post standardized asbestos warning signs and barrier tape to demarcate the area where asbestos work is being performed. For operations involving friable asbestos, Danger Asbestos Signs with Respiratory Hazard and Personal Protective Equipment (PPE) warnings 6

8 Exposure Monitoring must be posted. For operations involving intact floor tile and mastic removal, Danger Asbestos Tape and/or Danger Asbestos Signs must be posted. If the Danger Asbestos Sign is posted during these operations, the Respiratory Hazard and PPE Warning verbiage must be folded from view. The APC shall periodically observe work-in-progress to confirm that required work practices as outlined in the Asbestos Class III are being followed. Results of the APC s observations are to be documented in the Abestos Team Work Observation file. If an unplanned incident such as roof leak or pipe leak happens during normal business hours, The APC or other qualified EHS representative must assess the conditions to determine if ACM has been or will be disturbed and coordinate the appropriate response action. If ACM will not be disturbed, the work may be completed and services restored. If an unplanned incident such as a roof leak or pipe leak happens during second or third shifts, holidays or weekends, contact must be made to the APC or EHS Safety Officer through either the Heating Plant or ISU Police to determine the appropriate course of action. If an incident involves the unexpected release of friable ACM, the following measures shall be taken: a. Clear the area of all building occupants and secure the area with danger tape/signage b. If deemed necessary, call for the shut down of the air handling unit that serves the area c. If the release involves less then 3 square/3 linear feet of material, a member or members of the University Asbestos Team can be used for the clean-up response. d. If the release involves more then 3 square/3 linear feet, the APC will coordinate a response action with an Asbestos Contractor and/or Asbestos Consultant. All asbestos work activities peformed by Asbestos Team members will require exposure monitoring. All exposure monitoring will be conducted or coordinated by the APC. Note: All team members are trained and authorized to perform personal air monitoring. Methodology established by NIOSH 7400 will be strictly utilized. Only National Voluntary Laboratory Accreditation Program accredited labs will be utilized to analyze monitoring results. The APC will make personal air monitoring results available to asbestos team members as soon as possible, but no later than 5 working days after the receipt of the results from the laboratory. Affected employees may be notified of the results either individually in writing, or by posting the results on the EHS website. Negative Exposure Assessment For any one specific asbestos job which will be performed by employees who have been trained in compliance with this Program, the APC may demonstrate that employee exposures will be below the PELs by data which conforms to the following criteria: Objective data demonstrating that the product or material containing asbestos minerals of the activity involveing such product or material cannot relase airborne fibers in concentrations exceeding the TWA and excursion limit under those work conditions having the greatest potential for releasing asbestos; or Where the University has monitored prior asbestos jobs for the PEL and the excursion limit within 12 months of the current or projected job, the monitoring and analysis were performed in compliance with the asbestos standard in effect; and the data were obtained 7

9 during work operations conducted under workplace conditions closely resembling the processes, type of material, control methods, work practices, and environmental conditions used and prevailing in the current operations, the operations were conducted by employees whose training and experience are no more extensive than that of employees performing the current job, and these data show that under the conditions prevailing and which will prevail in the current workplace there is a high degree of certainty that employee exposures will not exceed the TWA and excursion limit; or The results of initial exposure monitoring of the current job made from breathing zone air samples that are representative of the 8-hour TWA and 30-minute short-term exposures of each employee covering operations which are most likely during the performance of the entire asbestos job to result in exposures over the PELs Note: Although the APC will develop Negative Exposure Assessments for specific types of jobs performed by the Asbestos Team, personal air monitoring will continue to be required for all jobs in order to confirm actual exposure (or lack thereof). Records The APC will maintain records of known locations and quantities of ACM on campus. These records will be maintained for the duration of ownership and shall be transferred to successive owners. The APC shall maintain exposure records which include the following information and shall be maintained for at least 30 years. The date of measurement; The operation involving exposure to asbestos that is being monitored; Sampling and analytical methods used and evidence of their accuracy; Number, duration, and results of samples taken; Type of protective devices worn, if any; and Name and exposure level of the employees whose exposures are represented. Student Health Services shall establish and maintain an accurate medical record for each employee on the Asbestos Team. The record shall include at least the following information, and shall be maintained during the employee s employment at ISU plus 30 years. The name and social security number of the employee A copy of the employee s medical examination results, including the medical history, questionnaire responses, results of any tests, and physician s recommendations. Physician s written opinions Any employee medical complaints related to exposure to asbestos; and A copy of the information provided to the physician by the APC The Asbestos Program Coordinator shall maintain all training records for one year beyond the last date of employment of the employee at ISU. Records shall include: Copies of original asbestos training class certifications. Copies of annual asbestos refresher training certifications. Copies of IDPH asbestos licenses. The APC or University designated individual shall maintain the written records related to the notification to contractors concerning the identification, location, and quantity of ACM and PACM as long as the University is in operation. If buildings or facilities are are sold, these records are to be transferred to the owners of such buildings. K-12 (Lab School) Asbestos Management Plans 8

10 The Illinois Department Public Health requires special Asbestos Management Plans to be in place and up to date at each K-12 school in Ilinois. The University has two K-12 lab schools that fall under these requirements, University High School and Metcalf Elementary School. The University contracts with a Licensed Asbestos Management Planner to conduct 6 month surveys and 3 year re-inspections as required by the Illinois Department of Public Health. The Asbestos Management Planner and APC work to together to oversee all activities pertaining to the Lab School s Asbestos Management Plans. The Asbestos Management Plans include the following sections: Remaining asbestos materials report and bulk sample results Periodic surveillance report to include 6 month surveillance and 3 year reinspections Annual notifications and training certificates Operations and maintenance activities Major response actions including fiber release episodes Short term worker acknowledgement CONTRACTOR ASBESTOS NOTIFICATIONS AND ABATEMENT WORK ACTIVITES Contractor Notifications Regarding Asbestos and Asbestos Work The University informs contractors bidding on work at Illinois State University of the presence of asbestos containing materials (ACM) via standard language included in the University Bid Documentation. The following language is provided: Asbestos Containing Materials (ACM) Contractor certifies that it is hereby informed of a website (ehs.illinoisstate.edu) which can be accessed to identify types and general locations of ACM within ISU facilities. It also acknowledges that it is offered the option of requesting more detailed information of ACM within any specific building/area, and/or conducting a walkthrough of area(s) in question with the University Asbestos Coordinator/designee. Contractor certifies that it will immediately stop work and contact the responsible University contractor management official if it believes it has inadvertently disturbed any ACM on campus. This same language is included in the successful bidder s contract. Abatement Contractors Upon request of any contactor, the APC will provide any inspection data regarding ACM or will walk down any work area to discuss the potential existence of asbestos to which the contractor could potentially disturb during the described scope of work. In addition to the formal notification above, Facilities Managmenent and Project Management personnel will also inform contractors of the presenece of ACM when the contractor s scope of work involves disturbance of ACM within Unviversity facilities. The APC is responsible for maintaining a list of pre-authorized contractors and consultants to perform work at ISU. The list is to be renewed each year, and blanket Purchase Orders approved by the University Purchasing Department. Only pre-approved contractors and consultants may perform asbestos work at ISU. 9

11 The APC (as the Authority Having Jurisdiction) will review the work to be performed by the designated asbestos contractor/consultant to ensure that the work is coordinated and communicated as warranted to building occupants. The APC shall attend the preconstruction meeting with the contractor and other status meetings scheduled by Facilities Project Management. The APC, in collaboration with the Project Manager will maintain communication with the asbestos contractor/consultant as work proceeds and serve as the University liaison with regard to asbestos issues. 10

12 Appendix A: Facilites Management Asbestos Containing Ceiling List Facilities Management Asbestos Containing Ceiling List Effective to Asbestos Containing Ceiling Tile Building Sample Area Location 411 W. Willow MCB 2 X 4 Lay in Room 113 FH CT-2 2 X 4 Lay in Rooms 204, 204A, 216, 217, B,C-H FH CT-10 2 X 4 Lay in Room 401A NSB MCB 1 st Floor-Rooms 101, 102A, 102B, 103, 105(except R), 109,(Hallways 110, 115) 2 nd Floor-Rooms 201B, 201G, 204, 207, 211, 212,(Hallways 217, 218, 219) Stairwell 215 and 220 RC Transite Panels Perforated Acoustic Rooms 2 nd Floor RC CT-2 Room 101 UH CT-1,CT-2 2 X 4 Lay in Room 107 Asbestos Containing Acoustic Ceilings Building Name Sample Area Location ATK/COL SCA Connecting lounges and basements BSC/Braden SPF Rooms 183(Circus Room), 184(Old Main), 223(Bookstore), 228(atrium lounge) CVA SCA Rooms: 145, 146, 147, 148, 149, 150, 151, 152, 177, 178, 179 (this is the rotunda area) FSA SCA Rooms 020/156(mechanical room) FEN SCA Room 101(dining room)contact EHS FH SCA Room 324-S.E.A.T. (often considered part of Metcalf) HAM/WHT SCA Connecting lounges and basements JG SCA Rooms: 113, 114, 123, 124, 125, 126, 127, 128, 129,130, 130A,131, 133, 134, 135 MLS A-1 ANY ACOUSTIC/TEXTURED CEILING(classrooms, teacher offices) UH A-2 Room 230 WIH SPB 315 suite OU SCA ANY ACCOUSTIC/TEXTUERD CEILING(in various areas) Asbestos Containing Fireproofing Building Name Sample Area Locations HOV SFA Spray on East basement ME ceiling (above S-5 only) Please contact the EHS Asbestos Program Coordinator at prior to beginning work to verify location to be disturbed or cleaned. Environmental Health and Safety Office 202 Nelson Smith Building, Campus Box 1320 Phone: Fax: Turn Over

13 Appendix B: Asbestos Team Job Summary Report ISU ASBESTOS TEAM JOB SUMMARY BUILDING/ROOM: DATE COMPLETED: AIR SAMPLING: PCM cassette # Pump # Pump pre cal reading Pump post cal reading Total minutes of air sampling Flow rate: Pump/cassette worn by: DESCRIBE WORK COMPLETED: JOB COMPLETED BY(signature): Glove Bag Removal Control Measures Utilized: Floor Tile Removal Control Measures Utilized: area restricted to limit access by unauthorized personnel pipe insulation was removed by wet methods using OSHA/EPA approved glove bag procedures exposed or loose ACM was encapsulated to lock down fibers exposed or lose ACM was wrapped with lag cloth to lock down fibers personal air monitoring was conducted protective suit and respirator worn area restricted to limit access by unauthorized personnel Intact methods utilized(circle method) HEAT WET HEPA vac used for clean up if necessary material disposed of in approved waste bag and disposed in ISU asbestos dumpster personal air monitoring was conducted other (please explain) material disposed of in approved waste bag, HEPA evacuated and goose necked waste bags disposed in ISU asbestos dumpster other (please explain) Housekeeping/Encapsulation/O and M Control Measures Utilized: area restricted to limit access by unauthorized personnel HEPA vac used for clean-up of loose/fallen material wet methods used for clean-up exposed or loose ACM was encapsulated to lock down fibers exposed or lose ACM was wrapped with lag cloth to lock down fibers Ceiling Tile Movement Control Measures Utilized: area restricted to limit access by unauthorized personnel 6 mil poly placed under work area HEPA vac used to clean the track and surrounding area personal air monitoring was conducted protective suit and respirator worn power tool with HEPA vac attachment used when ACM was disturbed material disposed of in approved waste bag, HEPA evacuated and goose necked(if required) 1