Asbestos Management Program

Introduction

Asbestos has been identified in several University buildings during the asbestos survey and inspection process.  Asbestos is a health hazard to humans when it becomes airborne during cutting, sawing, sanding, drilling and demolition of materials that contain asbestos.  The University is committed to the health and safety of the entire campus community that includes staff, students and visitors.  The asbestos program is designed to protect the campus community from potential asbestos hazards and to ensure that asbestos-containing materials (ACM’S) are maintained, removed, and handled in compliance with state and local asbestos regulations. 

Asbestos was used in numerous building materials until about 1978 and these building materials have a limited life span and they deteriorate due to age, gravity, moisture, and impact.  The University will maintain asbestos-containing materials until they are removed prior to renovation and demolition projects.  Asbestos-containing materials that become damaged or deteriorated will be either repaired or removed.  All asbestos-containing materials must eventually be removed from a building before the building is demolished.

Scope

This program will apply to all University owned, rented, or leased buildings and all campus department staff, including Campus Operations and the Housing Department.  The asbestos abatement projects conducted by contractors at the University will be coordinated and managed under this program and the contractors will be required to comply with all applicable regulations.  This program covers all aspects of training, asbestos inspection, maintenance, labeling, repair, emergency response, and removal of asbestos-containing materials in University buildings. 

Responsibilities

Campus Departments - Departments are responsible for contacting EHS during the planning process to evaluate projects that will impact building materials so that EHS staff can review records and collect samples as needed to characterize the materials to be impacted.  The department is responsible for expenses associated with asbestos removal and associated air monitoring and inspection.

Employees - Employees will be responsible for reporting damaged building materials so they can be evaluated for asbestos before they are removed or repaired.  Employees are also required to avoid disturbance of known asbestos-containing materials and building materials that may contain asbestos unless they have been determined to contain no asbestos by EHS staff.  Building materials should never be assumed to not contain asbestos because this must be confirmed by laboratory analysis.

Environmental Health and Safety (EHS) -The EHS asbestos program manager (APM) will be responsible for managing the asbestos program, providing asbestos awareness training, coordinating and managing all asbestos abatement work, coordinating response to emergencies that involve asbestos, maintain records for samples and abatement projects, and conducting and supervising annual asbestos inspections.  The APM will also hire and manage contracts for environmental consultants as needed to assist with asbestos surveys, abatement design, specifications, bidding, and contractor oversight.  EHS will maintain records of sample analysis for building materials, asbestos survey reports and documentation for regulatory compliance. 

Environmental Health and Safety (EHS) -The EHS asbestos crew will be responsible for maintaining and labeling ACM,  asbestos abatement, response to emergencies that involve asbestos, and repair and cleanup for projects.  All asbestos repair, and removal will be conducted in compliance with the state and local asbestos regulations.  The asbestos crew is also responsible for maintaining equipment used for asbestos abatement, ordering supplies for conducting asbestos repair and for handling and disposal of asbestos.

Supervisors -Supervisors will be responsible for identifying projects that will impact building materials that may contain asbestos and for notifying EHS staff to allow sufficient time for evaluation of the project, review of analysis records and sampling.  Supervisors are also responsible for immediate notification to EHS of any incidental asbestos impact or discovery of damaged materials that may contain asbestos so they can be evaluated and proper cleanup can be completed.

Capital Construction -The capital construction staff are responsible for contacting EHS early in the planning process of projects to allow adequate time for evaluation of the project scope, inspection of affected areas, sampling and analysis of building materials and to ensure adequate funding is identified to address asbestos abatement work.

Planning Department -The planning department is responsible for contacting EHS early in the planning process for large projects to allow sufficient time for the asbestos survey process and to provide budgetary cost estimates for probable abatement work.

Definitions

  • Aggressive method means removal or disturbance of building material by sanding, abrading, grinding or other method that breaks, crumbles, or disintegrates intact ACM.
  • Asbestos includes chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos, actinolite asbestos, and any of these minerals that has been chemically treated and/or altered. For purposes of this standard, asbestos includes PACM, as defined below.
  • Asbestos-containing material (ACM), means any material containing more than one percent asbestos.
  • Class I asbestos work means activities involving the removal of thermal system insulation and surfacing ACM and PACM.
  • Class II asbestos work means activities involving the removal of ACM which is not thermal system insulation or surfacing material. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics.
    Class III asbestos work means repair and maintenance operations, where ACM, including TSI and surfacing ACM and PACM, is likely to be disturbed.
  • Class IV asbestos work means 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.
  • Decontamination area means an enclosed area adjacent and connected to the regulated area and consisting of an equipment room, shower area, and clean room, which is used for the decontamination of workers, materials, and equipment that are contaminated with asbestos.
  • Demolition means the wrecking or taking out of any load-supporting structural member and any related razing, removing, or stripping of asbestos products.
  • Disturbance means activities that disrupt the matrix of ACM or PACM, crumble or pulverize ACM or PACM, or generate visible debris from ACM or PACM.
  • Employee exposure means that exposure to airborne asbestos that would occur if the employee were not using respiratory protective equipment.
  • Glovebag means not more than a 6060 inch impervious plastic bag-like enclosure affixed around an asbestos-containing material, with glove-like appendages through which material and tools may be handled.
  • High-efficiency particulate air (HEPA) filter means a filter capable of trapping and retaining at least 99.97 percent of all mono-dispersed particles of 0.3 micrometers in diameter.
  • Intact means that the ACM has not crumbled, been pulverized, or otherwise deteriorated so that the asbestos is no longer likely to be bound with its matrix.
  • Negative Initial Exposure Assessment means a demonstration by the employer, which complies with the criteria in paragraph (f)(2)(iii) of this section, that employee exposure during an operation is expected to be consistently below the PELs.
  • PACM means presumed asbestos containing material.
  • Presumed Asbestos Containing Material means thermal system insulation and surfacing material found in buildings constructed no later than 1980. The designation of a material as PACM may be rebutted pursuant to paragraph (k)(5) of this section.
  • Regulated area means: 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. Requirements for regulated areas are set out in paragraph (e) of this section.
  • Removal means all operations where ACM and/or PACM is taken out or stripped from structures or substrates, and includes demolition operations.
  • Renovation means the modifying of any existing structure, or portion thereof.
  • Surfacing material means material that is sprayed, troweled-on or otherwise applied to surfaces (such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, and other purposes).
  • Surfacing ACM means surfacing material which contains more than 1% asbestos.
  • Thermal system insulation (TSI) means ACM applied to pipes, fittings, boilers, breeching, tanks, ducts or other structural components to prevent heat loss or gain.
  • Thermal system insulation ACM is thermal system insulation which contains more than 1% asbestos.

General Requirements

EHS will conduct annual asbestos inspections to evaluate the condition of asbestos-containing materials and to determine if repair, removal or other maintenance is required. EHS will maintain required records for asbestos abatement work conducted by the EHS asbestos crew, including LRAPA notifications, waste disposal manifests and air clearance documentation.  Asbestos abatement projects will comply with LRAPA and OR-OSHA asbestos regulations by using methods and engineering controls that includes negative pressure enclosures, HEPA vacuuming, wet methods, air filtration, prompt debris cleanup and disposal, protective clothing, respiratory protection, regulated area signage, for all asbestos repair and removal.  EHS will also ensure that asbestos-containing materials are maintained in an undamaged condition until they can be properly removed.  Asbestos abatement projects that are contracted will be conducted by abatement contractors on the OUS retainer list and EHS will manage the contract and abatement process, including air clearance as required.

This program will remain in compliance with the Lane Regional Air Protection Agency (LRAPA) Title 43 asbestos requirements and OR-OSHA 1910.1101 (Construction Industry) and 1910.1001 (General Industry) regulations for asbestos.

Employee Training and Certifications

Asbestos Awareness Training-EHS will provide asbestos awareness training annually to various Campus Operations departments and custodial staff.  This training is provided to cover topics including health effects of asbestos, recognition of damage and proper response to asbestos damage. 

Asbestos Operations and Maintenance Training-Required for staff conducting asbestos repairs and removal of asbestos-containing materials for maintenance purposes less than 3 SF or 3 LF.

Asbestos full scale asbestos worker-Required for staff conducting removal of asbestos-containing materials over 3 SF or 3 LF when an asbestos supervisor is present.

Asbestos full scale asbestos supervisor-Required for staff conducting and supervising removal of asbestos-containing materials over 3 SF or 3 LF.

Asbestos Inspector-Required for staff to conduct asbestos surveys and for collecting building material samples for asbestos analysis.

Asbestos Project Designer-Required for staff to compile a scope of work document for asbestos abatement projects that involve abatement contractors.

Contractors

EHS staff will obtain bids and contract with asbestos abatement firms to conduct asbestos abatement work associated with capital projects.  EHS will manage the asbestos abatement projects and contract environmental consultants as needed to ensure that all asbestos abatement work is conducted in a safe manner and in compliance with applicable regulations.  EHS will assist general contractors by coordinating to have asbestos-containing materials removed by the EHS asbestos crew or abatement contractors to accommodate their work and to avoid project delays.  EHS will also coordinate prompt cleanup and repair of asbestos-containing materials and associated debris that may be discovered or caused by incidental disturbance by contractors.

Contact: Mike Eldredge, Asbestos Program Manager

541-346-2908 | mikee@uoregon.edu