36E77619R0091-005.pdf

ASBESTOS CONTAINING MATERIALS (ACM)

OPERATIONS AND MAINTENANCE (O&M) PLAN

VETERANS AFFAIRS MEDICAL CENTER

for

VISN 1

Project No. 2009023.003

July 13, 2011

5 Alfred Circle Bedford, MA 01730-2318

Telephone: (781) 275-6050 Toll Free: (800) 877-6050 Facsimile: (781) 275-5651 info@mabbett.com www.mabbett.com

© 2019, Mabbett & Associates, Inc.

http://www.boston.va.gov/about/ mailto:info@mabbett.com http://www.mabbett.com/

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ACKNOWLEDGMENT

This Asbestos Containing Materials (ACM) Operations & Maintenance (O&M) Plan was prepared for the U.S. Department of Veterans Affairs, New England Healthcare System (VISN 1), Veterans Affairs Medical Center (VAMC) located in Brockton, MA in accordance with an established scope of work as defined in Contract Number VA241-P-1653. The information presented herein is based on the facts and information conveyed to or received by Mabbett & Associates, Inc. (M&A) during the preparation of this Plan. If any of the information provided to M&A that was used in preparing this Plan is incorrect, incomplete, or subject to change, M&A would wish to alter its opinion(s) accordingly. In addition, the professional opinions and information contained in this report are based solely on the requirements of the applicable regulations and technical data as known to M&A as of the date of this Plan and considered applicable to this Plan.

This O&M Plan was prepared by the following Mabbett & Associates, Inc. personnel:

MABBETT & ASSOCIATES, INC.

BY:

Michael Delaney Project Manager Massachusetts Asbestos Inspector AI031436 Massachusetts Management Planner AP000048

This O&M Manual has been reviewed and approved by:

Robert K. McKinley, MPH, CIH, LIH Director of Industrial Hygiene Services Massachusetts Asbestos Inspector AI000314

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MANAGEMENT CERTIFICATION AND REVIEW

Management Certification

This Asbestos Operations and Management (O&M) Plan has been reviewed and approved by the Asbestos Program Manager. The facility is committed to safely managing asbestos containing materials (ACM) in accordance with applicable regulations and VA directives and local policies. The Plan is a key element of the overall asbestos management program and it will be implemented and subsequently revised as required in order to maintain its effectiveness.

Authorized Asbestos Program Manager:

Title:

Signature: Date:

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Asbestos Program Manager Review

The plan will be reviewed at least annually and when any change takes place at the facility which would necessitate a review, for example following any asbestos abatement projects or renovation projects with the potential to reveal previously unidentified ACM. If technical amendments are required as a result of these reviews, the plan will be amended within two (2) months and re-certified by the Asbestos Program Manager.

The VAMC has conducted and documented the following reviews and evaluations of this Asbestos Operations and Maintenance Plan:

Review

Date Reviewer Name/Title Signature

Revision Required?

(Y/N)

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TABLE OF CONTENTS

Description Page

1.0 INTRODUCTION

2.0 PROJECT INFORMATION

3.0 ASBESTOS BACKGROUND

4.0 INTRODUCTION TO THE OPERATIONS AND MAINTENANCE PROGRAM

5.0 IMPLEMENTING THE OPERATIONS AND MAINTENANCE PROGRAM

6.0 OPERATIONS AND MAINTENANCE PROCEDURES

7.0 O&M WORK PRACTICES AND ENGINEERING CONTROLS

8.0 INCIDENT AND EMERGENCY WORK PRACTICES

9.0 O&M SURVEILLANCE AND DOCUMENTATION

10.0 OPERATION AND MAINTENANCE PROCEDURES FOR VARIOUS ACM/PACM ...26

11.0 FUTURE O&M WORK PRACTICES

12.0 SCHEDULE

13.0 QUALIFICATIONS STATEMENT

14.0 REFERENCES

Appendix A: Forms Form 1 - Employee Notification Form Form 2 - Employee Awareness Form Form 3 - Contractor Notification Form Form 4 - Asbestos Training Documentation Form 5 - Building Inspection Form Form 6 - Building Re-inspection Form

Appendix B:

Summary of ACM Tables & Risk Categories

Appendix C:

VHA Asbestos Management Program Directive 2010-036 dated August 2010

Appendix D:

VAMC ACM Liability Report Table

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Appendix E:

CADD Plan Modification Procedures

Appendix F:

O&M Procedures

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O&M DIRECTORY

The following is a directory of the personnel involved in the VAMC’s ACM Operations and Maintenance Program. The names are listed in the order in which notifications should take place in the event of an incident or emergency involving ACM or Presumed ACM (PACM). An incident involves the sudden disturbance of ACM or PACM in a small, localized area, while an emergency involves the sudden disturbance of larger amounts of ACM or PACM.

Title Personnel/Phone/E-mail

1. Asbestos Program Manager Bryan Soltysik

857-203-6522/617-839-6705 bryan.soltysik@va.gov

2. Alternate Asbestos Program Manager Dawn Tesorero 857-364-6225/ 617-519-6575 Dawn.Tesorero@va.gov

3. Building Asbestos Coordinators/ Dan Willis FMS/Engineering Contact 857-364-5412/617-594-4189 Dan.Willis@va.gov

4. Asbestos Program Consultants Mabbett & Associates, Inc.

(800) 877-6050

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1.0 INTRODUCTION

This site-specific Asbestos O&M Plan has been prepared exclusively for the Boston, MA VAMC. This plan has been developed using a VISN 1 approved general template to help guide and direct asbestos management program activities at the facility. The VAMC staff are still required to tailor the plan, associated forms, and attachments, and procedures to best meet the needs of the facility. Areas requiring specific input from the VAMC are indicated as such.

The purpose of this Asbestos O&M Plan (Plan) is to protect VAMC employees, patients, volunteers, and visitors from unsafe asbestos exposure. This document provides guidance on in-place management of Asbestos Containing Materials (ACM) and Presumed Asbestos Containing Materials (PACM). PACM is ACM that has been reported by VAMC representatives as ACM or PACM based on historical knowledge or has been presumed to be ACM based on the experience of the inspector. The Plan includes an O&M directory, project information, a list of the identified ACM and PACM, associated risk categories, and future O&M work practices. A properly conducted O&M program can be an important asbestos control strategy. However, it is important that everyone involved in the program be trained in the O&M plan and be committed to implementing it properly.

In addition, this site-specific Plan includes: a general description of common ACM/PACM; an introduction to the O&M program; procedures for implementing the plan;

a review of routine work practices; incident and emergency work practices; guidance outlining training; inspection and recordkeeping activities; and staff, contractor and agency notification procedures.

Asbestos management guidance and templates developed by the United States Occupational Safety & Health Administration (OSHA) and/or the United States Environmental Protection Agency (US EPA) have been incorporated into this plan in cases where the VAMC did not have specific policies, procedures or documentation related to that aspect of the management of ACM/PACM. Examples of this guidance are provided in Appendix A.

VISN I has adopted an asbestos management strategy that requires that all maintenance, repair or renovation work that may impact or involve ACM/PACM be completed by a properly trained, licensed and equipped asbestos abatement contractor. VISN I staff are prohibited from conducting any activities that may disturb, damage, or negatively impact ACM/PACM including repairs of ACM/PACM or asbestos abatement activities. This O&M Plan has been developed in accordance to this policy.

2.0 PROJECT INFORMATION

The O&M plan is part of the VA VISN 1 ACM Building Survey Program. The scope of work, as defined under Contract Number VA241-P-1653, included asbestos inspections of the above listed buildings (see Section 1.0). The information provided in this Plan is reliant upon the findings of those inspections. Building inspection reports containing CADD drawings that indicate the location of ACM/PACM found on site, survey

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VAMC.

If any ACM/PACM is damaged or becomes damaged it should be repaired or removed entirely. Materials with a high potential for disturbance should be removed immediately upon discovering damage to the material especially when located in occupied areas.

The VISN 1 Risk Hazard Assessment Scale 1 – 4 is a relative indicator of the risk and need for response/remediation. (1) represents the highest priority, removal or encapsulation of damaged friable ACM or friable ACM with potential for damage from an occupied space. (2) represents removal or encapsulation of damaged friable ACM from an un-occupied space. (3) represents monitoring of damaged non-friable ACM and (4) represents the lowest priority, monitoring of ACM in good condition as part of the O&M program. The rating assigned by an Asbestos Management Planner, takes into account:

condition; friable vs. non-friable; accessibility; occupancy (e.g. continuous, intermittent or occasional and patients/staff/visitors); potential for air erosion; potential for vibration damage; potential for disturbance/damage (e.g. exposed and in an accessible location);

and potential for water damage. All identified ACM/PACM is included in the Summary Tables presented in Appendix B and includes the estimated amount and Risk Hazard Assessment Scale Rating.

All identified ACM/PACM must be removed prior to any planned renovation, maintenance, or demolition activities if ACM/PACM will be disturbed, in compliance with all Federal, state and local asbestos regulations. All asbestos waste generated during routine construction, renovation or abatement activities must be disposed of in accordance to state and federal regulations. The use or re-introduction of new ACM or PACM at VAMC facilities is expressly prohibited. The procedures set forth within are considered industry recognized O&M procedures.

3.0 ASBESTOS BACKGROUND

3.1 What is Asbestos?

Asbestos is a term used to describe a group of six naturally occurring fibrous minerals (chrysotile, amosite, crocidolite, anthophyllite, tremolite, and actinolite) found in certain types of rock formations. Of that general group, the minerals chrysotile and amosite are commonly found in building products.

3.2 Asbestos Uses in Buildings

Asbestos has been used extensively in buildings throughout the world as a component in fireproofing, insulation materials, floor coverings, roofing materials, and as reinforcement for plaster binders in building products. Asbestos became a popular commercial product because of its strength, fire and corrosion resistance, and insulating qualities. In the United States, its commercial use began in the early 1900s.

Applicable regulations make a major distinction between friable and non-friable asbestos materials. Friable materials are defined in state and Federal regulations as a “material that when dry, may be crumbled, pulverized, or reduced to powder with hand pressure.”

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Friable ACM is considered likely to release fibers when damaged or disturbed and is therefore generally of more concern than non-friable materials. For example, pipe insulation, a common ACM, can easily become friable if damaged. The USEPA defines pipe insulation as non-friable if the material “has retained its structural integrity and has an undamaged protective jacket or wrap that prevents fiber release (40 CFR Part 763, Section 763.85).”

Non-friable materials such as floor tiles typically present a very limited potential for fiber release. As such, non-friable floor tile is typically of less concern from a fiber release standpoint than friable pipe insulation. However, both friable and non-friable materials may release fibers if significantly damaged and both are subject to regulation.

3.3 Health Effects

Asbestos fibers can cause serious health problems if inhaled. Three specific diseases --asbestosis (a fibrous scarring of the lungs), lung cancer, and mesothelioma (a cancer of the lining of the chest or abdominal cavity) have been linked to asbestos exposure.

These diseases do not develop immediately after inhalation of asbestos fibers; it may be 20 to 40 years before symptoms appear.

3.4 Regulatory Review

Asbestos is regulated at the Federal level by the USEPA, the Occupational, Safety, and Health Administration (OSHA), and at the state level under the Commonwealth of Massachusetts Department of Environmental Protection (DEP), the Department of Public Health (DPH) and the Department of Occupational Safety (DOS). In addition, there is a Veterans Health Administration (VHA) Directive 2010-036 entitled “Asbestos Management Program” issued August 2010. Section 14.0 contains links to the applicable standards and regulations.

Since the early 1970s, awareness of the potential health hazards associated with inhalation of airborne asbestos fibers has increased. In 1973, the US EPA enacted the National Emission Standards for Hazardous Air Pollutants (NESHAPs) which banned the spray application of asbestos-containing materials, such as fireproofing, insulation and acoustical surfacing materials. Also enacted was a no visible emissions standard for building renovation and demolition.

Because of its carcinogenic nature and because of its common use in public buildings, the US EPA mandated in the May 27, 1982 Federal Register that all public and private schools (kindergarten through grade 12) be inspected for the presence of asbestos containing materials. This was the first legal mandate requiring any type of action concerning asbestos in buildings.

On October 22, 1986, Congress passed the Asbestos Hazard Emergency Response Act (AHERA) that, among other provisions, required US EPA to develop final asbestos rules by October 17, 1987. It included inspection, testing, risk assessment, management planning including establishment of an O&M Program, and removal of ACM when warranted.

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VA facilities are public buildings and therefore must also comply with the Asbestos School Hazard Abatement Reauthorization Act (ASHARA). Congress passed ASHARA in 1992 which extended AHERA to cover public and commercial buildings.

OSHA has two applicable regulations for exposure to asbestos: VAMC’s are required to follow OSHA regulations in 29 CFR 1910.1001, Occupational Exposure to Asbestos, and 29 CFR 1926.1101, Construction Asbestos Standard, to protect employees and maintenance workers. Among other requirements, these standards mandate that building owners do the following:

• Identify and label ACM and PACM;

• Notify affected parties;

• Maintain records of notifications;

• Train housekeeping staff about the location of ACM and PACM, and anyone who may be exposed to levels of asbestos above the permissible exposure limit; and,

• Designate a competent person to oversee asbestos activities.

If ACM/PACM is found during an inspection, there is no requirement that they be addressed in a manner similar to that which Congress mandated for schools. There is an USEPA requirement to remove most asbestos containing materials, with the possible exception of roofing materials, vinyl asbestos floor tiles and linoleum, from a building prior to demolition under the asbestos NESHAP regulations. In addition, there is no Federal law requiring removal of asbestos currently in place in buildings.

The current VHA Asbestos Management Program Directive mandates compliance with the regulations cited above as well as applicable state asbestos management regulations. The Directive also requires certain actions be taken by Facility Directors, Occupational Health Providers, and Facility Management Supervisors in order to implement a comprehensive asbestos management program which helps to ensure the health and safety of VA employees, patients, volunteers and visitors from the risks associated with asbestos. Certain key elements of this directive are incorporated into this O&M Plan and a copy of the complete directive is provided in Appendix C.

4.0 INTRODUCTION TO THE OPERATIONS AND MAINTENANCE PROGRAM

4.1 Objective of the Asbestos Operations and Maintenance Program

The principal objective of the Asbestos O&M program is to minimize exposure of building occupants to airborne asbestos fibers. To accomplish this objective, an O&M program includes work practices to:

(1) Eliminate the use of any asbestos containing products by specifying asbestos-free building materials for all future construction and renovation projects. All VAMCs must ensure that no new ACM/PACM products are used or stored on campus.

(2) Monitor the condition of ACM/PACM to remain in use on site,

(3) Maintain existing ACM/PACM in good condition,

(4) Prevent further release of asbestos fibers, and

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(5) Ensure proper repair or abatement of damaged ACM/PACM found on site.

4.2 Types of Asbestos Containing Materials

For the purpose of the Asbestos O&M program, ACM/PACM is placed into three major categories:

(1) Surfacing Material: Surfacing material is ACM/PACM that is sprayed or troweled onto surfaces, such as plaster, sprayed finishes, acoustical surfaces, or fireproofing.

(2) Thermal System Insulation (TSI): TSI is ACM/PACM insulation applied to pipes, boilers, tanks, and ducts to prevent heat loss, heat gain, or condensation.

(3) Miscellaneous ACM/PACM: Miscellaneous ACM/PACM is other asbestos containing materials such as ceiling tiles, floor tiles, floor coverings, asbestos-cement (e.g., Transite) panels, asbestos siding, caulking, and roofing materials.

4.3 Types of Operations and Maintenance Projects

Generally, the Asbestos O&M program is comprised of three types of projects:

No Hazardous Contact with ACM/PACM Expected

Those projects that are unlikely to involve any direct exposure to asbestos - for instance, routine cleaning of floors (provided no ACM/PACM debris is present). The custodial and maintenance staff with proper training can generally handle these projects/tasks.

Low Impact Activities Involving ACM/PACM

Those projects which involve relatively minor contact with ACM/PACM, but do not result in any damage or disturbance may be considered by VAMC staff. Placing carpet, new sheet vinyl flooring or floor tile over asbestos-containing flooring (without removing the existing flooring) can be performed by maintenance personnel provided that they are aware of the location of ACM/PACM and are instructed not to disturb the material.

However, if these materials are to be removed, or damaged ACM/PACM requires repair or removal then these projects will require the involvement of an asbestos removal contractor.

Potential for ACM/PACM Exposure

Those projects which may cause accidental disturbance of ACM/PACM; for instance, maintenance work that may expose workers to TSI identified at the facility or removing and replacing damaged flooring material or miscellaneous materials will require the involvement of an asbestos removal contractor. VAMC staff are prohibited from initiating or conducting any asbestos abatement, repair or clean up activities. A state licensed asbestos abatement contractor will be required to complete all activities that involve the removal, repair or abatement of ACM/PACM at the VA Medical Center.

Larger, more complex projects involving the intentional removal of ACM/PACM are beyond the scope of an Asbestos O&M program and are considered asbestos abatement projects (see Section 9.0). All abatement projects will be completed by state

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In addition to the guidance above, the Asbestos Program Manager with assistance from others as needed must identify and list in the O&M Plan the specific work tasks and locations that require engineering controls, work practice controls and/or personal protective equipment to address the potential for incidental exposure to ACM/PACM or debris (e.g., entry into tile ceilings with potential for spray-on ACM/PACM debris on tile, entry into crawl space, chases or utility zones with potential ACM/PACM debris, etc.

This includes:

(a) Developing written standard operating procedures for these tasks which impact

ACM/PACM.

(b) Verifying that the controls and procedures are implemented by trained VHA employees with representative personal air monitoring for asbestos exposure.

(c) Ensuring contractors are informed of the requirements and verifying compliance.

Under OSHA regulations, these O&M procedures may require compliance with Class III (repair and maintenance) or Class IV (custodial) operations. See Section 5.5.2 for definitions of Level III and IV operations.

Sample Activities That May Require Asbestos Abatement Contractor Support

The following is a partial listing of common maintenance activities that could damage, impact or involve ACM/PACM. Note that each VISN I facility will need to review its facility and maintenance activities in order to identify and develop a complete list of activities that will impact ACM/PACM at their facility. In addition, each VISN I facility will need to hire a state licensed asbestos abatement contractor to support the completion of these types of tasks when asbestos is known or suspected to be associated with the area requiring repair or modification.

• Repair, removal or replacement of damaged asbestos floor tiles.

• Repair, removal or re-location of asbestos containing ceiling tiles.

• Repair or replacement of a pipe wrapped in asbestos TSI or asbestos joint compound.

• The opening or demolition of hard walls or ceilings suspected or presumed to contain ACM.

• The removal or repair of equipment and apparatus that contain asbestos.

• The repair or removal of doors and windows equipped with asbestos containing caulk.

• The cutting or modification of fire doors that contain ACM/PACM.

Works Tasks Requiring Engineering Controls

The following tasks have been identified by the Asbestos Program Manager (APM) as requiring engineering controls or the use of personal protection procedures to address the potential to disturb ACM/PACM:

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1. Floor tile stripping or buffing activities – use of low abrasive buffing pads and low speed on buffing equipment.

2. Work conducted above ceiling tiles labeled with an “A” indicating ACM above the ceiling or any work behind a solid wall – Engineering personnel conducting maintenance operations in this scenario must first review the O&M Plan to determine the presence and condition of ACM in or adjacent to the work area. A determination must be made as to whether or not the potential of ACM disturbance exists within the scope of work to be completed. A high risk would necessitate an abatement of ACM in the work area.

4.4 Plan Distribution

This Asbestos O&M Plan must be maintained by the Asbestos Program Manger (APM).

Each person or group of persons responsible for asbestos management, including the entire Engineering Section, will have access to an updated electronic copy of the Asbestos O&M Plan. This would include Management, Safety, Project Engineering, Engineering Maintenance and Operations, Facilities and Housekeeping. This plan should also be made available for on-site review by representatives of contractors hired to complete work activities that may impact ACM/PACM. The APM is responsible for ensuring that the plan is effectively implemented. If the APM designates someone other than himself/herself to be responsible for this plan, he/she must be competent and qualified.

5.0 IMPLEMENTING THE OPERATIONS AND MAINTENANCE PROGRAM

5.1 Asbestos Management Team’s Functions and Responsibilities

Implementation and effective on-going management of the asbestos program requires a team approach and involvement from senior management, Safety, Engineering, Facilities, Housekeeping and others. It is recommended that Medical Center Directors assign qualified individuals, including Asbestos Program Managers, to coordinate and oversee asbestos impacting activities to ensure effective management of on-going revisions of this facility asbestos survey, asbestos removal and maintenance activities.

Members of the asbestos management team should ensure that all program requirements are met with regard to regulatory requirements. The management team is responsible for the management and update of the program and for instituting a system of accountability to ensure compliance with legal, regulatory, and policy requirements pertaining to asbestos. The members of the team will ensure that accurate information concerning potential health risks associated with exposure to airborne asbestos fibers and dust is disseminated hospital-wide and that hospital personnel involved in the management and assessment of ACM receive adequate and appropriate training.

Key team members include the following:

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5.1.1 The Asbestos Program Manager (APM)

APM Qualifications

Primary and secondary Asbestos Program Managers (APM) must be appointed by the VAMC Director. These individuals will be responsible for supervising the implementation of the Asbestos O&M Plan. The APM’s must be AHERA trained/certified inspectors.

The VAMC Director can assign responsibilities to others as appropriate to support the APM’s. Proper management of ACM/PACM requires an integrated approach from Safety, GEMS, Project Engineering, Engineering Maintenance and Operations, Facilities, Housekeeping, Management and others.

APM’s Responsibilities

The APM’s responsibilities are numerous and the APM’s will act as the decision-makers on all routine, as well as emergency, asbestos-related matters. The APM’s ensure that workers are properly trained, oversee all asbestos activities, and maintain files containing asbestos records and documentation. The APM’s have the authority with concurrence from the VAMC Director to clarify, define, and assign responsibilities to other asbestos management team members. The APM’s are responsible for maintaining the latest asbestos inspections and assuring that the Asbestos O&M Plan is updated on a regular basis. The APM’s will notify the appropriate environmental regulatory agencies of any known or suspected hazardous exposure to asbestos.

The APM’s are also responsible for the planning and accomplishment of asbestos surveillances and re-inspections within the required time periods outlined in this plan.

The APM’s or qualified designee or contractor will verify the presence or absence of ACM/PACM, identify appropriate management measures (i.e., maintain in place, repair, remove, etc.), and to rank abatement activities. The asbestos survey will constantly evolve as new sources are identified and others are abated. The survey is actually an ongoing evaluation of locations and sources for ACM/PACM.

The APM’s are responsible for establishing an asbestos monitoring and maintenance program. The entire Engineering Service staff will be critical in providing support for this effort. This portion of the overall asbestos program is designed to reduce the possibility of inadvertent exposure to ACM by maintaining a surveillance and inspection system over existing locations of ACM until ultimate removal/disposal. This program includes such items as labeling ACM, training staff members including custodial and maintenance to conduct surveillance of ACM in their facilities to check for deterioration, establishing special precautions before starting any maintenance, repair, or construction activities and periodic surveillance by designated personnel. The APM’s are responsible for establishing appropriate training in asbestos identification and procedures for those personnel involved in management activities and the Asbestos O&M Program.

The APM’s will ensure that all asbestos waste is stored in a sealed and properly labeled container in a secure area. The APM’s will ensure that all waste is disposed of at a licensed facility in accordance with applicable state and federal regulations.

5.1.2 The Building Asbestos Coordinator (As Applicable)

A Building Asbestos Coordinator (BAC), such as the maintenance managers associated with each building, can be appointed to assist the APM’s. Where assigned, BACs are responsible for notifying the APM of building operations that could disturb ACM/PACM or

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A well-developed O&M Program is ineffective unless the BACs are committed to implementing it properly. The BAC should convey this commitment to key personnel involved in the building's management and operations.

5.1.3 Safety Office

The Safety Office staff will help ensure the health and safety of staff, patients and visitors; and compliance with applicable asbestos regulations and this O&M Plan. If someone from the Safety Office is not an APM, then they will provide the necessary environmental, occupational health and safety support to the APM’s. This could include training, project reviews, recordkeeping support and other responsibilities as may be assigned. Safety office staff needs to be trained by the APM’s regarding their responsibilities under this plan.

5.1.4 Project Engineering

Project Engineering is responsible for drawings specifications and cost estimates for renovation, construction, and equipment/utility site preparation projects. They maintain space utilization data and record drawings of buildings, utilities, and land. This section is responsible for the 5-year facility plan and project applications.

Project Engineering will assist in the implementation of the Asbestos O&M Plan by assuring the architects, engineers, and contractors are aware of any ACM that may be impacted by capital projects. The project engineers will be an integral part of the success of the Asbestos O&M Plan. Advanced planning with the APM’s will assure that construction and renovation activities do not disturb any ACM/PACM. Engineering staff need to be trained by the APM’s regarding their responsibilities under this plan.

5.1.5 Engineering Maintenance Section

The Engineering Maintenance Section is responsible for inspecting, testing, and maintaining buildings, water systems, natural gas systems, sewage systems, medical gas/vacuum systems, steam systems, electrical/emergency power systems, and kitchen equipment. This section is responsible for maintaining/repairing ceilings, walls, floors, casework, roofs, plumbing fixtures, lights, etc., as well as painting and controlling keys.

The Engineering Maintenance Section will assist the APM’s in performing their daily activities following the Asbestos O&M Program guidelines. Advanced planning with the APM’s regarding any anticipated construction, renovation, maintenance, or equipment repair work is crucial to the success of the program. The APM’s should be informed of any damage to ACM/PACM that is observed or when asbestos debris needs to be cleaned up. Avoid patching or repairing any damaged ACM/PACM. The Maintenance staff needs to be trained by the APM’s regarding their responsibilities under this plan.

5.1.6 Engineering Operations Section

The Engineering Operations Section is responsible for operating and inspecting, testing, and maintaining the boiler plant, chiller plant, and HVAC systems. This section is responsible for inspecting, testing, and maintaining refrigerators, freezers, coolers, and

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The Engineering Operations Section will assist the APM’s in performing his/her daily activities following the Asbestos O&M Program guidelines. Advanced planning with the APM’s regarding any anticipated construction, renovation, maintenance, or equipment repair work is crucial to the success of the program. The APM’s should be informed of any damage to ACM/PACM that is observed or when asbestos debris needs to be cleaned up. Avoid patching or repairing any damaged ACM/PCM. Operations staff needs to be trained by the APM’s regarding their responsibilities under this plan.

5.1.7 Housekeeping (Environmental Services)

Housekeeping is responsible for cleaning VAMC buildings which may contain ACM/PACM. Housekeeping activities must be performed in such a way as to minimize asbestos exposure and risk. Housekeeping will assist the APM’s in performing his/her daily activities by following the Asbestos O&M Program guidelines. The APM’s should be informed of any damage to ACM/PACM (e.g., vinyl asbestos tiles) that is observed or when asbestos debris needs to be cleaned up. Clean up of asbestos debris should not be performed by housekeeping staff. Housekeeping staff need to be trained by the APM’s regarding their responsibilities under this plan.

5.2 Cleaning

If an area needs to be cleaned due to the inadvertent disturbance of ACM/PACM, an asbestos abatement contractor must be contracted for cleaning.

The APM should help ensure that cleaning procedures for ACM/PACM outlined in the O&M Plan are followed.

5.3 Notification

The APM’s or designee will inform maintenance employees, tenants and contractors about the location and physical condition of the ACM/PACM that might be inadvertently disturbed, and stress the need to avoid disturbing the material. Informed building occupants are less likely to unintentionally disturb ACM/PACM and release fibers into the air. Notification will include an explanation of the asbestos labeling system.

The APM’s or designee will inform building occupants about the presence of ACM/PACM by holding awareness or information sessions and posting signs in common areas at the VAMC where affected occupants can see them. In addition to staff training (Section 5.5.2), the following methods will be used by the APM’s or designee to complete these notifications:

Awareness Meetings

As a minimum all housekeeping, project engineering, and engineering maintenance and operations staff shall attend an annual awareness/information session. This session will inform them of the presence of ACM/PACM in their facility and the associated control measures developed and implemented as part of the Asbestos O&M Plan.

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Employee Letter

Email or post the annual employee/tenant notification letters for the VAMC employees, tenants and contractors working at the facility. It is a simple method for conveying information describing the management of ACM/PACM within the facility (Form 1 in Appendix A is a sample template prepared for use by the APM).

Employee Asbestos Awareness Form

All employees who are likely to come in contact with ACM/PACM should sign the employee awareness form (sample Form 2 in Appendix A) including the APM’s, each engineering site manager, engineering maintenance and operations and or housekeeping employees or anyone else who may encounter ACM/PACM during maintenance or renovation.

All other personnel whose work may involve disturbing ACM/PACM should also sign the awareness form. Form 2 is a sample notification and may be modified to meet the APM’s needs. The APM’s will retain these forms on file for no less than 30 years as a critical document to support the VA in the event of regulatory enforcement or legal proceedings. Through the use of this acknowledgment form, the management of the VAMC is showing its intent to abide by USEPA and OSHA regulations.

Contractor Notification Form

OSHA regulations require facility owners to inform contractors and other outside personnel working at the facility of the presence and location of ACM/PACM.

All affected outside contractors, vendors, and others must sign the contractor notification form (sample Form 3 in Appendix A) to document that they have been advised of the presence of ACM/PACM within your facility. Where appropriate, this form may also be modified by adding a narrative or CADD drawing to provide a more detailed or comprehensive description of the ACM/PACM present in their work area. This form should be signed by the contractor's superintendent or project manager indicating that all of the contractor's workers have been informed of the presence of ACM/PACM.

ACM/PACM Labeling Procedures

Per the VHA Asbestos Management Program Directive 2010-036, labels have been affixed to asbestos containing thermal system insulation (TSI) (pipeline, tank, and boiler) wherever feasible. Where direct labeling is not feasible, an alternate means has been used. ACM/PACM is identified using alternate locations/means when labeling is not feasible (e.g. spray on, tile floors, liners, gaskets). In addition, VISN 1 requires that identified asbestos containing ceiling tiles be labeled due to friability and potential for disturbance. It is important that staff that may impact ACM/PACM are familiar with the labeling system. In summary the following ACM/PACM should labeled according to this standard:

o Thermal Surface Insulation (TSI) o Pipe insulation

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The following ACM/PACM has not been labeled: floor tile, mastic, caulking, transite, and other miscellaneous materials not listed above.

The following types of labels and signs have been used to identify ACM/PACM found present in the facility.

Piping Insulation: The label presented in Figure 1 has been attached to pipe insulation containing asbestos. Figure 1 and/or Figure 2 labels have been attached to pipe fitting insulation based on the size of the fitting. In addition, the black circle with red A labels have been posted on the ceiling tile grid in rooms at the primary door entrance to indicate that ACM/PACM TSI insulation is above the ceiling. In cases, where the pipe is inaccessible, such as due to equipment obstructions, height i.e. > 8’ foot ladder is required, isolation room with a patient, etc., then only the black circle with the red A will be utilized.

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Figure 1 Figure 2

Ceiling Tiles: Ceiling tiles that contain asbestos have been labeled by either attaching a copy of the warning label provided in Figure 1 or simply a black circle with a red A sticker.

Boiler and Tank Insulation: The label presented in Figure 1 has been attached to boiler and tank insulation found to contain asbestos.

Routine Maintenance Areas: Routine maintenance areas such as mechanical rooms, boiler rooms, pipe chases, tunnels and crawlspaces that contain asbestos containing TSI have been identified by posting with the black circle with a red A sticker (Figure 2) on the outside of each access door or hatch. Inside the hatch or door OSHA warning label has been posted (Figure 1). In boiler plants, red arrow labels and striping have been used to enhance labeling and better delineate the locations of ACM where there is both asbestos TSI and non-asbestos TSI on the same pipe run. Striping has been used to indicate the beginning or end of asbestos containing TSI and arrows indicate the direction.

Label Ordering Information: The following is a list of ordering information for the stickers shown in Figure 1 and Figure 2, as well as red pipe arrow labels:

o Figure 1 MySafetySign (MySafetySign.com)

32 Court St., STE 2201, Brooklyn, NY 11201

(800) 952-1457

Item Numbers:

• 502912 (10”x7” Vinyl)

• 502868 (10”x7” Plastic)

• 502908 (5”x3.5” Vinyl)

Description: “Danger ASBESTOS DUST HAZARD CANCER AND LUNG

DISEASE HAZARD AUTHORIZED PERSONNEL ONLY”

o Figure 2

QuickLabel Systems USA (quicklabel.com) 600 East Greenwich Ave., West Warwick, RI 02893 http://www.mysafetylabels.com/Safety-Signs/Asbestos-Fibers-Avoid-Dust/SAF-SKU-S-0101.aspx

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Sales: (877) 757-7978 o Pipe Arrows

PipeMarker (pipemarker.com) Brimar Industries, Inc., P.O. Box 467, 64 Outwater Lane, Garfield, NJ 07026 Phone: (800) 274-6271 Fax: (800) 279-6897

Sku/ Name:

• A3301/ 1XSM EX Arrows Pipe O.D. ¾” to 1¼” (Arrow size 11/8 x 4”)

• A3302/ 1SM EX Arrow Pipe O.D. 11/8” to 23/8” (Arrow size 11/8 x 4”)

• A3303/ 1EZ Arrows Pipe O.D. 2½” to 6” (Arrow size 2¼ x 6”)

• A3304/ 1LG EZ Arrows Pipe O.D. 8” to 10” (Arrow size 4 x 7”)

• A3305/ 1XLG EZ Arrows Pipe O.D. over 10” (Arrow size 4 x 7”)

Warning Signs and Restricted Areas

In order to minimize the chance for accidental entry into areas with a high risk of exposure, warning signs (Figure 3) shall be posted and access restricted to authorized personnel only in areas that are undergoing maintenance activities that may disturb ACM/PACM. This is necessary to prevent personnel, both employees and contractors, who are unaware of the presence of asbestos and its potential hazards from inadvertently disturbing ACM/PACM.

Figure 3

ACM CADD Plan Signage

Color copies of each ACM/PACM CADD plan depicting locations of identified ACM/PACM have been provided with the 2010 baseline survey to help fulfill VISN 1’s need to address notification and worker protection requirements for TSI and non-TSI ACM/PACM. Individual plans have been prepared for each floor of each building surveyed and placed in plastic sleeves for easy posting and use. The plans include the OSHA label Figure 3. The purpose of these plans is to notify staff, contractors, etc.

about the locations of identified ACM and PACM so that appropriate procedures can be followed. These plans will be maintained electronically by the Asbestos Program Manager on the Engineering S Drive and made available to all Engineering, Housekeeping, Safety and Management staff that require access.

These plans will need to be revised and updated as new ACM/PACM is identified or ACM/PACM is abated. Procedures for revising these drawings are outlined in this plan.

http://www.smartsign.com/img/lg/s/asbestos-dust-hazard-danger-sign-s-0095.gif

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Worker training will direct employees (e.g. Environmental Management Services/housekeeping, Facilities Management Service, Engineering, etc) where to find and how to read the CADD plans as well as what work/tasks need to be avoided. Such an approach is consistent with OSHA’s standard letter of interpretation dated January 24, 1996.

5.4 Employee Medical Surveillance Program

The VAMC will hire an asbestos abatement contractor to perform removal where ACM/PACM will be disturbed, removed or abated. A Medical Surveillance Program for VAMC personnel will therefore not be necessary under these conditions.

5.5 Employee Training

This section addresses the training requirements for all employees who will participate in asbestos-related activities at the VA Medical Center. In order for the asbestos management team to prepare and implement the Asbestos O&M Plan, the team members who will be actively involved in the technical aspects of the plan must be appropriately trained in accordance with all Federal and State requirements. The training requirements will vary depending on the anticipated job duties.

The APM’s will be required to attend formal training programs (e.g. AHERA Inspector) on the presence of ACM within the facility. Although not required by VHA Directive 2010-036, APMs may find the AHERA Management Planner helpful in performing their duties. Verbal notice with an acceptance signature will apply to contractors used by the VAMC prior to conducting work that will disturb the ACM/PACM. Each training program is targeted for a certain group of employees depending on their exposure to the ACM/PACM in the building.

5.5.1 Training Requirements

AHERA established a Model Accreditation Program (MAP) that describes the minimum training standards for individuals managing asbestos in schools. These training standards were extended to include public and commercial buildings when the Asbestos School Hazard Abatement Reauthorization Act (ASHARA) was enacted in 1990. In addition, VHA Directive 2010-036 mandates adherence with the AHERA standard as a result the VA Medical Center personnel will be trained in accordance to the ASHARA standard.

5.5.2 Asbestos Awareness Training Program

In-house annual Asbestos Awareness Training should be attended by all employees with limited contact with ACM/PACM. On-line training is acceptable if it meets the training requirements outlined in this O&M Plan and associated regulations. These employees include but are not limited to:

• Engineering Maintenance and Operations staff/FMS staff

• Housekeeping/EMS staff

• Other employees with minimal contact with ACM/PACM on a regular basis

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New employees must receive training within 60 days of assignment. Refresher training will be provided on annual basis. All training activities should be documented and recorded. Form 2, an employee training acknowledgement, and Form 4, a training syllabus and attendance record, are provided in Appendix A to support the tracking of in-house training efforts.

Each worker will receive a certificate of training for each level of training completed.

Copies of the training certificates will be required for the records of an asbestos abatement project.

AHERA requires that all custodial staff and maintenance workers receive from 2 to 16 hours of training depending on their work activities. The training must address the steps to be taken to avoid the release of asbestos fibers from ACM/PACM. The asbestos general awareness training for VAMC employees will include a review of the following:

a. The facility labeling and notification system used for identification of ACM.

b. The hazards of asbestos exposure.

c. Recognition of ACM/PACM types and damage.

d. Procedure for reporting damaged ACM/PACM and fiber release.

e. Access to ACM/PACM location information for assigned work areas.

f. Role of the building employees in a success Asbestos O&M Program.

The Asbestos Awareness Program is vital to the dissemination of information to employees and tenants that have minimal contact with ACM/PACM on a daily basis.

This program should be well documented, and a record of each person in attendance should be kept on file. Training should be provided in such a manner that the employees can understand the materials presented. In addition, the employee should sign Form 2 indicating that he/she understood the material presented. The trainer should complete Form 4. The training records are maintained by the APM and should be reviewed annually for completeness.

Three levels of training are recognized under AHERA for O&M programs:

Level I: Awareness Training

This training is designed for custodians and maintenance workers whose normal duties would not bring them into contact with ACM/PACM; they may, however, disturb ACM accidentally. Awareness training can range from two to eight hours in length and addresses the following topics: background information on asbestos; health effects, worker protection, facility labeling and notification system, location of ACM/PACM in the building; recognition of ACM/PACM damage and deterioration; the building Asbestos O&M program; and proper response to fiber release episodes.

Level II: O&M Training This training is designed for workers involved in general maintenance and asbestos material repair. At least 16 hours of instruction is required. The O&M training should

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