Penn State University Environmental Health and Safety Asbestos Management Program I. Introduction Over the past several decades the hazards of asbestos exposure have become well known. With this influx of information, the problem of managing the hazard of asbestos has also arisen. Due to the large scale use of asbestos containing materials (ACM) in a wide variety of products, the magnitude of the problem is immense. Asbestos has been widely used in building materials since the 1940's. Examples of these materials include trowelled-on acoustical ceiling coatings, sprayed-on fire- proofing for building superstructures, roofing, pipe and boiler insulations; the list goes on and on. The use of most types of ACM in building materials was banned in the early 1970's. Since most University buildings were built when ACM was still allowed in building materials, asbestos management is a major program. The University's Asbestos Management Program was developed and implemented by the Department of Environmental Health and Safety (EHS). The Office of the Physical Plant (OPP) also plays a major role in the program. The University's current policy is that of in-place management. That is, ACM is only disturbed or removed when absolutely necessary. This means only during building renovation, demolition or when the material is found to be damaged. II. Federal and State Regulatory Requirements and Guidelines A. Regulatory Requirements Currently, the University is mainly regulated by three authorities, two state and one federal. The three agencies are the US Environmental Protection Agency (EPA), the PA Department of Environmental Protection (PA DEP) and the PA Department of Labor and Industry (PA Labor and Industry). The pertinent regulations and their respective enforcement agencies are as follows: 1. Section 40 of the Code of Federal Regulations, Part 61 (40 CFR Part 61); The EPA National Emissions Standards for Hazardous Air Pollutants (NESHAPS), Asbestos Revision, November 20, 1991. This has also been adopted and promulgated by PA DEP. These standards require that the University handle ACM so that there are no visible emissions from the work area, disposal containers, etc. The use of a waste disposal manifest or shipment record is also required to track the disposal of ACM. Finally, NESHAPS requires the University to notify the EPA and PA DEP of impending asbestos abatement activities. This notification must be post marked 10 working days prior to the start of projects that exceed 260 linear feet of pipe insulation and 160 square feet on other facility components. Smaller projects, such as in-house Operations and Maintenance activities are reported on a yearly basis. 2. 40 CFR Part 763; The Asbestos Hazard Emergency Response Act (AHERA), EPA Worker Protection Rule, February 25, 1987. This protects those that may be exposed to asbestos, but do not fall under the jurisdiction of the Federal Occupational Safety and Health Administration (OSHA). An example of this would be state employees, such as Penn State faculty and staff and tradesmen. However, the regulation is exactly the same as OSHA's. Actually, it was adopted word for word from OSHA. Page 1 of 8
3. 40 CFR Part 763; The AHERA Reauthorization Act, November 28, 1990. This act requires that anyone involved in asbestos related work in public and commercial buildings be certified by an EPA accredited training provider. States have also been mandated to set up their own accreditation programs. 4. PA Act 194-1990; The Asbestos Occupations Accreditation and Certification Act, July 1, 1991. This is the result of the above AHERA Reauthorization Act. The certification requirements have, however, been extended to include all facilities, including private residences. The occupations currently mandated for certification are as follows: Asbestos Removal Worker Asbestos Removal Worker/Supervisor Building/Facility Asbestos Inspector Building/Facility Asbestos Management Planner Asbestos Project Designer Asbestos Abatement Contractor All require yearly refresher training and fee submittal to PA Labor and Industry. There are other regulations that do apply to the program. These are related to such agencies as the Department of Transportation (PA and Federal), Allegheny County, PA and the City of Philadelphia. The Federal Clean Water Act must also be complied with when disposing or treating asbestos contaminated water. Although descriptions of these requirements are not included, they are important, and are dealt with in the program. B. Federal Guidelines Since the asbestos regulations that the University is governed by are not wholly comprehensive, Federal Guidelines are also used for direction. Examples of these guidelines are: EPA - Managing Asbestos in Place, A Building Owners Guide to Operations and Maintenance Programs for Asbestos Containing Materials (EPA Green Book), July 1990. EPA - Guidance for Controlling Asbestos Containing Materials in Buildings (EPA Purple Book), June 1985. EPA - Asbestos Exposure Assessment in Buildings, Inspection Manual, October 1982. Also, there are regulations that the University is not required to comply with, but are still used for guidance. The most prominent example of this is AHERA. This regulation was developed for the management of asbestos in public school systems, grades K-12. AHERA regulations are considered by many to be the state of the art for asbestos management, sample analysis, etc. III. Asbestos Identification Due to the large amount and diversity of ACM found within the University system, several approaches to asbestos identification are utilized. These include visual inspection, bulk sampling of suspect materials and the assumption that certain materials commonly found in facilities contain asbestos. Laboratory analysis of samples is the final confirmation step in identifying ACM. Page 2 of 8
A. Definition of Asbestos Containing Materials as stated by EPA NESHAPS 1. Friable - any material containing more than 1% asbestos, as determined using AHERA mandated analytical methods, that when dry can be crumbled, pulverized or reduced to a powder with hand pressure. 2. Non-friable - any material containing more than 1% asbestos, that when dry cannot be crumbled, pulverized or reduced to a powder by hand pressure. a. Category I - asbestos containing packings, gaskets, resilient floor covering and asphalt roofing products containing more than 1% asbestos. b. Category II -any material, excluding Category I non-friable ACM. An example of this would be "Transite" sheeting. B. Visual Inspection The first step in identifying suspect ACM is visual inspection of the building or buildings in question. This inspection is also used to quantify the amount of ACM in the building if the suspect material is indeed found to contain asbestos. Visual inspection information from confirmed ACM is then used to demarcate areas to be resurveyed on a periodic basis. Changes in the condition of the ACM can then be tracked over time. If the material is seen to be deteriorating, funding is requested for removal or repair, whichever best suits the situation. EPA AHERA requirements for surveying buildings for asbestos are followed as much as possible. Although this is not required, it is as previously mentioned, the current state of the art. With the proliferation of asbestos litigation, it is legally prudent to use the most advanced techniques whenever possible, as well as, most ethical. C. Bulk Sampling As with visual inspections, AHERA requirements are followed when collecting bulk samples of suspected ACM. To avoid possible non-survey personnel exposure and concern, areas are sampled when not occupied whenever possible. Samples are collected by PA Labor and Industry certified individuals only. D. Assumption of Certain Suspect Materials Certain materials are commonly found to contain asbestos and are, therefore, always assumed to be ACM. These include any thermal system insulation (TSI) that is not obviously fiberglass or foam rubber. TSI's are those found on plumbing, boilers, furnaces, steam heat exchanges, etc. This assumption is also made because of the age of most buildings and the expense of surveying all suspect systems. Many asbestos containing thermal insulations within the University still have the manufacturer's label. These are immediately considered asbestos containing. An example of these labels is shown below. Note that the label makes no mention of the material containing asbestos. However, it is a well known fact that the balance of the material is asbestos. Page 3 of 8
Floor tiles, sheet flooring, backing and the adhesives holding them in place are also assumed to be ACM. This includes both 9"x 9" and 12"x 12" tiles. If large scale removal is required, they may be sampled to confirm their content. These materials are managed as separate entities, because they are considered nonfriable. Another non-friable material that is assumed to be ACM is Transite. This is the brand name for a performed material used for roofing, oven liners, chemical fume hood liners, piping and sheeting (both flat and corrugated), etc. The material was made by compressing a mixture of asbestos and Portland Cement. Asphaltic roofing materials such as shingles and tar paper are also assumed to be ACM. However, as long as they are not cut, drilled, ground, sanded or otherwise reduced to a powder they can be handled and disposed as standard construction waste. As with flooring, if large scale removal is required, they may be sampled before removal. E. Laboratory Analysis As previously mentioned laboratory analysis is the final confirming step in identifying a substance as ACM. The analytical procedure is that which is required by EPA AHERA regulations. This entails the use of Polarized Light Microscopy (PLM). 1. Laboratory Prequalification Before being used by the University, a laboratory must hold certain nationally recognized credentials. These are accreditations by the US Department of Commerce, National Institute of Standards and Technology National Voluntary Laboratory Accreditation Program (NVLAP) and the American Industrial Hygiene Association (AIHA). In addition to using outside laboratories, a lab has been set up at EHS. However, to avoid conflict of interest, quality control and questionable samples will be sent to an independent lab for re-analysis. IV. Information Management The University system is comprised of approximately 1000 buildings, most of which contain ACM in one form or another. Consequently, there is a large amount of information generated during inspections, sample collection, project documentation, etc. A. Databases For ease and speed of access to information, computerized databases were developed for asbestos abatement projects and air and bulk sample data. 1. Asbestos Abatement Projects This database includes information from both OPP in-house projects at University Park and projects conducted by contractors at all University locations. The information stored includes project date, amount of material involved, action taken, cost of project, who conducted the project, as well as, several other pertinent items. Page 4 of 8
2. Air and Bulk Sample Analytical Data This includes the analytical results from all air and bulk samples known to be collected within the University system. The information can be searched by campus, building, building number, samples contents, etc. B. Building Floor plans Floor plans of buildings that are known to contain trowelled or spray applied ceiling, wall or superstructure coatings, Transite ceilings or walls and ceiling tiles are kept on file at University Park at EHS, OPP and the Office of Telecommunications. This allows quick reference to the locations of these materials for tradesmen and designers that may be involved with building renovations or demolitions. Emergency notification of occupants is also expedited in the event of a ceiling/roof leak or other structural failure. An example of a typical floor plan is shown below. C. Abatement Project Documentation All asbestos abatement projects are documented from design to completion. This information is kept on file forever, as is the associated computer generated information for each project. The information contained in these files includes regulatory authority notification, asbestos waste shipment and disposal manifests, daily project logs, inspection reports and air monitoring and inspection data from the independent project monitoring consultant used for each project. V. Hazard Management The actual day to day management of the University's ACM is conducted mainly by two departments. The first is EHS, which is responsible for the development, implementation and coordination of the program. The second is the University OPP, which is mainly responsible for Operations and Maintenance, Page 5 of 8
developing renovation and demolition plans, calculating cost estimates and developing budgets for projects and so on. Since both departments are required to effectively run the program, coordination between the two is quite important. Part of that coordination entails deciding how to best conduct the required work. Due to the scope and complexity of the problem, the University mainly uses two schemes to complete all asbestos related work within the system. These are In-House and Contracted Hazard Management. A. In-House Hazard Management 1. OPP 227 Asbestos Crew The majority of asbestos related projects at University Park are conducted by the specially trained OPP 227 Asbestos Crew. This crew consists of several tradesmen and two supervisors, all of whom are PA Labor and Industry certified for their respective occupation. They are responsible for conducting small-scale short duration Operations and Maintenance activities. These include limited removal of pipe insulation using the glove bag technique, and damaged ACM debris clean-ups and insulation repairs. Due to their limited equipment inventory and crew size, they are restricted from large scale projects and removal of most trowelled or spray applied materials. These types of activities are conducted by outside contractors, under full containment conditions only. Since locations other than University Park do not have in-house Operations and Maintenance crews, all asbestos related work at these sites is conducted by outside contractors. 2. Asbestos Awareness Training Due to the large number of tradesmen in employees in OPP, etc. that work in close proximity to ACM, EHS regularly instructs tradesmen, janitorial, designers and project managers in various aspects of asbestos awareness. These are usually short, informal discussions with small groups on the location and hazards of ACM in the vicinity of their work. Formal seminars are also given from time to time. OPP also instructs their personnel on the location of ACM, the use of the aforementioned asbestos building floor plans and work stoppage procedures when ACM is unexpectedly encountered. Although several standard operating procedures have been developed and documented, there is not a formal asbestos awareness training program for University employees. B. Contracted Hazard Management> 1. Asbestos Abatement Contractors When a project at University Park is determined to be beyond the scope of OPP in-house Operations and Maintenance activities, an asbestos abatement contractor is asked to conduct the work. Also, as previously mentioned, all work at locations other than University Park is conducted by contractors. However, before a contractor is allowed to conduct asbestos related activities within the University system, they must be prequalified by EHS and OPP. a. Prequalification Prequalification consists of sending a prospective contractor a letter of request for information used to verify their competence in asbestos abatement. The documentation required includes proper licensing, insurance, past projects completed with references and the names of any industrial hygienists that have inspected or monitored their projects. Page 6 of 8
A contractor must also have been in business under the same management structure for at least three continuous years. This is due to the proliferation of inexperienced companies since the inception of the AHERA regulations. Regulatory authorities in the jurisdictional area of past projects or corporate offices are also contacted. This is to ensure that the contractor in question has not had any previous citations, convictions, work stoppages, etc. OPP also prequalifies contractors as to their insurance bonding capacity. If the contractor meets all of the above criteria, they are added to a listing of qualified bidders. After prequalification contractors are sometimes found to be in noncompliance with the University's requirements and are immediately removed from the qualified bidders list. b. Retainer Contract For ease of use and quick response during emergencies, two contractors are kept under a retainer contract (standing order). This is renewed every year and is used for projects that are less than $25,000.00. Projects estimated to be over this amount are contracted on a competitive bid basis from the aforementioned list of qualified bidders. 2. Asbestos Management Consultants Independent (third party) asbestos project monitoring firms are utilized for each abatement project conducted by a contractor. The firms provide personnel to monitor contract and/or specification compliance, regulatory compliance, conduct visual inspections of the work areas and collect and analyze air samples before, during and after the project. a. Prequalification Prequalification of monitoring firms is similar to that of abatement contractors. However, certain nationally recognized accreditations are required of the firm's personnel and laboratory. First, the person or persons on-site must be National Institute of Occupational Safety and Health (NIOSH) or equivalent certified to analyze air samples for airborne fibers. Additionally, the laboratory that the firm wishes to use for quality control re-analysis of samples must be accredited by the AIHA. Finally, all analysts, both on-site and laboratory, must be participants in the AIHA's Proficiency Analytical Testing (PAT) program. This program, requires analysts to continually prove competence by analyzing samples that only the AIHA knows the concentration. The analysts are regularly tested and notified of their performance, and a national listing is kept for public information. b. Retainer Contract Two project monitoring firms are also kept on retainer contract (standing order) for the same reasons as the asbestos abatement contractors. Also, constant use of the same firms ensures a thorough knowledge of the requirements of the University. This avoids delays due to questions that may arise during projects. 3. Asbestos Abatement Project Performance Specifications EHS has developed a performance specification for any asbestos abatement activity conducted by a contractor. This document defines specific activities that are to be conducted during an asbestos abatement project. Requirements are specified for both the abatement contractor and the project monitoring firm. Both parties are also expected to comply with all statutory requirements in effect at the location and time of the project. Page 7 of 8
VI. Costs of Asbestos Management The annual cost for the University's Asbestos Management Program is approximately $500,000.00 a year. This includes all aspects of the program, except salaries of those involved. Costs have held steady for the past several years. Costs may increase as additional regulations are enacted. For example the current AHERA regulations, which currently apply only to public primary and secondary educational facilities, may be extended to all public and commercial buildings. This may require resurveying many facilities and development of specifically structured management plans and abatement activities. VII. Conclusions The University's Asbestos Management Program has proven to be rather effective. There have been few incidents where the system has been unable to cope with a problem. The program is consistent with the EPA's current philosophy that asbestos hazards can be kept low with conscientious in-place management. This type of program and philosophy is also most cost effective, especially in terms of long range planning and management. Prepared By: Michael J. Burke, Industrial Hygiene Specialist PA Dept. of Labor and Industry Asbestos Management Planner/Project Designer #001970, March 1996 For more information on PSU EHS asbestos policies, services, etc. please call (814)865-6391 or e-mail Mike Burke. Page 8 of 8