P01 Asbestos_and_Lead_Paint_Survey_FINAL_Combined_15april16.pdf

Asbestos and Lead Paint Survey Final Resubmission for Bruce W. Carter Medical Center

Miami VA Healthcare System, Miami Florida Contract No.: VA248-15-P-1779

April 15, 2016

Prepared for:

Miami VA Healthcare System

1201 NW 16th Street Miami, Florida 33125 for

Bruce W. Carter Medical Center Miami VA Healthcare System, Miami Florida

Table of Contents Asbestos Containing Materials O&M Manual

Appendix A Regulations and Guidance Document Appendix B Forms Section II - Notification and Labeling

- Notification for Occupants and Contractors

- Labeling/Posting Log

- General Asbestos Awareness - Training Log

- Example Notification Letter

Section III - Training

- Level 1 - Training Log

- Level 2 - Training Log

- Level 3 - Training Log Section IV - Specialized Cleaning Procedures & Preventative Measures for Custodial/Maintenance Activities

- Initial and Periodic Cleaning Log

- Preventative Measures Checklist

- Preventative Measures Log Section V - Work Control Permit System

- Work Control Permit System Log

- Job Request Form

- Maintenance Work Authorization Form

- Maintenance Work Evaluation Form Section VI - Specialized Work Practices

- Small Scale O&M Activity Log

- Large Scale O&M Activity Log

- Contractor’s Submittal Checklist Section VII - Emergency Response Procedures

- Asbestos Spill/Fiber Release Log Section VIII - Periodic Inspection & Surveillance and Record Keeping

- Periodic Inspection Form Other Forms

- NESHAP Notification Form

Comprehensive Asbestos Re-Inspection Report Appendix A Approved Work Plan and Technical Approach Appendix B Photo Log Appendix C Re-Inspection Findings and Updated ACM Tables Appendix D Sample Location Drawings (Provided Electronically) Appendix E Asbestos Containing Material Drawings (Provided Electronically) Appendix F Laboratory Analysis Appendix G Consultant Credentials for

Bruce W. Carter Medical Center Miami VA Healthcare System, Miami Florida

Table of Contents (continued) Lead-Based Paint Operations and Maintenance Manual

Appendix A Health and Safety Program (Lead Specific)

Historic Report: Lead-Based Paint Screening Survey Appendix A Photograph Log of Positive Materials Appendix B XRF Screening Results Appendix C References and Industry Guidance Appendix D Lead Safe, Renovate Right Pamphlet

Bruce W. Carter Medical Facility – Hazardous Materials Abatement Cost Estimate

Asbestos Containing Materials O&M Manual

Asbestos Containing Materials O&M Manual

ASBESTOS CONTAINING MATERIALS

OPERATIONS AND MAINTENANCE MANUAL

For

Bruce W. Carter Medical Center

Miami VA Healthcare System, Miami Florida

March 25, 2016

Prepared for:

Miami VA Healthcare System

1201 NW 16th Street

Miami, Florida 33125

Inspection Report Prepared and Report Reviewed by:

Canyon Concepts Service, inc.

4072 Turnberry Court

Colorado Springs, Colorado 80909

Asbestos Operations and Maintenance Manual Bruce W. Carter Medical Center, VA Hospital Miami, Florida i

Table of Contents

1.0 INTRODUCTION TO ASBESTOS MANAGEMENT

Foundation and Purpose of an O&M Program

2.0 BACKGROUND ON ASBESTOS

3.0 ADVERSE HEALTH AFFECTS

The Respiratory System Asbestosis Lung Cancer Mesothelioma Risks Associated With Low Level Exposure

4.0 REGULATORY COMPLIANCE

Occupational Safety and Health Administration

5.0 POLICY STATEMENT

6.0 ORGANIZATION CHART

Asbestos O&M Program Manager Responsibilities

7.0 ASBESTOS INSPECTION

8.0 NOTIFICATION AND LABELING

Employee/Occupant Notification

9.0 REGULATORY AGENCY NOTIFICATION

10.0 TRAINING

Building Maintenance Staff Training Awareness Training Special O&M Training Abatement Worker Training Management/Administration Training Additional Training and Employee Protection Programs

11.0 NORMAL MAINTENANCE ACTIVITIES

Specialized Cleaning and Preventative Measures for Custodial or Maintenance Activities Specialized Initial and Periodic Cleaning Routine Cleaning Preventative Measures for Custodial/Maintenance Activities

12.0 WORK CONTROL PERMIT SYSTEM

Job Request Form Maintenance Work Authorization Form (MWAF) Maintenance Work Evaluation Form ii

13.0 SPECIAL WORK PRACTICES

Introduction and Assumptions Accidental Disturbance of Friable ACM Disturbance of ACM Intended or Likely

14.0 SUPPLEMENTAL PROCEDURES

Encapsulation of Damaged ACM Temporary Repair Procedures Replacement of Filters in HVAC Units Response Procedures in Disastrous Situations Removal Using Mini-Enclosure Technique Glove-Bag Removal Technique Pipe and Mudded Joint Packing Repair Vinyl Floor Tile, Linoleum, and Mastic Drill Into or Attach Item to Surfacing ACM Cementitious Panels and Other Cementitious Materials Trace (<1%) Asbestos Containing Materials

15.0 EMERGENCY RESPONSE PROCEDURES

Minor Fiber Release Episodes Major Fiber Release Episodes

16.0 PERIODIC SURVEILLANCE AND RE-INSPECTION

Periodic Visual Surveillance/Re-Inspection Periodic Air Monitoring Area Monitoring Exposure Monitoring

17.0 RECORD KEEPING

Appendices Appendix A – Regulatory Guidance Appendix B – Forms iii

Acronyms and Abbreviations

ACBM Asbestos Containing Building Material

ACM Asbestos Containing Material

AHERA Asbestos Hazard Emergency Response Act

APM Asbestos Program Manager

CCSi Canyon Concepts Service Inc.

C.F.R. Code of Federal Regulations

FDEP Florida Department of Environmental Protection

EPA Environmental Protection Agency f/cc Fibers per cubic centimeter

Fla. Admin. Code Florida Administrative Code

GAC General Abatement Contractor

HEPA High Efficiency Particulate Air

JRF Job Request Form

MWAF Maintenance Work Authorization Form

NESHAPs National Emission Standards for Hazardous Air Pollutants

Non RACM Non Regulated Asbestos Containing Material

NVLAP National Volunteer Laboratory Accreditation Program

O&M Operations and Maintenance

OSHA Occupational Safety and Health Administration

PACM Presumed Asbestos Containing Material

PEL Permissible Exposure Level

PPE Personal Protective Equipment

PLM Polarized Light Microscopy

RACM Regulated Asbestos Containing Material

The Facility Bruce W. Carter Medical Facility

TSI Thermal System Insulation

TWA Time Weighted Average

SWP Standard Work Practice

Miami VA Miami VA Healthcare System

1.0 INTRODUCTION TO ASBESTOS MANAGEMENT

Foundation and Purpose of an O&M Program This document constitutes the Operation and Maintenance (O&M) Program Manual for the Bruce W.

Carter Medical Center in Miami, Florida. CCSi prepared this program to minimize exposure of all building occupants to asbestos fibers from asbestos-containing materials (ACM) or asbestos-containing building materials (ACBM). The objective of this O&M program is to ensure work practices that:

Maintain the ACBM in good condition.

Cleanup previously released asbestos fibers.

Prevent further releases of asbestos fibers.

Monitor the condition of the ACBM.

This program addresses all types of ACBM discovered at the Bruce W. Carter Medical Center. ACBM falls into three general categories:

Surfacing ACM: Examples include sprayed on or troweled on ACM acoustical plaster on ceilings and fireproofing materials on structural supports.

Thermal System Insulation (TSI): Examples include ACM applied to pipes, boilers, tanks, and ducts to prevent heat loss or gain, or condensation.

Miscellaneous ACM: Examples include asbestos-containing ceiling or floor tiles, textiles, asbestos cement panels, asbestos siding, roofing materials, adhesives, sealants, pads, and gaskets.

The Environmental Protection Agency (EPA) and other regulatory agencies distinguish between friable and non-friable forms of ACBM. Friable ACBM can be crumbled or reduced to powder by hand pressure and is considered more likely to release fibers into the air. Non-friable asbestos cannot be reduced to powder by hand pressure; however, many types of non-friable ACBM can also release fibers if disturbed.

The program will provide specific direction on how to deal with each of these two categories of ACBM.

An O&M program is an integral part of an overall asbestos management plan. The O&M program, if properly followed, will control the release of asbestos fibers, thus minimizing exposure. The O&M program is not designed to replace other viable abatement alternatives such as removal, encapsulation, or enclosure. These other options are appropriate when ACBM materials are damaged beyond repair, disturbed routinely, or affected by maintenance, renovation, or demolition.

2.0 BACKGROUND ON ASBESTOS

The term “asbestos” describes six naturally occurring fibrous minerals found in certain types of rock formations. Of that general group, the minerals chrysotile, amosite, and crocidolite have been the 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 that 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. Once fibers are released into the air, they may be inhaled by people in the building.

Asbestos became a popular commercial product because it is strong, will not burn, resists corrosion, and insulates well. In the United States, its commercial use began in the early 1900s and peaked in the period between World War II and the 1970s.

Asbestos in buildings has been commonly used for thermal insulation and fireproofing. It has also been used in various building materials such as floor covering, ceiling tile, cement pipe, cement sheeting, corrugated paper pipe wrap, acoustical ceilings, and decorative treatments. It was often used as pipe and boiler insulation and spray-applied fireproofing or soundproofing.

Under the Clean Air Act of 1970, the EPA has regulated many asbestos-containing materials, which by

EPA definition are materials with more than one percent asbestos. The Occupational Safety and Health

Administration (OSHA), Asbestos Construction Standard regulates materials containing more than 0.1 percent asbestos. In the mid-1970s, several major kinds of asbestos materials such as spray-applied insulation and fireproofing and acoustical surfacing materials were banned by the EPA. This was done because of growing concern about health effects, particularly cancers associated with exposures to such materials.

Note: Reference is made to both ACBM and ACM. Several regulations make a distinction between the two categories. However, in the O&M portion of this document they are collectively referred to as ACM.

3.0 ADVERSE HEALTH AFFECTS

The adverse health effects associated with asbestos exposure have been extensively studied for many years. Results of these studies and epidemiological investigations have shown that inhalation of asbestos fibers may lead to increased risk of developing one or more serious diseases. Exactly why some people develop these diseases and others do not, is unclear. This discussion will examine each of the major diseases associated with asbestos along with the risks and how each risk can be minimized.

It is important to recognize that most people who have died due to asbestos exposure were workers employed in mining, manufacturing, or installation of asbestos. These workers were frequently exposed to high concentrations of asbestos fibers each work day with little or no protection. The asbestos abatement worker of today is required to follow specific work practices and wear appropriate protection, including a respirator, to minimize the risk of exposure.

The Respiratory System Since the primary asbestos health hazards affect the lung, it is necessary to gain a brief understanding of the respiratory system. Inhaled air passes through the mouth and nose into the windpipe or trachea.

The trachea splits into two smaller airways called the bronchi. Each bronchus divides into smaller and smaller tubes, which terminate into air sacs called alveoli. It is in the alveoli that oxygen is absorbed into small blood vessels, and waste gases such as carbon dioxide are passed out of the blood.

The lungs are located in the pleural cavity. This cavity and the outside of the lung have a membrane lining (called pleura) which looks like Saran-wrap. These linings are in contact with each other and are very moist. Like two panes of glass with a drop of water between them, these linings slide easily across each other, but are difficult to pull apart. Accordingly, as the chest cavity expands, the lungs expand and air rushes in. If these linings become damaged, inhalation cannot occur properly.

The body has several mechanisms by which it “filters” the air it breathes. First, very large particles are removed in the nose and mouth. Many smaller particles are caught by the mucous-coated walls of the airways. These airways have a hair-like lining (ciliated cells) which constantly beat upward. Accordingly, particles caught in the mucous are swept up into the back of the mouth where it is swallowed or expelled. Unfortunately, cigarette smoking temporarily paralyzes these ciliated cells inhibiting one of the body's natural defenses against unwanted dust. During the night, in absence of smoke, the hair-like cells start working again and carry large amounts of mucous into the back of the mouth. This causes the so-called "smoker's hack" in the morning. After the first cigarette or two, the cleansing mechanism is paralyzed again and the coughing stops. Therefore, cigarette smokers who are exposed to asbestos appear to be at greater risk. Other reasons will be discussed later in this section.

Even with the above-mentioned natural defenses of the body, some dust particles inevitably reach the tiny air sacs. When this occurs, large cells (called macrophages) attempt to engulf the particle and

"digest" it. Therefore, they are sometimes called the lung's garbage collectors. However, because asbestos is a mineral fiber, the macrophages are often not successful. When this occurs, these cells deposit a coating on the fiber and may begin forming scar tissue around it. This is another natural defense mechanism the body uses against unwanted dust and debris in the lung. If many asbestos fibers are inhaled and much scar tissue is formed, a condition known as asbestosis develops.

Asbestosis Asbestosis is a disease characterized by fibrotic scarring of the lung. This is a restrictive lung disease that reduces the capacity of the lung. The common symptom is shortness of breath. Asbestosis is prevalent among workers who have been exposed to large doses of asbestos fibers over a long period of time.

Accordingly, there is a clear dose-response relationship between asbestos exposure and developing this disease. This means the greater the asbestos exposure; the more likely asbestosis will develop. All forms of asbestos have shown the ability to cause asbestosis. As with all asbestos related diseases, it may take many years for the disease to show up. The typical latency period for asbestosis is 15-30 years.

Even after exposure to asbestos has ceased, scar tissue will continue to form around existing scar tissue and fibers in the lung. Limiting exposure will reduce the amount of new scar tissue, since additional fibers entering the lung will be reduced. The current OSHA Asbestos Standards contained in 29 C.F.R. §§

1910.1001, 1926.58 were enacted to help reduce asbestosis among asbestos workers, by reducing their daily exposure to asbestos.

Lung Cancer There are many causes of lung cancer, of which asbestos is only one. While employees exposed to industrial concentrations of asbestos in years past have an increased risk of getting lung cancer (five times), their risk is not as great as the cigarette smoker (ten times). However, a cigarette smoker who also works with asbestos is 50 times more likely to contract lung cancer than the normal nonsmoking population. Like asbestosis, there is a long latency period between initial exposure and the occurrence of lung cancer, typically 30 years. There appears to be a dose-response relationship between asbestos exposure and lung cancer although no "safe level" has yet been determined. Several research papers published in the mid-1980s have studied exposure levels for some forms of asbestos. They suggest that the occurrence of lung cancer related to asbestos will not exceed that of the general population, below certain exposure levels.

Mesothelioma The asbestos-associated disease of greatest concern is probably mesothelioma. Fortunately, it is also the rarest. Mesothelioma is a cancer of the chest cavity lining (mesothelium). It can also occur in the lining of the abdominal cavity. If it occurs in the chest cavity, it is called pleural mesothelioma. In the abdominal cavity it is known as peritoneal mesothelioma. This type of cancer spreads very rapidly and is always fatal. The exact mechanism of this disease remains unknown. There does not appear to be any increased risk of getting mesothelioma for smokers, and there does not appear to be a dose-response relationship between asbestos exposure and mesothelioma. Cases have been documented where the person's asbestos exposure has been limited, such as actor Steve McQueen (automotive brake linings).

Like other asbestos related diseases, mesothelioma often appears 30 to 40 years after initial exposure.

Several other diseases are found more often among persons exposed to asbestos more than the normal population. These include cancer of the esophagus, stomach, colon, and pancreas. Pleural plaques, pleural thickening, and pleural effusion can also result from asbestos exposure. Again, the importance of using proper work practices and respiratory protection cannot be overemphasized to minimize the occurrence of these diseases.

Risks Associated With Low Level Exposure Intact and undisturbed asbestos materials pose a low health risk: the mere presence of asbestos in a building does not imply that the health of building occupants is endangered. ACM that is in good condition and does not become damaged or disturbed is not likely to release asbestos fibers into the air.

However, when ACM is damaged or disturbed (e.g., by maintenance repairs conducted without proper controls) elevated airborne asbestos concentrations can create a potential hazard for workers and building occupants.

When discussing the risk posed by asbestos, it must be realized that asbestos fibers can be found almost everywhere in our environment (usually at low levels). At this time there is insufficient information concerning health effects resulting from low-level asbestos exposure. It is therefore difficult to accurately assess the magnitude of cancer risk for building occupants, tenants, and building maintenance and custodial workers.

Asbestos is hazardous, based on studies of asbestos workers and laboratory animals. However, the risks associated with low level, non-occupational exposure (e.g., a worker in a building containing ACM) are not well established. Attempts have been made to estimate low level risks by extrapolation from occupational exposure data; but this is not a straightforward process and its validity is questionable.

Based on a thorough review of the health effects literature, the EPA concludes: "there is no level of exposure below which the risks of contracting an asbestos related disease are zero." That is, there is no threshold level of exposure.

A 1988 survey sponsored by the EPA attempted to assess exposure to ACM in public and commercial buildings. According to the data, fewer public and commercial buildings contain friable ACM than do school buildings (20% versus 35%). However, limitations in the data prevent firm conclusions.

A mathematical model was developed by the EPA to assess risk. Risk calculations suggest that if asbestos exposure is eliminated in schools, we have the potential to significantly reduce the overall risk for this segment of our population which may later be exposed to asbestos in public and commercial buildings.

Of note, though the elimination of exposure in schools may reduce risk, the risk of exposure to asbestos elsewhere remains

Although the risk is likely to be negligible for building occupants, health concerns remain, particularly for custodial and maintenance workers. Their jobs are more likely to bring them into contact with the

ACBM, and may require them to disturb the ACBM during maintenance activities. For these workers in particular, an effective O&M program can greatly reduce asbestos exposure. The O&M program can also minimize asbestos exposure for other building occupants. Despite uncertainties associated with low level exposure risks, if we accept the fact that there is no safe level of exposure to asbestos, we should control or eliminate exposure.

4.0 REGULATORY COMPLIANCE

ACBM identified in this program is subject to the EPA National Emissions Standards for Hazardous Air

Pollutants (NESHAP) Regulations for Asbestos contained in 40 C.F.R. § 61 and the Florida Department of

Environmental Protection (FDEP) asbestos removal program contained in Florida Administrative Code

(Fla. Admin. Code) r. 63-257. Florida adopted the asbestos NESHAP by reference in Fla. Admin. Code r.

62-204.800.

Occupational Safety and Health Administration ACBM is subject to OSHA Standards for Asbestos contained in 29 C.F.R. § 1910.1001. Materials containing 1% or less asbestos may be subject to OSHA regulations if air concentrations are at or above the personal exposure limit (PEL) of 0.1 fibers per cubic centimeter (f/cc) or the excursion limit of 1.0 f/cc. Revised OSHA regulations for General Industry contained in 29 C.F.R. § 1910.1001 and the

Construction Industry contained in 29 C.F.R. § 1926.1101 include the following provisions for communication of hazards to employees:

Employers must inform housekeeping employees whether building components they maintain may expose them to asbestos.

Building owners shall maintain records concerning the presence, location, and quantity of ACBM in the building for the duration of ownership or occupancy. Also records shall be transferred to successive owners.

Where a building owner or employer identifies ACBM, labels or signs shall be affixed or posted to notify employees of what materials contain asbestos. These signs or labels shall be placed in areas where they will be noticed by employees who are likely to be exposed, such as entrances to mechanical rooms.

The OSHA regulations also identify four classes of asbestos work, with each class of work having specific work requirements.

Class I asbestos work means activities involving the removal of TSI and surfacing ACM and Presumed Asbestos Containing Material (PACM).

Class II asbestos work means activities involving the removal of ACM which is not TSI 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 means repair and maintenance operations, where "ACM", including thermal system insulation and surfacing material, is likely to be disturbed.

Class IV asbestos work means maintenance and custodial activities during which employees come in contact with ACM and PACM as well as activities to clean up waste and debris containing ACM and PACM.

OSHA requires employers to provide adequate training, exposure monitoring, personal protective equipment (PPE) and engineering controls based on the class of work performed.

5.0 POLICY STATEMENT

Employees and Contractors without proper training and supervision must not work with ACBMs if the activity might reasonably be expected to release asbestos fibers. Routine cleaning and maintenance of non-friable materials, (e.g., vinyl asbestos floor tiles) are permissible following specific established guidelines. All maintenance, repairs and cleanups, alterations, renovations, or removal that may release or re-entrain asbestos fibers must be accomplished by qualified asbestos contractors. Small scale short duration activities approved by the Asbestos Program Manager (APM) that follow the special work practices section of the O&M program may be conducted by properly trained and equipped individuals.)

6.0 ORGANIZATION CHART

The following is an administrative/organizational chart identifying personnel involved with the Asbestos

O&M Program.

Figure 1 – Organization Chart

Asbestos O&M Program Manager Responsibilities Asbestos Identification: Determine the location and nature of asbestos-containing materials within the facility. Notify building occupants and outside contractors performing work within the facility of the presence and location of ACM within the building.

Hazard Assessment: Determine the asbestos exposure hazards to which employees may be exposed during their work activities. This assessment must include measurements of exposure.

Training: Prescribe, coordinate, and oversee the delivery of appropriate training to all employees who may be potentially exposed to harmful concentrations of asbestos.

Work Practices: Prescribe precautions to be taken to perform work safely. Implement the Work Permit

Control System. Maintain copies of all job request forms and maintenance work authorization forms.

Coordinate maintenance of other documentation required under the O&M Program.

Contract Specifications for Asbestos Removal: Prescribe detailed specifications to be followed by the asbestos abatement contractor when performing work on facility premises. Prescribe and implement air monitoring and oversight of asbestos removal work. Coordinate asbestos abatement contractors and emergency response teams.

Initial and Periodic Re-cleaning: Prescribe, coordinate, and implement procedures for initial and periodic re-cleaning of designated portions of the facility.

Building Owner

APM

Custodial Maintenance

Services Construction

Services Contractors

Lawyer Consultants

Regulators

Periodic Surveillance: Prescribe, coordinate, and oversee semi-annual surveillance of all ACM in the facility. Implement semi-annual air sampling.

Compliance: Comply with all federal, state, and local regulations.

Documentation: Maintain all records of the Asbestos O&M Program.

7.0 ASBESTOS INSPECTION

Following the inspection of a building for asbestos, the APM should implement an ACM hazard assessment to assist with developing an overall strategic management plan. The hazard assessment involves analysis of factors contributing to the actual or potential exposure of building occupants to a hazardous substance. The materials are often prioritized to determine the appropriate response actions based on the results of the hazard assessment. Factors evaluated during a hazard assessment include the following:

Friability: Materials which are friable are more likely to release fibers, if disturbed, than non-friable materials.

Physical Damage: Accidental or deliberate contact with ACBM can result in damage. Evidence of physical damage includes, but is not limited to, finger marks, dislodged or missing pieces, scrape marks, and powders on horizontal surfaces.

Water Damage: Water damage is usually caused by roof leaks. High humidity in the vicinity of pools, locker rooms and lavatories can also cause water damage. Water dissolves and washes out binders, causing the ACBM to blister, delaminate, or transport asbestos fibers away from the

ACBM.

Disturbance Factors: The potential for the ACBM to be disturbed is determined by evaluating three factors: accessibility, vibration, and air movement. Accessibility of ACBM to service workers or other building occupants suggests disturbance by physical contact. Vibration due to activities of building occupants, the operation of mechanical equipment, or other influences can also disturb the material. Erosion of fibers from ACBM, by the force of air, is another form of disturbance.

Air Flow: An air flow transports fibers from the point of release of the ACBM to other areas in the building. Factors such as air plenums, air shafts, and elevator shafts represent different types of air flow.

General Occupancy Characteristics: These characteristics describe how many and which type of a building's occupants may be exposed to asbestos. This information is useful in prioritizing response actions in those areas of higher occupancy that generally deserve greater attention.

Condition assessments and evaluations were beyond the scope of work for the investigative inspections discussed in the previous section.

8.0 NOTIFICATION AND LABELING

The APM must notify building workers, occupants, and outside contractors about the location and physical condition of the ACM as well as stress the need to avoid disturbing the material. Occupants should be notified for two reasons:

Building occupants have the right to know of any potential hazard in their vicinity.

Informed persons are less likely to unknowingly disturb the material and cause fibers to release into the air.

Employee/Occupant Notification Part of the Asbestos O&M Program includes notifying building occupants of the presence of ACM. The

APM must decide which notification procedure will be most appropriate for the building occupants. The following forms are used to notify employees/occupants.

Written Notices: The APM shall decide if written notices should be posted in central locations where building occupants can see them. Written notices are an effective form of communication to outside contractors. Written notification will include the following statements and instructions:

Statement:

o “ACM has been found in the building and is located in areas where the material could be disturbed.”

o Include the condition of the ACM and the response which is appropriate for that condition.

Statement:

o “Asbestos only presents a health hazard when fibers become airborne and are inhaled.

The mere presence of ACM does not represent a health hazard.”

o Include the specific locations of confirmed or presumed asbestos containing materials.

o Also, include how to avoid disturbing the ACM.

Instructions:

o Report any evidence of disturbance or damage to ACM.

o Report any dust or debris that might come from the ACM or any change in the condition.

Awareness/Information Sessions, such as a general 2-hour awareness training, should be provided to custodial/maintenance individuals. The APM shall decide what other types of building occupants shall receive this awareness training. The specific information given to each type of building occupant will vary. Service workers carry out certain tasks that tenants often do not perform. Therefore, the service workers will receive additional information. Building occupants will receive the training necessary for them to perform their tasks safely.

Floor Plans The APM shall decide if drawings showing the locations of ACM should be posted in central areas showing asbestos locations on that floor, and whether to post where the building custodial/maintenance individuals can easily view them.

Area Posting and Material Labeling in service and maintenance areas will be placed adjacent to ACM to remind maintenance workers not to inadvertently disturb the ACM. Labeling, as opposed to notification, is not intended as general information. Labeling serves as a final line of defense to prevent unprotected individuals from disturbing ACM or entering areas where repair or renovation activities involving ACM are underway.

Signs will be placed at entrances to areas where ACM is prevalent, such as boiler rooms, and signs for areas shall read:

CAUTION

ASBESTOS-HAZARD

DO NOT DISTURB

WITHOUT PROPER

TRAINING AND EQUIPMENT

Prominent warning signs will be placed next to all boilers, pipes, and other equipment which contain

ACM. Warning signs placed directly on ACM shall read:

DANGER

CONTAINS ASBESTOS FIBERS

AVOID CREATING DUST

CANCER AND LUNG DISEASE HAZARD

DO NOT DISTURB

WITHOUT PROPER TRAINING AND EQUIPMENT

Warning signs used in conjunction with renovation or repair involving the disruption of ACM will be posted at the entrance and surrounding the perimeter of the project. Signs will be posted to prevent unauthorized persons from entering the work area. The signs shall read:

DANGER - ASBESTOS

CANCER AND LUNG DISEASE HAZARD

AUTHORIZED PERSONNEL ONLY

RESPIRATORS AND PROTECTIVE CLOTHING

ARE REQUIRED IN THIS AREA

Areas which are accessed by the general public may be labeled with danger stickers. However, depending on the location, the APM may not wish to display the sticker where viewed by the general public.

Contractors and subcontractors working at this facility shall be notified of the presence of ACM.

Contractors and subcontractors should review the O&M Plan for their information.

9.0 REGULATORY AGENCY NOTIFICATION

Prior to asbestos abatement, renovation, and demolition activities, the EPA and the State of Florida must be notified. The APM or the abatement contractor that will perform the work should make these notifications

10.0 TRAINING

The key element in initiating and carrying out asbestos O&M program is the building maintenance staff.

Two distinct types of training can be provided:

Building Maintenance Staff Training

Management/Administration Training

Building Maintenance Staff Training There are three levels of O&M training for custodial, maintenance and other personnel:

Awareness Training

Special O&M Training

Abatement Supervisor/Worker Training

The APM shall decide which levels of training to provide.

OSHA requires worker training programs for all employees exposed to fiber levels, either measured or anticipated, at or above the action level [0.1 f/cc 8 hour Time Weighted Average (TWA)] or the excursion limit (1.0 f/cc, 30 minute TWA). EPA requires worker training for those activities involving greater than

160 square feet or 260 linear feet of friable asbestos-containing material. All maintenance, custodial, and other personnel that work in a building with ACM should be trained to successfully deal with ACM in place, thus reducing the release of asbestos fibers.

The APM shall ensure that all maintenance, custodial staff, and others who work in a building containing

ACM receive awareness training. This applies whether or not they are required to work with ACM. New employees, custodial, and maintenance staff will be trained during employee orientation or within 30 days after commencement of employment.

Awareness Training Awareness level (hazard communication) training is designed for maintenance and custodial personnel, and other personnel involved in cleaning and simple maintenance tasks where ACM may be accidentally disturbed. (e.g., fixing a light fixture, changing light bulbs, or cleaning activities near ACM). This training will take place during the employee's orientation or within 30 days after commencement of employment. Such training will include the following topics:

Background information on asbestos

Health effects of asbestos

Worker protection programs

Locations of ACM within the building

Recognition of ACM damage and deterioration

The O&M Program for that building

Proper response to fiber release episodes

Name and telephone number of the APM

Special O&M Training This level of training is designed for individuals who perform emergency response and removal where a small scale disturbance of ACM is intended or likely, or for minor fiber release episode responses where less than three square feet or three linear feet of ACM is involved. Such training is at least 16 hours duration and involves more detailed discussions of topics included in Level 1 training in addition to the following topics:

Federal, state, and local asbestos regulations

Proper asbestos-related work practices

ACM handling methods (including waste handling and disposal)

Respirator use, care, and fit-testing

Use of protective clothing

Hands-on exercises for glove bag work, High Efficiency Particulate Air (HEPA) vacuum use, respiratory protection, personal protection measures, and good work practices

Worker decontamination procedures

Abatement Worker Training This is for abatement/emergency response personnel who perform asbestos abatement, such as large scale disturbances exceeding three linear or three square feet of ACM or responses to major fiber release episodes. The duration of the recognized abatement worker training courses approved by EPA and OSHA range from 24 to 32 hours. In addition, at least one person on site should be a certified

Abatement Supervisor. Abatement Supervisor training courses recognized by EPA must be 40 hours in length and performed by an approved training center.

This level of training is much more involved than Levels 1 and 2, although it includes some of the same elements. It will include the following specialized topics:

Preparation Activities before asbestos abatement work

Work Area Preparation

Establishing Decontamination Units

Personal Protection (including respirator selection, use, fit-testing, and protective clothing), Worker Decontamination Procedures.

Safety Considerations in the Abatement Work Area

Proper Handling and Disposal of ACM Wastes

In the state of Florida, if the amount of ACM disturbed exceeds 260 linear feet or 160 square feet, notifications, permits, supervisor accreditation, worker training requirements, and procedures will all apply. The APM shall ensure that all contract workers have received the appropriate level of training before they begin any work. Copies of training certificates may be required as evidence of training.

Management/Administration Training The APM is responsible for management and administration of the Asbestos O&M Program. The APM shall have a higher degree of technical training and shall be responsible for special activities and work practices. Within 90 calendar days after transfer to the owner responsible for operation and maintenance, the designated APM shall complete the following EPA approved training courses to obtain this technical knowledge:

Asbestos Inspector/Management Planner Course - 5 days

Asbestos Supervisor/Contractor Course - 5 days

Asbestos Project Designer Course - 3 days

For regional training providers, contact the Toxic Substance Control Act Assistance Hotline (202) 554-

1404.

Additional Training and Employee Protection Programs Certain worker protection programs are crucial for the success of the O&M Program. The following asbestos specific programs should be used in conjunction with this Asbestos O&M Program.

Hazard Communication Program.

Respiratory Protection Program.

Medical Surveillance Program.

Training Program.

Air Monitoring Program.

11.0 NORMAL MAINTENANCE ACTIVITIES

Normal maintenance activities can disturb ACM and raise levels of airborne asbestos. Maintenance workers must be cautioned against conducting any work in a manner that may disturb ACM. The nature and extent of special work practices are tailored to reflect the likelihood that the ACM will be disturbed and that fibers will be released. Three categories of potential disturbances are defined:

Contact with ACM Is Very Unlikely.

Accidental Disturbance of Friable ACM Is Possible.

Disturbance of ACM Is Intended or Likely.

Special work practices are designed to reduce or contain materials, dust, or fiber releases resulting from work performed on or near asbestos-containing materials. The work practices are also intended to minimize the extent or impact of any releases that do occur. The procedures provided are not exhaustively complete and do not document every established/accepted procedure for every possible situation. The APM shall be responsible for review and approval of any special work practices that are implemented.

Specialized Cleaning and Preventative Measures for Custodial or Maintenance Activities Cleaning up existing asbestos contamination within a facility is one of the primary objectives of the O&M

Program. Dry brooms, mops, dust cloths and standard vacuum cleaners can release asbestos fibers into the air, requiring special cleaning procedures. Repair of any damaged asbestos should be performed in conjunction with cleaning activities. It is essential that specialized cleaning procedures be implemented by the APM.

Maintenance and custodial personnel should never touch, attempt to clean-up, or repair damaged materials which have been found to contain asbestos. If debris from materials which are asbestos-containing is found, the program manager should be notified immediately. If ACM is in an area, some level of exposure potential exists. If damaged ACM is in an area, it should be assumed that exposure has occurred and the potential for future exposure still exists.

In locations where friable ACM is identified, initial cleaning and periodic cleaning (and any repair) shall be conducted by a qualified abatement contractor as described in this section.

Specialized Initial and Periodic Cleaning This section is designed to address areas of concern where damaged or delaminated asbestos containing materials have potentially impacted the space or functional area that is typically accessed by building maintenance personnel in their daily activities. This is determined by the APM during the recommended periodic inspections of the mechanical spaces of the building based on historic knowledge of the

ACM/PACM throughout the building and the determination to assume the material as asbestos or collect bulk samples for analysis.

Initial spill response should be performed to remove any asbestos contamination that could cause exposure to asbestos and the APM should continually inspect the area to evaluate if additional spill response by a general abatement contractor is required.

Properly trained and equipped contractors (to be performed by qualified contractors at the direction of the APM) must conduct a thorough initial cleaning in affected areas of the building as soon as the O&M

Program is in place. A combination of wet-mopping, wiping, and HEPA vacuuming must be used to clean all surfaces within the building where ACM has been identified. The following procedures should be observed:

Carpets, curtains, and other porous surfaces should be HEPA vacuumed, and then steam cleaned.

Floors shelves, cabinets, light fixtures, and other horizontal surfaces should be wet wiped.

Uncarpeted floors should be HEPA vacuumed then wet mopped.

Cloths, vacuum filters, cartridges, mop heads, and other materials used in the process should be disposed of as asbestos-containing materials.

Ladders, mops, buckets, vacuum cleaners, and all cleaning equipment should be washed or wiped with damp cloths when the cleaning is finished.

It is important for O&M workers to use caution when handling HEPA vacuums and contaminated materials. Exposures could result from the cleaning process or improper filter changes. The APM must evaluate the need for workers to wear respiratory protection or protective clothing. It may also be prudent to schedule this type of cleaning after normal working hours. Cleanup of damaged ACM should never be performed without the use of respiratory protection. Repair of any damaged asbestos should be performed in conjunction with cleaning activities.

Sometimes damaged ACM will be located in an “air plenum.” These fibers can be transported by the heating, ventilation, and air conditioning (HVAC) system throughout the building. Special cleaning practices may be extended to the entire building, including the HVAC system itself. Include HVAC filter replacement as part of the cleaning process.

Special cleaning practices are appropriate for a building with exposed surfacing, thermal or miscellaneous ACM, especially if the ACM is friable. If gradual deterioration or damage of ACM has occurred, asbestos-containing dust or debris could be present. The program must include subsequent specialized periodic or episodic cleanings to prevent disturbance of the ACM dust.

In general, less frequent periodic cleanings will be required in areas where:

Only non-friable ACM is present.

ACM, which has been encapsulated, has been encased or enclosed behind airtight barriers.

ACM is known to be undamaged or undisturbed since the last cleaning.

ACM is confined to a single room (special cleaning of just that area may be sufficient).

The APM shall be responsible for determining the necessary intervals for periodic cleaning. Periodic cleaning shall be conducted on an annual basis in functional spaces where friable ACBM has been identified. The APM shall record the initial and periodic cleaning dates in the “Initial and Periodic

Cleaning Log.” Supplemental information shall be filed.

The Installation Head/Maintenance Supervisor shall inspect each of the specialized initial and periodic cleanings to ensure adequate performance by the abatement contractor.

Routine Cleaning Special cleaning practices for day-to-day activities are appropriate for a building with exposed asbestos-containing material, especially where this material is friable. Building maintenance and/or custodial personal that have had a 2-hour asbestos awareness class may perform these activities. Dust and debris in an area containing friable ACM shall not be dusted or swept dry, or vacuumed without using a HEPA filter. The use of wet cleaning methods and HEPA vacuums for day-to-day cleanings will minimize the potential for disturbance during routine cleaning. A qualified contractor shall perform disposal of contents of vacuum or filter replacement. The following precautions apply to the maintenance of flooring materials that contain asbestos:

Sanding of flooring is prohibited.

Stripping of finishes shall be conducted using wet methods and low abrasion pads at speeds lower than 300 rpm.

Burnishing or dry buffing may be performed only on asbestos-containing flooring that has sufficient finish so that the pad cannot contact the asbestos-containing material.

Custodial and maintenance workers in the course of normal work can also identify and report areas, which are in need of special cleaning or repair.

Preventative Measures for Custodial/Maintenance Activities Preventative training of custodial and maintenance workers will significantly reduce the potential for disturbance of, and exposure to, asbestos. Preventative measures provide general guidelines for day to day operations of custodial and maintenance staff. The APM can take many steps to prevent accidental disturbance of ACM (e.g., limit access to areas containing ACM to maintenance and custodial personnel only).

Where potential exists for disturbance of ACM, access should be limited, if possible. Certain custodial and maintenance activities occurring in the vicinity of ACM can also cause damage, which may result in asbestos fiber release. Maintenance and custodial personnel should be instructed as follows:

Avoid bumping ACM with mops, brooms, vacuums, ladders, and other cleaning equipment.

Avoid dry stripping or buffing of asbestos floor tile.

Avoid disturbing ACM when changing light bulbs. If contact is likely, inform APM so it may be managed under the O&M Program.

Do not drill, cut, abrade, sand, chip, break, saw, puncture, remove, or alter of ACM.

Do not attach pictures, posters, plants, or other objects to ACM.

Do not lean anything (mops, brooms, etc.) against any material identified as ACM.

Do not store any materials or equipment near or on any material identified as friable ACM.

Do not stand on, or otherwise use materials identified as ACM as a ladder or stool.

When carrying large items through areas where ACM has been identified, be careful not to damage or disturb material.

Do not damage asbestos material when moving furniture, or other items.

Do not allow curtains, drapes or dividers to damage asbestos materials.

Do not dust with a brush or dry sweep floors where friable ACM is present. Instead, dust with a damp cloth and wet mop the floors.

Do not use an ordinary vacuum where friable ACM is present. Instead use a HEPA vacuum.

The situations listed above can cause the release of asbestos fibers, even if the ACM has been encapsulated. All dusting and mopping in spaces with ACM must be done with wet cleaning techniques.

The APM will decide how information on preventative measures for custodial and maintenance activities will be distributed, which may include the following methods:

Preventative measure information will be posted in designated areas throughout the building along with small-scale floor plans showing ACM locations. Refer to floor plans located in “Informing Building Occupants” section of this document.

Custodial and maintenance staff will receive, read, and sign a copy of the “Preventative Measures Checklist” located in Appendix B. These checklists shall be kept on file by the APM.

The APM shall maintain the “Preventative Measures Log.”

12.0 WORK CONTROL PERMIT SYSTEM

A work control permit system should be designed to control all work that could disturb ACM. The APM is responsible for providing information about the work permit system for any operations and maintenance work. A Job Request Form (JRF) and Maintenance Work Authorization Form (MWAF) must be completed by the individual anticipating performing the activity prior to beginning work. Where possible, the APM should integrate the work control permit system with existing documentation and procedures to ease implementation and acceptance of the system. The JRF/MWAF only applies to facility maintenance personnel that might impact or disturb asbestos that is part of their daily job duties.

These individuals will at a minimum have the 2-hour asbestos awareness training and a direct understanding on the location and type of ACM within their work area.

Job Request Form The job request form (JRF) gives the time and location of the requested work, the type of work needed, and the type of material present at the work location. The contractor or authorized person performing the work is identified in the form. Initially, all daily custodial and maintenance activities should be reviewed by the APM to determine if in-place work procedures are adequate to ensure that no ACM is disturbed.

All in-house personnel must complete a JRF and receive the APM’s (or designated representative’s) approval prior to beginning work. Outside contractors must also complete a JRF and receive a MWAF from the APM (or designated representative). The APM has the discretion to delegate work control permit activities.

All occupants and outside contractors must be informed of the procedures for completing a JRF…