Attachment 3 - Crawl Space Asbestos Compliance Program_SEP2025.pdf

This is an Asbestos Compliance Program document established by the Atlanta Veterans Administration Medical Center (VAMC) to address occupational health and safety risks for employees entering and working in the crawl space beneath buildings A, B, and C at their Decatur, Georgia facility, where asbestos-containing materials (ACM) have been identified and remain in place.

The program implements engineering and work practice controls to maintain employee exposure to airborne asbestos fibers at or below the OSHA permissible exposure limit (PEL) of 0.1 fibers per cubic centimeter (f/cc) as an 8-hour time-weighted average. Air breathing zone sampling conducted on June 26, 2024, on VA pipefitters revealed exposures exceeding the OSHA PEL, triggering implementation of this written program. Identified ACM includes pipe fitting insulation, contaminated soil, mastic on fiberglass piping insulation, and canvas-wrapped piping insulation located in the crawl spaces beneath buildings B and C. Key program requirements include mandatory personal protective equipment (3M 6800PF PAPR with HEPA filters, Polysafe coveralls, nitrile gloves), quantitative and qualitative respirator fit testing annually, comprehensive asbestos and confined space entry training with annual 4-hour refreshers, and medical surveillance examinations for all exposed employees. The program establishes detailed procedures for entering and exiting the crawl space through designated hatch locations, requires a two-stage personnel decontamination unit with HEPA filtration at the exit, mandates proper containment and storage of asbestos-contaminated waste in leak-proof containers within secured areas, and requires extensive recordkeeping for medical surveillance, training certifications, air monitoring results, and periodic surveillance inspections at six-month intervals. The crawl space is designated a Permit Required Confined Space (PRCS), necessitating compliance with Atlanta VAMC's PRCS procedures and assessment of additional hazards including heat stress.