Solomon_ACM_Mgmt_Plan_2008.docm

General Services Administration NW/Arctic Region

ASBESTOS MANAGEMENT PLAN

Property Manager/

REV.Dec 2008

REV. Dec 2008

ASBESTOS MANAGEMENT PLAN INDEX

Topic & No.

Maintenance and Renovation

1. EXECUTIVE SUMMARY

The General Services Administration (GSA) is responsible for the health and safety of its employees, employees of other agencies, and outside contractors when they work in GSA owned facilities. It is important that all GSA building occupants and visitors understand, and comply with policies and procedures regarding potential health and safety hazards, including asbestos.

This is the Asbestos Management Plan for Gus Solomon US Courthouse. This Management Plan includes policy, procedures, and technical guidance in accordance with the EPA document entitled, “Managing Asbestos in Place”, also known as the Green Book.

Property Manager/

2. GSA POLICY STATEMENT

GSA’s National Asbestos Policy is described in the memorandum entitled “Public Buildings Service Asbestos Policy”, formally issued on March 27, 2008.

Asbestos inspections to determine the type, locations, and conditions of asbestos containing materials (ACM) will be conducted by AHERA accredited asbestos inspectors, and asbestos abatement projects will be prepared or approved by AHERA accredited asbestos project designers.

ACM that is in good condition and not disturbed presents a negligible exposure hazard. GSA intends to maintain any ACM in an undamaged condition.

All work having the potential to contact or damage ACM (e.g., renovations, repair and routine maintenance activities) within a GSA facility shall be reviewed by the facilities asbestos program manager (APM).

Work performance and clearance verification following asbestos abatement (prior to re-occupancy) will be monitored by an independent environmental consultant under the direction of GSA and not under the direction or under contract with the contractor performing the abatement.

It is the APM’s primary responsibility to monitor the condition of ACM within the facility and to evaluate all activities within the facility as to their potential for disturbance of existing ACM.

3. ASBESTOS MANAGEMENT PLAN OBJECTIVES

This Management Plan delineates responsibility and defines procedures for the control of asbestos containing material in GSA operated buildings. General objectives are as follows:

· Abate (repair, enclose, encapsulate or remove) damaged asbestos.

· Abate asbestos likely to be disturbed during routine operation or construction activities.

· Conduct pre-alteration asbestos assessments for activities, which may disturb asbestos.

· Safely manage in place asbestos, which is undamaged and not likely to be disturbed.

· Monitor ACM through periodic visual surveillance.

· Ensure that all employees, employees of other agencies, and private contractors that conduct work which may disturb ACM receive a minimum of 2 hours asbestos awareness training. In addition, they must be made aware of GSA policies and procedures regarding ACM and have been provided a copy of the most recent asbestos survey.

4. ASBESTOS PROGRAM MANAGEMENT

Regional Asbestos Program Manager

The Regional Industrial Hygienist (IH) develops policy/procedures and provides oversight for the asbestos program in the Region. In addition, the Regional IH makes decisions regarding asbestos less than 1%, and makes interpretations for handling ACM where clear regulatory standards are unavailable.

Facility Asbestos Program Manager

The facility Asbestos Program Manager (APM) (In nearly all cases, the GSA Property Manager) has the authority and responsibility to oversee all asbestos-related activities in the building, including inspections, operations and maintenance (O&M) activities, and other abatement actions.

The APM will ensure that appropriate O&M and other asbestos-related training takes place. In addition, he or she will periodically monitor the custodial and maintenance staffs, contractors, and outside service vendors with regard to all asbestos-related activities.

Maintenance Personnel

Maintenance personnel, whether GSA employees or contractors, will:

· Maintain documentation verifying that they have received a minimum of 2 hours of asbestos awareness training, and have been made aware of the asbestos management plan for the facility.

· Verify whether or not asbestos containing materials (ACM) are present, and may potentially be disturbed, prior to initiating any work item.

· Report damaged ACM, and unauthorized activities, which may disturb ACM, to the Asbestos Program Manager.

5. INSPECTION REPORT

Asbestos containing building materials have been identified in the most recent asbestos re-inspection, conducted in February 2007. The following tables list those materials, which tested positive and negative for asbestos, and those materials which are presumed to contain asbestos. Specific information regarding the condition and location of ACM may be found in the survey report.

6. ASSESSMENT

Initial Inspections

All GSA owned buildings built prior to 1981 will be inspected and assessed for the presence and condition of ACM. Asbestos inspections will conform to EPA Asbestos Hazard Emergency Response Act (AHERA), OSHA and GSA specifications and regulations. All persons (whether GSA staff or contractor) performing initial asbestos inspections shall be EPA accredited AHERA Inspectors.

Periodic-Inspections

Re-inspections shall be accomplished at five year intervals.

Visual inspections of ACM in occupied space and common areas will be conducted at least annually.

7. EDUCATION AND TRAINING

GSA Property Managers and Asst. Property Managers must receive a minimum of two hours of asbestos awareness training. This training must be updated every two years.

Contract Custodial or Building Maintenance Workers who do not handle asbestos but may be exposed to asbestos incidental to their work must receive a minimum of two hours of asbestos awareness training. The training shall include what asbestos is, health effects, GSA's policy, types and locations of ACM, avoiding overexposure, precautions to be taken when working around ACM, and the person to contact if damaged ACM is noted.

Asbestos Workers will receive AHERA asbestos worker or supervisor training. Washington, Oregon and Alaska have state approved asbestos worker and supervisor certification programs, which meet these requirements.

Individuals Who Design Asbestos Abatement Projects must have successfully completed the AHERA project design training from a training provider accredited by the EPA. O&M projects are excluded from this requirement.

The Regional Asbestos Program Manager must have successfully completed the AHERA building inspector and project designer accreditation.

Personnel Conducting Asbestos Air Monitoring shall have successfully completed the NIOSH 582 course, "Sampling and Evaluation of Airborne Asbestos".

8. ASBESTOS OCCUPANT COMMUNICATION

In general, tenant agencies should be notified of:

· The presence of asbestos containing materials in the building.

· The availability and implementation of the asbestos management and O&M plans.

· Asbestos abatement plans which may affect tenant operations.

· Asbestos conditions, air monitoring results, and abatement or alterations in tenant space.

It is the responsibility of the APM to ensure that all communications with tenant agencies regarding asbestos are documented.

All persons whether GSA employees, contractors or tenants who could possibly come into contact with ACM are to be notified as to the location of such material. Each tenant agency with authority to make alterations to its space must be notified of the presence and location of ACM.

9. MEDICAL SURVEILLANCE AND PPE

This section is only applicable when GSA employees that perform asbestos work and exposure may exceed the OSHA PEL. It is not anticipated that any GSA employees will be exposed above the PEL, since all O&M work and asbestos abatement is conducted by contracted maintenance and/or certified workers.

A medical surveillance program is necessary for any GSA employees potentially exposed to asbestos above the OSHA Permissible Exposure Limit (PEL). The medical surveillance shall follow OSHA guidelines. Personal Protective Equipment (PPE) shall be assigned to GSA personnel potentially exposed above the PEL as determined through the exposure assessment. The regional GSA Safety and Environmental Team shall administer the PPE and oversee the medical surveillance program.

10. NOTIFICATION REQUIREMENTS

Environmental Protection Agency (EPA)

Notification is a written intent to renovate or demolish. The US EPA has specific requirements concerning notifications prior to disturbing ACM. Reference the National Emission Standard for Hazardous Air Pollutants (NESHAP), 40 CFR 61.145 (b). The EPA must be advised of the intent to demolish or renovate at least 10 working days before disturbing ACM above applicable thresholds.

Under NESHAP, there are several conditions that require EPA Notification:

· Demolition or renovation of large areas, e.g., at least 260 linear feet, 160 square feet, 35 cubic feet of ACM will be disturbed.

· Demolition or renovation of individual, small areas that when combined will total at least 260 linear feet, 160 square feet, or 35 cubic feet.

· When a non-scheduled operation (emergency) occurs which would qualify the facility based on the above conditions.

Local Pollution Control Agencies

Local Pollution Control Agencies requires notification whenever asbestos is removed, encapsulated or enclosed. Like EPA, a 10-day notice is required prior to start. Additional information regarding specific reporting requirements may be obtained from the GSA Safety and Environmental Team, EPA, or the local pollution control agency.

11. OPERATIONS AND MAINTENANCE (O&M) PROGRAM

Responsibilities

The facility APM is responsible for the implementation of the O&M program and shall ensure that all aspects of this program are implemented.

The APM will ensure that any workers performing asbestos-related work in buildings under their control have received appropriate training.

The maintenance contractor is responsible for using appropriate work practices and equipment when conducting work, which may impact asbestos.

Work Practices

Work practices for asbestos-related activities are described in the “Guidance Manual, Asbestos Operations & Maintenance Work Practices” (hereafter referred to as the “NIBS O&M Manual”), published by the National Institute of Building Sciences (NIBS). GSA has adopted this manual as industry best practice for O&M activities involving small-scale asbestos activities. A copy of this manual will be available in each GSA controlled building with ACM. Copies may be purchased from NIBS at the following URL: http://www.nibs.org/pubsasb.html

Required Equipment

The NIBS O&M Manual lists recommended equipment (see Worker General Procedures W1) for an asbestos O&M program. Actual equipment needs will be determined by the APM, in coordination with the maintenance contractor, as building conditions dictate.

OSHA Asbestos Work Classifications

The Occupational Safety & Health Administration (OSHA) uses a work classification system to determine how asbestos work is controlled. Work practices are classified into four categories (class I through IV), and are described below.

· Class I: Asbestos work involving the removal of thermal system insulation and/or surfacing asbestos-containing material.

· Class II: Asbestos work involving the removal of asbestos-containing material, which is not thermal system insulation or surfacing material. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics.

· Class III: Asbestos work involving repair and maintenance operations, where asbestos-containing materials, including thermal system insulation and surfacing material, is likely to be disturbed and is incidental to the scope of the job. The amount of asbestos waste material must not exceed that which can be contained in a standard waste bag (60” x 60”).

· Class IV: Asbestos work involving maintenance and custodial activities during which employees contact asbestos-containing material and activities to clean up waste and debris containing asbestos.

NIBS Work Practice Levels

NIBS judged that up to three levels were sufficient to encompass a broad range of situations, which are likely to be encountered. The levels are simply a means of structuring the guidance, which the manual provides. Up to three levels are included for each work practice to address different degrees of potential asbestos fiber release. A change of level does not imply a different task to be accomplished. It implies a changed potential for asbestos fiber release, typically related to either the condition of asbestos, nature of the work practice, skill of the workers or the building context in which the task will be performed.

The NIBS work practice levels are as follows:

· Level A: is work that may contact ACM, but which will not disturb it.

· Level B: is work that may disturb ACM, but where the OSHA PEL is not exceeded and release of ACM, dust and debris is confined to the immediate location of the disturbance.

· Level C: is work where ACM is disturbed and the PEL may be exceeded or ACM, dust, and/or debris may be scattered beyond the immediate location of the disturbance.

The work practices in this manual are mandatory, and will be adhered to by all personnel performing asbestos related O&M activities.

Routine Cleaning

As maintenance staff conduct their normal activities, any loose or damaged ACM shall be reported to the APM. Small amounts of loose ACM, when found, will be cleaned up promptly by trained personnel and may be treated as a fiber release episode (see Section 16 of this Plan).

12. WORK CONTROL SYSTEM FOR ASBESTOS RELATED MAINTENANCE AND RENOVATION

A potentially serious problem occurs when tenant agencies, outside contractors, or unauthorized personnel perform activities, which may disturb ACM without either them, or the APM knowing. In order to minimize or eliminate such occurrences, all personnel who perform work in an area with identified ACM should be required to notify their immediate supervisor for clearance to commence work. The following decision trees describe correct procedures for handling potential asbestos impacts during O&M and project work.

13. AIR MONITORING:

General Information

Asbestos

In instances where ACM may be disturbed, OSHA requires that monitoring be performed to accurately determine the airborne concentrations of asbestos to which employees may be exposed. This data will also be used to evaluate the effectiveness of work practices and engineering controls. Air monitoring results are compared against the OSHA permissible exposure limit (PEL) of 0.1 fibers/cc (see OSHA regulations for details). Sufficient and representative air monitoring that reveals consistent exposure below the OSHA PEL can be used in justifying a " negative exposure assessment." O&M workers who will disturb ACM will use respiratory protection and other protective measures until adequate data are generated that indicate exposure levels are consistently below the OSHA PEL.

A "negative exposure assessment" is necessary to determine if a work practice is appropriate for use under the O&M conditions present in a given facility. Data generated can be used by the APM during future selection of work practices. If O&M activity monitoring data are to be used to qualify for OSHA control exemptions or for maintaining OSHA exposure records, it is necessary that the information be kept in strict accordance with the requirements of the OSHA construction standard (29 CFR 1926.1101). The APM is responsible for proving compliance with all applicable federal, state and local regulations.

Based upon the monitoring data obtained, the APM might decide to use a higher or lower level of work practice controls for a specific task. Substantially more data are required to justify the lessening of engineering controls. Any data indicating higher exposures than anticipated will require implementing additional controls sufficient to prevent exposure to workers and adjacent areas. Note also that state or local regulations may require more stringent work practices, higher levels of precaution or additional monitoring.

Air samples will be collected and analyzed in accordance with NIOSH sampling and analytical method 7400. All samples will be analyzed by laboratories that are participants in the Proficiency Analytical Testing (PAT) program administered by the American Industrial Hygiene Association (AIHA). It must be remembered that phase contrast microscopy (PCM) analysis is not specific to asbestos fibers. Transmission Electron Microscopy may be performed to confirm asbestos fiber content of a sample.

Records of all monitoring results will be maintained indefinitely as part of this management plan.

Routine Air Monitoring

Routine air monitoring will be conducted on an as needed basis at this facility.

Personal and Area Air Monitoring During O&M Activities

Personal, and in some cases, area air monitoring is required if ACM may be disturbed. The following types of air monitoring may be necessary during certain O&M activities:

· Initial Monitoring: Area monitoring in the vicinity of the planned O&M activity to determine background contaminant levels.

· Area Monitoring during O&M activities.

· Clearance Monitoring at the conclusion of O&M activities.

· Personal monitoring during O&M activities which may include:

1. Excursion Limit (EL) Monitoring: Monitoring in the workers breathing zone for 30 minutes to determine peak exposures.

2. Eight hour Time Weighted Average (TWA) Monitoring: Monitoring in the workers breathing zone to determine an average exposure calculated over an 8 hour day.

Air monitoring will be required for all O&M activities, unless a negative exposure determination has been made. As historical air monitoring data is accumulated for a particular work practice, and monitoring results are relatively consistent over a period of time, the APM may decide to reduce the monitoring frequency for that work practice. The APM should consult with Regional Industrial Hygienist prior to making this decision.

Response to Monitoring

O&M Monitoring: If any personal or area air monitoring results collected during O&M activities show that airborne asbestos levels exceed or may reasonably be expected to exceed the OSHA permissible exposure level of 0.1 fibers/cc, the work shall be performed by a qualified asbestos abatement contractor.

Routine Area Monitoring: If routine area air sample results indicate an airborne fiber level above the ambient air standard of 0.01 fibers/cc, the following actions will be taken by the APM:

Fiber Level Action Taken

.01 - .09 f/cc The APM and/or other responsible individual attempts to identify the source of the high fiber count. If a source is identified, the APM initiates engineering controls (e.g., HEPA vacuuming, wet wiping, providing physical barriers if necessary, etc.) to limit the spread of fibers, and begins repair of ACM if necessary. The APM will expedite re-sampling and forward representative samples for analysis by transmission electron microscope (TEM). Any fiber count above 0.01 fibers/cc will be treated as a fiber release episode in the same way as a visible release of ACM fibers.

.10 f/cc I any area air sample results indicate an airborne fiber level, which exceeds the OSHA PEL of 0.1 fibers/cc, the affected space must be evacuated until fiber counts are reduced to 0.01 fibers/cc.

14. EMERGENCY PROCEDURES:

Procedures to be followed during minor incidents, such as asbestos fiber release episodes, are described elsewhere in this management plan. If a major incident occurs (e.g., earthquake, sudden water damage, etc.) which significantly impacts the condition of asbestos containing material in a building, the following procedures will be implemented.

In the event of a catastrophic incident at the building, such as a major earthquake, damage assessments must be performed. First, the structural integrity of the building must be determined to see if the building is safe to enter. This assessment should be performed by a structural engineer, or other appropriately trained personnel. NOTE: In some instances, extensive ACM debris may be present as a result of the catastrophic incident. In such cases, if debris is evident, the initial building inspectors should be protected from potential asbestos exposure (e.g., respiratory protection and protective clothing). After the building has been determined to be safe to enter, the condition of the ACM present must be assessed. The initial assessment may be performed by the designated asbestos worker for the building. A subsequent survey may be conducted by an AHERA accredited asbestos inspector if the APM feels it is necessary, based on the potential for damage, type of material, tenant reaction, etc. These assessments will determine the amount of damaged ACM present and the amount of cleaning, repair and abatement required before the building can be reoccupied.

15. ASBESTOS LABELING, WASTE HANDLING, AND DISPOSAL:

Information regarding waste handling and disposal is referenced in the NIBS Asbestos O&M Work Practices Manual. For specific information, see Worker General Procedures W11 (Packaging and Labeling Waste), W14 (Decontaminating Waste), W17 (Waste Transport, Storage and Disposal), and W19 (Disposal of Contaminated Water).

16. FIBER RELEASE EPISODES:

A fiber release episode is an uncontrolled or unintentional disturbance of ACM resulting in visible emissions of asbestos. The following procedures should be utilized in the event of a fiber release episode:

· Immediately notify appropriate staff (e.g., the APM, Supervisors, GSA Property Manager, O&M Staff, etc).

· Shut down or modify the HVAC system in the area of the release to prevent contamination of other areas of the building.

· Restrict the area from non-essential personnel.

· Saturate the debris from the release with amended water.

· Clean up the debris with HEPA Vacuums, steam cleaning, or other wet methods.

· Repair the area of the release or conduct alternate response action if necessary.

· Conduct visual clearance inspection of affected area.

· Initiate clearance air monitoring of the affected area. When a clearance fiber level of 0.01 fibers/cc is obtained, the area may be re-opened and the HVAC system activated.

· Notify Regional Industrial Hygienist (10PTP) at (253) 931-7696.

· Complete the Fiber Release Episode Report found in Appendix A, send a copy to 10PTP within two days, and file a copy as required by this management plan.

Under EPA Superfund regulations, when a pound or more of friable asbestos is released into the environment, or there is a threat of such a release, the National Response Center must be notified (800) 424-8802. GSA, or Abatement Contractors as applicable, are responsible for remedial action.

17. RECORDKEEPING:

All asbestos related documents discussed in this plan should be stored in permanent files, and maintained indefinitely. Examples of asbestos records include, but are not limited to:

· Asbestos Building Inspections

· Asbestos Project Records

· Air Monitoring Reports

· Training Documentation

· EPA Project Notification Letters

· Fiber Release Episode Reports

· Tenant or Contractor Notifications

· Asbestos-related Correspondence

Appendix “A”

GSA REGION 10 FIBER RELEASE EPISODE REPORT

Property Mgmt Office_____________Mail Code___________ Bldg. #__________

Address:________________________________________ Ph. #___________

Name and Title of Person Reporting Incident __________________________

Name and Title of Person Contacted __________________________

Date and Time of Incident_____________________________________________

Cause of the Incident__________________________________________________

Area Sealed Off from HVAC Shut Down (Y/N)_______ Non-essential Personnel?_______

Cleanup Conducted by:________________________________________________

Equipment Used: _______ HEPA Vacuums _________Respirators

_______ Wet Wiping _________Protective Clothing

_______ Steam Cleaning _________Other

How was the Contaminated Material Cleaned up?_____________________________

Were Clearance Air Samples Collected? Describe_____________________________

Clean-up evaluated by?__________________________________________________

Was Regional Office Contacted? (Y/N) ______ Person Contacted____________________________

Appendix “B” – Asbestos Related Definitions

"Asbestos" includes chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos, actinolite asbestos, and any of these minerals that have been chemically treated and/or altered.

"Asbestos-containing material (ACM)" means any material containing more than 1% asbestos.

"Authorized person" means any person authorized by the employer and required by work duties to be present in regulated areas.

"Building/facility owner" is the legal entity, including a lessee, which exercises control over management and record keeping functions relating to a building and/or facility in which activities covered by this standard take place.

"Certified Industrial Hygienist (CIH)" means one certified in the practice of industrial hygiene by the American Board of Industrial Hygiene.

"Employee exposure" means that exposure to airborne asbestos that would occur if the employee were not using respiratory protective equipment.

"Fiber" means a particulate form of asbestos 5 micrometers or longer,with a length-to-diameter ratio of at least 3 to 1.

"High-efficiency particulate air (HEPA) filter" means a filter capable of trapping and retaining at least 99.97 percent of 0.3 micrometer diameter mono-disperse particles.

"Homogeneous area" means an area of surfacing material or thermal system insulation that is uniform in color and texture.

"Industrial hygienist" means a professional qualified by education, training, and experience to anticipate, recognize, evaluate and develop controls for occupational health hazards.

"PACM" means presumed asbestos containing material.

"Presumed asbestos containing material" means thermal system insulation and surfacing material found in buildings constructed no later than 1980. The designation of a material as "PACM" may be rebutted pursuant to paragraph (j)(8) of this section.

"Regulated area" means an area established by the employer to demarcate areas where airborne concentrations of asbestos exceed, or there is a reasonable possibility they may exceed, the permissible exposure limits.

"Surfacing ACM" means surfacing material which contains more than 1 percent asbestos.

"Surfacing material" means material that is sprayed, troweled-on or otherwise applied to surfaces (such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, and other purposes).

"Thermal System Insulation (TSI)" means ACM applied to pipes, fittings, boilers, breeching, tanks, ducts or other structural components to prevent heat loss or gain.

"Thermal System Insulation ACM" means thermal system insulation which contains more than 1 percent asbestos.

Appendix “C” – Example Building Occupant Notification

Date

Name, Company, Address, etc.

Subject: Notice of Asbestos Building Materials (Insert Building Info.)

The Occupational Safety and Health Administration (OSHA) Standards (29 CFR 1910.1001) requires that notification be given in public buildings where Asbestos Containing Material (ACM) is present. Under this regulation, a building owner is required to notify employees, tenants, and contractors who work in the building of the presence of ACM.

By this notice, all building tenants, employees, and outside contractors are hereby informed that ACM has been identified in the subject building. The enclosed report lists material identified as containing asbestos.

All building occupants should keep in mind that the presence of asbestos in the building, if undisturbed and in good condition, does not present a health hazard. Therefore, untrained personnel must not drill, saw, sand, grind, abrade, or otherwise disturb any materials that contain, or are presumed to contain asbestos. Work that may result in the disturbance or abatement of asbestos must only be performed by trained workers and licensed abatement contractors. In the event any of these materials are inadvertently disturbed, contact Name at Telephone # during normal business hours. In the event of an after-hours emergency, contact Name at Telephone #.

Under the terms of your lease agreement, you must obtain written approval from GSA prior to initiating any alteration, demolition, or renovation at this facility. This will allow us to assess any potential impacts to ACM prior to actual construction.

If you have any questions regarding this notification, please contact Name at Telephone #.

Sincerely, Name Title image2.png image3.wmf oleObject1.bin Work order is received by contract maintenance staff.�

Scope of work order is reviewed and compared against current asbestos survey.�

Is it possible that work will disturb existing asbestos containing materials (ACM)?�

Conduct work per normal procedures.�

Notify asbestos program mgr. (APM). Determine if the work is classified as an asbestos project, or if it is small-scale O&M asbestos work.*�

* The amount of ACM disturbed by any O&M activity should be limited. Projects producing more waste than will fit in a single 60 inch X 60 inch waste bag, as well as work falling outside OSHA's O&M work classifications, should be performed by asbestos abatement contractors. �

* Is the work small-scale O&M work?�

Develop asbestos project.�

Remove ACM or establish appropriate asbestos controls in order to accomplish work. Utilize appropriate NIBS Asbestos O&M procedure. Conduct air monitoring as required.

NOTE: Provide notification to local pollution control agency if required.�

Submit project record, including job logs and air monitoring records to APM.�

Asbestos Operations & Maintenance Work Requirements� image4.wmf oleObject2.bin Scope of Project Defined�

PM Reviews ACM Survey to determine if ACM is present. Conduct additional ACM survey of areas not previously addressed (e.g., behind walls, under multiple layers of flooring, and other areas which were inaccessible during previous survey. For additional information, see GSA Technical Guide - Pre-Alteration Assessments (available on 10PTP web site).�

Is ACM Present?�

No ACM Design Required.�

Is it likely that ACM may be disturbed by the Project?�

No abatement required. Provide ACM survey to Contractor. Some trades may require asbestos awareness training if working in proximity to ACM. �

Is ACM Fireproofing Present?�

Is complete removal planned?�

Develop Abatement Design. �

Develop spot abatement specification. Include GSA Section 01550, "Coordination to Abatement".�

Develop Abatement Design as applicable for other ACM.�

Asbestos Related Project Requirements�

Procure the project. Abatement contractor will be required to submit an abatement plan to GSA per abatement specifications. The abatement plan should be submitted to the Regional Industrial Hygienist (RIH) for review and comment. Submit any revisions to the RIH for review and approval.

It is required that an independent environmental consultant (3rd party) be retained by GSA to conduct final abatement clearance inspection and air monitoring. This is a minimum requirement. In addition, it is recommended that the consultant be retained to provide periodic QA oversight of abatement activities on behalf of GSA.

At completion of the project, submit all abatement project records to the APM. � image1.png