Managing Asbestos In Place

A Building Owner’s Guide to Operations and Maintenance Programs for Asbestos-Containing Materials

Contents

ACKNOWLEDGEMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v

FOREWORD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii

1. WHY IS ASBESTOS A PROBLEM?

Introduction and Overview

● Background

● Chapter Summary

2. WHAT IS AN O&M PROGRAM?

Purpose and Scope of an Operations and Maintenance program

● Purpose of O&M Program

● Scope of an O&M Program

● Chapter Summary

3. HOW DOES THE PROGRAM START?

Laying the Foundation for an Effective O&M Program

● The Asbestos Program Manager

● BuildingInspectionandAssessment

● Developing an O&M Program

● IrnplementingandManaging an O&M

Program

● Cost Considerations

● Selectingandhnplementing Alternative Abatement Actions

● Chapter Summary

4. WHAT DOES AN O&M PROGRAM INCLUDE?

O&M Program Elements

● Informing Building Workers, Tenants, and Other Occupants

● ACMSurveiUance-Reirwectionand Periodic Surveillance

● Supplement to Visual/Physical Evaluation

● WorkControl/Permit System

● O&M Work Practices

–Worker protection programs –Basic O&M Procedures –O&M Cleaning Practices –Procedures for Asbestos Fiber Release Episodes

● Recordkeeping

● Chapter Summary

5. WHAT O&M TRAINING IS NECESSARY?

Types of Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 3

● Chapter Summary i i i

6. WHAT REGULATIONS AFFECT ASBESTOS MANAGEMENT PROGRAMS IN

BUILDINGS, ESPECIALLY O&M PROGRAMS?

Federal, State, and Local Regulations Affecting O&M Programs

● OSHA Regulations &EPA Worker Protection Rule –Small-scale, Short-duration Projects

● EPA National Emission Standards for Hazardous Air Pollutants (NESHAP) Regulations –Notification –Emissions Control and Waste Disposal

● Resource Conservation and Recovery Act (RCRA); Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, or "Superfund")

● Asbestos Hazard Emergency Response Act (AHERA)

● Asbestos Ban and Phaseout Rule

● Chapter Summary

APPENDIX A.

Glossary

APPENDIX B.

Sample Recordkeeping Forms

APPENDIX C.

Illustrative Organzation Charts

APPENDIX D.

Additional Assistance (EPA, NESW, OSHA; Training )

APPENDIX E.

Respiratory Protection Recommendations

APPENDIX F.

Existing EPA Guidance For ACM Control

APPENDIX G.

Sample List: Suspect Asbestos-Containing Materials

APPENDIX H.

References

DISCLAIMER

This document was prepared under contract to an agency of the United States Government. Neither the United States Government nor any of their employees makes any warranty, expressed or implied, or assume any legal liability for any third party’s use of or the results of such use of any information, product, or process discussed in this document. Mention or illustration of company or trade names, or of commercial products does not constitute endorsement by the U.S. Environmental Protection Agency.

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Acknowledgements

The time and effort that many individual contributed to the development of this document is gratefully acknowledged by the U.S. Environmental Protection Agency (EPA). The material in this publication represents EPA’s approximately 11 years of experience in considering public input and fine tuning policies on managing asbestos-containing materials in buildings. This document incorporates views expressed by safety and health professionals, property owners and managers, public officials, general industry representatives, workers, and the general public.

The primary EPA developer and coordinator of the final document was Dr. Robert Jordan of the Technical Assistance Section, Environmental Assistance Divi-sion, Office of Toxic Substances. Without Bob’s con-stant oversight, combined with his technical knowledge and concern that the document be representative of state-of-the-art asbestos management, this document would not have reached the public.

Joe Schechter, Chief of the Technical Assistance Sec-tion, managed the project and helped clarify and edit the Guide. Bob McNally Chief of the Assistance Programs Development Branch, was instrumental in the forma-tive period of the Guide’s development and also devoted long hours to its review Other important contributions within the Environmental Assistance Division came from Tom Tom and Dave Kling. Sylvia Thomas provided necessary assistance in revisions of the early drafts. Esther Tepper and Jane Gurin helped review the Guide in its final revisions, to make sure the document was written in easy-to-understand language.

The original work which provided the foundation for the project was performed under a contract with Battelle Memorial Institute (No. 68-02-4294) by Dr. Dale Keyes and Dr. Jean Chesson, under the direction of Edie Sterrett and Cindy Stroup of the EPA Exposure Evaluation Division. They prepared the first drafts of the document and were instrumental in establishing its final format.

EPA staff also gratefully acknowledge the work of staff from the Georgia Tech Research Institute (GTRI).

Through a cooperative agreement with EPA they served as the overall project coordinator and provided thoughtful technical guidance throughout this entire process. The GTRI team also developed several key sections of the Guide.

This publication was refined through a peer review meeting held in October 1988 in Washington, DC, and by a series of comment periods provided through May 1990. The following individuals gave their time and provided comments:

John Biechman, Safe Buildings Alliance Wolfgang Brandner, U.S. EPA Region VII Frank Bull, Bull, Brown & Kilgo Architects Eva Clay The Environmental Institute William Cobbs, U.S. General Services

Administration Mark Demyanek, Georgia Tech Research

Institute Michael Duffy, Service Employees International

Union Paul Fidducia, Winston and Strawn Eugene Fisher, Association of Wall and Ceiling

Industries Douglas Greenaway Consultant (formerly, Building Owners and Managers Association International)

David Harris, National Institute of Building Sciences

Steve Hays, Gobbell Hays Partners Joseph Hopkins, U.S. Department of Energy David Mayer, Georgia Tech Research Institute Richard Mendes, New York City Department of

Environmental Protection Michael Miles, Tishman Spyer Properties Roger Morse, ENTEK Environmental and

Technical Services, Inc.

Robert Navratil, RREEF Funds, Construction and Engineering Anthony Restaino, U.S. EPA Region V Richard Roth, Social Security Administration Sims ROy, U.S. EPA, Office of Air Quality

Planning and Standards v

Scott Schneider, Workers’ Institute for Occupational Safety and Health

Henry Singer, U.S. General Services Administration

Thomas Warren, Rose Associates, Inc.

In addition to these individuals, the EPA acknowledges the contribution of the Policy Dialogue Group on

Asbestos in Public and Commercial Buildings, which met several times during 1989–1990. The purpose of this multidisciplinary group was to identify the prob-lems associated with asbestos in public and commercial buildings and to develop policy recommendations for solving these problems. Many comments raised by the Dialogue Group in the area of asbestos management were incorporated into this document.

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Foreword

In February 1988, the Administrator of the Environmental Protection Agency (EPA) recommended to Congress that the Agency work during the next three years to enhance the nation’s technical capability in asbestos by helping building owners better select and apply appropriate asbestos control and abatement actions in their buildings. The publication of this guidance document is EPA’s most extensive effort to date to carry out that recommendation. In fact, Managing Asbestos In Place is the most comprehensive asbestos guide published by EPA since the Agency expanded and updated Guidance for Controlling Asbetos-Containing Materials in Buildings (also known as the Purple Book) in June 1985. Based on the insights and recommendations of nationally recognized asbestos experts, this new guide, along with a new operations and maintenance work practices manual expected to be available in 1991, provides “state-of-the-art” instruction to building owners to help them successfully manage asbestos-containing materials in place.

Managing Asbestos in Place does not supplant the 1985 Purple Book as EPA’s principal asbestos guidance document. Rather, based on our experience since 1985, it expands and refines the Purple Book’s guidance for a special operations and maintenance (O&M) program.

In particular, the guide more strongly emphasizes the importance of in-place management. The guide’s pur-pose is two-fold. First, it offers building owners the more detailed and up-to-date instruction they need to carry out a successful O&M program. Second, it informs building owners, lenders, and insurers that a properly conducted O&M program can in many cases be as appropriate an asbestos control strategy as removal. Furthermore, in some cases, an O&M pro-gram is more appropriate than other asbestos control strategies, including removal.

Emphasizing the importance and effectiveness of a good O&M program is a critical element of EPA’s broader effort to put the potential hazard and risk of asbestos exposure in proper perspective. That effort centers around communicating the following jive facts, which EPA hopes will help calm the unwarranted fears that a number of people seem to have about the mere presence of asbestos in their buildings and discourage the spontaneous decisions by some building owners to remove all asbestos-containing material regardless of its condition.

FACT ONE: Although asbestos is hazardous, the risk of asbestos-related disease depends upon exposure to airborne asbestos fibers.

In other words, an individual must breathe asbestos fibers in order to incur any chance of developing an asbestos-related disease. How many fibers a person must breathe to develop disease is uncertain. However, at very low exposure levels, the risk maybe negligible or zero.

FACT TWO: Based upon available data, the average airborne asbestos levels in buildings seem to be very low. Accordingly, the health risk to most building occupants also appears to be very low.

A 1987 EPA study found asbestos air levels in a small segment of Federal buildings to be essentially the same as levels outside these buildings. Based on that limited data, most building occupants (i.e., those unlikely to disturb asbestos-containing building materials) appear to face only a very slight risk, if any, of developing an asbestos-related disease.

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FACT THREE: Removal is often not a building owner's best course of action to reduce asbestos exposure. In fact, an improper removal can create a dangerous situation where none previously existed.

By their nature, asbestos removals tend to elevate the airborne level of asbestos fibers. Unless all safeguards are properly applied, a removal operation can actually increase rather than decrease the risk of asbestos-related disease.

FACT FOUR: EPA only requires asbestos removal in order to prevent significant public exposure to airborne asbestos fibers during building demolition or renovation activities.

Asbestos removal before the wrecking ball swings into action is appropriate to protect public health. At other times, EPA believes that asbestos removal projects, unless well-designed and properly performed, can actually increase health risk.

FACT FIVE: EPA does recommend a pro-active, in-place management program whenever asbestos-containing material is discovered.

As this guide will explain in some detail, in-place management does not mean “do nothing.” It means having a program to ensure that the day-to-day manage-ment of the building is carried out in a manner that minimizes release of asbestos fibers into the air, and ensures that when asbestos fibers are released, either accidentally or intentionally proper control and cleanup procedures are implemented. As such, it may be all that is necessary to control the release of asbestos fibers, until the asbestos-containing material in a building is scheduled to be disturbed by renovation or demolition activities.

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Why Is Asbestos a Problem?

Introduction: Asbestos in Buildings

This U.S. Environmental Protection Agency (EPA) guide is primarily directed to owners and managers of office buildings, shopping centers, apartment buildings, hospitals, and similar facilities which may contain asbestos materials. Managers of industrial plants and other types of structures may need to supplement this information with additional specialized guidance. This document gives building owners, managers, workers, and other key building staff basic information on how to develop and carry out high-quality operations and maintenance programs for managing asbestos in place to safeguard the health of all building occupants. An operations and maintenance (O&M) program can be defined as a formulated plan of training, cleaning, work practices, and surveillance to maintain asbestos-containing materials (ACM) in good condition.

In this document you will find the following information:

The objectives of an O&M program, and an indication of the scope of O&M activities (Chapter 2);

Basic steps to take before starting an O&M program, including an initial survey and evalua-tion of ACM (Chapter 3);

How to implement and manage the program, including some basic cost considerations (Chapter 3);

O&M work practices that protect both workers and the general building environment (Chapter 4);

Recordkeeping suggestions and requirements (a section of Chapter 4);

Training recommendations and requirements for workers performing O&M activities (Chap-ter 5); and

An overview of federal regulations, including those affecting O&M programs (Chapter 6).

In addition, the Appendices provide other useful infor-mation, including a glossary of useful terms, and contacts for additional assistance.

How O&M There are steps which a building Fits In owner can take to prevent as-bestos fiber releases or resuspen-sion of already-released fibers, or control fiber releases quickly and safely if they occur. O&M programs are designed to achieve both these goals. This guide’s purpose, therefore, is to inform building owners about how to develop, implement and manage effective O&M programs, and to encourage their use.

EPA recommends a pro-active, in-place management program whenever asbestos is discovered. In many buildings, a well-run O&M program may be all that is necessary to control the release of asbestos fibers until the ACM in the building is abated through renovation or demolition activities. Also, an emergency repair to equipment or building services, or an unexpected incident such as ACM falling from a surface could necessitate a different control strategy However, bar-ring such events, if ACM is properly managed, release of asbestos fibers into the air is minimized. The exposure to asbestos fibers, and therefore the risk of asbestos-related disease, can be reduced to a negligible level for all building occupants.

An O&M program may also provide an effective, less costly alternative to wholesale removal operations.

Some additional cost-related considerations are dis-cussed in Chapter 3.

The EPA National Emission Standards for Hazardous

An O&M program can be defined as a formulated plan of training, cleaning, work practices, and surveillance to maintain asbestos-containing materials in good condition.

Air Pollutants (NESHAP) regulations on asbestos may require ACM removal prior to renovation and/or demolition projects, to prevent significant asbestos releases into the air (see Chapter 6). Additionally removal of some ACM in a building will be necessary if the material has been damaged beyond repair. However, at other times, removal is often not a building owner’s best course of action to reduce asbestos exposure.

(Extraneous factors –for example, difficulty in obtain-ing insurance, or obtaining financing relative to a real estate transaction-may actually represent the driving forces in a decision to remove all ACM, rather than a health-based need for removal.) In fact, unless all safeguards are properly applied by trained, experienced individuals, removing ACM can actually increase build-ing occupants’ risk of asbestos-related disease.

Background

Asbestos fibers can cause se-The Asbestos rious health problems. If in-Issue haled. they can cause diseases which disrupt the normal functioning of the lungs.

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 years or more before symptoms appear.

In general, as with cigarette smoking and the inhalation of tobacco smoke, the more asbestos fibers a person inhales, the greater the risk of developing an asbestos-related disease. Most of the cases of severe health problems resulting from asbestos exposure have been experienced by workers who held jobs in industries such as shipbuilding, mining, milling, and fabricating, where they were exposed to very high levels of asbestos in the air, without benefit of the worker protections now afforded by law Many of these same workers were also smokers. These employees worked directly with as-bestos materials on a regular basis and, generally for long periods of time as part of their jobs. Additionally there is an increasing concern for the health and safety of construction, renovation, and building maintenance personnel, because of possible periodic exposure to elevated levels of asbestos fibers while performing their jobs.

Whenever we discuss the risk posed by asbestos, we must keep in mind that asbestos fibers can be found nearly everywhere in our environment (usually at very low levels). There is, at this time, insufficient informa-tion concerning health effects resulting from low-level asbestos exposure, either from exposures in buildings or from our environment. This makes it difficult to accurately assess the magnitude of cancer risk for building occupants, tenants, and building maintenance and custodial workers. Although in general the risk is likely to be negligible for occupants, health concerns remain, particularly for the building’s custodial and maintenance workers. Their jobs are likely to bring them into close proximity to ACM, and may sometimes require them to disturb the ACM in the performance of maintenance activities. For these workers in particular, a complete and effective O&M program can greatly reduce asbestos exposure. This kind of O&M program can also minimize asbestos exposures for other building occupants as well.

The term “asbestos” describesWhat is six naturally occurring fibrousAsbestos? minerals found in certain types of rock formations. Of that general group, the minerals chrysotile, amosite, and crocidolite have been most commonly used in building products. When mined and processed, asbestos is typically separated into very thin fibers. When these fibers are present in the air, they are normally invisible to the naked eye. Asbestos fibers are commonly mixed during processing with a material which binds them together so that they can be used in many different products. Because these fibers are so small and light, they may remain in the air for many hours if they are released from ACM in a building. When fibers are released into the air they may be inhaled by people in the building.

Asbestos became a popular commercial product be-cause it is strong, won’t burn, resists corrosion, and insulates well. In the United States, its commercial use began in the early 1900’s and peaked in the period from World War II into the 1970’s. Under the Clean Air Act of 1970 the EPA has been regulating many asbestos-containing materials which, by EPA definition, are materials with more than 1 percent asbestos. The Occupational Safety and Health Administration’s (OSHA) asbestos construction standard in section K, “Communication of hazards to employees," specifies labeling many materials containing 0.1% or more asbestos. In the mid-1970’s several major kinds of asbestos materials, such as spray-applied insulation, fireproofing, and acoustical surfacing material, were banned by EPA because of growing concern about health effects, particularly cancer, associated with exposures to such materials.

In July 1989, EPA promulgated the Asbestos Ban and Phasedown Rule. The rule applies to new product manufacture, importation, and processing, and essen-tially bans almost all asbestos-containing products in the United States by 1997. This rule does not require removal of ACM currently in place in buildings.

Where is Asbestos In February 1988, the EPA released a reportLikely to be Found titled EPA Study of As-in Buildings? bestos-Containing Ma-terials in Public Buildings: A Report to Congress. EPA found that “friable” (easily crumbled) ACM can be found in an estimated 700,000 public and commercial buildings. About 500,000 of those buildings are believed to contain at least some damaged asbestos, and some areas of significantly damaged ACM can be found in over half of them.

According to the EPA study significantly damaged ACM is found primarily in building areas not generally accessible to the public, such as boiler and machinery rooms, where asbestos exposures generally would be limited to service and maintenance workers. Friable ACM, if present in air plenums, can lead to distribution of the material throughout the building, thereby possi-bly exposing building occupants. ACM can also be found in other building locations.

Asbestos in buildings has been commonly used for thermal insulation, fireproofing, and in various building materials, such as floor coverings and ceiling tile, cement pipe and sheeting, granular and corrugated paper pipe wrap, and acoustical and decorative treat-ment for ceilings and walls. Typically it is found in pipe and boiler insulation and in spray-applied uses such as fireproofing or sound-deadening applications.

The amount of asbestos in these products varies widely (from approximately 1 percent to nearly 100 percent).

The precise amount of asbestos in a product cannot always be accurately determined from labels or by asking the manufacturer. Nor can positive identification of asbestos be ascertained merely by visual examina-tion. Instead, a qualified laboratory must analyze representative samples of the suspect material. Appen-dix G contains a sample list of some suspect materials.

When is Asbestos Intact and undisturbed a Problem? asbestos materials do not Dose a health risk.

The mere presence of asbestos in-a building does not mean that the health of building occupants is endan-

ACM which is in poor physical condition.

Under a proper oper-ations and mainte-nance program, cor-rective action would normally prevent deterioration of the insulation.

gered. ACM which is in good condition, and is not somehow damaged or disturbed, is not likely to release asbestos fibers into the air. When ACM is properly managed, release of asbestos fibers into the air is prevented or minimized, and the risk of asbestos-related disease can be reduced to a negligible level.

However, asbestos materials can become hazardous when, due to damage, disturbance, or deterioration over time, they release fibers into building air. Under these conditions, when ACM is damaged or disturbed– for example, by maintenance repairs conducted without proper controls — elevated airborne asbestos concen-trations can create a potential hazard for workers and other building occupants.

ACM with sound structural integrity on the exterior of a domestic hot water tank. Note that the insulation jacketing is intact and there is no evidence of disturbance.

Chapter Summary

This document, directed to owners and managers of office buildings and similar facilities, should help lay the ground work for developing and implementing effective operations and maintenance programs.

Major highlights in this section have focused on background information concerning asbestos and have touched on the current asbestos-in-buildings situation. Important points to remember are the following:

● Inhalation of asbestos fibers has been shown to ● Asbestos-containing materials (ACM) are reg-cause asbestosis, lung cancer and meso- ulated by EPA, OSHA, and the Consumer thelioma. Much of our knowledge of these Product Safety Cornmission (CPSC), and indi-health effects has come primarily from studies vidual state and local agencies.

of workers exposed routinely to very high levels of asbestos in their jobs, ● Friable ACM can be found in about 700,000 public and commercial buildings. Many areas

● Information health effects of low-level where asbestos is found are not accessible to asbestos exposure is less certain; custodial/ the general public.

maintenance workers who sometimes disturb asbestos as part of their job would benefit from ● Some common uses of asbestos have included properly executed O&M programs. pipe/boiler insulation, spray-applied fireproof-ing, floor and ceiling tile. cement pipe/sheeting

● Three of the six naturally occurring asbestos and paper pipe wrap.

minerals, chrysotile, amosite, and crocidolite, have been most commonly used in building ● Positive identification of asbestos requires products. laboratory analysis; information on labels or visual examination only is not sufficient.

● Asbestos became a popular commercial prod-uct because of its strength, heat resistance, ● Intact, undisturbed materials generally do not corrosion resistance, and thermal insulation pose a health risk; they may become hazardous properties. when damaged, disturbed, or deteriorated over time and release fibers into building air.

What Is an O&M Program?

Purpose and Scope of an Operations and Maintenance Program

Purpose of O&M

The principal objective of an O&M program is to minimize exposure of all building occupants to asbestos fibers. To accomplish this objective, an O&M program includes work practices to (1) maintain ACM in good condition, (2) ensure proper cleanup of asbestos fibers previously released,

(3) prevent further release of asbestos fibers, and (4) monitor the condition of ACM.

Scope of an O&M Program An effective O&M program should address all types of The O&M program can be divided into three types of ACM present in a building. ACM that maybe managed projects as part of an O&M program in buildings can be classified in one of the following categories: ● those which are unlikely to involve any direct contact with ACM;

1 Surfacing Material: Examples include ● those which may cause accidental disturbance ACM sprayed or troweled onto surfaces, such of ACM;

as decorative plaster on ceilings or acoustical ACM on the underside of concrete slabs or ● those which involve relatively small distur-decking, or fireproofing materials on struc- bances of ACM.

tural members.

The first type may involve routine cleaning of shelves 2 Thermal System Insulation (TSI): Exam- and counter tops or other surfaces in a building ples include ACM applied to pipes, boilers, (provided ACM debris is not present). Generally such tanks, and ducts to prevent heat loss or gain, or condensation.

3 Miscellaneous ACM: Examples include asbestos-containing ceiling or floor tiles, tex-tiles, and other components such as asbestos-cement panels, asbestos siding and roofing materials.

The O&M program, when developed and implemented in a particular facility should include specific direction on how to deal with each of these general categories of ACM. Specified O&M work practices and procedures should be employed by trained personnel during build-ing cleaning, maintenance, renovation, and general operational activities that may involve surfacing, ther-mal, or miscellaneous ACM. Some elaboration of O&M work practices and procedures is found in Chapter 4.

An example of spray-applied surfacing ACM on a metal deck above a suspended cei l ing.

An example of as-bestos-containing thermal system insu-lation on pipes in a building’s mechanical room.

activities would not be expected to disturb ACM. The second type of project could include maintenance work above a suspended ceiling in an area that may have surfacing ACM overhead. The third type of project— small-scale, shor-duration maintenance, repair, or installation projects involving minor disturbances of ACM – includes activities such as installation of new light fixtures on or in an ACM ceiling. A single glovebag operation to remove a small amount of ACM to repair a pipe in a boiler room is another example of intentional small-scale, short-duration disturbance.

An example of an asbestos-containing cement sheet product (miscellaneous ACM).

Larger projects involving more complex procedures for the intentional removal of ACM are considered asbestos abatement projects. These require asbestos control and abatement procedures that are outside the scope of an O&M program. Before taking action, building owners should consult qualified professionals for advice and alternative solutions. Guidance for building owners on the management of abatement projects is included in EPA’s “Guidance for Controlling Asbestos-Containing Materials in Buildings” June 1985, also known as the “Purple Book.”

Chapter-Summary

The purpose of an operations and Maintenance Program is to minimize exposure of all building occupants to asbestos fibers. Through super-vised work practices, ACM can be managed in place. Important points to remember are:

ACM can be classified into three categories:

● Surfacing Material

● Thermal System Insulation (TSI)

● Miscellaneous Material

O&M Programs can be divided into three types of project%

● Unlikely to involve direct contact with ACM.

● Accidental disturbance of ACM.

● Small-scale, short-duration maintenance or repair activity which may involve intentional disturbance of ACM.

How Does the Program Start?

Laying the Foundation for an Effective O&M Program

A comprehensive asbestos control program for a building should include these basic steps:

● Appoint an Asbestos Program Manager and develop an organizational policy

● Conduct a physical and visual inspection of the building and take bulk samples of suspect materials to determine if ACM is present, establish an ACM inventory and assess the ACM’s condition and potential for disturbance.

● If ACM is located, develop an O&M program, based on the inspection and assessment data.

Implement and manage the O&M program conscientiously

● Select and implement abatement actions other than O&M when necessary

This chapter provides information about each of these basic steps. In addition, see Appendix F for a chart of references outlining existing EPA guidance for each of these steps.

The Asbestos Program Manager The position of Asbestos Program Manager (APM) is frequently held by the building engineer, superinten-dent, facilities manager, or safety and health director. In a small organization, the building owner may have this role. Regardless of who holds this position, EPA stresses the need for the Asbestos Program Manager to be properly qualified, through training and experience, and to be actively involved in all asbestos-control activities.

EPA accreditation under the Asbestos Hazard Emer-gency Response Act (AHERA) or state certification as a Building Inspector/Management Planner would be typical of the requisite training.

If the person selected is not adequately prepared, he or she should receive the training necessary to develop and manage an asbestos control program prior to beginning the job. If for some reason this is not possible, the building owner should strongly consider hiring a prop-erly trained, experienced, and credentialed outside consultant or firm to provide direction to the owner or the Asbestos Program Manager.

In general, the Asbestos Program Manager should have the authority to oversee all asbestos-related activities in the building, including inspections, O&M activities, and other abatement actions. The Asbestos Program Man-ager will either train building workers in O&M tech-niques or ensure that such worker training takes place.

In addition, he or she should oversee the custodial and maintenance staffs, contractors, and outside service vendors with regard to all asbestos-related activities.

Building Inspection and Assessment To determine whether an asbestos control and manage-ment program should be implemented, the owner should have an initial building inspection performed to locate and assess the condition of all ACM in the building. A trained, experienced and qualified inspector, who is able to perform the sampling of suspect ACM for laboratory analysis, should conduct the inspection. If an inspection is not performed, then certain suspect materials should be assumed to contain asbestos, and treated accordingly (Refer to Appendix G for a sample list of suspect ACM.)

EPA guidance on how to take “bulk” samples of suspect ACM is contained in several publications (see Appendix H) and from EPA Regional Asbestos Coordinators (listed in Appendix D).

The building inspection by a qualified professional serves as the basis for establishing an effective overall plan for dealing with the asbestos in the building. The inspector should advise the owner and the Asbestos

To determine whether an asbestos control and management program should be implemented, the owner should have an initial building inspection performed to locate and assess the condition of all ACM in the building.

program Manager of inspection findings. Of course, the inspection may show that ACM is not present and that an asbestos-control program is not required.

If ACM is found, the material’s characteristics, condi-tion, quantity and location within the building, as well as building use, will affect how the building owner should deal with the ACM. For example, operations and maintenance procedures may be appropriate and suffi-cient in a particular building for ACM in good condition.

But O&M procedures alone are not sufficient for ACM that the inspector determines is significantly damaged, and may not be sufficient for some types of ACM situated in highly accessible areas; in these instances, some form of full scale abatement — repair, encapsula-tion, enclosure, encasement, or removal – will be necessary Removal of the ACM may also be appropriate when performed in conjunction with major building renovations, or as part of long-term building manage-ment policies (such as staged removal in conjunction with renovation over the life of the building, as covered by the EPA NESHAP requirements for removal before demolition or renovation).

Developing an O&M Program If ACM is found, the building owner should have an O&M program developed as soon as possible. Either the Asbestos Program Manager or a qualified consult-ant should develop the O&M program. The written O&M program should state clearly the O&M policies and procedures for that building, identify and describe the administrative line of authority for that building, and should clearly define the responsibilities of key partici-pants, such as the Asbestos Program Manager and custodial and maintenance supervisors and staff. The written O&M program should be available and under-stood by all participants involved in the management and operations of the building.

In general, the O&M program developed for a particu-lar building should include the O&M program elements discussed in the next chapter. However, the building owner should make sure that the O&M program developed is site-specific and tailored for the building.

The O&M program should take into account use, function, and design characteristics of a particular building.

Implementing and Managing an W&M Program A well-developed O&M program is ineffective unless the building owner is committed to implementing it properly The building owner should convey this com-mitment to key personnel involved in a building’s management and operations — particularly the As-bestos program Manager and custodial and mainte-nance supervisors and staff. The O&M program’s success is contingent upon key personnel understand-ing the O&M program and committing themselves to implementing it effectively

To the greatest extent possible, the building owner should incorporate the O&M program into the existing system for managing a building’s operations. Each building owner, therefore, will determine the appropri-ate organizational structure on a case-by-case basis.

Two possible arrangements are suggested in Figures 1 and 2 in Appendix C.

When managing an O&M program, the Asbestos Program Manager should oversee all asbestos-related activities. In instances where a building owner hires a contractor to perform custodial and maintenance work, the Asbestos Program Manager should ensure that the contractor is qualified to conduct work that may involve ACM. Before hiring a contractor, the Asbestos Program Manager should investigate to determine whether the contractor’s staff is qualified, trained and equipped to deal with O&M asbestos activities. Thoroughly check-ing the references of a contractor is a good recom-mended practice.

The Asbestos Program Manager should also monitor the work performed in the building by other contrac-tors, such as electricians and plumbers, who might inadvertently disturb ACM. Instituting a work permit system, as discussed in the next chapter, may prevent accidental disturbances of ACM. Under this system, a

A properly trained and protected build-ing inspector collect-ing a bulk sample of suspected asbestos-containing thermal system insulation.

contractor must receive a work permit from the Asbestos Program Manager before commencing work.

At that time, the Asbestos Program Manager will inform the contractor whether the project could disturb ACM and provide any special instructions to make sure the work is done properly Communication between the Asbestos Program Manager and tenants occupying the building is essential to prevent activities that might compromise the O&M program.

In addition, the Asbestos Program Manager should routinely and frequently check the work being per-formed in the building by contractors and custodial and maintenance staff to see if their work is disturbing ACM. By maintaining close surveillance over these activities, the Asbestos Program Manager can help ensure that work which may disturb ACM is being done safely Tenants should be required (by legal agreement or understanding) to notify the building owner or the Asbestos Program Manager before conducting even small planned renovations. This would help prevent building tenants from unknowingly disturbing ACM. For both the work permit system and the renovation notification requirement, clear and effective communi-cations to workers and tenants are crucial to the success of the O&M management program.

The Asbestos Program Manager should periodically review the written O&M plan to determine whether it should be updated. For example, if all ACM were removed from some areas of the building during a recent renovation, or if some ACM was damaged, the O&M program should be revised accordingly The O&M program should remain in effect as long as there is ACM present in the building.

The costs associated withCost Considerations implementing and manag-ing an O&M program may vary significantly depending on the types-of ACM, building-specific factors, actual O&M procedures adopted, types of equipment used, and the useful life of the building. Owners may find it more cost-effective to continue a well-supervised and managed O&M pro-gram than to incur the costs of immediate, large-scale removal. In addition to the direct costs of removal, other costs related to ACM removal include moving building occupants, arranging alternative space for building occupants during the removal work, and restoring the building after the removal is completed.

Clearly many factors enter into the decision. Only by conducting a cost-effectiveness analysis of the long-term options (e.g., comparing (a) immediate removal with (b) phased removal plus O&M with (c) removal just before demolition plus lifetime O&M) will owners be truly able to determine which option is most cost-effective for their buildings. The prudent owner may need to consult one or more qualified consultants or firms for advice, if such expertise does not exist within the owner’s organization, Selecting and Implementing Alternative Abatement Actions In some instances, due to the condition of ACM or upcoming building renovations, a building owner may decide to take other abatement actions to deal with ACM in the building. These response actions could include encapsulation (covering the ACM with a sealant to prevent fiber release), enclosure (placing an air-tight barrier around the ACM), encasement (covering the ACM with a hard-setting sealing material), repair, or removal of the ACM. Qualified, trained, and experi-enced contractors should be used for any of these actions. EPA’s Purple Book discusses most of these alternatives in some detail. In general, repair, encap-sulation, enclosure, and encasement, are intended to help prevent the release of asbestos fibers. As aspects of O&M, these techniques manage ACM in place. See Appendix F of this document for additional federal reference sources on asbestos response actions.

When determining which response alternative to select, the building owner and Asbestos Program Manager may consider seeking advice from qualified, independ-ent consultants with specific training and experience in asbestos management.

Asbestos consultants should have a background in engineering, architecture, industrial hygiene, safety, or a similar field. Experts who are Registered and/or with Board Certified backgrounds are recommended. To help ensure that no “conflict of interest” exists, consultants should not be affiliated with the abatement contractors who may be used on a recommended ACM control project, nor with analytical laboratories which perform sample analyses. As with other similar busi-ness decisions, building owners should interview sev-eral consultants and check references.

Renovations (including remodeling or redecorating) of buildings or replacement of utility system increases the potential for disturbing ACM. Before conducting any renovation or remodeling work, the building owner should have the Asbestos Program Manager review asbestos inspection and assessment records to deter-mine where ACM may be located, visually reinspect the area, and evaluate the likelihood that ACM will be disturbed. Any suspect or assumed ACM that could be disturbed during the renovation work should either be sampled and analyzed to determine whether it contains asbestos, or the work should be carried out as if the materials did contain asbestos. The Asbestos Program Manager should also ensure that no new ACM is introduced into the building as part of the renovation work.

Removal of the ACM before renovation begins maybe necessary in some instances. Removal is required by the Asbestos NESHAP regulations for projects which would break up more than a specified minimum amount of ACM; specifically at least 160 square feet of surfacing

Renovations (including remodeling or redecorating) of buildings or replacement of utility systems increase the potential for disturbing ACM.

Asbestos-containing thermal system insu-lation which has sus-tained significant damage in a mechan-ical/boiler room of a building.

or miscellaneous material or at least 260 linear feet of thermal system insulation (40 CFR 61.145-147). Build-ing owners and managers are encouraged to contact their state or local health or environmental department for further clarification of these requirements (also, see Chapter 6 of this document). It is important to ensure that new materials placed in the building do not contain asbestos in order to comply with the recent EPA Asbestos Ban and Phase Out rule (see Chapter 6).

In general, building owners should thoroughly consider any decision to remove ACM. O&M, encapsulation, encasement, enclosure, or repair may be viable alter-natives to removal. Building owners should assess these in-place management techniques carefully before deciding to remove undamaged ACM.

Under certain circumstances, however, such as when some ACM must be removed during building renova-tions, when the ACM has sustained a great deal of damage, or ACM disturbance will be difficult to manage properly the building owner may decide to remove ACM in parts of the building.

When removal must occur, only qualified, trained and experienced project designers and contractors should be permitted to design and perform the work. Building owners might consider contacting local, state, and federal asbestos regulatory agencies to see if prospec-tive contractors have received citations for violating asbestos regulations in the past. In addition, if the building owner and Asbestos Program Manager are not properly qualified themselves, they should retain a qualified and independent project designer and a project monitor with training and experience in asbestos abatement to oversee and ensure that the asbestos abatement work is done safely. When these precautions are taken, asbestos removal is more likely to proceed safely and effectively

Proper completion of the ACM removal is best evalu-ated by means of the analytical procedures using transmission electron microscopy (TEM). (These are described in 40 CFR Part 763, Appendix A to Subpart E.) Clearance protocols for statistically comparing asbestos fiber levels inside the work area with outside levels are available. If the measured levels inside are not statistically higher than the average airborne asbestos concentration measured outside the abatement area, the cleanup is considered successful, and the space is judged ready for reoccupancy (For reference, see Appendix H, U.S. EPA “Guidelines for Conducting the AHERA TEM Clearance Test . . . .")

Chapter Summary

Laying the foundation for a comprehensive asbestos control program for a building includes some basic steps. Important points contained in this discussion are the following

An Asbestos Program Manager needs to be The success of any O&M program lies in the properly qualified through training and experi- commitment by the building owner to imple-ence, and be actively involved in all asbestos ment it properly control and disturbance activities.

When outside contractors are used for as- An Asbestos program Manager should have bestos-related activities, their references and authority to oversee and to direct custodial/ training should be thoroughly checked and maintenance staff and contractors with regard their subsequent work monitored.

to all asbestos-related activities.

Periodically review written O&M programs.

An initial building inspection should be per-formed by a trained, qualified, experienced Alternatives or control options that may be inspector to locate and assess the condition of implemented under an O&M program include:

all ACM in the building.

● repair The inspection results serve as the basis for encapsulation establishing an O&M program. O&M pro- ● enclosure cedures may not be sufficient for certain ACM ● encasement that is significantly damaged or in highly ● removal (minor) accessible areas.

Removal of ACM before renovations may be An Asbestos Program Manager or qualified necessary in some instances. (See NESHAP consultant should develop the written O&M and State/Local regulations discussion in program that is site-specific and tailored for Chapter 6.)

individual buildings. The O&M program should take into account use, function and design characteristics of a building.

The success of any O&M program depends on the building owner’s commitment to implement it properly.

What Does an O&M Program Include?

O&M Program Elements

To achieve its objectives, an O&M program should include seven elements. Although these should appear in any O&M program, the extent of each will vary from program to program depending on the building type, the type of ACM present, and the ACM’s location and physical condition. For example, if only nonfriable ACM is present, minimal notification might be needed, and custodial or maintenance staff would most likely have fewer work practices to be followed. If friable ACM is present, a more detailed O&M program should be prepared and followed. Each of the first six elements listed below is described in this chapter to provide an illustration of a basic O&M program.

The seventh program element, training of the Asbestos Program Manager and custodial and maintenance staff, is very important. If staff are not adequately trained, the O&M program will not be effective. Chapter 5 is devoted exclusively to O&M training topics.

A successful O&M program should include the follow- Informing Building Workers, ing elements: Tenants, and Other Occupants

● Notification: A program to tell workers, Building owners should inform building workers, occu-tenants, and building occupants where ACM is pants, and tenants about the location and physical located, and how and why to avoid disturbing condition of the ACM that they might disturb, and stress the ACM. All persons affected should be the need to avoid disturbing the material. Occupants properly informed. should be notified for two reasons: (1) building occu-pants should be informed of any potential hazard in their If staff are ● Surveillance: Regular ACM surveillance to vicinity; and (2) informed persons are less likely to not adequately note, assess, and document any changes in the unknowingly disturb the material and cause fibers to be ACM’s condition. released into the air.trained, the O&M program will not ● Controls: Work control/permit system to Building owners can inform occupants about the be effective. control activities which might disturb ACM. presence of ACM by distributing written notices, posting signs or labels in a central location where

● Work Practices: O&M work practices to affected occupants can see…