J5a MAF ATCT and SSC Asbestos OM Plan Aug 2024.pdf

i

FEDERAL AVIATION ADMINISTRATION (FAA)

AIRWAY FACILITIES (AF)

ASBESTOS CONTROL PROGRAM

OPERATIONS AND MAINTENANCE PLAN

Midland SSC – MAF ATCT & SSC (Co-located together)

PREPARED BY

DFW EOSH Professional, 817-858-7450

29 JULY 2024

Revised 8/22/2024 ii

Table Of Contents

1.0 INTRODUCTION

1.1 Objective

1.2 Scope

1.3 Document Use

1.4 Asbestos O&M Elements

1.5 Applicable Standards And Guidance Documents

1.6 Background And Site Description

2.0 ROLES AND RESPONSIBILITIES

3.0 NOTIFICATION

3.1 Building Occupants & Contractors

3.2 Regulatory Agencies

3.3 Signs and Labels

4.0 TRAINING

WORKER PROTECTION PROGRAM

4.2 Medical Surveillance

4.3 Personal Protective Equipment (PPE)

4.4 Respiratory Protect ion

4.5 Air Monitoring

4.6 Equipment and Supplies

5.0 WORK PRACTICES

5.1 OSHA Class I and Class II

5.2 OSHA Class III and IV

5.3 Fiber Release Episodes

5.4 Regulated Areas

6.0 ASBESTOS WORK CONTROL SYSTEM

6.1 Asbestos Work Controls/ Permits

6.2 Asbestos Work Permit Process (AWP

6.3 Pre-Construction Checklist

6.4 OSHA Class I and Class II Asbestos Operations

6.5 Asbestos Work Control System Schedule

7.0 FACILITY ASBESTOS SURVEYS

7.1 Baseline Surveys

7.2 Periodic Surveillance

8.0 RECORDKEEPING

8.1 BUILDING INFORMATION

8.2 Employee Records

8.3 Other Recordkeeping

9.0 ASBESTOS WASTE DISPOSAL

9.1 Types Of Materials

iii

9.2 Requirements For Bags, Barrels, Or Drums For Storage

9.3 Transportation Requirements

9.4 Landfill And Disposal Requirements

10.0 AGENCIES AND INFORMATION

APPENDIX A: STANDARD WORK PRACTICES, GENERAL AND JOB SPECIFIC

Note: NEA’s ( Negative Exposure Assessments) and operational Asbestos standard operating procedures (SOP’s) can be found on the MyFAA EOSH Services Group:

Asbestos Control (faa.gov) ,This link to the site provides important operational information for identification and rules for mitigation. for Asbestos. Negative Asbestos assessments. These assessments provide the guidance for the standardized work practices in appendix A

The site provides:

a) FAA orders for Asbestos remediation

b) Specifications, Standards and Control Programs

c) Standard Operating Procedures

d) Memorandums

e) Archived Documents

f) Negative Asbestos Assessments Category: General— General Work Practice 1: Tools, Equipment, and Materials Category: General— General Work Practice 2: Shut Down and Lockout of HVAC and

Electrical Systems Category: General— General Work Practice 3: Securing Area Category: General— General Work Practice 4: Critical Barriers Category: General— General Work Practice 5: Respirators Fit and Pressure (User) Seal

Checks Category: General— General Work Practice 6: Putting on Personal Protective Clothing .. 45 Category: General— General Work Practice 7: Conducting Air Monitoring During Work

Practices Category: General— General Work Practice 8: Cleaning Procedures − Wet Wiping and

HEPA Vacuuming Category: General— General Work Practice 9: Waste Handling Category: General— General Work Practice 10: Decontamination of Tools, Equipment, and The Work Area Category: General— General Work Practice 11: Worker Decontamination

APPENDIX B SAFETY CONSIDERATIONS

APPENDIX C:

PLEASE REFER TO THE ELECTRONIC WRR SYSTEM

APPENDIX D: DEFINITIONS

APPENDIX F: REFERENCES

APPENDIX G: FACILITY SPECIFIC RESPIRATORY PROTECTION PROGRAM

[INSERT LOCAL PROGRAM HERE]

iv

List of Tables

Table 1. Applicable Standards And Guidance Table 2. Asbestos Training And Certification Requirements Listed By Type Of Operation

1.0 INTRODUCTION

1.1 Objective

Federal Aviation Administration (FAA) Order 3900.19C, Occupational Safety and Health Program, Chapter 15, Asbestos Control Program (ACP), delineates policy for management of asbestos-containing materials (ACM) and presumed asbestos containing materials (PACM) in FAA facilities.

FAA Order 1050.20B, Management of Asbestos in Air Traffic Organization (ATO) Facilities, provides Airway Facilities (AF) specific requirements for the ACP. These FAA orders require that each Facility develop and implement an Asbestos Operations & Maintenance (O&M) Plan. The Asbestos O&M Plan is one of the key elements in the FAA’s ACP. It provides a responsible alternative to asbestos removal by developing a pro-active, in-place asbestos management program for existing asbestos in and around buildings.

The purpose of this MAF ATCT & SSC Asbestos O&M Plan, hereafter referred to as the “Plan”, is to provide policies, work practices and procedures that minimize the exposure of all FAA employees, FAA contractors, and visitors to asbestos fibers at this facility. This will be accomplished by the implementation of asbestos control and management practices designed and used to:

1. Maintain ACM/PACM in good condition.

2. Ensure proper cleanup of debris resulting from damaged ACM/PACM.

3. Minimize future release of asbestos fibers and ensure appropriate responses.

4. Monitor the condition of known ACM/PACM.

1.2 Scope

This Plan contains policies, work practices and procedures for FAA employees and FAA contractors performing Occupational Safety and Health Administration (OSHA) Class III and IV asbestos work and routine management of ACM/PACM in this facility.

1.3 Document Use

Appendix A to this Plan contains General Safety Considerations that should be followed when completing any of the job specific work practices; Appendix B identifies safety considerations during Asbestos removal activities; Appendix C provides applicable forms for the reports and permits referenced in this Plan; Appendix D contains definitions used in this Plan; and Appendix E lists references used to develop the Plan and for further information.

1.4 Asbestos O&M Elements

All ATO facilities with ACM/PACM must have a site-specific Asbestos O&M plan. The goal of the Asbestos O&M plan is to maintain ACM in good condition and minimize the possibility of exposure to airborne asbestos.

This is accomplished using:

a. An effective Asbestos O&M plan that includes standard operating procedures (SOPs) and work practices for Class III and IV work as defined in 29 CFR § 1926.1101.

b. Each staffed facility with ACM/PACM covered by this program must have a site specific written Asbestos O&M plan kept current and following all applicable Occupational Safety and Health Administration (OSHA), EPA, and FAA requirements.

c. For unstaffed facilities with ACM/PACM, one Asbestos O&M plan may include more than one facility as long as the information contained includes site-specific information on each facility covered by the plan.

d. Effective written Asbestos O&M plans shall contain the following:

1) Notification: A program to notify building occupants, maintenance and custodial personnel, visitors, and contractors of the location of ACM and procedures to avoid disturbance.

2) Training: Properly trained personnel are critical to achieving successful implementation of the asbestos O&M Plan objectives. The training program shall be in accordance with FAA Orders 1050.20B and 3900.19C.

3) Worker Protection: Ensuring that workers are protected from exposure to asbestos by providing personal protective equipment, respiratory protection and medical surveillance.

4) Work Practices: Work procedures established to avoid or minimize asbestos fiber release during activities affecting ACM/PACM.

5) Asbestos Work Control System: A system designed to control the activities, facility personnel, and work practices that may impact ACM/PACM within the facility.

6) Surveillance: Periodic observation of ACM/PACM to note, assess and document changes in condition.

7) Record Keeping: Documentation of asbestos related O&M activities such as:

surveillance data, asbestos O&M abatement actions, employee training, and medical and respiratory program information.

1.5 Applicable Standards And Guidance Documents

Federal and all applicable state or local regulations provide the basis for developing a facility asbestos O&M Plan. Table 1 shows the most pertinent regulations applicable to MAF ATCT & SSC. Since rules and regulations affecting asbestos management are often revised, some conflicting information may be found within the listed documents. In such cases, follow the most applicable current and more restrictive guidance. In addition to the requirements of the regulation listed in Table 1, adherence to the provisions contained in current applicable bargaining agreements concerning asbestos is required.

On August 10, 1994, a classification system for asbestos construction work was established for specific work practices and for control measures to minimize exposure to airborne asbestos. Construction work is defined as demolition, removal, alteration, repair, maintenance, installation, clean-up, transportation, disposal and storage, and is regulated by the construction industry standard. Pure custodial work is not considered a construction activity; however, there are provisions in the standards addressing custodial workers who may inadvertently come in contact with ACM. Four classes of work have been designated: with Class I work being the most hazardous and decreasing risk potential in each successive class.

• Class I asbestos work involves the removal of thermal system insulation (TSI) and/or sprayed-on or troweled-on or otherwise applied surfacing materials which are known or presumed to be asbestos-containing.

• Class II asbestos work is defined as removal of other types of ACM or presumed ACM or ("PACM") that are not TSI or surfacing materials. Examples of Class II work include removal of floor coverings and roofing materials.

• Class III work involves maintenance and repair operations where ACM's or PACM's are disturbed. For example, Class III work includes cutting away of small amounts of ACM or PACM. Waste must not exceed half filling a standard asbestos waste disposal bag (60” x 60”) to access mechanical or structural components for routine maintenance or repair.

• Class IV work consists of maintenance and custodial operations during which employees may come in contact with but would not disturb ACM or PACM and activities to clean up asbestos-containing waste and debris. Such activities may include picking up and removing loose non-friable floor tiles, Corrugated or Styrofoam ceiling tiles, dusting surfaces, mopping floors or changing a battery in a smoke detector, which is attached to an asbestos-containing ceiling.

Larger scale projects (OSHA Classes I and II) involving more complex procedures for the intentional removal of ACM are considered asbestos abatement projects. These projects require asbestos control and abatement procedures that are outside the scope of this asbestos O&M Plan.

However, information on the location of the asbestos that was removed, enclosed, or encapsulated should be used to update the building asbestos O&M files.

Table 1. Applicable Standards And Guidance

REGULATION/

GUIDANCE

TYPE

CITATION

REMARKS

NESHAP1,

Subpart M

Federal Regulation

40 CFR 61 • Regulates asbestos demolition, construction, and removal activities.

• Defines friable and non-friable asbestos as greater than 1% as determined by PLM. 2

Louisiana ERC, Title 33: Part III

State/Local Regulation

• Enforces NESHAP requirements and defines state and local waste management.

DOT Federal 49 CFR 171-173 • Hazardous materials rules.

AHERA3

ASHARA 4

Federal Regulation

40 CFR 763 • Defines procedures for handling and managing asbestos in schools.

• Sets forth training requirements of asbestos workers under the Model Accreditation Plan.

• FAA requires accredited inspectors to perform baseline surveys in accordance with 40 CFR § 763, Subpart E, AHERA, and 40 CFR § 763, Subpart E, Asbestos School Hazard Abatement Reauthorization Act (ASHARA) requirements.

FAA

FAA

Order

1050.20B 3900.19C

• Defines FAA asbestos control program.

OSHA5 Federal Regulation

29 CFR 1926.1101

29 CFR 1910.1001

• Defines exposure and excursion limits, general health and safety.

Green Book Federal Guidance

EPA 20T-2003 • Guidance on managing asbestos in-place.

Respiratory Protection

Federal Regulation

29 CFR 1910.134

29 CFR 1926.1101

• Regulations for respirator use, fit test, training.

1NESHAP: National Emissions Standard For Hazardous Air Pollutants 2PLM: Polarized Light Microscopy 3AHERA: Asbestos Hazard Emergency Response Act 4ASHARA: Asbestos Schools Hazard Abatement Reauthorization Act 5OSHA: Occupational Safety and Health Administration

1.6 Background And Site Description

MAF ATCT & MAF SSC are co-located together, was built in 1961, and is a maintained by the FAA. The facility is located at the Midland TX Airport. The facility is used to office SSC Tech Ops Personnel and Air Traffic Controller personnel.

This asbestos O&M Plan was prepared by Sammy J Herrell, cell number 318-456-2567. The asbestos O&M Plan applies to material, assumed and confirmed to contain asbestos, material identified in the facility asbestos survey and material identified during subsequent building inspections.

2.0 ROLES and RESPONSIBILITIES

1. ATO Executive-level Managers. ATO Executive-level Managers must ensure compliance with and incorporate the requirements of this order into programs and activities managed by their organizations, particularly those involving deployment of new systems and modernization projects that could impact asbestos.

2. ATO Managers. ATO Managers must:

a. Ensure compliance with the requirements of this order at all facilities with ACM/PACM within their respective organizations and facilities.

b. Ensure that their employees, contractors, and other non-Federal Aviation Administration (FAA) personnel have been informed of the presence, location, and quantity of ACM/PACM at their facility.

c. Ensure that their employees receive all necessary training as required by this order.

d. Coordinate with the Technical Operations Manager to ensure that a Facility Asbestos Coordinator (FAC) has been identified for their facility/facilities that contain asbestos.

e. Consider the impact to asbestos for all projects and work tasks within their control, particularly those involving deployment of new systems or facility modernization. Ensure that the requirements of this order are incorporated into all project planning and implementation.

f. Ensure that personnel involved with projects and activities in which building materials will be disturbed or impacted verify that an asbestos survey has been performed in all affected areas of the facility prior to the start of work.

g. Ensure written notification is provided to supervisors and bargaining unit representatives in affected areas prior to the start of asbestos projects in the facility. Coordinate with the FAC on all upcoming asbestos work to be conducted at the facility. Notify their employees of preconstruction briefings to be held prior to the start of asbestos work to be conducted at the facility.

h. Ensure review and coordination of project documents that involve disturbance of ACM/PACM.

i. Ensure that anyone performing work in ATO facilities adheres to the asbestos work permit system and that anyone performing work in facilities with ACM/PACM has a signed asbestos work permit before performing any work at the facility that will or could disturb ACM.

j. Coordinate with Project Managers/Project Initiators to ensure that asbestos abatement notifications are provided to federal, state, and local regulatory agencies as required.

k. Designate qualified personnel to prepare and sign asbestos waste shipment records. Ensure completed asbestos waste shipment records are received from the disposal site and kept on file at the facility for the duration of facility ownership. Coordinate with the FAC to ensure that they have completed their required waste disposal actions as detailed in Chapter 3, Section 5(b)(3) of this order.

l. Ensure that documentation verifying the use of asbestos-free materials for all construction and renovation projects within their organization is received and kept.

m. Ensure that incidents involving known or potential release of asbestos are thoroughly investigated, that appropriate response actions are implemented, and that all required incident reports are prepared. Ensure the FAC, Safety and Environmental Compliance Manager (SECM), Technical Operations Manager, and Bargaining Unit representatives are immediately notified of any known or potential release of ACM/PACM. Provide assistance and resources as needed in the incident evaluation.

n. For leased facilities, coordinate with the FAA real estate office point of contact and the lessor to ensure that all asbestos requirements in the lease agreement are met.

3. ATO Environmental Occupational Safety and Health (EOSH) Services Group. ATO EOSH Services Group must:

a. Designate a national ATO Asbestos Lead.

b. Serve as the Office of Primary Responsibility (OPR) to revise this order.

c. Provide asbestos technical guidance and requirements to all ATO organizations.

d. Provide resources for the overall management of asbestos in ATO facilities.

e. Coordinate with and provide technical assistance to the Office of Safety and Technical Training (AJI) on asbestos training requirements for ATO employees.

f. Develop, disseminate, and revise as necessary national ATO asbestos documents to supplement this order.

4. Technical Operations Managers. Technical Operations Managers must:

a. Designate, in writing, a FAC for the facility/facilities that contain ACM/PACM.

Maintain a current listing of all FACs and the facilities in which they are responsible.

b. Ensure that baseline and periodic surveillance of asbestos is conducted as described in Chapter 3, Section 2, Facility Asbestos Surveys, of this order.

5. ATO Project Managers/Project Implementers. ATO Project Managers/Project Implementers must:

a. Implement requirements of this order into project planning and execution.

b. Consider requirements and associated costs as early as possible in all construction, installation, commissioning, modification, and other projects managed by their organization.

c. Ensure all project employees are trained and provided with Personal Protective Equipment (PPE) as required by this order.

d. Ensure that all project contractors comply with the requirements of this order.

e. Prior to any construction project, coordinate with the FAC to determine if an asbestos survey of the affected area has been conducted. If additional samples are needed to characterize the materials in the path of the construction project, ensure that those samples are collected, and the costs are included in the project planning.

f. Coordinate project planning with the responsible, geographical ATO Manager(s), the FAC, and ATO safety and health specialist.

g. Ensure the use of the latest version of ATO Order JO 3900.57, Environment and Occupational Safety and Health (EOSH) Requirements in the Planning and Execution of Construction and Maintenance Activities at National Airspace System (NAS) Facilities, and other applicable work permits.

h. Ensure compliance with the ATO Asbestos Work Control System as outlined in this order.

i. Ensure that the costs for compliance with project specific asbestos requirements are included in all cost estimates prepared by their organization.

j. Incorporate the applicable requirements of this order and applicable federal, state, and local asbestos regulatory requirements into contract documentation, including specifications, to ensure that contractor operations comply with these requirements.

k. Coordinate with ATO managers to ensure that asbestos abatement notifications are provided to federal, state, and local regulatory agencies as required.

l. Require that all new construction, renovation and modernization projects will use asbestos-free materials and will be documented as such upon completion:

1. Ensure all new project specifications contain specific verbiage stating that no ACM will be utilized or installed during the course of the project.

2. Ensure that project specifications require the Prime Contractor to sign a statement that no ACM was used during the project.

3. If the Prime Contractor does not submit the signed statement with supporting documentation, the project implementer must have a building survey performed as dictated by Chapter 3, Section 2 of this order, with the survey and testing costs deducted from the Prime Contractor's final payment. Sampling must be performed in accordance with the AHERA sampling protocol contained within 40 CFR § 763 by an AHERA accredited asbestos inspector. Follow additional state requirements for asbestos-free certifications, if applicable.

4. If ACM is subsequently found during the sampling of the building materials, the Prime Contractor must remove and replace the ACM at their expense. In addition, the Prime Contractor must incur the costs of the original testing and/or any additional testing that is necessary.

5. Documentation regarding the Asbestos-free certification and any supporting sample results must be provided to the local ATO Manager, FAC, and SECM.

6. ATO Safety and Health Specialists. ATO Safety and Health Specialists must:

a. Serve as the geographical/organization asbestos technical point of contact and provide technical support on asbestos issues.

b. Conduct activities as required by this order.

c. Assist ATO managers with the requirements of this order.

d. Assist ATO managers in the formulation and review of asbestos budgets and requirements.

e. Coordinate with the FAC on all incidents regarding asbestos.

f. Complete training as required by this order.

7. SECMs. SECMs must:

a. Review and approve all asbestos work permits submitted to them, including Class I and Class II asbestos work permits provided by the

FAC.

b. Complete initial and maintain Asbestos Hazard Emergency Response Act (AHERA) Asbestos Supervisor and Asbestos Inspector training as specified in the Environmental Protection Agency (EPA) Asbestos Model Accreditation Plan (40 Code of Federal Regulations (CFR) § 763, Subpart E, Appendix C).

c. Assist the Technical Operations Managers in identifying facilities requiring baseline and periodic surveillance of asbestos as described in Chapter 3, Section 2, Facility Asbestos Surveys, of this order.

d. Provide assistance to the FAC in the development and implementation of the facility specific Asbestos Operations and Maintenance (O&M) Plans.

e. Provide site-specific asbestos awareness training to ATO employees, when required.

8. FACs. FACs must:

a. Serve as the designated asbestos contact for asbestos at the facility.

One person may serve as the FAC for more than one facility.

b. Review specifications and plans for all projects in the facility and determine if asbestos will be disturbed by the work.

c. Review all maintenance activities that may impact ACM/PACM to determine if asbestos will be disturbed by the work.

d. Review Asbestos Work Control System documentation submitted for projects at the facility. Review, approve, or disapprove the asbestos work permit and sign and return the documentation to the project initiator. For Class I or II asbestos work, forward documentation to the SECM for second-level approval. For Class III and Class IV asbestos work and other projects conducted at the facility, seek assistance from the SECM in the preparation of the asbestos work permit as needed.

e. Coordinate with the ATO Manager to ensure that documentation concerning asbestos waste shipments is received from the disposal site operator in accordance with Chapter 3, Paragraph (5)(b)(3) of this order.

f. With the assistance of the SECM, develop and oversee the facility-specific Asbestos O&M plan.

g. Notify the SECM and ATO Manager of any changes in the material condition of the ACM/PACM. Maintain up-to-date asbestos inspection survey reports for the facility.

h. Coordinate with the ATO Manager regarding posting of work permits, regulated area signs, ACM warning signs and labels.

i. Assist in the preparation of asbestos incident reports. Ensure that the ATO

Manager and SECM are immediately notified of any known or potential release of ACM/PACM.

j. At a minimum, receive initial and maintain AHERA O&M Worker training and Asbestos Inspector training as specified in the EPA Asbestos Model Accreditation Plan (40 CFR § 763, Subpart E, Appendix C).

k. Assist in providing site-specific asbestos awareness training to ATO employees, when required.

l. Maintain equipment and supplies for facility Asbestos O&M activities.

9. Employees. Employees must:

a. Notify their manager/supervisor and the FAC prior to conducting work that could disturb any building materials.

b. Notify their manager/supervisor and the FAC of any damaged ACM/PACM. Avoid contact with any disturbed building materials that are ACM/PACM

3.0 NOTIFICATION

The term “notification” is commonly used to cover two areas of concern. In this section, the first area concerns informing building occupants and workers of the hazards associated with disturbing asbestos. The second area concerns notifying regulatory agencies prior to disturbing asbestos during renovation/demolition projects.

Clear lines of communication with all building occupants, custodial workers, contractors, and maintenance staff is an integral part of this asbestos O&M Plan. This approach, along with information regarding the presence, location, and condition of ACM, encourages understanding that the presence of asbestos is not necessarily hazardous, and that ACM can be effectively managed in place.

3.1 Building Occupants & Contractors

(a) Building occupants shall be notified of the following:

1. The presence, location, and condition of known ACM/PACM in the facility.

2. The name and telephone number of the FAC.

3. Building occupants who may be affected by scheduled asbestos O&M projects shall be notified prior to the commencement of the project. The [FAC][SECM] is responsible for providing such notification to [supervisors][Union representatives] who then provide notification to building occupants. This notification should be made [at least 30 days] prior to the start of an asbestos abatement project. If necessary, the notification shall include notice that relocation of personnel to a location outside of the affected project area may be necessary due to potential disturbance of ACM/PACM. This notification shall include at a minimum a brief description of the areas to be impacted, scope of the project, and schedule for completion.

4. Notification of the presence of ACM/PACM to FAA Contractors should be made as far in advance of commencement of work in the facility as possible. The [FAC][Contracting Officer’s Technical Representative (COTR)/Resident Engineer (RE)][Project Manager] is responsible for notifying contractors of the locations, types, and approximate quantities of ACM/PACM present and whether or not it will be disturbed by the contractor’s work. The [RE][Project Manager] is also responsible for ensuring contract documents contain appropriate references to

ACM/PACM.

3.2 Regulatory Agencies

Some small asbestos O&M projects may be subject to regulatory notification requirements.

Notification of unscheduled removal of ACM/PACM is required if the estimated total of Regulated Asbestos Containing Material (RACM) that will be removed as part of unscheduled repair, maintenance, and renovation work during the calendar year exceeds 160 square feet, 260 linear feet, or 35 cubic feet. Notification shall be submitted by the FAC to the EPA Regional Office or Appropriate State or Local Regulatory Agency at least 10 working days prior to the start of each calendar year. The EPA Regional Office or State Regulatory Agency should be contacted to determine the correct format for this notification and the office to which it should be submitted.

3.3 Signs and Labels

a. Asbestos warning signs shall be posted at all regulated areas at such distance from a regulated area so that an employee can see them and take protective steps to avoid entering the area.

b. Signs shall be posted at the entrance to mechanical rooms/areas containing ACM/PACM into which employees can reasonably be expected to enter. The applicable provision in the Asbestos standard, 29 CFR 1910.1001, concerning the revised text of warning signs for regulated areas, may be found at paragraph 1910.1001(j)(4)(ii)(A), wherein the revised legend on the warning sign must read:

DANGER

ASBESTOS

MAY CAUSE CANCER

CAUSES DAMAGE TO LUNGS

AUTHORIZED PERSONNEL ONLY

c. Where feasible, warning labels shall be affixed to previously identified TSI or surfacing that is ACM/PACM, e.g., in areas where routine maintenance takes place and/or where there is reasonable likelihood of contact with these materials.

d. Notification of outside contractors. All contractors performing work in FAA facilities covered by FAA Order 1050.20A, Airway Facilities Asbestos Control Program shall be subject to the Asbestos Work Control System (see Appendix C, Applicable Forms).

4.0 TRAINING

1. Training and Communications.

a. Training and Briefings. ATO employees who work in facilities containing ACM/PACM must receive training at a level consistent with their level of involvement with asbestos. The asbestos training courses and instructors must meet the standards established by the EPA AHERA regulation or by FAA orders, whichever is more stringent.

b. Preconstruction Briefing. ATO employees who work in facilities containing ACM/PACM must receive a preconstruction briefing prior to any major renovation or construction projects involving Class I and Class II asbestos work. The preconstruction briefing will include the following topics:

i. Overview of the asbestos abatement project.

ii. Types and meaning of asbestos signage that will be present during the project.

iii. Special procedures that will be in effect during the project to protect ATO employees located outside the asbestos regulated work area.

c. Asbestos General Awareness Training.

i. Maintenance and custodial workers who will be working in close proximity with but will not be disturbing ACM/PACM (Class IV asbestos work) must receive this training. The training will inform these workers about the presence and location of ACM/PACM in the facility. The training will also caution these workers against disturbing these materials. Initial training must be completed before the worker's activity begins, and at least annually so long as the worker is involved with ACM/PACM.

ii. ATO employees who are not engaged in Class III and Class IV asbestos work but who work in facilities containing ACM/PACM must receive the initial asbestos general awareness training, which is two hours in length. Annually thereafter, the employees will be provided with a review of the facility-specific asbestos information.

d. Two-hour Initial Asbestos General Awareness Training. Two-hour Initial Asbestos General Awareness Training will include:

i. Background information on asbestos

ii. Health effects of asbestos

iii. Overview of asbestos regulations.

iv. Precautions for working around ACM/PACM

v. Facility-specific asbestos plans (e.g., Asbestos O&M Plan).

vi. Location and types of ACM/PACM in the facility

vii. Name and phone number of the FAC

(1) Asbestos O&M Training.

(a) Initial Asbestos O&M Training. This training is required for workers performing Class III asbestos work in accordance with the EPA AHERA regulation. Workers must complete initial training before they conduct any Class III asbestos work. This training is also required for the FAC. Initial Asbestos O&M Training will consist of 16 hours of training. In addition to the asbestos general awareness training topics listed above, initial Asbestos O&M training must include the following:

i. Federal regulatory requirements and FAA orders.

ii. Nature of operations that could result in exposure to asbestos and proper asbestos related work practices.

iii. Methods for recognizing ACM/PACM.

iv. Proper methods of handling ACM/PACM, including labeling and waste disposal procedures.

v. Respirator purpose, use, care, limitations, and fit testing.

vi. Protective clothing use and handling.

vii. The relationship between smoking and asbestos in producing lung cancer and contact information for smoking cessation programs.

viii. Hands-on exercises for techniques such as the use and maintenance of the glove bag and High Efficiency Particulate Air (HEPA) vacuum.

ix. Occupational medical surveillance program requirements.

x. Proper worker decontamination procedures.

(b) Refresher Asbestos O&M Training. Refresher training will be conducted annually, so long as the worker is involved in Class III asbestos work. The annual refresher training is required for the FAC. Refresher Asbestos O&M training must be a minimum of two hours in length.

(c) Asbestos Abatement Worker Training. Since FAA employees currently do not perform Class I and Class II asbestos work, ATO personnel are not required to complete asbestos abatement worker training. However, this training is required for contractor employees who will perform Class I and Class II asbestos work in FAA facilities.

(d) Asbestos Supervisor Training. This training is required for ATO employees responsible for the oversight and management of Class I and Class II asbestos work performed by contractors. Project Managers/Project Implementers who oversee NESHAP sized projects in staffed ATO facilities must also receive this training. The SECM must also receive and maintain this training.

(e) The initial AHERA Supervisor course is a minimum of 40 hours of training, which includes 14 hours of hands-on training. Refresher training is required annually and will be 8 hours in length

2. Asbestos Inspector Training. This training is required for all persons collecting asbestos bulk samples and performing baseline asbestos surveys in ATO facilities. The initial AHERA

Inspector course is a minimum of 24 hours of training. Annual refresher training is required and is a minimum of four hours of training.

3. Asbestos Project Designer Training. All Class I and Class II asbestos projects in staffed facilities with asbestos quantities greater than 160 linear feet, 260 square feet or 35 cubic feet at ATO facilities must be designed by an AHERA accredited Project Designer. The initial EPA AHERA Project Designer course is a minimum of 24 hours of training. Refresher training is required annually and will be a minimum of eight hours in length.

4. Respiratory Protection Training. ATO employees must receive respiratory protection training prior to using a respirator. The training must meet the requirements outlined in 29 CFR § 1910.134 and FAA orders. Employees are required to be re-trained when any of the following situations occur:

(a) Changes in the workplace or the type of respirator render previous training obsolete.

(b) Inadequacies in the employee's knowledge or use of the respirator indicate that the employee has not retained the requisite understanding or skill.

(c) Any other situation arises in which re-training appears necessary to ensure safe respirator use.

Table 2. Asbestos Training And Certification Requirements Listed By Type Of Operation

TYPE OF

PERSONNEL

INITIAL TRAINING

REQUIREMENT

ANNUAL RECERT

OR REFRESHER &

LENGTH

REGULATORY

CITATION

Maintenance And Housekeeping Supervisors, Competent, Qualified Person

16 Hour Operations and Maintenance Course

Yes

Not Specified [State/local]

FAA ORDER 1050.20A

29 CFR 1926.1101(o)(4)(ii)

Maintenance Workers

16 Hour Operations & Maintenance Course.

Requirements Are Relaxed When Only One Generic Category Of Building Material In OSHA Class III Work Is Done.

Not Specified In 1050.20 A

29 CFR 1926.1101(k)(9)

Maintenance & Custodial Workers

2 Hour Asbestos Awareness Course

2 Hours

29 CFR 1910.1001 (j)(7) 29 CFR 1926.1101(k)(9) [State/local]

ATO Safety and Health Specialists

40 Hours Asbestos Abatement Contractor/Supervisor Course

Yes 8 Hours

FAA ORDER 1050.20A

29 CFR 1910.1001 (o)(4)(i) 29 CFR 1926.1101(o)(4)(i)

40 CFR 763.92

40 CFR 61 Subpart M

ATO Safety and Health Specialists

40 Hours Asbestos Abatement Contractor/Supervisor Course

Yes 8 Hours

FAA ORDER 1050.20A

29 CFR 1910.1001 (o)(4)(i) 29 CFR 1926.1101(o)(4)(i)

40 CFR 763.92

40 CFR 61 Subpart M

ATO Safety and Health Specialists

24 Hours Asbestos Abatement Designer Course

Yes 8 Hours

40 CFR 763.92

WORKER PROTECTION PROGRAM

A worker protection program includes medical surveillance, personal protective equipment, personal exposure monitoring, and engineering controls. Engineering controls are the preferred method for worker protection. Contractors conducting maintenance and repair operations will notify the FAC, in writing, that they have an asbestos worker protection program in place. Additionally, OSHA regulations require a written respiratory protection program whenever an asbestos O&M Plan specifies that asbestos workers wear respirators, or where respirators are made available to workers. The FAC, with assistance of the SECM, must verify and approve these programs prior to allowing any asbestos work to begin.

4.2 Medical Surveillance

1. The ATO must ensure medical surveillance is provided for all ATO employees who have been issued a respirator in accordance with 29 CFR § 1926.1l0l(m)(l)(ii) and (m)(2).

2. Prior to wearing a respirator for any reason, the employee must first receive an occupational medical evaluation. This medical evaluation must be performed before an employee's respirator fit test or any asbestos operation that requires the use of a respirator.

3. In addition to the requirements identified in this order, the ATO must follow the occupational medical surveillance requirements in FAA Order 3900.19, Occupational Safety and Health Program based on OSHA Asbestos standards for medical monitoring.

a. Employees engaged in OSHA Class III asbestos work for 30 or more days per year.

(Employees engaged in OSHA Class III asbestos work for less than 30 days a year and who are required to wear a negative pressure respirator, will undergo medical surveillance, which will be limited to determining the worker is physically able to perform and wear respirators.)

b. Employees exposed at or above the OSHA permissible exposure limit (PEL) of 0.1f/cc or excursion limit (EL) of 1.0 f/cc for a combined total of 30 or more days per year.

c. Employees who are required to wear respiratory protection.

d. Employees involved in OSHA Class IV asbestos operations requiring the use of a respirator shall at a minimum be required to complete the medical questionnaire, as outlined in 29 CFR 1910.134 (e), Medical Evaluations, and as supervised by a physician or other licensed health care professional.

4.3 Personal Protective Equipment (PPE)

1. Employees performing OSHA Class III asbestos work and OSHA Class IV asbestos work within a regulated area shall be provided with and required to wear disposable full body coveralls with hoods and footwear. The coveralls shall be worn only once and disposed of in bags labeled as asbestos-containing waste. An evaluation of employee exposure to heat stress should be performed

2. Whenever employees wear PPE for extended periods or work in hot or high humidity environments

3 . Depending on specific site conditions and the work being performed, the employee may use other PPE as needed. These items may include, but are not limited to hard hats, safety glasses, gloves, hearing protection, safety shoes as required by 29 CFR 1910.132.

4. If the employee is using a respirator, PPE must not impede the fit of the respirator

5. Employees must receive training in the proper use and limitations of the required PPE

4.4 Respiratory Protection

1) OSHA asbestos regulations require the use of engineering controls as the preferred method to eliminate employee exposure to airborne asbestos. The ATO will provide respirators during the implementation of engineering controls, when engineering controls are not feasible, or if the engineering controls do not provide sufficient control of airborne asbestos exposure.

2) Each facility with ACM/PACM, which requires the use of respirators in their Asbestos O&M plan, must have a written Respiratory Protection program in accordance with 29 CFR § 1910.134, 29 CFR § 1926.1101, 29 CFR § 1910.1001 and applicable FAA orders

The written Respiratory Protection Program document must be site-specific and must be maintained at the facility. Employees who are required to wear a respirator must be familiar with the facility Respiratory Protection Program. These employees must receive training in the use of respirators in accordance with Chapter 3, Section 9, Training and Communications, of this order.

ATO employees must wear respirators in the following cases:

a. During all Class III and IV asbestos work where employee exposure exceeds or has a reasonable possibility of exceeding the OSHA Permissible Exposure Limit (PEL) or Excursion Limit (EL).

b. During Class III asbestos work for which a negative exposure assessment (NEA) has not been conducted.

c. During all Class III jobs where Thermal System Insulation (TSI) or surfacing ACM/PACM is being disturbed.

d. As mandated in the facility Asbestos O&M Plan.

a. Respirator selection must be made using the following criteria:

e. Federal regulatory requirements and FAA orders.

f. Level of employee exposure or expected exposure to airborne asbestos fibers as based on air monitoring data, type of asbestos material, and work tasks to be performed.

g. Each respirator's protection factor as defined by OSHA regulations or quantitative fit testing procedures.

h. The employer must select negative pressure respirators from a sufficient number of models and sizes so that the respirator is acceptable to, and correctly fits the user.

i. If respiratory protection is required, the employee will be provided with a tight fitting Power

Air Purifying Respirator (PAPR) instead of a negative pressure respirator when the employee chooses to use this type of respirator and if the PAPR respirator will provide adequate protection to the employee.

3) Any employee who is issued a negative pressure respirator must be given a quantitative or qualitative fit test at the time of initial respirator issue, when there are changes in the employee's physical condition that could affect respirator fit, and at least annually thereafter. The employee must perform positive and negative pressure fit checks prior to each respirator use.

4) No ATO employee will be allowed to use a respirator without prior, required medical approval and training. Employees are required to receive annual occupational medical evaluations to determine if they are medically able to continue using a negative pressure respirator

4.5 Air Monitoring

Air Monitoring will be conducted during routine asbestos O&M activities and asbestos-related incidents. The FAC and/or SECM will ensure that qualified personnel conduct the air monitoring.

The following minimum requirements will be followed when collecting air samples:

A. Personal Air Sampling. Personal air sampling must be performed as required by 29

CFR

§ 1926.1101. Samples must be analyzed using Phase Contrast Microscopy (PCM) in accordance with the most current version of National Institute of Occupational Safety and Health (NIOSH) Method 7400. OSHA requires personal sampling to document employee exposure and determine if respirators provide a sufficient protection factor.

The ATO must perform exposure assessments for ATO employees performing Class III and Class IV work. These exposure assessments must be performed in accordance with 29 CFR § 1926.1l0l(f). Affected employees and/or their designated representatives must be provided an opportunity to observe this monitoring. The sampling must be conducted under the direction of the OSHA competent person.

1) Initial Exposure Assessment. Exposure assessments must be performed at the beginning of each job involving Class III work. In addition, an initial exposure assessment will be required for Class IV asbestos work if the work will be performed within a regulated area. The exposure assessment must include collecting samples under work conditions having the greatest potential for exceeding the OSHA PEL or EL.

2) Negative Exposure Assessment (NEA). For Class III and Class IV asbestos projects, an NEA is useful in that it allows the ATO to perform projects using previous initial exposure data. A valid NEA has been established when:

a) Objective data is gathered demonstrating that the product or material containing asbestos minerals, or the activity involving such product or material, cannot release airborne fibers in concentrations exceeding the PEL and EL under those work conditions having the greatest potential for releasing asbestos, or;

b) Workplace conditions closely resemble the process, type of material, control methods, work practices, environmental conditions, and employee training of an asbestos job monitored within the past 12 months. Documentation must address these six areas for the NEA and must be available at each new worksite, or;

c) The results of initial exposure monitoring of the current job made from breathing zone air samples are representative of the 8-hour time weighted average (TWA) and 30-minute short term exposures of each employee covering operations which are most likely during the performance of the entire asbestos job to result in exposures over the PELs.

d) Asbestos-related jobs (Class III and Class IV) for which a valid NEA assessment is documented may be conducted without the use of a respirator, PPE and air monitoring after review and approval by the FAC.

B. Area Air Sampling. When area air sampling is conducted, the ATO must perform the sampling in accordance with the most current version of NIOSH Method 7400 PCM. The area air sampling results may warrant confirmation using Transmission Electron Microscopy (TEM). If confirmation is warranted, the ATO will use the most current version of NIOSH Method 7402. For Class I and Class II asbestos work, a qualified independent third-party air monitoring firm contracted by the FAA must perform oversight and air monitoring. For Class III and Class IV work, area air sampling will be performed by qualified FAA or contractor personnel. Area air samples include the following types:

1) Baseline Area Sampling. Baseline area air samples are required prior to the performance of any Class I and Class II asbestos abatement work in staffed facilities. Baseline area sampling may also be required for Class III asbestos abatement work, as dictated by the facility Asbestos O&M Plan.

2) Abatement Area Air Sampling. Abatement area air sampling is performed inside and outside Class I and Class II asbestos work areas during abatement in staffed facilities. The purpose of abatement area sampling is to confirm that engineering controls are working effectively and to ensure proper removal practices are being performed in asbestos abatement areas.

Abatement area air sampling during Class III and Class IV asbestos abatement activities will be performed at the approval of the FAC.

3) Clearance Air Sampling. Clearance air sampling is performed for Class I and Class II asbestos abatement work. The purpose of clearance air sampling is to determine whether the abatement area may be reoccupied. Clearance air samples must be collected and analyzed using NIOSH Method 7400 PCM.

In certain instances, clearance air samples may be collected and analyzed by TEM using the EPA AHERA protocol specified in 40 CFR § 763.

4.6 Equipment and Supplies

All personnel assisting with asbestos O&M activities in areas where ACM/PACM may be disturbed, must have the necessary equipment and supplies to contain ACM/PACM and to perform abatement and decontamination in regulated ACM/PACM areas. (See Appendix A, Standard Work Practices, General Work Practice 1)

5.0 WORK PRACTICES

The asbestos O&M Plan focuses on a special set of asbestos work practices for OSHA Class III and Class IV asbestos operations.

In addition, OSHA Standards require the following work practices and engineering controls regardless of the levels of exposure or classes of asbestos work:

• High Efficiency Particulate Air (HEPA) filter equipped vacuums

• Wet methods

• Prompt clean-up and disposal of waste/debris

Additional controls may be necessary to achieve compliance with the OSHA PEL/EL, including:

• Negative pressure system with local exhaust ventilation and HEPA filters

• Enclosure or isolation of processes

The following work practices are prohibited regardless of measured exposure or the results of initial exposure assessments:

• Use of dust generating powered tools (e.g., high-speed abrasive saws) without attached HEPA filter

• Use of compressed air

• Dry sweeping, shoveling or other dry clean-up method

• Employee rotation as means of reducing exposure

• Smoking, drinking, eating, chewing gum, chewing tobacco or applying cosmetics in regulated areas

Proper implementation of the asbestos O&M worker protection plan is very important to ensure worker safety. All asbestos O&M work that involves contact with friable ACM or disturbance of friable or non-friable ACM will be performed and supervised by trained FAA employees or contractors.

5.1 OSHA Class I and Class II

OSHA Class I and II abatement requires more complex controls and procedures that are site specific and outside the scope of this asbestos O&M Plan. Perform these abatement projects in accordance with the FAA’s Asbestos Abatement Specification. If abatement is conducted by an asbestos contractor, then they will be bound by contract to comply with the provisions of the asbestos abatement specification. The FAC shall be informed of the extent of the asbestos abatement project. This can be accomplished by reviewing the drawings, contract, and attending the pre-construction meeting.

5.2 OSHA Class III and IV

(a) OSHA Class III Asbestos Work is defined as repair and maintenance operations, where ACM/PACM, including TSI and surfacing material, is likely to be disturbed. The maximum amount of disturbed material must not exceed that which will fit into one standard glove bag or standard waste bag. The standard glove bag/waste bag shall not exceed 60 inches in length and width. The minimum requirements for OSHA Class III Asbestos Work are:

• Isolate the work area

• Use wet methods; HEPA vacuums; prompt clean-up

• Use glovebags or mini-enclosures when removing or disturbing TSI or surfacing materials

(b) OSHA Class IV Asbestos Work is defined as maintenance and custodial activities during which employees contact but do not disturb…