AsbestosOM ProgramFinal 2019.pdf

UNITED STATES DEPARTMENT OF AGRICULTURE

AGRICULTURAL RESEARCH SERVICE

North Central Soil Conservation Research Laboratory 803 Iowa Ave. Morris, MN 56267

Updated July 2, 2019

ASBESTOS OPERATIONS AND

MAINTENANCE PROGRAM

(RL and LC)

(Administrative Officer)

THE North Central Soil Conservation

Research Laboratory in Morris, MN, ASBESTOS OPERATIONS AND

MAINTENANCE PROGRAM

Introduction

It is ARS policy to protect the health of its employees by limiting exposure to asbestos fibers.

This policy applies to all employee types including part-time, seasonal, and temporary at all ARS facilities. The Research Leader is responsible for recommending appropriate response actions for managing Asbestos Containing Building Materials (ACBM) found in a North Central Soil Conservation Research Laboratory building. An Operations and Maintenance (O&M) program must be implemented whenever any asbestos-containing building materials are found in a North Central Soil Conservation Research Laboratory building. The purpose of the O&M Program is to prevent the release of asbestos fibers through careful management of

ACBM.

Objectives of the O&M Program

An O&M Program consists of a set of procedures and practices for operating and maintaining a building to keep it as free of asbestos contamination as possible. The program should be designed specifically to address the ACBM present in the building involved.

An O&M program has three main objectives:

1. Clean up existing contamination;

2. Minimize future fiber release by controlling access to ACBM and instituting proper work practices; and

3. Properly maintaining the ACBM until it is removed.

The intentional disturbance of ACBM should be limited to the repair or removal of small areas of significantly damaged ACBM or to small areas where removal is necessary to make maintenance or minor renovation activities easier. It is not a means by which full-scale asbestos abatement can be accomplished. Limited encapsulation and enclosure should be used to enhance an O&M Program by reducing the likelihood of contact with the ACBM. National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations require that friable and non-friable ACBM which is likely to become friable be removed from buildings before demolition. In addition, the asbestos NESHAP may regulate the removal of asbestos as part of a renovation. Some small scale, short duration activities may be subject to asbestos NESHAP training and notification requirements if enough (more than 160 ft2, or 260 linear feet, or 35 ft3) ACBM will be disturbed during a calendar year. Larger abatement projects that require extensive planning and technical expertise are not part of the O&M program.

Required Elements of an O&M Program

The North Central Soil Conservation Research Laboratory must ensure that the O&M Program involve the following elements:

• Cleaning

• Specialized work practices and procedures for O&M activities disturbing friable ACBM

• Training

• Emergency Response Procedures

Cleaning Procedures

All areas of a building where friable ACBM and suspected ACBM, or significantly damaged Thermal System Insulation (TSI) ACBM is present must be cleaned at least once after the completion of the ACBM inspection. It must also be cleaned before the initiation of any response action (other than O&M activities or repair). The exception would be where the building had been cleaned using similar methods within the previous six months. The cleaning must include the following:

• HEPA-vacuuming or steam-cleaning all carpets

• HEPA-vacuuming or wet-cleaning all other floors and all other horizontal surfaces

• Disposing of all debris, filters, mop heads, and cloths in sealed, leak-tight containers

Specialized Work Practices and Procedures

The Research Leader must ensure that the following procedures are followed for any O&M activities disturbing friable ACBM:

• Restrict entry into the area by persons other than those necessary to perform the maintenance project.

• Post signs to prevent entry by unauthorized persons.

• Shut off or temporarily modify the air-handling system and restrict other sources of air movement.

• Use work practices or other controls, such as wet methods, protective clothing, HEPA vacuums, mini-enclosures, and glove bags, as necessary to inhibit the spread of any released fibers.

• Clean all fixtures or other components in the immediate work area.

• Place the asbestos debris and other cleaning materials in a sealed, leak-tight container.

Training

Within 60 days of hire, maintenance and custodial staff who may work in a building that contains ACBM must receive at least two hours of asbestos awareness training. Those members of the maintenance and custodial staff who conduct any activity that will disturb ACBM must receive an additional 14 hours of training

Emergency Response Procedures

As long as ACBM remains in a building, there is a risk of a fiber release episode. Custodial and maintenance workers should be aware of this and should always report any of the following occurrences to the Research Leader or designee:

• Any debris found on the floor or other horizontal surface where ACBM is present.

• Any water or physical damage to the ACBM.

• Any other evidence of possible fiber release.

There are two types of fiber release episodes: minor episodes and major episodes. The specific procedures that must be followed depend on which type of episode occurs.

Minor Fiber Release Episode

A minor fiber release episode consists of the falling or dislodging of three square or linear feet or less of friable ACBM. When such an event occurs, the Research Leader must ensure that:

• The debris is thoroughly saturated using wet methods.

• The area is cleaned.

• The asbestos debris is placed in a sealed, leak-tight container.

• The area of damaged ACBM is repaired with materials such as asbestos-free spackling, plaster, cement, or insulation; sealed with latex paint or an encapsulant; or an appropriate alternative response action is implemented.

When a minor fiber release episode occurs, the Research Leader or designee will assign an appropriately trained O&M in-house team to clean up the debris and make repairs as soon as possible.

Major Fiber Release Episode

A major fiber release episode consists of the falling or dislodging of more than three square or linear feet of friable ACBM. When such an episode occurs, the Research Leader must ensure that:

• Entry into the area is restricted and signs are posted to prevent entry into the area by persons other than those necessary to perform the response action.

• The air-handling system is shut off or temporarily modified to prevent the distribution of fibers to other areas in the building.

• The response action for any major fiber release episode is designed by persons accredited to design response actions and conducted by persons accredited to conduct response actions.

After a response action is implemented to manage a major fiber release episode, the final air clearance requirements must be met before the response action is considered complete.

Major and minor fiber-release episodes must be documented and included in the management plan regardless of whether the Research Leader uses in-house staff or an outside asbestos abatement contractor to implement an appropriate response action. If an outside contractor is used, be sure that the contractor's crew has been properly trained or certified before signing a contract.

Other Elements of the O&M Program

Other elements are either recommended or required by OSHA rules or related regulations.

These include:

• Notification;

• Labeling;

• Employee Protection and Medical Surveillance;

• Maintenance and Renovation Permit System;

• Special Work Practices for Maintenance Activities; and

• Special Work Practices for Renovation/Remodeling.

Notification

Once ACBM is identified or assumed to be present in a building, the Research Leader must provide an annual written notification to building occupants, and employees on the locations of asbestos-containing building materials in the buildings, the availability of the asbestos O & M plan, and recent and upcoming asbestos activities, such as abatement projects, re-inspections, etc. Other types of information to include in the notification are: what asbestos is and how it is typically used; the health effects associated with asbestos exposure; the type(s) of ACBM present in the building; the location(s) of these materials; how individuals can avoid disturbing the ACBM; how damage is recognized and to whom it should be reported;

how custodial and maintenance personnel are dealing with these materials to prevent fiber release; the asbestos-related training for custodial and maintenance personnel; the steps that will be taken to protect the health and safety of building occupants; and the name and telephone number of the Research Leader designated person responsible for asbestos-related activities in the building.

Such a notification alerts affected parties to a potential hazard in the building. Building occupants, employees, and others who are aware of the presence of ACBM are less likely to disturb the material and cause fiber release.

Notification of building occupants, employees and others is best accomplished through distributing written notices, such as through e-mail, which may be tailored to specific parties.

The designated person must document the notification process and maintain records of all notifications made.

Labeling

The Research Leader must attach a caution label immediately adjacent to any friable and non-friable ACBM and suspected ACBM that is located in routine maintenance areas (such as boiler rooms) at each Location building. Such material includes friable ACBM that was responded to by a means other than removal (e.g., encapsulation) and ACBM for which no response action was carried out.

The labels must be prominently displayed in readily visible locations (such as the door to the room), must be in print that is readily visible due to its large size or bright color, and must remain posted until the ACBM that is labeled is removed. An example of a caution label is:

CAUTION: ASBESTOS HAZARD – DO NOT DISTURB WITHOUT PROPER

TRAINING AND EQUIPMENT.

Unlike notification, labeling is not intended as a way to disseminate general information.

Instead, it is a last line of defense to prevent unprotected individuals from unknowingly disturbing ACBM.

Employee Protection & Medical Surveillance Programs

The OSHA Asbestos Standard for the Construction Industry explains when employees are required to wear a negative-pressure respirator and must be involved in a medical surveillance program. The purpose of a medical surveillance program is to determine whether or not an employee is healthy enough to wear a respirator and to detect any health changes in an employee's body resulting from working in asbestos-contaminated areas. Changes in health may indicate the onset of an asbestos-related disease.

In addition, any employee who works in an environment where fiber levels are at the Permissible Exposure Limit or higher or who wears a negative-pressure respirator as part of his or her job must participate in a respiratory protection program. The only way to determine whether these fiber levels exist is to collect air samples during projects that disturb ACBM.

In an O&M Program, the use of negative-pressure respirators will make it necessary for most custodial and maintenance workers to participate in both the medical surveillance program and the respiratory protection program. Even if fiber levels are below the Permissible Exposure Limit described above, it is strongly suggested that the Research Leader establish these programs and require that employees wear respirators any time they are likely to disturb

ACBM.

Maintenance & Renovation Permit System

One of the most difficult tasks that the Research Leader or other designated person faces is minimizing accidental disturbances of ACBM during maintenance and renovation operations.

One way that a designated person can control such disturbances is by establishing a permit system where all work orders or requests are processed through the designated person.

In a permit system, all requests for maintenance or renovation activities are given to the designated person before a work order to proceed is issued. The designated person then checks the management plan for information about the presence of ACBM where work is to be performed and physically inspects the area in question to make sure that the records reflect actual conditions. If no asbestos is present, the designated person can sign and issue the work order. If ACBM is present, the designated person can sign the work order and then either ensure that trained maintenance or renovation workers are properly equipped to handle the ACBM or dispatch an "emergency response" team to remove the ACBM. In situations where there are large amounts of ACBM, maintenance or renovation work that does not have to be done immediately should be postponed until the ACBM in the area can be removed by an accredited contractor. The permit system should be in place for all facility maintenance work conducted by the Research Leader staff, outside contractors, and outside short-term workers.

The permit system must limit ARS employees to completing maintenance activities that are classified as Class 3 or Class 4 only.

When outside contractors or short-term workers are likely to come into contact with ACBM in a building, they must be notified of the locations of ACBM or suspected ACBM in the building. This notification should be documented. These workers should have documentation of appropriate training, in case they disturb ACBM during their work.

Note that State licensing requirements vary.

Special Work Practices for Maintenance Activities

In buildings where ACBM is present, routine maintenance activities, such as work on light fixtures, plumbing fixtures and pipes, air registers, HVAC ducts, and other accessible parts of a building's utility systems, can disturb ACBM and raise levels of airborne asbestos. As a result, maintenance workers should be instructed not to perform any maintenance work that could disturb ACBM unless they are appropriately trained and use specific work practices.

These work practices should be tailored to reflect the likelihood that an activity will disturb the ACBM and cause fibers to be released. In determining which work practices should be followed, activities should be placed in one of four categories:

• Contact with ACBM Unlikely -- In some buildings with ACBM, many routine maintenance activities can be conducted without contacting the ACBM. Changing a light bulb in a fixture that has asbestos-containing acoustical plaster nearby can usually be performed without jarring the fixture, for example. In such situations where contact with ACBM is unlikely, the only precaution other than normal care generally necessary is to ensure that respirators and a HEPA vacuum are available if needed. These do not have to be taken to the site of the project; they should just be available at a known location in the building.

When maintenance is performed in parts of the building that are free of ACBM, no special precautions are usually necessary. An exception would be work in an area containing no ACBM that causes vibrations to be transferred to a location where ACBM is present.

• Accidental Disturbance of ACBM Possible -- Where routine maintenance and repair activities are conducted on fixtures or system parts that are located near friable ACBM, maintenance workers may unintentionally disturb the ACBM and release asbestos fibers.

Maintenance work on ventilation ducts in an air-handling room where asbestos fireproofing is on the structural beams could accidentally disturb the fireproofing, for example.

• Disturbance of ACBM Intended or Likely -- Some maintenance and repair activities will make ACBM disturbance almost unavoidable. Installing new sprinkler or piping systems will make it necessary to hang pipes from structural members or from the ceiling, and if the beams or ceilings are insulated with ACBM, the ACBM will be scraped away to install hangers. Similarly, pulling cables or wires through spaces with ACBM or ACBM debris is likely to dislodge pieces of the ACBM or disturb ACBM debris and dust. Any time ceiling tiles are moved to allow for entry into the space above a suspended ceiling, settled dust on top of the tiles will be recirculated into the air. If the beams or decking above the ceiling are covered with ACBM, the dust is likely to contain asbestos fibers.

A designated person should not allow such intentional disturbances of ACBM to proceed in an uncontrolled manner. The designated person should ensure that the elements required under the OSHA Asbestos Standard for the Construction Industry are followed.

• A Large Amount of ACBM Will be Disturbed -- If the maintenance work is part of general building renovation, federal regulations may require that ACBM be removed before the project begins. Even if smaller amounts of ACBM are to be disturbed, building owners should consider removing all ACBM from the area of the building where the maintenance work is planned. Typically, an outside abatement contractor would be hired for the removal project before the maintenance work begins. If the Research Leader decides to use its own staff to remove the ACBM, these workers must be fully trained and accredited in asbestos abatement.

Maintenance of Vinyl Asbestos Tile

(Revised from a "Guidelines for the Maintenance of Asbestos-Containing Floor Coverings" developed by Rhode Island Department of Health and the Environmental Protection Agency, New England)

Vinyl Asbestos Tile (VAT) is the most prevalent source of asbestos containing material in our buildings and most likely will be for years to come. Although VAT is considered non-friable, the frictional forces exerted on these materials during routine floor-care maintenance operations can release asbestos fibers.

The principle types of floor covering maintenance performed routinely on resilient floor tiles include:

1) spray-buffing and dry burnishing; and

2) wet scrubbing and stripping followed by refinishing.

The following are guidelines on the maintenance of asbestos-containing floor coverings.

When properly implemented, these guidelines should help you reduce the potential for the release of asbestos fibers into the air. [You may want to keep a copy of these guidelines in the Operations and Maintenance section of your Asbestos O & M Plan.]

Stripping of Vinyl Asbestos Floor Coverings

Training: Custodial and maintenance personnel who are responsible for the care and maintenance of asbestos containing floor coverings must be thoroughly trained to safely and properly operate the machines, pads and floor care chemicals used at the facility.

Frequency of Stripping: Stripping of vinyl asbestos floor coverings should be done as infrequently as possible (e.g., once per year maximum and preferably when the building is unoccupied). Excessive stripping of floors using aggressive techniques will result in increased levels of asbestos fibers in the air.

Prior to Stripping: Prior to machine operation, apply an emulsion of chemical stripper in water to the floor. Use a mop to soften the wax or finish coat.

Stripping Operations: When stripping floors becomes necessary, the machine used for stripping the finish should be equipped with the least abrasive pad as possible (black pads are usually the most abrasive and the white pad the least abrasive). Consult with your floor tile and floor finish product manufacturer for recommendations on which pad to use on a particular floor covering. Incorporate the manufacturer's recommendations into your floor maintenance work procedures.

The machine used to remove the wax or finish coat should be run at a low rate of speed (i.e., ranging between 175-300 rpm) during the stripping operation. There is a direct correlation between machine speeds and the release of asbestos fibers from asbestos containing floor coverings. The higher the machine speed the greater the probability of asbestos fiber release.

Never perform dry stripping. Always strip floors while wet. Do not operate a floor machine with an abrasive pad on unwaxed or unfinished floor containing-asbestos materials.

Consult with floor tile and floor finish product manufacturers concerning specific or unique problem(s) on the maintenance of your floors.

After Stripping: After stripping and before application of a high solids floor finish, the floor should be thoroughly cleaned, while wet and preferably with a Wet-Vac HEPA filtration vacuum system.

Finishing of Vinyl Asbestos Floor Coverings

Use of Sealer and Solids Finish: Prior to applying a finish coat to a vinyl asbestos floor covering, apply 2 to 3 coats of sealer. Continue to finish the floor with a high percentage solids finish.

It is an industry recommendation to apply several thin coats of a high percentage solid finish to obtain a good sealing of the floor's surface, thereby minimizing the release of asbestos fibers during finishing work.

Spray-Buffing Floors: When spray-buffing floors, always operate the floor machine at the lowest rates of speed possible and equip the floor machine with the least abrasive pad possible. A recent EPA study indicated that spray-buffing with high-speed floor machines resulted in significantly higher airborne asbestos fiber concentrations than spray-buffing with low speed machines.

Burnishing Floors: When dry-burnishing floors, always operate the floor machine at the lowest rate of speed possible to accomplish the task (i.e., 1200-1750 rpm), and equip the floor machine with the least abrasive pad possible.

Cleaning After Stripping & Sealing Floors: After stripping a floor and applying a new coat of sealer and finish, use a wet mop for routine cleaning whenever possible. When dry mopping, a petroleum-based mop treatment is not recommended for use.

Maintenance During Winter

During the winter months when sanding and / or salting of icy parking lots becomes necessary, it is an industry recommendation that matting be used at the entrance way to the building and inside the doorway where feasible. This would significantly eliminate the scuffing of floors by abrasive sanding materials brought into the building on the shoes of building occupants. More frequent wet mopping and dry mopping of floors should be performed during the winter months to minimize damage to the floors.

The same recommendations holds true of buildings located in areas where occupants could track sand into the building.

Additional Precautions

Conditions of Glides: Check to see if chair and desk glides are in good condition and replace where indicated. Worn glides can gouge the floor coverings and possibly cause asbestos fiber release.

Parking Lot / Walkway Maintenance: During the winter months, have parking lots and walkways swept to avoid tracking salt and ice-melting compounds into the building by occupants. These materials can cause severe scuffing of floor coverings and lead to the release of asbestos fibers into the building(s).

Use of Mats: Where feasible, use mats at entrance ways to protect against possible scuffing of floor covering(s), etc. from salt and ice-melting compounds and from sand.

Special Work Practices for Renovation / Remodeling

Building renovation or building system replacement can cause major disturbances of ACBM that are beyond the scope of this O&M Program. Moving walls, adding wings, and replacing heating or air conditioning systems are likely to involve breaking, cutting, or otherwise disturbing ACBM that may be present. It is highly recommended that ACBM that may be disturbed be removed before any of these activities are begun. The Location Facility Manager may be required to remove the ACBM if the amount of ACBM that is likely to be disturbed exceeds the threshold amounts of 160 square feet or 260 linear feet established by the National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations.

Although remodeling projects change the building structure less dramatically than renovation projects, disturbances of ACBM are still possible. When a remodeling project involves direct contact with ACBM (such as painting or wallpapering over ACBM), the O&M procedures described in § 763.91(d) of the AHERA Rule must be followed. If the work to be done will make the material friable, the work must either be limited to small-scale, short-duration or be treated as a response action.

Handling and Disposing of Asbestos Wastes

The amount and type of asbestos present both determine whether the Research Leader must notify EPA (or delegated states) and what procedures that the Research Leader must follow to control asbestos emissions. If the amount exceeds the regulatory threshold, then a written notification must be submitted ten working days prior to any asbestos stripping or removal operation or demolition operation. EPA regulations (along with state and local requirements) provide detailed instructions on the handling, transport, and disposal of asbestos materials. This includes emission control methods (such as wetting and leak proof wrapping), labels on the containers, recordkeeping and a trained representative on-site. Waste must be disposed of at a site meeting federal, state and local requirement. For a site in your area, contact the local public health department.

Summary Key Points About the Operations and Maintenance Program

An O&M Program must be implemented whenever any friable ACBM is present or assumed to be present in a building or whenever any non-friable ACBM or assumed non-friable ACBM is about to become friable as a result of activities performed in the building. Unless the building has been cleaned using similar methods in the previous 6 months, all areas of a building where friable ACBM, friable suspected ACBM assumed to be ACBM, or significantly damaged TSI ACBM is present must be cleaned at least once after the completion of the inspection and before the initiation of any response action, other than O&M activities or repair. Specialized work practices and procedures must be followed for any O&M activities disturbing friable ACBM. When a fiber release episode occurs, the work practices that must be followed depend on whether the episode is minor or major in nature. A minor fiber release episode consists of the falling or dislodging of 3 square or linear feet or less of friable ACBM. A major fiber release episode consists of the falling or dislodging of more than 3 square or linear feet of friable ACBM. Once ACBM is identified or assumed to be present, the Research Leader should start a notification and warning program to alert affected parties to a potential hazard in the building and to provide basic information on how to avoid the hazard. The Research Leader is required to attach a warning label immediately adjacent to any friable and non-friable ACBM and suspected ACBM that is assumed to be ACBM that is located in routine maintenance areas. Where employees work in areas where fiber levels exceed Permissible Exposure Limits or are required to wear pressure respirators, the Research Leader must establish medical surveillance and respiratory protection programs. A designated person can minimize accidental disturbances of ACBM during maintenance and renovation activities by establishing a permit system that calls for all work orders and requests to be processed through the designated person. The specific work practices that must be followed when routine maintenance activities are being conducted depend on the likelihood that the activities will disturb the ACBM and cause fibers to be released.