OFPM Asbetos-containing-material-policy-05012021_Official.pdf

Effective: 1 May 2021 Page 1 of 6

OFFICE OF THE CHIEF FACILITIES MANAGEMENT OFFICER

Procedure # CFMO – 2021 – XXX

Title: OFPM Asbestos Containing Material (ACM) Abatement Policy

SUBJECT: PROCEDURES FOR ASBESTOS CONTAINING MATERIAL (ACM) ABATEMENT

Ref: U.S. Environmental Protection Agency, National Emission Standards for Hazardous Air

Pollutants (NESHAP) – 40 CFR Part 61.

U.S. Occupational Health and Safety Administration (OSHA), General Industry

Standard for Asbestos – 29 CFR Part 1926.1101.

Code of Maryland Regulations (COMAR) 26.11.21 – Control of Asbestos

Colorado Department of Public Health and Environment (CDPHE), Regulation #8, Control of Hazardous Air Pollutants, Asbestos.

OFPM Asbestos Management Program

I. PURPOSE: To establish a written policy and common procedures for contracting asbestos containing material abatement for assigned requirements.

II. POLICY: It is the policy of OFPM to provide complete and usable construction projects while ensuring a safe workplace for NIST personnel, visitors, and contractors including projects containing ACM. Work shall be in accordance with Code of Maryland Regulations COMAR 26.11.21 – Control of Asbestos, Colorado Department of Public Health and Environment, Regulation #8, Control of Hazardous Air Pollutants, Asbestos and applicable Occupational Health and Safety Administration (OSHA) for training and exposure requirements, Environmental Protection Agency (EPA) notification and methodology and the Department of Transportation (DOT) transportation and disposal requirements.

III. PROCEDURE: The following procedures shall be used for all requirements/work orders/contracts within OFPM, unless otherwise specified by an OFPM group leader or higher.

A. Asbestos Containing Material (ACM) Identification

1) Upon receipt of a work order or requirement assignment, the assigned OFPM employee shall review the scope of work for the potential of impacting ACM with OFPM safety personnel in accordance with form 899. The review will include, but not be limited to, the following elements:

i. Equipment/infrastructure being demolished and discarded such as:

a. Flooring

b. Ceiling materials

c. Piping and ductwork insulation (exterior & interior)

d. Fire wrapping

e. Fire proofing (i.e. – on joists)

f. Caulking/Adhesive materials

g. Fume Hoods and exhaust systems

h. Wall systems/Joint Board and Finishes

i. Electrical components

j. Roofing Materials

k. Interior Finishes and Components

l. Thermal System Insulation/Building Insulation

ii. Identification of equipment/infrastructure to be reused

iii. Extents of area of disturbance to include utilities originating out of the immediate project area.

iv. Identify any construction activities to occur above the ceiling to include running utilities

v. Identify any work in the attic and service closets

vi. New equipment/infrastructure to be installed

B. OFPM Safety Personnel Identification Report

After consultation with the project manager, OFPM Safety personnel will provide a report to the requesting project manager within 5 days that will identify any ACM. If any ACM is identified, the extent and the amount of the ACM will be delineated. If OFPM Safety does not have the necessary documentation to verify the presence or absence of ACM in the project location, an asbestos survey will be initiated by OFPM Safety. The report will be provided to the project manager, the employee performing the work and the supervisor of their team.

The assigned project manager shall be responsible for ensuring that OFPM Safety personnel have received this request and for verifying inclusiveness of the findings of this report as it pertains to the goals of the project. The extent of the review is to ensure that all scope elements and construction extents are addressed and evaluated for completeness.

All information shall be forwarded unedited to the designer and/or the construction contractor including a clear statement that additional sampling or investigation is required by OFPM or the Contractor to adequately delineate the ACM in the work area.

C. Asbestos Containing Material (ACM) Removal (Contracting)

1) OFPM employees will contract the removal of ACM, as follows:

i. For contract constructions projects, ACM abatement will be included with the overall construction contract requirements (procurement package with 02 8213 Asbestos Remediation) with project manager taking the lead and OFPM Safety assisting by participating in preconstruction document submittals, project observations and independent clearances in accordance with applicable regulatory guidance. With this method, the OFPM employee and assigned project manager accept responsibility for ACM abatement and compliance through contracting with qualified and thoroughly vetted contractors. See section III F items 1 - 5 for oversight details.

ii. For facility support projects, such as internal OFPM Gaithersburg shop projects, an ACM abatement task order may be prepared by the assigned project manager (with the help if OFPM Safety) against an existing NIST asbestos abatement IDIQ contract held by OFPM Safety. With this method, there would be a construction procurement package and a second procurement package for ACM abatement would be separately awarded by AMD against the ACM abatement IDIQ contract. Using the method, the OFPM Safety accepts responsibility for ACM abatement and compliance.

See section III F item 6 for oversight details.

D. Asbestos Containing Material (ACM) Abatement Design

1) For contract designs, the contract designer shall obtain and review any available ACM Identification report(s) with the assistance of the assigned project manager. The assigned project manager shall ensure the contract designers incorporate NIST standard asbestos abatement specifications (02 8213 Asbestos Remediation) and applicable regulatory requirements in the construction documents. This specification along with the drawings and any subsequent additional investigations shall identify the ACM delineated in the report provided by the OFPM Safety personnel

2) In the event of an in-house design, the assigned project manager shall include in the contract any technical requirements noted by the OFPM Safety Personnel such as ACM Identification report in the design package.

In addition to the ACM Identification report, the NIST standard asbestos abatement specification (02 8213 Asbestos Remediation) shall be included with the procurement package.

3) OFPM Safety personnel shall be part of the review during the design process. OFPM Safety personnel will review and initial off on ACM and non- ACM construction requirements specified within all designs. The design is only considered complete after this review and initialing process. Design documents containing ACM abatement will not be sent to AMD without this review.

E. Procurement Package’s Requirements for ACM Abatement (non-IDIQ Contracts)

1) Procurement package in which the construction contractor is performing

ACM abatement activities shall have contractor evaluation criteria. The evaluation criteria shall be as follows:

i. The Contractor performing asbestos work must supply past experience showing three commercial NESHAP size project references completed within the last 3 years. Also, the General Abatement Contractor (GAC) shall have at least 3 years of abatement experience within the least three years and no Notice of Violations within that time frame. Preferably, Federal or State project, but will accept any commercial project reference.

Upon award, the contractor selected asbestos subcontractor is required to demonstrate successful completion of at least three comparable jobs and provide the following upon NIST request:

a. References, including

• name,

• address and

• telephone number of contact person and

• email address

b. project description including type and extent of work,

c. dates started and completed,

d. location,

e. information on overruns (if any),

f. citations (if any),

g. terminations and legal proceedings (if any),

h. Include air monitoring data demonstrating compliance with regulations regarding monitoring/analysis requirements.

F. ACM Abatement Oversight

1) The OFPM Safety involvement may vary based upon the duration and extent of abatement anticipated. The following tasks are defined as minimum activities unless detailed in the chosen specification package.

i. The assigned construction project manager will forward contract awards containing ACM abatement and health and safety plan to OFPM Safety personnel.

ii. The assigned project manager will invite OFPM Safety personnel to the notice to proceed (NTP) meeting.

iii. The assigned project manager shall treat all ACM submittals by the contractor as they would other submittals, i.e. it this their responsibility to

a. receive it,

b. review it for contract compliance to the best of their ability, and then

c. forward it to OFPM Safety personnel for review, comment, and action. The OFPM project manager shall facilitate and coordinate timely review and comments back to the contractor by NIST.

involve:

iv. The assigned project manager shall coordinate the involvement of

OFPM Safety personnel who shall assist in the oversight of asbestos contractors and/or subcontractors (license holders) who are abating ACM, including final clearance air monitoring.

Coordination shall involve:

o Prior to NTP and constantly during the project, verifying that all workers and supervisors possess a current Maryland Department of Environment or the State of Colorado asbestos certifications. Verifying that the contractor’s employees hold valid medical evaluations and respirator fit tests submitted during the contract evaluation phase are the same employees performing the work.

o Routinely keeping the NIST OFPM Safety personnel abreast of the schedule related to ACM abatement activities.

o OFPM project manager shall send notices to the building occupants for construction activities via approved OFPM communication methods.

o OFPM employee or project manager, in coordination with OFPM Safety personnel, shall verify that the contractor has either posted and removed State Agencies mandated asbestos notifications and warning notices or provided the notifications and warning notices to OFPM Safety for posting/removal.

o The contractor shall make all required State and or Agency Notifications. The PM shall require copies of all Notifications and will provide a copy to OFPM Safety.

o OFPM Safety personnel may provide daily input to the OFPM project manager on ACM abatement activities in order to document the GAC’s performance. These reports should be included in the General Contractor’s (GC’s) daily reports.

o OFPM Safety personnel will approve the final clearances related to the conclusion of ACM construction activities to ensure the contractor is in compliance with all State and Federal regulations. OFPM Safety personnel shall furnish the approved final clearances to the project manager in writing.

2) In the event an OFPM employee prepared a stand-alone task order against the IDIQ ACM contract, an OFPM Safety person will be assigned the project manager. OFPM Safety group leader will assign the project manager.

G. ACM Abatement Training

1) OFPM employees and project managers who are including ACM abatement in the overall construction contract requirements will take the Asbestos Awareness Training annually. Additionally, these individuals will be required to attend an OFPM project manager ACM Abatement Process training given by OFPM Safety.

IV. EFFECTIVE DATE: This instruction is effective as of the date indicated and will remain in effect until superseded.