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DOCUMENT RESUME 



ED 326 981 



EA 022 545 



TITLE 



PUB TyPE 



REPORT NO 
PUB DATE 
NOTE 



INSTITUTION 



Managing Asbestos in Place: A Building Owner's Guide 
to Operations and Maintenance Programs for 
Asbestos-Containing Materials. 

Environmental Protection Agency, Washington, D, C. 

TS-799 

Jul 90 

50p- 

Guides - Non-Classroom Use (055) 



EDRS PRICE 
DESCRIPTORS 



IDENTIFIERS 



MF01/PC02 Plus Postage. 

^Asbestos; ^Building Operation; Environmental 
Standards; Facility Improvement; Federal Regulation; 
^Hazardous Materials; Maintenance; Occupational 
Safety and Health; Operating Expenses; Program 
Development 

^Environmental Protection Agency 



ABSTRACT 



Instructions for building owners on the selection and 



application of appropriate asbestos control and abatement actions are 
presented in this guidebook. Chapter 1 offers background information 
on the asbestos problem. Chapter 2 describes the purpose and scope of 
an operations and maintenance (O&M) program. The third chapter 
discusses planning steps, including a survey and evaluation of 
asbestos-containing materials and program implementation and 
management, with a focus on cost. Work practices, recordkeeping 
suggestions and requirements, and elements of an O&M program are 
described in chapter 4. Chapter 5 offers training recommendations for 
workers performing O&M activities, and the last chapter provides an 
overview of federal, state, and local regulations. Appendices contain 
a glossary, sample recordkeeping forms, organization charts, 
additional assistance contacts, respiratory protection 
recommendations f existing EPA guidance, and a sample list of suspect 
asbestos-containing materials. (16 references) (LMI) 



* Reproductions supplied by EDRS are the best that can be made 

* from the original document. 



I 

I- 



Managing Asbestos In Place 

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




r" 



Contents 



ACKNOWLEDGEMENTS v 

FOREWORD vi^ 

1. WHY IS ASBESTOS A PROBLEM? 

Introduction and Overview 1 

• Background 2 

• Chapter Summary 4 

2. WHAT IS AN O&M PROGRAM? 

Purpose and Scope of an Operations and Maintenance Program 5 

• Purpose of O&M Program , 5 

• Scope of an O&M Program 5 

• Chapter Summary 6 

3. H0W DOES THE PROGRAM START? 

Laying the R)undation for an Effective O&M Program 7 

• The Asbestos Program Manager 7 

• Building Inspection and Assessment 7 

• Developing an O&M Program 8 

• Implementing and Managing an O&M 

Program 8 

• Cost Considerations 9 

• Selecting and Implementing Alternative Abatement Actions 9 

• Chapter Summary 11 

4. WHAT DOES AN O&M PROGRAM INCLUDE? 

O&M Program Elements 12 

• Informing Building Wbrkers, Tenants, and Other Occupants 12 

• ACM Surveillance — Reinspection and Periodic Surveillance 14 

• Supplement to Visual/Physical Evaluation 14 

• Work Control/Permit System 15 

• O&M Work Practices 16 

— Woricer Protection Programs 17 

—Basic O&M Procedures 18 

— O&M Cleaning Practices 19 

— Procedures for Asbestos Fiber Release Episodes 20 

• Recordkeeping 22 

• Chapter Summary 22 

5. WHAT O&M TRAINING IS NECESSARY? 

Types (rf Training 23 

• Chapter Summary * * 25 



4 



Hi 



6. WHAT REGULATIONS AFFECT ASBESTOS MANAGEMENT PROGRAMS IN 
BUILDINGS. ESPECIALLY O&M PROGRAMS? 

Federal, State, and Local Regulations Affecting O&M Programs 26 

• OSHA Regulations & EPA Worker Protection Rule 26 

— Small-scale, Short-duration Projects 27 

• EPA National Emission Standards for Hazardous Air Pbllutants (NESHAP) Regulations 27 

-Notification 28 

—Emissions Control and Waste Disposal 28 

• Resource Conservation and Recovery Act (RCRA); Comprehensive Emironmental Response, 
Compensation, and Liability Act (CERCLA, or "Superfiind") 28 

• Asbestos Hazard Emergency Response Act (AHERA) 28 

• Asbestos Ban and Phaseout Rule 28 

• Chapter Summary 29 

APPENDIX A. 

Glossary 30 

APPENDIX B. 

Sample Recordkeeping Forms 31 

APPENDIX C. 

Illustrative Organization Charts 35 

APPENDDCD 

Additional Assistance (EPA, NESHAP, OSHA; Training) 37 

APPENDIX E. 

Respiratory Protection Recommendations 38 

APPENDIX F 

Existing EPA Guidance For ACM Control 39 

APPENDKG 

Sample List: Suspect Asbestos-Containing Materials 40 

APPENDKH. 

References 40 



This document was prepared under contract to an agency of the United States Government. Neitlier the United States Government 
nor any of their employees makes any warranty, expressed or impbed, oi assumes any legal liabihty 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 



niSCLAIMER 

This document was prepared under contract to an agency of the United States Government. Neitlier the United States 
nor any of their employees makes any warranty, expressed or impbed, oi assumes any legal liability for any third party *£ 
results of such use of any information, product, or process discussed in this document. Mention or illustration of com] 
names, or of commercial products does not constitute endorsement by the U.S. Environmental Protection Agency. 



Acknowledgements 



The time and effort that many individuals contributed to the development of this document is 
gratefally acknowledged by the US. 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 EFA 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 impoi tant contributions 
within the Environmental Assistance Division came 
from Tom Tillman and Dave Kling. Sylvia Thomas 
provided necessary assistance in revisions of the early 
drafts. Esther Tepper a^id Jane Gurin helped review the 
Guide in its fin?J revisions, to make sure the document 
was written in easy-to-understand language. 

The original work whiai provided the foundation for the 
project was performed under a contract with Battelle 
Meniorial 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, US. 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, US. EPA Region V 
Ri'^hard Roth, Social Security Administration 
Sims Roy, US EPA, Office of Air Quality 

Planning and Standards 



ERIC 



6 



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 contiibution of the Policy Dialogue Group on 



Asbestos in Public and Conmftrcial Buildings, vMdi 
met several times during 1989-1990. ITie purpose of 
this multi-disciplinary 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. 



Foreword 



in February 1988, the Administrator of the Environmental Protection Agency (EPA) recommended 
to Congress that the Agency ^wrk during the next three years to enhance the nations technical 
capability in asbestos by helping building ov/ners 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 Cmtrolling Asbestos-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 cf in-place management. The guide's pur- 
pose is two-fold. First, it offers building owners the 
more detailed and up-to-date inbtructimi they need to 
carry out a successful O&M pro^F^. Second, it 
informs building owners, lenders, and insurers that a 
properly conducted O&M program can in mai^ case^ 
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 five 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 
dsbestos-related disease. How many fibers a person 
must bi^^athe to develop disease is uncertain. However, 
at very low exposure levels, the risk may be 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 au* levels in a smaii 
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. 



ERIC 



8 



vii 



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, 3:)bestos 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. 



FACT FIVE: EPA does recommend a pro- 
active, in-place management program 
whenever asbestos-containing materj?ii 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 
miiiimizes release of asbestos fibers into the air, and 
ersures 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. 



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 wellnlesigned and properly performed, can 
actually increase health risk. 



ERLC 



9 




Why Is Asbestos a Problem? 

Introduction: Asbestos in Buildings 



This U.S. Envlronment3l Protection Agency (EPA) guide is primarily directed to owners and 
managers of office buildings, shopping centers, apartment buildings, hospitals, and similar facilities 
\^ch 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 m 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^ontaining materials (ACM) in good condition. 



In this document you will find the following information: 

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

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

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

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

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

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

0 An overview of federal regulations, including 
those aifecting 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* 



O&M There are steps which a building 
HOW U6t 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. 



10 



1 



Air Pbllutants (NESHAP) regulations on asbestos may 
require ACM removal prior to renovation and/or 
demolition projects, to prevent sigmficant asbestos 
releases into the air ( ee 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 tlian 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 



A K *^ Asbestos fibers can cause se- 
The Asbestos . „ . 

. nous health problems. If in- 

haled, they can cause diseases 
which disrupt the normal functioning of the lungs. 
Three specific diseases— asbestosis (a fibrous scarring 
of thelungs), 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 oi 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 kin^' of O&M program 
can also minimize asbestos exposures for other building 
occupants as well. 



What is 
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 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 i900'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. 



In February 1988, the 
EPA released a report 
titled EPA Study of As- 
bestos-Containing Ma- 
terials in Public Buildings: A Report to Congress, EPA 
found that "friable" (easily crumbled) ACM can be 



Where is Asbestos 
Likely to be Found 
in Buildings? 



11 



found in an estimated 700,000 public and commercial 
buildings. About 500,000 of those bu^' lings axe believed 
to contain at least scwne damaged asbestos, and scwne 
aieas of significantly damaged ACM can be found in over 
half (tf them. 

According to the EB\ 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 >vould be 
limited to service and maintenance >vori<ers. FHable 
ACM, if present in air plenums, can lead to distribution 
d 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 conmionly 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 sudi 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 positwe identification 
of asbestos be ascertained merely by visual examina- 
tion. Instead, a qualified laboratory must analyze 
representative samples of the suspert material. Appen- 
dk G contains a sample list of some suspect materials. 




When is Asbestos 
a Problem? 



Intact and undisturbed 
asbestos materials do 
not pose a health risk. 
The mere presence of asbestos in a building does not 
mean that the health of building occupants is endan- 



gered. ACM \^uch is in good conditkm, and is not 
somehow damaged or disturbed, is not likely to release 
asbestos fibers into the a;r. 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 neg^ble level. 

However, asbestos materials can become hazardous 
vAien, due to damage, disturbance, or deterioration 
over time, they release fibers into buikiing air. Under 
these conditions, Mlien ACM ^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 buikiing occupants. 



ACMwtiich itifipooc 
phyftlcsi conditkm. 
Ul1dtcapro^op•^ 
aUofissndmatat*- 
lUMlc•pffOg^MltCO^ 
rsctivs actkm would 
normaMyprovofit 
dottf knation of tho 
insvlstlofi. 




ACM with uound 
ttrticttiral inttgrlty 
ofittiooxtorlorof a 
domottic hot wattr 
taiUc. Nolo that tho 
ifiaiilatlofiJaclcotiRg 
ia intact and thoro 
ianoovidoncoof 
ditturbanco. 



12 



This document, directed to owners and managers of office buildings and similar facilities, should help 
lay the groundwork 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 
cause asbestosis, lung cancer and meso- 
thelioma. Much of our knowledge of these 
health effects has come primarily from studies 
of workers exposed routinely to very high levels 
of asbestos in their jobs. 

Information on health effects of low-level 
asbestos exposure is less certain; custodial/ 
maintenance workers who sometimes disturb 
asbestos as part of their job would benefit from 
properly executed O&M programs. 

Three of the six naturally occurring asbestos 
minerals, chrysotile, amosite, and crocidolite, 
have been most commonly used in building 
products. 

Asbestos became a popular commercial prod- 
uct because of its strength, heat resistance, 
corrosion resistance, and tliermal insulation 
properties. 



Asbestos-containing materials (ACM) are reg- 
ulated by EPA, OSHA, and the Consumer 
Product Safety Commission (CPSC), and indi- 
vidual state and local agencies. 

Friable ACM can be found in about 700,000 
public and commercial buildings. Many areas 
where asbestos is found are not accessible to 
the general public. 

Some common uses of asbestos have included 
pipe/boiler insulation, spray-applied fireproof- 
ing, floor and ceiling tile, cement pipe/sheeting 
and paper pipe wrap. 

Positive identification of asbestos requires 
laboratory analysis; information on labels or 
visual examination only is not sufficient. 

Intact, undisturbed materials generally do not 
pose a health risk; they may become hazardous 
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 miniiiiize exposure of all building occupants to 
asbestos fibers, lb 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&iVI Program 

An effective O&M program should address all types of 
ACM present in a building. ACM that may be managed 
as part of an O&M program in buildings can be 
classified in one of the following categories: 



1 Surfacing Material: Examples include 
ACM sprayed or troweled onto surfaces, suclj 
as decorative plaster on ceilings or acoustical 
ACM on the underside of concrete slabs or 
decking, or fireproofing materials on struc- 

I tural members. 

2 Thermal System Insulation (TSI): Exam- 
pies include ACM applied to pipes, boilers, 

L tanks, and ducts to prevent heat loss or gain, 

or condensation. 

3 Miscellaneous ACM: Examples include 
asbestos-containing ceiling or floor tiles, tex- 

I tiles, and other components such as asb^tos- 

cement panels, asbestos siding and roofing 
materials. 

The O&M program, when developed and implemented I 
in a particular facility, ^ould include specific direction j 
on how to deal with each of these genti-al 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 imroWe surfacing, ther- 
mal, or miscellaneous ACM. Some elaboration of O&M 
work practices and procedures is found in Chapter 4. 

I ERIC 14 



The O&M program can be divided into three types of 
projects: 

O those which a;e unlikely to involve any direct 
contact with ACM; 

O those which may cause accidental disturbance 
ot ACM; 

O those which involve relatively small distur- 
bances of ACM. 

The first type may invoke routine cleaning of shelves 
and counter tops or other surfaces Li a building 
(provided ACM debris is not present). Generally, such 



Antxampleof tpray- 
applied surfacing 
ACMonamftaidacK 
abovaatuspandtd 

ctllinc; 



' -'-'"lei 




An«xamploof «»• 
h«sto«^ont«lning 
ttmm«l tytttm insu- 
lation on pipts In a 
iNiiMInK^ mechanical 
room* 



activities would iwt be expected to disturb ACM The 
second type of project could include maintertance woric 
above a suspended ceiling in an area that may have 
surfodng ACM overhead. The third typ^ of project- 
smaD-sade, sh(wrt-duration niaintenance, repair, or 
installation projects invohong minor disturbances of 
ACM — includes acthrities such as imtallation of new 
light fbctures on or in an ACM ceiling. A ^n£^ ^ovebag 
operation to remove a small amount of ACM to repair a 
pipe in a boiler room is another esrami^e of intentional 
small-scale, short-duration disturbance. 




jAn examplo of an 
atboitot*c6ntilnlnjf 
ctmontshaatproiluct 
(mlaoallaiiooua ACM), 



Larger pn))ecb invohong nK)re conq^ 
the mtentional removal ct ACM are considered asbestos 
abatenoent projects. These require asbestos control and 
abatenoent procedures that are outside the scope of an 
O&M program. Before taking action, building owners 
should consult qualified profes^onals for advice and 
altematwe solutions. Guidance for buiWiog owners on 
the management <rf abatement projects is included in 
ER\'s^"Guidance for ControlKng'Asbestos-^taining 
Materials in Buildings " June 1985, also known as the 
"Purple Book.^ 




The purpose df an Operations and Mamtenance 
Ptp£p[Bm is to miiunuze e3qx^ 
ocaq)ants to asbestos fibers. Through super- 
vised work practices, ACM can be managed in 
I^ce. Important points to remember are: 



ACM can be classified into three categories: 
O Surfacing Material 
O Thermal System Insulation (TSI) 
O Miscellaneous Material 



O&M Programs can be divided into three types of 
projects: 

O Unlikely to involve direct contact witli ACM. 

O Accidental disturbance of ACM, 

O Small-scale, short-duration maintenance or 
repair activity, >^ch may invoke intentional 
disturbance of ACM, 



How Does the Program Start? 

Laying the Foundation for an Effective O&M Program 



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



O Appoint an Asbestos Program Manager ?nd 
develop an organizational policy. 

O 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. 

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

O Implement and manage the O&M program 
conscientiously. 

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

This chapt'^r provides information about e?xh of these 
basic steps. In addition, see Appendix F for a chai t of 
references outlining existing EPA guidance for each of 
these steps. 



The Asbestos Program IVIanager 

The position oi Asbestos Program Manager (APM) is 
frequently held by the building engineer, superinten- 
dent, facilities manager, or safety and health director. In 
a smaD organization, the building owner may have this 
role. Regardless of ^\*o 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 nece? ary to develop and 
manage an asbestos control program prior to beginning 

ERIC 



die 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 : 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 Cooi-dinators 
(listed in Appendix D). 

Tne 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 



JL b 



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. 




A properly trained 
and prot«ct«d build- 
ing inspector collect- 
ing a bulk sample of 
suspected asbestos* 
containing th<trmal 
system insulatit^r. 



Program Manager (rfmspectionfindi^ the 
inspection niay show that ACM is «o/ 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 paiormed in conjunction with mjyor 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 cleai^^ the O&M polides 
and iTOceduies for that bdlding, identify and describe 
the administrative line d authority for that building, and 
should clearly define the responsibilities of partid- 
pants» such as the Asbestos Program Manager and 
custodial and maintenance supervisors and st^. The 
written O&M program should be available and under- 
stood by all participants invohred in the management 
and operations oS 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-spedfic 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 O&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 invoked in a building's 
management and operations — particularly the As- 
bestos Program Manager and custodial arid mainte- 
nance sn)ervisors and staff. The O&M program's 
success is contingent upon key personnel understand- 
ing the O&M program and committing themsdves to 
implementing it effectively 

lb Lhe greatest extent possible, the building owner 
should incorpo rate the O&M program into the existing 
system for managing a building's (q^erations. Each 
buikling owner, ther^re, will determine the appropri- 
ate organizational structure on a case-by-case basis. 
Tm possible arrangements are suggested in Figures 1 
and 2 in ^pendbc C 

When managing an O&M i>rQgram, the Asbestos 
Program Manager should cversee all asbestos-idated 
activities. In instances ^^iiere 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 woric that may invoke 
ACM. Before hiring a contractor, the Asbestos Pn^ram 
Manager should investigate to determine vsiiether the 
contractor's staff is qualified, trained and equipped to 
deal with O&M asbestos activities. Thorou^ check- 
ing the references of a contractor is a good recom- 
mended practice* 

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



ERIC 



17 



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 wiiether 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 bemg 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 pern^at system and the renovation 
notification requirement, clear and effective communi- 
cations to workers and tenants are crucial to the succebb 
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. 



Cost 

Considerations 



The costs associated with 
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 pi us 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 hygitr.*^, safety or 
a similar field. Experts who are Registered and/or with 
Board Certified backgrc.inds are recommended. To 
help ensure that no conflict of interest" exists, 
consultants should not be affiliated with theabatement 
contractors who maybe 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 
' ampled and analyzed to dete. mine 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 may be 
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 
utUity systems 

increa*^e the 

potential for 
disturbing ACIVI. 



ERIC 



9 




^ Atlmtoft-cofitaining 
1^ tii«rm«l tytttm insu- 
1 iitlofl which hat MS* 
1^ taintd significant 
f damaf t In a machan- 
Ical/boilerroomof a 
^ iMiHtflnC. 



I: 

|er!c 



or misc^ianeous imterial or at le^ 
thermal system insulation (40 CFR 61.145-147X Build- 
ing owners and managers are encouraged to contact 
their state or local health or environmental department 
for further clarification (A 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^oHnply with the recent EPA 
Asbestos Ban and Phase Out rule (see Chapter 6). 

In general, building owners should thoroughly considei* 
any decision to remove ACM. (Xfey'f, 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, v^en the ACM has sustained a great deal cA 
damage, or ACM disturbance will be difficult to manage 
prop^, 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 woric. Building 



owners might consider contactmg local, state, and 
federal asb^tos regulatory agencies to see if prospec- 
twe contractors have recewed citations for violating 
asbestos regulations in the past. In addition, if the 
building owner and Asbestos Program Manager are not 
property qualified themseWes, the^^* should retain a 
qualified and independent project designer and a prefect 
monitor^ with training and-experience in asbestos 
abatement to oversee and ensure that the asbestos 
abatement woric is done safely When these precautions 
are taken, asbestos removal is more likely to proceed 
safely and effectively 

Proper completion of the ACM rema.al is best evalu- 
ated by means of the analytical procedures using 
transmission dectron microscopy (TEM). (These are 
described in 40 CFR Piurt 763, ^)pendfac A to Subpart 
E.) Clearance pratocds for statistically comparing 
asbestos fiber levds inside the work area with outside 
levds are available. If the measured levels inskie are iK>t 
statistically hi^er than the average airborne asbestos 
concentration measured outside the abatanent area, 
the cleanup is considered successfiil, and the space is 
judged ready for reoccupancy (Fbr reference, see 
Appendix H, U.S. ERV "Guidelines for Conducting the 
AHERA TEM Clearance Test . . . 



19 



Laying tlie foundation for a comprehensive asbestos control progrc-n for a building includes some 
basic steps. Important points contained in this discussion are the following: 



, • An Asbestos Program Manager needs to be 
properly qualified through training and experi- 
ence, and be actively involved in all asbestos 
control and disturbance activities. 

.\n Asbestos Program Manager should have 
authority to oversee and to direct custodial/ 
maintenance staff and contractors with regard 
to all asbestos-related activities. 

An initial building inspection should be per- 
formed by a trained, qualified, experienced 
inspector to locate and assess the condition of 
all ACM in the building. 

The inspection results serve as the basis for 
establishing an O&M program. O&M pro- 
cedures may not be sufficient for certain ACM 
that is significantly damaged or in higlily 
accessible areas. 

J An Asbestos Program Manager or qualified 
consultant should develop the written O&M 
program that is site-specific and tailored for 
individual buildings. The O&M program 
should take into account use, function and 
design characteristics of a building. 



O The success of any O&M program lies in the 
commitment by the building owner to imple- 
ment it properly 



When outside contractors are used for as- 
bestos-related activities, their references and 
training should be thoroughly checked and 
their subsequent work monitored. 

Periodically review written O&M programs. 



O A\if natives or control options that may be 
implemented under an O&M program include: 

• repair 

• encapsulation 

• enclosure 

• encasement 

• removal (minor) 

O Removal of ACM before renovations may be 
necessary in some instances. (See NESHAP 
and State/Local regulations discussion in 
Chapter 6.) 



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



ERIC 



11 



•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. K 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. 



If staff are 
not adequately 
trained, the O&M 
program will not 
be effective. 



A successful O&M program should include the follow- 
ing elements: 

Notification: A program to teP workers, 
tenants, and building occupants where ACM is 
located, and how and why to avoid disturbing 
the ACM. All persons affected should be 
properly informed. 

J Surveillance: Regular ACM surveillance to 
note, assess, and document any changes in the 
ACM's condition. 

7 Controls: Work control/permit system to 
control activities which might disturb ACM. 

Work Practices: O&M work practices to 
avoid or minimize fiber release during activities 
affecting ACM. 

. . Recordkeeping: To document O&M activ- 
ities. 

O Worker Protection: Medical and respiratory 
protection programs, as applicable. 

Z TVaining: Asbestos Program Manager, and 
custodial and maintenance staff training. 



informing Building Workers, 
Tenants, and Other Occupants 

Building owners should inform building workers, occu- 
pants, and tenants about the location and physical 
condition of the ACM that they might disturb, and stress 
the need to avoid disturbing the material. Occupants 
should be notified for two reasons: (1) building occu- 
pants should be informed of any potential hazard in their 
vicinity; and (2) informed persons are less likely to 
unknowingly disturb the material and cause fibers to be 
released into the air. 

Building owners can inform occupants about the 
presence of ACM by distributing written notices, 
posting signs or labels in a central location where 
affected occupants can see them, and holding aware- 
ness or information sessions. The methods used may 
depend on the type and location of the ACM, and on the 
number of people affected. Some states and localities 
have "right-to-know" laws which may require that all 
occupants, workers, and visitors in buildings with ACM 
be informed that asbestos is present. 

In service and maintenance areas (such as boiler 
rooms), signs such as "Caution — Asbestos — Do Not 
Disturb" placed directly adjacent to thermal system 
insulation ACM will alert and remind maintenance 




O t 



workers not to inadvertently disturb the ACM. In most 
cases, all boilers, pipes, and other equipment with ACM 
in service areas ^ere damage may occur should have 
prominent warning signs placed next to the ACM. As an 
alternative, color coding can be used to identify the 
ACM in certain situations provided that all potentially 
involved parties understand the coding system. 

Infmnation sessions reinforce and clarify written 
notices and signs, and provide an opportunity to answer 
questions. Ail employees and tenants or tenant repre- 
sentatives likely to disturb ACM should be included in 
the notification program on a continuing basis. Building 
owners should inform new employees about the pres- 
ence of ACM before they begin work. Owners should 
provide additional signs and information sessions in 
languages other than English yfhere a significant 
niunber of workers, occupants, or visitors do not speak 
En^ish. It may be necessary to make special provisions 
for illiterate workers, such as providing clear verbal 
information or signs, about potential hazids of disturb- 
ing ACM and showing them yfhere ACM is located. 

The specific information given to types of building 
occupants will vary. Fbr example, since service workers 
carry out certain tasks that office workers or tenants do 
not perform, they should receive additional informa- 
tioa Most important, O&M wo-kers should receive the 
training necessary for them Uy perform their tasks 
safely. 

Whatever its form, the information given to buiWing 
occupants and workers should contain the following 
points to the extent they reflect building conditions: 



O ACM has been found in the building and is 
located in areas whee the material could be 
disturbed. 

O The condition of the ACM, and the response 
which is appropriate for that condition. 

O Asbestos only presents a health hazard >^^en 
fibers become aurbome and are inhaled. The 
mere presence of ACM does not represent a 
health hazard. 

O The ACM is found in the following locations 
(e.g. , ceilings in Rooms 101 and G-323, walls in 
the lobby, above suspended ceilings in the first 
floor corridor, on columns in the main entry, on 
pipes in the boiler room). 

O Do not disturb the ACM (e.g., do not push 
furniture against the ACM, do not damage 
TSD. 

O Report any evidence of disturbance or damage 
of ACM to (name, location, and phone number 
of Asbestos Program Manager). 




Routine maintenance 
activities can causa 
disturbance of ACM If 
workers are not prop- 
erly trained in opera- 
tions and mainte* 
nance procedures. 
Here, a worker care- 
lessly contacts ACM, 
possibly damaging it 



O Report any diKt or debris that migji*- come 
from the ACM or suspect ACM, any change in 
the condition d the ACM, or any improper 
action {relative to ACM) of building personnel 
to (name, location, and phone number of 
Asbestos Program Manager). 

O Cleaning and maintenance personnel are tak- 
ing special precautions during their work to 
properly clean up any asbestos debris and to 
guard against disturbing ACM. 

O AH ACM is inspected periodically and addi- 
tional measures will be taken if needed to 
protect the health of building occupants. 




It is important to undertake an honest and open 
approach to the ACM notification procedure. Owners 
should strK'e to establish clear lines of communication 
with all building occupants regarding asbestos issues. 
People yfho are informed of the presence, location and 
condition of ACM in a building vAiere they work or Uve, 
who understand that the mere presence of ACM is not 
necessarily hazardous to them, and vAio accept that 
ACM can often be managed effectively in place, can be 



An example of an 
asbestos caution sign 
placed directly on a 
section of asbestos- 
containing duct insu- 
lation. Signs such as 
this help to ensure 
that workers will not 
inadvertently disturb 
ACM. 



: ERJC 



22 



13 



visual relntpectlons 
of atb«stosmattrls!s 
at regular Intarvals 
can detect changes In 
material condition. 
Here, surf aclnf ACM 
lias delamlnated from 
acelllnclnabulldinf; 
OBM routines can 
keep small problems 
from becoming big 
problems. 



very helpful to the owner in eliminating or reducing 
hysteria on the part d other less informed building 
occupants. On the other hand, if occupants suspect the 
building owner is not being honest about asbestos 
activities in the bmlding, that owner's credibility may be 
questioned and the situation can become hx more 
(Mcult to manage. If and when asbestos incidents 
occur, it is especially important f)r the building owner 
to deal with occupants ar^d contractors openly and 
honestly for that is the best way to maintain occupant/ 
tenant confidence in both the owner and the building's 
asbestos program. 



ACM Surveillance 



Reinspection and 
Periofi!;; Surveillance 



Avisual reinspection 
of all ACM should be 
conducted at regular 
intervals as part of the O&M program* Combined with 
ongoing reports ci changes in the condition d the ACM 
made service woricers, the reinspections should help 
ensure that any ACM damage or deterioration will be 
detected and corrective action taken. 




According to recent ER\ regulations covering schools 
(the Asbestos Hazard Emergency Response Act, 
*'AHERA"), an accredited inspector must reinspect 
school bufldings at least once every three years to 
reassess the condition of ACM. The AHERA regula- 
tions for schools also require a routine surveillance 
check (A ACM every six months to monitor the ACM's 
condition. The AHERA Rule permits this surveillance 
to be conducted by a trained school custodian or 
maintenance worker. While these intervals are men- 
tioned here as a gukle, they may also be appropriate for 
other buildings. The Asbestos Pn^gram Manager 
should establish appropriate intarvals, based on consul- 
tation with the building owner and any other qualified 
professionals invoked in the O&M program. 



ERIC 



ERV reccMnmends a visual and physical evaluation of 
ACM during the reinspections to note the ACM's 
current OHidition and phydcal characteristics. Throu^ 
this reinspectkm, it is possible to determine both the 
relative degree d damage and asse^ the likdihood d 
future fiber release. Maintenance a set of visual 
records (photos or vkleo tape) of the AC M over time can 
be d great value during reinspections. 

Some asbestos consultants recommend examining set- 
tied dust for accumdations d asbestos fibers as another 
surveillance tool in an O&M program. While no 
universal^ accepted standardized protocols currently 
exist for sampling and analysis d settied dust, positive 
results (i.e., ACM is present in the dust) may indicate 
the need for special cleaning of the affected area, or 
other action. Because the results d this testing are 
difficult to interpret and evahiate at this time, building 
owners should carefully conskler the appropriateness of 
this testing to their situation. 



Supplement to 
Visual/Physical 
Evaiuation 



As part of an O&M pro- 
gram, a carefully designed 
an: monitoring program to 
detect airbcMme asbestos fi- 
bers in the building may provide usefiil supplemental 
information v^en conducted ak)ng with a comprehen- 
sive visual and physical ACM inspecuon and reinspec- 
tion program. If the ACM is aurrently in good condition, 
increases in airborne asbestos fiber levels at some later 
time may pnmde an early warning of deterioration or 
disturbance of the material. In that way, supidemental 
air monitoring can be a usefid management tod. If an 
owner chooses to use air monitoring in an '"early 
warning" context, a knowledgeable aikl experienced 
indhndual should be consulted to design a proper 
sampling strategy ^pendix H contains a reference to a 
usefid guide to monitoring airborne asbestos, ^ch can 
be consulted for further discussion of this subject. 

If supplemental air monitoring is done, a baseline 
airborne asbestos fiber level should be established soon 
after the O&M program is initiated; Representative, 
multiide air samples should be cdlected throu^out the 
building during periods of normal building operation. 
This should be done over a k)ng enough period (rf time to 
be representatwe of existing conditions, in order « to 
adequately characterize prevailing fiber levels in the 
building. This air monitoring should supplement, not 
replace, physical and visual inspection. Visual inspec- 
tion can recognize situations and anticipate future 
exposure (e.g., worsening water damage), wiiereas air 
monitoring can only detect a problem after it has 
occurred, and fibers have been released. 

Note that the collection of air samples for supplemen- 
tary equation should notixse aggresshne air sarrqding 
methods. Aggressive sampling methods, in ^ch air is 
deliberately disturbed or agitated by use of a leaf Uower 
or fans, should be used at the completion d an asbestos 
removal project vAien the building or area is unoc- 



23 



r 



-:4 



cupied, not for routine monitoring. 

The most accurate and preferred method of analysis of 
air samples collected under an O&M program would 
requite the use of transmissicm electron miax)scopy 
(JEM). Phase contrast microscqjy (PCM), which is 
commonly used for personal air sample analysis and as a 
screening tool for area air monitoring, cannot distin- 
guish between asbestos fibers and other kinds of fibers 
which may be present in the air. PCM analysis also 
cannot detect thin asbestos fibers, and does not count 
short fibers. TEM analysis is approximately ten times 
more expensive than PCM analysis. However, the more 
accurate information on actual levels of airborne 
asbestos fibers should be more beneficial to the building 
owner who elects to use supplemental air monitoring in 
the asbestos management program. TEM analysis is 
most reliably performed by laboratories accredited by 
the National Institute for Standards and Technology 
(NIST; see Appendbc D for telephone number), and who 
follow ERV's quality assurance guidelines. (Appendfac H, 
US. EB^, Dec 1989, "IVansmission Electron Micro- 
scopy Asbestos Laboratories: Quality Assurance 
Guidelines.") 

Selection of a reliable and experienced air monitoring 
firm and analytical laboratory is important, if the 
building owner elects to conduct supplemental air 
monitoring under the O&M program. A consultant 
knowledgeable in air sampling and analysis protocols 
can be contacted for recommendations if the building 
owner or Asbestos Program Manager has limited 
knowledge in this area. 

Periodic air monitoring, conducted simultaneously with 
the visual reinspections or surveillance, would then be 
used to see if asbestos levels have changed relative to the 
baseline. Some building owners may wish to present 
current air monitoring results to building occupants in 
addition to information regardmg the physical reinspec- 
tions. Although this supplemental use of air monitoring 
as part of an O&M program may provide useful 
information, it is likely to be very expensive, particularly 
if the more accurate and recommended TEM analysis is 
used. Use of ovSy a small number of measurements or 
measurements taken only at one time may be mislead- 
ing (i.e., overestimate or underestimate of fiber levels), 
and can lead to inappropriate decisions. 

It should be noted thatsomeoftheexposuresof persons 
to airborne asbestos fibers in buildings may result from 
episodic events, such as repair woiic or the accidental 
disturbance of the ACM or of ACM debris by mainte- 
nance activities inside the building. Air monitoring ma^ 
not be done frequently enough to include such episodic 
events; this can lead to a misleading interpretation of air 
sampling results. In particular, air samplbg may under- 
estimate the exposure of O&M workers and building 
occupants. A good reference sourcebook for additional 
information on air sampling and analysis for asbestos 
fibers is ''A Guide to Monitoring Airborne Asbestos in 
Buildings" (see /i4>pendbc H). 



Work Control/Permit System 

The O&M program shouW include a system to control 
all woric that could disturb ACM . Some buiWing owners 
have had success usinga ^yoricpermit** 
requires the person requesting the work to submit a Job 
Request Fbrm to the Asbestos Program Manager 
(^^ndix B, Fbrm 2) before any maintenance work is 
begun. The form gwes the time and location <rf the 
requested woric, the type (rf maintenance needed, and 
avilable information about any ACM in the vicinity (rf 
the requested work. The contractor or other person 
authorized to perform the woric should be identified on 
the work request 




Upon receiving a pre-woric Job Request Fbrm, the 
Asbestos Program Manager should take the following 
steps: 

1 Refer to written records, building plans and 
specifications, and any building ACM inspec- 
tion reports to determine vdiether ACM is 
present in the area vdiere woric will occur. If 
ACM is present, but it is not anticipated that 
the material will be disturbed, the Asbestos 
Program Manager should note the presence 
of the ACM on the permit form and provide 
additional instruction on the importance of 
not disturbing the ACM. 

2 If ACM is both present and likely to be 
disturbed, the Asbestos Program Manager or 
a designated supervisor qualified by training 
or experience, should visit the site and 
determine v^at woric practices should be 
instituted to minimize the release of asbestos 
fibers during the maintenance activity. 

Q This determination should be recorded on the 
Maintenance Waric Authorization Fbrm (see 
example in Appendix B, Fbrm 3), M^ch is 
then sent to the in-house maintenance super- 
visor or to the maintenance contractor to 
authorize the woric. 

A The Asbestos Program Manager should 
make sure that a copy of both the request and 
the authorization forms (if granted) are placed 
in the permanent file. 



An •xamplt of • 
maintenanct worker 
conducting actlvltlot 
nMrafriabit 
•sbottot-contalning 
ctiling. Undtr • 
proper permitting 
sytttm, tht building 
AtlMttot Program 
IManagtr would 
ovaluatt and 
authorize projects 
such at this prior to 
beginning work. 



ERJC 



24 



15 



It IS important 
to undertake an 
honest and open 
approach in ACM 
notification. 



C Where the task is not covered by previously 
^ approved standard work practices, the As- 
bestos Program Manager should make sure 
that tlie appropriate work practices and 
protective measures are used for the job. 

For all jobs where contact witli ACM is likely 
^ the Asbestos Program Manager or a desig- 
nated supervisor qualified by training or 
experience should visit the work site when 
the work begins to see that the job is being 
performed properly For lengthy jobs where 
disturbance of ACM is intended or likely 
peri(xiic inspections should be made for the 
duration of the project. 

"7 The Asbestos Program Manager's observa- 
tions should be provided on an Evaluation of 
Work Form (see Appendix B, Form 4). Any 
deviation from standard and approved work 
practices should be recorded immediately on 
this form and the practices should be imme- 
diately corrected and reported to the Asbestos 
Program Manager. 

Q Upon completion of the work, a copy of the 
^ evaluation form should be placed in the 
permanent asbestos file for the building. 



Building owners should consider using asbestos O&M 
work control forms similar to those which already may 
be in use for non-ACM work in their facilities, or 
expanding the existing forms to include the content of 
the request, approval, and evaluation forms illustrated in 
Appendix B. 

The O&M management system should also address 
work conducted by outside contractors. Many building 
owners contract for at least some custodial and mainte- 
nance services. A building's asbestos work control/ 
permit system, as described above, should also cover 
contract work. 

At a minimum, contracts with service trades or 
abatement companies should include the following 
provisions to ensure that the servi'^e or abatement 
workers can and will follow appropriate work practices: 

^ . Proof that the contractor's workers have been 
properly notified about ACM in the owner's 
building and that they are properly trained and 
accredited (if necessary) to work with ACM. 

Copies of respiratory protection, medical sur- 
veillance, and worker training documentation 
as required by OSHA, EPA and/or state regula- 
tory agencies. 

O Notification to building tenants and visitors 
that abatement activity is underway (per- 
formed by owner). 



] Written work practices must be submitted by 
the vendor or contractor for approval or 
modification by the Asbestos Program Man- 
ager. The vendor or contractor should then 
agree to abide by the work practices as finally 
accepted by the Asbestos Program Manager. 

Assurance that the contractor will use proper 
work area isolation techniques, proper equip- 
ment, and sound waste disposal practices. 

Historical air monitoring data for representa- 
tive examples of the contractor's previous 
projects, with emphasis on projects similar to 
those likely to be enc<juntered in the building. 

Provisions for inspections of the area by the 
owner's representative to ensure that the area 
is acceptable for re-entry of occupants/ten- 
ants. 

A resume for each abatement contractor/ 
supervisor or maintenance crew chief, known 
as the "competent person" in the OSHA 
standard and EPA Worker Protection Rule. 

Criteria to be used for determining successful 
completion of the work (i.e., visual inspections 
and air monitoring). 

Any other information deemed necessary by 
the owner's legal counsel. 

Notification to EPA (and other appropriate 
agencies) if the abatement project is large 
enough (see Chapter 6). 



O&M Work Practices 

The O&M program focuses on a special set of 
work practices for the custodial, maintenance, 
and construction staff. The nature and extent 
of any special work practices should be tailored 
to the likelihood that the ACM will be disturbed 
and that fibers will be released. In general, four 
broad categories of O&M work practices are 
recognized: 

j[ Worker Protection Programs — These 
work practices help ensure custodial and 
maintenance staff are adequately protected 
from asbestos exposure. 

2 Basic O&M Procedures — Basic pro- 
cedures are used to perform routine custodial 
and maintenance tasks that may involve ACM. 

2 Special O&IVI Cleaning Techniques - 

Special techniques to clean up asbestos fibers 
on a routine basis. 



ERIC 



25 



Sin 



4 Procedures for Atbestoe Fiber Release 
Episodes — If nx)derate to relatively large 
amounts d ACM are disturbed, the buiWmg 
owner should use these procedures to address 
the ha^. 

A brief synopsis of woricer protection and^O&M work 
practices fdlows. (Note: A more detailed, technically 
oriented O&M "work practices'' manual specifically 
addressing topics such as work practices, worker 
protection, and specie infmnation on how to carry 
out O&M plans, is being developed, with publication 
expected in 1991) 



... . ^ ^ ^, A worker protection 
Worker Protection p^g^ j^^^^^ 

Programs neering controls, per- 

sonal exposure monit(»:ing. medical surveillance, and 
personal protection. While engineering controls are the 
preferred method of woriter protection, there are few 
engineering control options available for O&M work. 
This section discusses two aspects of personal 
protection; use (rf respiratory protection and protective 
ctothing for workers in an asbestos O&M program. 
According to OSHA regulations (see Chapter 6), a 
written respiratory protection program is necessary 
v^^enever an O&M program specifies that service 
workers wear respirators, or ^diere respirators are 
made available to employees. OSHA regu^^ ions also 
require a respirator program A^enever workers are 
exposed, or are likely to be exposed, to fiber levels above 
OSHA's "permis^ble exposure limits" such as the 
8-hour time wei^ted average (TWA) limit or the 30- 
minute "excursion limit" (EL). The 8-hour TWA limit 
and the EL are described in more detail in Chapter 6. In 
addition, OSHA requires workers to wear special 
protective clothing under the same circumstances. 



Respiratory Protection/Worker Protection Pro- 
grams The selection of approved respirators, suitable 
for the hazards to \^idi the worker is exposed, is only 
one aspect of a complete respiratory protection pro- 
gram. Other elements include written operatmg pro- 
cedures for respirator use; outlining personnel riisspon- 
sibQities for respirator cleaning, storage, and repair; 
medical examination of woriters for respirator use; 
training in proper respirator use and limitations; 
respirator fit testmg; respirator cleaning and care; and 
work-site supervision. All of these are described in 
detail in the OSHA respirator standard, 29 CFR 
1910.134. The O&M respirator program can be admin- 
istered by the facility safety and health manager or the 
Asbestos Program Manager, if properly quaDlied. 

Proper respiratory protection is an integral part of all 
custodial and maintenance activities invohring potential 
exposure to asbestos. When in doubt about exposure 
during a certain woA operation , building owners should 
provide respiratory protection to custo^al and mainte- 
nance workers. OSHA specifies general types of 

O 



respirators for protection against airborne asbestos 
during "construction" acthdties, which include abate- 
ment* renovation, maintenance, repair, and remodeling. 

Personal air sampling is not the same as area air 
monitoring. Personal idr samj^ (required b/ OSHA) 
is designed to measure an individual worker's exposure 
to fibers M^iile the woiicer is conducting tasks that may 
disturb ACM. The samirfing device is worn by the 
wori<ar and positioned so that it samite air in the 
workerl^ breathing zone. In contrast, area (or ambient) 
air sampling is conducted to get an estimate of the 
numbers of airborne asbestos fibers present in a 
building. It is used as an assessment tool in evaluating 
the potential hazard posed by asbestos to all buikling 
occupants. (See the previous discussion <rf area air 
monitoring on page 14.) 

When adequate care is taken to prevent or minimize and 
control fiber rdease, routine, small-scale/short-dura- 
tion maintenance or custodial tasks are not likely to 
generate levds of airborne asbestos compared to 
large asbestos removal projects; and req)irators ^^difch 
filter breathing air may be used. OSHA> EPA, and 
NIOSH are on record as not recommending 
single use, disposable pq>er dust masks for use 
against asbestos; in foot, OSHA has disallowed 
their use against airborne asbesto8 fibers. 

The options that may be used include: 

O A half-face or fidlfacepiece,negatwe pressure, 
air-purifying respirator with replaceable hi^- 
efficiency filters. 



Ricturtd Mem M 
diff^rsfit sxsinplM of 
iirpttrifylfig« Mgativs 
prsMiiromplratofs 
•^MipfMii wHIi higti* 
•mdsiicycartrldgM 
whtoficsfilMttssdto 
prottct work«f • 
sgslsttasbMtos 
•xposMrs.Ontli«l«n 
art mmiplst of half • 
mstkfscoplocos 
•qttippod with Itfgh* 
ofScloiicy csrtrMgoo, 
«mt on tt»f right sro 
txamplosoffiill 
facopioco, high- 
•MehKieyiiiMKs. 




26 



17 



O A half or full facepiece powered air-purifying 
respirator (B\PR) with replaceable hi^-effi-* 
dency filters. This has a battery powered pump 
\^ch assists breathing and provides positive 
pre^.>aie iu the facepiece. 




Pictured above are 
two difforont typas of 
powarad ai^|iurifying 
raaplratora (PAPR'a) 
aquippad with high- 
afHclancy filters. On 
the left Is an example 
of a tight fitting, full 
facepiece PAPR, and 
on the right Is an 
example of a loose* 
fitting helmet style 
PAPR. 



Under the OSHA standards for asbestos, any employee 
required to wear a negatwe pressure respirator can 
request a powered air-purifying respirator, and the 
employer is required to provide a fiilty functional and 
approved unit, provided it will afford the worker at least 
equal protection. 

Currently, only respirators approved by NIOSH and the 
Mine Safety and Health Administration (MSHA) are 
permitted for use. If they are air-purifying respirators, 
the filtration device(s) must be rated as "high-effi- 
ciency." 



Selecting the most appropriate respirator for each 
O&M task requires knowledge of the levels of airborne 
asbestos fibers and other possible air contaminants 
generated by the task or likdy to be present vfhere the 
task is performed. This knowledge is best gained 
throu^ personal air monitoring conducted during 
woriter performance of the actual task. (Obviously, the 
woricers must have respiratory protection while this 
initial persona! air sampling is carried out.) In fact, 
OSHA and EPA require air monitoring under certain 
circumstances (see Chapter 6)» lb learn more about the 
difierent types of respirators available and the degree of 
pix)tection they provide, see Appendix E. Ow^. 5 may 
also wish to contact the nearest OSHA officv , a local 
trained and qualified industrial hygienist (preferably 
Certified), or an occupational he^ professional for 
more information on respirators. The expertise of these 
specialists should be used to ensure proper selection, fit 
testing, and training of woriters in respirator use. 

Building owners and other facility managers may not be 
familiar with some of the terms used in discussions of 
respirators, ahrborne fiber levels, and related topics. 



Appendix E contains more information on these topics^ 
and gives the minimum EPA*reconunended levds d 
respiratory protection to be provided during typical 
O&M tasks. 

R)r additional information on respirator programs, 
respirator types, and respirator use, the building owner 
or Asbestos Program Manager xroiy want to use the 
Mowing references: 

O ''Respiratory Protection: An Employer's Man- 
ual " NIOSH, October 1978; 

O ''A Guide to Respiratory Protection for the 
Asbestos Abatement Industry,'' EPA/NIOSH, 
1986; 

O OSHA respirator standard (29 CFR 
1910.134); 

O OSHA asbestos regulations (29 CFR 
1910.1001 and 1926.58); 

O "Occupational Exposure Sampling Strategy 
Manual," NIOSH #77-173, January 1977. 

O "Respirator Deciaon Logic," NIOSH, May 
1987; and 

O "NIOSH Guide to Industrial Respiratory Pro- 
tection," September 1, 1987. 



Protective Clothing/Worker Protection Pro- 
grams In addition to the use of respirators, some O&M 
procedures may require workers to wear protec^^ive 
clothing. Most often, protective clothing is disposable 
and consists of coveralls, a head cover, and foot covers 
made (rf a synthetic &br ic which does not allow asbestos 
fibers to pass throu^. This type of clothing prevents 
•;wkers' regular clothing from becoming contaminated 
with asbestos fibers. Contaminated clothing could be 
taken home, creating a possible risk to the worker's 
family members. 

OSHA and EPA regulations require woricers to wear 
protectee clothing wiienever they are exposed, or likely 
to be exposed, to fiber levels above OSHA's permissible 
levels (see Chapter 6). It is important that workers be 
propeily trained in tlie use, removal and disposal of 
protectee clothing after use. All O&M activities may 
not require the use of protective clothing. It is important 
for the Asbestos Program Manager to assess this need 
on a case-by-case basis. 



Be tic O&M procedures to mini- 

Procedures ™^ and/or contain asbestos fi- 
bers may include wet methods, 
use of mini-enclosures, use cif portable power tools 
equipped with special local ventilation rtcachments, and 
avoidance of certain activities, such as sawing, sanding, 



ERIC 



27 



and drilling ACM. Maintenance activities can be divided 
into three categories with regard to their potential for 
disturbing ACM: 

4 Those which are unlikely to involve any direct 
* disturbance of ACM; for example, deaning 
she^es or counter tops with a damp cloth. 

2 Those which may cause accidental distur- 
bance of ACM; for example, working on a 
fixture near a ceiling with surfacing ACM. 

O Those which invohre intentional small-scale 
manipulation or disturbance of ACM; for 
example, removing a small segment of TSI 
ACM to repair a pipe leak. 

The O&M program s!xOuld include work practices for 
each type of ACM that is present in the building 
(surfacing, TSI, and miscellaneous) as well as for each 
type and category of maintenance activity performed 
(e.g., general cleaning, electrical woric, plumbing). 

Special work practices such as wet wiping, area 
isolation, and HEPA vacuuming, and the use of personal 
protecthre equipment such as respirators and protective 
ck)thing, may be needed where disturbance of ACM is 
likely. The need for these practices varies with the 
situation. For example, removing light fixtures located 
near surfacing ACM may disturb the material and might 
invoWe the use of special deaning, possibly area 
isdation, and respiratory protection. Periodic emptying 
of a trash can near heavily encapsulated asbestos- 
containing plaster ms^ not disturb the material at all, so 
no spedal woric practices would generally be necessary. 
These woric practices and procedures are intended to 
ensure that disturbance oif any ACM during O&M 
actwities should be minimized, or carried out under 
controlled conditions when the disturbance is required 
by the nature of a specific O&M task. 

In addition, ACM may readily release asbestos fibers 
into the air when certain mechanical operations are 
performed directly on it. For example, fiber releases can 
occur when woricers are drilling, cutting, sanding, 
breaking, or sawing vinyl asbestos floor tile. 

The action of drilling, cutting, abrading, sanding, 
chipping, breaking, or sawing is the aitical factor here, 
since it is likely to cause a release of fibers. Maintenance 
or repair operations im'ohong those actions should be 
eliminated or carefully controlled with basic O&M 
procedures in order to prevent or minimize asbestos 
fiber release. 

Certain activities that occur in the vicinity of ACM can 
also cause da^nage \^^ch may result in asbestos fiber 
release. R)r example, maintenance and custodial staff 
may damage ACM acddentally with broom handles, 
ladders, and foric lifts ^e performing other tasks. 
Activities performed in the vicinity of ACM should 
ahvays be performed cautiously to prevent fiber release. 

er|c 



lb summarize, if in doubt about the possibility of 
disturbing ACM during maintenance activities, ade- 
quate precautions should be taken vo minimize fiber 
release; these will protect workers as well as the 
building environment Basic O&M procedures, indud- 
ing use of wet methods and spedally equipped tools, 
should be used to protect building occupants. 



O&M Cleaning 
Practices 



Special cleaning practices 
are appropriate for a building 
with exposed surfacing or 
thermal system insulation ACM, espedally if the ACM 
is friable. If gradual deterioration or damage of ACM has 
occurred or is occurring, asbestos-containing uust or 
debris could be present. If the building in^^pection has 
determined that asbestos-containing dust or debris is 
present in some areas, then the O&M program should 
indude spedal deaning practices to collect reddual 
asbestos dust. Routindy deaning floors using wet 
methods is an example of one such practice. Custodial 
and maintenance workers in the course of normal work 
can also identify and report areas vMch are in need of 
spedal deaning or repair. Special cleaning techniques 
should supplement^ not replace, repair or abatement 
actions for damaged, friable ACM. The deaning 
program should include an initial deaning followed, as 
needed, by subsequent periodic or episodic deanings. 

Buildmg owners and custodial and maintenance staff 
should ensure that spedal O&M cleaning is done 
correctly. Proper cleaning is impor^t for two reasons: 

O The use of improper techniques to dean up 
asbestos debris caused tiy previous deteriora- 
tion or damage may result in widespread 
contamination, and potentially increase air- 
borne asbestos fiber levels in the building. 

O Improper cleaning may cause damage to the 
ACM, thus releasing more airborne asbestos 
fibers. 

Proper O&M cleaning will invoke the use of wet 
deaning or wet-wiping practices to pick up asbestos 
fibers. Dry sweeping or dusting can result in asbestos 
fibers being re-suspended into the building's air and 
therefore should not be used. Once wet cloths, rags, or 
mops have been used to pick up asbestos fibers, they 
should be properly discarded as asbestos waste while 
still v/et. TTiey should not be allowed to dry out, since 
the collected fibers might be released at some later time 
when disturbed. The use of special vacuum cleaners, 
comj^nonly referred to as HEPA vacuums, may be 
preferable to wet deaning in certain situations. These 
vacuums are equipped with filters designed to remove 
very small partides or fibers — such as asbestos — by 
filtering those particles from the air passing through the 
vacuum. Since the exhaust air from an ordinary vacuum 
cleaner is not filtered sufiidently, it is possible for tiny 
asbestos fibers to pass through the filter and back into 
the building air. 



28 



If in doubt about 
the possibility 
of disturbing 
ACM during 
maintenance 
activities, 
adequate 
precautions 

should be taken 
to minimize 
fiber release. 



19 



Special 
procedures are 
generally needed 
to minimize the 
spread of fibers in 
the building after 
asbestos fiber 
release occurs. 



H«re, a worker uses 
a HEPA vacuum 
(backpack type) to 
clean ACM debris 
from one of several 
carpeted areas in a 
room where surfacing 
material had fallen. 



It is important fDr O&M woiters to use caution ^en 
emptying HER\ vacuums and changing the filters. 
Exposures could result from such activities. Workers 
should move the HEPA vacuum to a physically isolated 
area of the facility and put on proper personal protective 
equipment before emptying the dust and debris into 
property labeled, sealed, and leak-tight containers for 
disposal as asbestos-containing waste. When custodial 
workers do not woric with ACM, trained mamtenance 
workers can be used to empty the HEPA vacuums and 
change their filters. Decisions regarding special clean- 
ing practices should be based on the building inspection 
and ACM assessment data, including the potential for 
ACM disturbance. In gena:al, the building would not 
need special O&M cleaning >^en the building contains 
only nonfriable (not easily crumbled) ACM; ACM v/bich 
has been encapsulated, encased, or enclosed behuid air- 
tight barriers; or ACM known to be undamaged/ 
undisturbed since the last special cleaning. Further- 
more, w^ere ACM is confined to a single room or area, 
special cleaning of just that area rather than other parts 
of the building may be sufficient. 

If ACM has been released onto a carpeted area of a 
building, it may not always be possible to adequately 
clean the carpeted area. "Steam" cleaning and HEPA 
vacuuming methods are sometimes employed for this 
purpose. A preliminary study carried out by EPA in 
1989 showed that hot water vacuums were more 
effective in carpet cleaning than HEPA vacuums, under 
the test conditions. FUrther field studies are planned to 
confirm these findings. 



For carpets, successful cleaning will likely depend on 
factors such as the amount (rf ACM released onto the 
carpet, how long the situation has existed, traffic over 
the area, as well as the structure and composition of the 
carpet itself. It is prudent to evaluate indivuiual 
situations on a case-by-case basis. The Asbestos 
Program Manager should consider the need for woricers 
engaged in cleaning asbestc^ fiber-contaminated car- 
pets to wear proper respiratory prote/jon. It may also 
be prudent to arrange fDr this typ;, of cleaning to be 
done after normal woridng hours or when the facility is 
less occupied. Additionally, it may be more cost effective 
to property dispose of contaminated carpets and other 
fabrics as asbestos-containing waste if a permanent 
asbestos control option is being undertaken in the 
building. 

Where the ACM is damaged and located in an **air 
plenum'' — where fibers can be transported by the 
heating, ventilation, or air conditioning (HVAC) system 
throu^out the building — special cleaning practices 
may be extended to the entire building, including the 
HVAC system itself. 



Procedures for 
Asbestos Fiber 
Release Episodes 



Special procedures are 
generally needed to min- 
imize the spread of fibers 
throughout the building 
after asbestos fiber releases occur, such as the partial 
collapse of an ACM ceiling or wall. These procedures 
are needed whether the ACM disturbance is intentional 
or unintentional, lb provide building owners with some 
guidance, irnder EPA regulations for schools a ''major 
fiber release" is defined as one invoking more than 
three square or linear feet of ACM. The procedures to 
be followed will vary according to the site of the major 
release episode, the amount of ACM affected, the 
extentof fiber release from the ACM, the relationship of 
the release area to the air handling systems, and 
whether the release site is accessible to building 
occupants. Depending on the severity of the episode, 
asbestos abatement consultants and contractors may be 
needed to develop a strategy for conducting the clean- 
up operations. 

In general, for major fiber releases, the area should be 
isolated by dosing doors and/or erecting temporary 
barriers to restrict airflow as well as access to the site. 
Signs should be posted as necessary immediately 
outside the fiber release site to prevent persons not 
invoked in the cleanup operation from inadvertently 
entering the area. If asbestos fibers could enter the 
HVAC system, the system should be modified to prevent 
fiber entry, or should be shut down and sealed oflf. The 
final step should be to employ thorough cleanup 
procedures to property control the ACM, a careful visual 
inspection, and final clearance air monitoring to verify 
satisfactory cleanup. 

Similar procedures can be used for much smaller fiber 
release events; vA\ere the amount of ACM is on the 



29 



£ order of three square or linear feet or less. The HER\ 
i vacuuming, wet wiping, and woricer protection pro- 
I' cedures outlined in this guidance document, as well as 
I wetting ACM wastes aiid properly placing them in an 
I appropriate leak-tight container (such as a pn^ly 
\ labeled, 6-mil-thick plastic bag), are examples of some of 

the procedures which could be used for both major and 

minor fiber releases* 

? It is important to recognize that different levels of 
; training ar^ needed for woricers invoWed with fiber 
f rdease episodes. A major release will generally require 
"asbestos abatement worker training," rather than the 



degree of training considered adequate for O&M 
workers, 

EPk suggests that building owners and Asbestos 
Program Maragers consult with state and local regula- 
tory officials before establishing formal training pro- 
cedures for each type of situation. 

The following table should be useful in determining 
^en to apply certain O&M work practices in buildings. 
The table illustrates the O&M work practices that 
should be ased by custodial and maintenance staff, 
depending on the likelihood of ACM disturbance. 








Ukelihooa of ACM Disturbanct 






Contact Unliktiy 


Accidtntal Ottturbanca 
Potttlbia 


DItturbanca 
Intandad or Ukaiy 










Need Pre-Work Approval from Asbestos 
Program Manager 


Review by Program 
Manager 


Yes 


Yes 


Special Scheduling or Access Control 


No 


Yes 


Yes 


Supervision Needed 


No 


Initial, At Least 


Yes 


HVAC System Modification 


None 


As Needed* 


Shut Down* 


Area Containment 


None 


Drop Cloths» Mini-enclosures 


Yes2 




Respiratory Protection 


Available Fbr Use 


Yes 


Yes 


Protective Clothing 


None 


Review by Asbestos Program 
Manager 


Yes 



Use of Wet Methods 


No 


As Needed 


Yes 


l^ofHER\ Vaaxmi 


Available For Use 


Available For Use 


AsNseded 


1) In the area where work takes place 

2) TVpc of conlainmeni may varyi Fbr example. snuH'Scale. short Hluration tasks may , eqoire full containment. 



EPA recommends 
that building 
owners make 
available all 
written elements 

of the O&M 
program to the 
building s O&M 
staff as well as 
to tenants and 
other building 
occMpants. 



Recordkeeping 

All the building asbestos management documents 
discussed in this Guide (inspection and assessment 
reports, O&M program plan, woric practices and 
procedures, respirator use prcKedures, fiber release 
reports, application for maintenance >vork and vfork 
approval forms, evaluations of work affecting ACM, and 
reinspections/surveillance of ACM) should be stored in 
permanent files. In addition, for employees engaged in 
asbestos-related work, federal regulations (see Chapter 
6) require that employers retain: 

O personal air sampling records, for at least 30 
years. Personal air samples are those collected 
in the worker's breathing zonf» during perform- 
ance of work involving asbestos exposures. 

O objective data used to qualify for exemptions 
from OSHA's initial monitoring reqmrements 
for the duration of the exemption. 

O medical records for each employee subject to 
the medical surveillance program for the 
duration of their employment plus 30 years. 



O all employee training records for one year 
beyond the last date of each worker's employ- 
ment. 

In addition, OSHA requires that employers provide to 
each employee their record of exposure and medical 
surveillance under the Records Access Standard (29 
CFR 1910.20) and the Hazard Communication Standard 
(29 CFR 1910. 1200). See the OSHA Construction Rule 
(29 CFR 1926.58) or the EPA ^fker Protection Rule 
(40 CFR 763 Subpart G) for more details of recordkeep- 
ing requirements. 

EPA recommends that building owners make available 
all written elements of the O&M program to the 
building's O&M staff a& well as to tenants and other 
building occupants, if applicable. Building owners arc 
also encouraged to consult with their legal counsel 
concerning appropriate recordkeeping strategies as a 
standard part of their O&M programs. Additionally, 
state and local regulations may also require additional 
recordkeeping procedures. 



Althoq^ the elements discussed in this chapter shouM ^pear in any O&M program^ the extent to 
which each applies will vary depending on the building type, the type d ACM present, and the ACM's 
location and physical condition. To achieve its objectives an O&M program should include the 
following: 



O A notification program to inform building 
occupant:,, workers, and tenants about the 
locatron of ACM and how to avoid disturbing 
ACM. 

O Periodic surveillance and reinspection of ACM 
at regular intervals by trained woricers or 
property trained inspectors. Air monitoring to 
detect airborne asbestos fibers in the building 
may provide useful supplemental information 
when conducted atong with a comprehensive 
visual and physical ACM inspection/ reinspec- 
tion program. Air samples are most accurately 
analyzed using transmission electron micro- 
scopy (TEM). 



O A "work control/permit" system, ^^Wch some 
building owners have used si xessfiilly to 
contnrf work that could disturb ACM. This 
system requires the person requesting work to 
submit a Job Request Form to the Asbestos 
Program Manager before aity work is begun. 

O O&M work practices to avoid or minimize fiber 
release during activities af][ecting ACM. 

O Recordkeeping. OSHA and EPA have specific 
requirements for workers exposed to asbestos. 



31 




What O&M It-aining Is 
Necessary? 



Types of IVaining 



Ttraining of custodial and maintenance workers is one of the keys to a successful O&M program. K 
building owners do not emphasize the importance of well-trained custodial and maintenance 
personnel, asbestos O&M tasks may not be performed properly This could result in higher levels of 
asbestos fibers in the building air and an increased risk faced by both building workers and occupants. 



OSHA and EPA require a worker training program 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— the TWA) and/or the 
excursion limit (1.0 f/cc, 30-niinute TWA— see Chapter 
6). According to the EPA regulations governing schools, 
all school staff custodial and maintenance workers vAio 
conduct any activities that will result in the disturbance 
of ACM must receive 16 hours of O&M training. Some 
states and municipalities may also have specific training 
requirements for workers who may be exposed to 
asbestos, or who woric in a building with ACM present. 

With proper training, custodial and maintenance staff 
can succes^y deal with ACM in place, and greatly 
reduce the release of asbestos fibers. Thdning sessions 
should provide basic information on how to deal with all 
types d maintenance activities involving ACM. How- 
ever, building owners should also recognize that O&M 
woricers in the field often encounter unusual, **non- 
textbook" situations. As a result, training should 
provide key concepts of asbestos hazard control. If these 
concepts are cleariy understood by workers and their 
supervisors, woriters can develop techniques to address 

ERIC 



a specific problem in the field. Building owners who 
need to provide O&M training to their custodial and 
maintenance staff shoidd contact an ER^ environmental 
assistance center (see Appendix D) or equally qualified 
training organization for more information. 

At least three levels of maintenance worker training can 
be identified: 

LEVEL 1: AWARENESS TRAINING. For custo- 
dians involved in cleaning and simple main- 
tenance tasks wliere ACM may be acciden- 
tally disturbed. 

For example, fixing a light fixture in a ceiling covered 
with surfacing ACM. Such training may range from two 
to eight hours, and may include such topics as: 

• Background information on asbestos. 

• Health effects of asbestos. 

• Worker protection programs. 

• Locations of ACM in the building. 

• Recognition of ACM damage and deterioration. 

• The O&M program for that building. 

• Proper response to fiber release episodes. 

32 



IVaining of 
custodial and 
maintenance 
workers is 
one of the 
keys to a 
successful 

O&M 
program. 



23 




A properly protected 
and trained worker 
conducts a glovebag 
removal job on a sec- 
tion of thermal sys- 
tem insulation. Under 
a proper operations 
and maintenance pro- 
gram, any worker in- 
volved In such activ- 
ities would have Level 
i and 2 training. 



LEVEL 2: SPECIAL O&M TRAINING. For 
maintenance workers Involved In general 
maintenance and asbestos material repair 
tasks. 

For example, a repair or removal of a small section of 
damaged TSI, or the installation of electrical conduit in 
an air plenum containing ACM or ACM debris. Such 
training generally invohres at least 16 hours. This level of 
training usually invokes more detailed discussions of 
the topics included in Level 1 training as well as: 



LEVEL 3: ABATEMENT WORKER TRAININa 
For workers who may conduct asbestos 
abstement 

Fbr example, conducting a renK)val job, constructing an 
endosurc, or encapsxdating a surface contaimng ACM. 
This work invdves direct, intentional contact with 
ACM. The recognized "abatement woricer" training 
courses approved by EPA or states, under the EPA 
AHERA model accreditation plan for schools, ^di 
invoWe 24 to 32 hours of training, would fulfill this level 
of training. 

If this level of training is provided to in-house staff, it 
may save time and money in the long run to use these 
individuals to perform such acthdties. This level of 
training is mudi more invoked than Levels 1 and 2, 
although it should include some of the same elements 
(e.g., health effects of asbestos). It will typically include 
a variety of specialized topics, such as: 



Pre-asbestos abatement work activities. 
Work area preparation. 
EstaUishing decontamination units. 
Personal protection, including respirator selec- 
tion, use, fit-testing, and protective clothing. 
Worker decontamination procedures. 
Safety considerations in the abatement work 
area. 

A series of practical hands-on exercises. 
Proper handling and disposal of ACM wastes. 



• Federal, state, and local asbestos regulations. 

• Proper asbestos-related work practices. 

• Descriptions of the proper methods of handling 
ACM, including waste handling and disposal. 

• Respirator use, care, and fit-testing. 

• Protectee dothing donning, use, and handling. 

• Hands-on exercises for techniques such as 
glovebag work and HEPA vacuum use and 
maintenance. 

• ^propriate and proper worker decontamination 
procedures. 



The Asbestos Program Manager should consider con- 
ducting the training program for Levels 1 and 2 if he or 
she has sufficient specific asbestos knowledge and 
training. If the Asbestos Program Manager does not 
conduct the training, the building owner should hiv^ an 
outside consultant or send workers to an appropriate 
O&M training course. A trained (preferably Certified) 
industrial hygienist or equally qualified safety and health 
professional should conduct the training on respirator 
use and fit-testing. A health professional should conduct 
the training on health effects. 



This it an example 
of a lari^e-tcaie 
atbettot removal 
project (note mltelng 
tcaffold safety rails). 
Such projects are well 
beyond the scope of 
an program. The 
EPA NESHAP regula- 
tions require that as* 
bestos materials be 
removed from build* 
ings prior to demoli- 
tion or renovation 
when the asbestos 
will be disturbed. 





OSHA or EB\ Regional Offices, as well as state and k)cal 
a^ndes and professional associations, may be able to 
suggest courses or direct you to listings of training 
providers for each of the three levels. Appendbc D 
provkles the addresses and/or phone numbers for 
OSHA, ER/\, and ER\-sponsored training provWers. 

Where custodial and maintenance services are per- 
formed by a service company under contract, or where 
some installatwn or repairs are performed by em- 
ployees d trade or craft contractors and subcontrac- 
tors, those worioersnu^ need to have training at level 1, 
2, or 3 as aK)ropriate for their work. The Asbestos 
Program Manager or buiWing owner shouW verify that 
these emptoyees recewe ^propriate training before 
th^ begin any work. 



33 



I 



In sunimary, good training is crudaJ to the succe^ maintenance workers that following the appropriate 

O&M program. Strong support for O&M training by work procedures is critical to protecting their own 
the buildmg owner should convince custodial and health as well as the health of other building occupants. 



Properiy trained custodial and maintenance workers are critical to a successfid O&M program. The 
following items are highlighted training requirements: 



O OSHA and EPA require worker training pro- 
gram for all employees exposed to fiber levels 
at or above the action level (0. 1 f/cc, 8-hr. TWA) 
and/or the excursion limit (LO f/cc, 30-minute 
TWA -see Chapter 6). 

O Some states and municipalities may have 
specific worker training requirements. 

O At least three levels of maintenance worker 
training can be identified: 

Level 1 Awareness training for workers 
invoh^ in activities where ACM may be 
accidentally disturbed. May range from 2-8 
hours. 



Level 2 Special O&M training for mainte- 
nance workers involved in general maintenance 
and incidental ACM repair tasks. At least 16 
hours. 

Level 3 Abatement worker training for 

workers viho may conduct asbestos abatement. 
This woric involves direct, intentional contact 
with ACM. "Abatement worker" training 
courses that involve 24 to 32 hours of training 
fulfill this level of training. 



Strong support 
by the building 
owner can 
convince workers 
that following 
appropriate 
procedures is 

critical to 
protecting their 
own health as 
well as the health 
of other building 
occupants. 



RIC 



34 



25 




What Regulations Affect 
Asbestos Management 
Programs in Buildings, 
Especially O&M Programs? 



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



Building owners are governed by a variety of federal, state, and local regulations \^ch influence the 
way they must deal with ACM in their facilities. Some of these regulations, particularly at the state 
and local level, may change frequently. Building owners should contact their state and local 
govemn.ent agencies, in addition to organizations such as the National Conference of State 
Legislatures (NCSL), the National Institute of Building Sciences (NIBS), or EPA environmental 
assistance centers, for updated information on these requirements, (Appendix D lists phone numbers 
for these organizations,) 



Building owners 
are governed by a 
variety of federal, 

state, and local 
regulations which 
influence the way 

they must deal 
with ACM \(\ 

their facilities. 



OSHA Regulations 
and the U.S, 
EPA VVorker 
Protection Rule 



There are several im- 
portant Occupational 
Safety and Health Ad- 
ministration (OSHA) 
and EPA regulations 
that are designed to protect workers. They are summa- 
rized here, as guidance. OSHA has specific require- 
ments concerning woricer protection and procedures 
used to control ACM. These include the OSHA 
construction industry standard for asbestos (29 CFR 
1926.58X which applies to O&M woric, and the general 
industry asbestos standard (29 CFR 1910.1001). State- 
delegated OSHA plans, as well as local jurisdictions, 
may impose additional requirements. 

For most operations and maintenance activities in 
building areas where only non-friable ACM is present or 
vfhere friable ACM is in good condition, applicable 
OSHA permissible exposure limits are not likety to be 
exceeded. However, it is possible that some O&M 
activities will disturb ACM to such an extent that the 
OSHA limits are exceeded, unless good woric practices 
are followed. 



The OSHA standards generally cover private sector 
workers, and public sector employees in states which 
have an OSHA state plan. Public sector employees, such 
as dty or county government employees, or certain 
school emptoyees, v/ho are not abeady subject to a state 
OSHA plan are covered by the ER\ **Worker Protection 
Rule" (Federal Register February 25, 1987; 40 CFR 
763 Subpart G, Asbestos Abatement Projects; Worker 
Protection, Final Rule). Note: As this document goes to 
press, OSHA is considering a substantial number of 
changes to it^ regulations. 

The OSHA standards and the EPA Worker Protection 
Rule require employers to address a number of items 
which are triggered by exposure of employees to 
a^^bestos fibers. Exposure is discussed in terms of fibers 
per cubic centimeter (cc) (rf air. A cc is a volume 
approximately equWalent to that of a sugar cube. 

Im main provisions of the regulations fall into the 
general category of "Permissible Exposure Limits 
(PELs)'* to airborne asbestos fibers. They are: 



i| 8-Hour TIma-waightad avaraga limit 
* (TWA) — 0.2 fiber per cubic centimeter (f/cc) 
of air based on an 8-hour time-wei^ted 
average (TWA) sampling period. This is the 
maximum level ctf airborne asbestos, on 
average , that any employee may be exposed to 
over an 8-hour period (normal woric shift). 

2 Excursion limit (EL) — 1.0 f/cc as averaged 
^ over a sampling period of 30 minutes. 

These levels trigger mandatory requirements, vAuch 
include the use of respirators and protective clothing, 
the establishment of "regulated areas," the posting of 
danger signs as well as the use of engineering controls 
and specific work practices. 

OSHA regulations also establish an "Action Level *\ 0. 1 
f/cc for an 8-hour TWA. Employee training is required 
once the action level of 0.1 f/cc and/or the "Excursion 
Limit'' is reached. This training must include topics 
specified by the OSHA rules. If an employee is exp(^ 
at or above the action level for a period of 30 days or 
more in a calendar year, medical surveillance is required 
according to the (^HA construction industry asbestos 
standard. 

OSHA also requires medical examinations under its 
"General Industry Standi" for any employee exposed 
to fiber levels in the air at or above the OSHA "action 
level" (0.1 f/cc) and/or the "excursion limit" (l.Of/cc). In 
both cases— the action level and excursion limit — the 
OSHA medical examination requirement applies if the 
exposure occurs for at least one day per year. 

The OSHA "Construction Industry Standard" (29 CFR 
1926.58) for asbestos, is generally ap^cable £cr the 
workers ^^o carry out the kinds of work discussed in 
this O&M guidance document. The OSHA construc- 
tion industry asbestos standard applies to demolition 
and asbestos removal or encapsulation projects, as well 
as to repak, maintenance, alteration, or renovation if 
ACM is invdved. ACM spills or emergency clean-up 
actions are also covered tnis regulation. 

According to those regulations, participation in a 
medical surveillance program is required for any 
emptoyee ^\iio is required to wear a negative pressure, 
air-purifying respirator. Preplacement, annual, and 
termination physical exams are also required for these 
employees. However, a termination exam is only 
necessary under the construction industry standard 
(^^1lich applies to custodial and maintenance employees) 
if a physician nn^mmends it. While not mandatory, ERA 
and MOSH recommend physical examinations, includ- 
ing cardiac and pulmonary tests, for any employee 
required to wear a respirator by the building owner. 
These tests determine ^^ether workers will be unduly 
stressed or uncomfortable ^^en using a respirator. 

Additional requirements of the OSHA asbestos stand- 
aids, such as the use of air filtration systems and hygiene 
fedlities^ invoke procedures which are most applicable 
to large-scale asbestos abatement projects. However, 

er|c 



these rules also include a number of recommendations 
for procedures which mi^t be appropriate for a variety 
of O&M programs for buildings. 



cmoii c^^io "^pendbc G" vrfiich is spe- 
eu 4 ! !; cified as a non-mandatory 
Short-duration ^^^^ ^ QgHA reguia- 
Kfojects 29 CFR 1926.58, may 

become mandatory under certain circumstances >\iiere 
"small-scale, short-duration" asbestos prqiects are 
conducted. These projects are not predsely defined in 
terms of either size or duration, altfioug^ thdr nature 
and scope are illustrated by examples presented in the 
text of the regulation. Property trained maintenance 
woriters may conduct these projects. Examples may 
include removing small sections of pipe insvdation or 
covering for pipe repair, replacing vabes, installing 
electrical conduits, or patching or removing small 
sections of drywall. OSHA issued a clarification of the 
definition of a "small-s^e, short-duration" (SS/SD) 
project in a September 1987 asbestos directive. The 
directive focuses on intent, stating that in SS/SD 
projects, the removal of ACM is not the primary goal of 
the job. If the purpose erf a small-scale, diort-duration 
project is maintenance, repair, or renovation of the 
equipment or surface bdiind the ACM— not abatement 
of ACM— then the appendbc provisions may apply. If the 
intent of the woric is abatement of the ACM, then the 
M-scale abatement control requirements apply. 

In aiy event, this appendbc section of the OSHA 
construction standard outlines requirements for the use 
of certain engineering and work practice controls such 
as ^ovebags, mini-enclosures, and special vacuuming 
techniques. Similar information on these procedures 
may be found in the EPA's AHERA regulations for 
schools. (See final AHERA rule, Appendbc B, for SS/SD 
projects.) 



EPA's rules concern- 
ing the application, 
removal, and disposal 
of ACM, as well 



U.S. EPA National 
Emission Standards 
for Hazardous Air 

Pollutants (NESHAP) , ^ . 

(40 CFR 61 Subpart M) manufacturing, 
' spraymg and fabri- 
cating of ACM, were issued under the asbestos 
NESHAP. The asbestos NESHAP regulation governs 
asbestos demolition and renovation projects in all 
fecilities. The NESHAP rule usually reqmres owners or 
operators to have all friable ACM removed before a 
building is demolished, and may require its removal 
before a renovation. Fbr renovation projects where 
fi-iable ACM will be disturbed, the NESHAP rule may 
require appropriate work practices or procedures for 
the control of emissions. It is prudent to note that any 
ACM A^*dch may become friable poses a potential 
hazard that should be addressed. The building owner 
should consider that in many instances, the removal of 
friable ACM prior to demolition could be less expensh^e 
than removals >^e the building is still occupied and 
being used. Some revisions to the current NESHAP 
rule are anticipated by the end of 1990. 



38 



In general, 
applicable OSHA 

permissible 
exposure limits 
are not likely to 
be exceeded for 
most O&M 
activities in 
building areas 
where only non* 
friable ACM is 
present or where 
friable ACM is in 
good condition. 



27 



Depending on 
project size, EPA 
or the state must 
be notified before 
a building is 
demolished or 
renovated. 



Notification 

EPA or the state (if the state has been delegated 
authority under NESHAP) must be notified before a 
building is demolished or renovated. The following 
information is required on the NESHAP notice: 

4 Name and address of the building owner or 
manager; 

2 Description and location of the building; 

O Estimate of the approximate amount of friable 
^ ACM present in the facility; 

A Scheduled starting and completion dates of 
ACM removal; 

C Nature of planned demolition or renovation 
^ and method(s) to be used; 

Ct Procedures to be used to comply with the 
^ requirements of the regulation; and 

■7 Name, address, and location (rf the disposal 
ate vAiexe the friable asbestos waste material 
will be deposited. 

The notification requirements do not apply if a building 
owner plans renovation projects which will disturb less 
than the NESHAP limits d 160 square feet of friable 
ACM on facility components or 260 linear feet of friable 
ACM on pipes (quantities involved over a one-year 
period). For renovation operations in yMch the amount 
of ACM equals or exceeds the NESHAP limits, notifica- 
tion is required as soon as possible. 



Emissions Control 
and Waste Disposal 

The NESHAP asbestos rule prohibits visible emissions 
to the outside air by requiring emission control pro- 
cedures and appropriate work practices during collec- 
tion, packaging, transportation or disposal of friable 
ACM waste. All ACM must be kept wet until sealed in a 
leak-tight container that includes the appropriate label. 
The foUowing table provides a simplified reference for 
building owners re^rding the key existing NESHAP 
requirements. 



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



Under ex- 
panded au- 
thority of 
RCRA, a few 
states have 
classified 
asbestos-con- 
taining waste 



waste agency should be contacted before disposing of 
asbestos for approved disposal methods and re- 
cordkeeping requirements, and for a list of j^)proved 
disposal sites. 

Friable asbestos is also included as a hazardous sub- 
stance under EE\'s CERCLA regulations. The owner or 
manager Oi a facility (e.g., buildfag, installation, vessel, 
landfill) msf have some reporting requirements. Check 
with your EPk Regional Office for further information. 
(See Appendix D for telephone numbers.) 

_ , ^ ^ In October 1987, 

The Asbestos gp^ j^g^^ ^,^31 ^. 

Hazard Emergency ^^^^^^ ^ ^ 
Response Act the Asbestos Hazard 

Regulations (AHERA) Emergency Re- 
sponse Act of 1986 (AHERA). The AHERA regulatory 
requirements deal only with public and private elemen- 
tary and secondary school buildings. The regulations 
require schools to conduct inspections, develop com- 
prehensive asbestos management plans, and select 
asbestos response actions to deal with asbestos hazards. 
The AHERA rules do not require schools to remove 
ACM. 

A key element of the AHERA regulations requir^ 
schools to develop an O&M program if friable ACM is 
present. The AHERA O&M requirements also cover 
non-friable ACM which is about to become friable. For 
examine, drilling through an ACM waU will likely result 
in friable ACM. Under the AHERA O&M provisions, 
schoolsmust carry out specific O&M procedures vWch 
provide for the dean-up of any ACM releases and help 
ensure the general safety <rf school maintenance and 
custodial woricers, as well as all other school building 
occupants. The AHERA regulation's O&M require- 
ments mandate that schools employ specific work 
practices including wet wiping, HEPA vacuuming, 
proper waste disposal procedures, and spedfic training 
for custodial and maintenance ^pl^^vrtio work in^ 
buildings with ACM. 



U.S. EPA 
Asbestos Ban 
and Phaseout Rule 



as a hazardous 
waste, and require stringent handling, manifesting, and 
disposal procedures. In those cases, the state hazardous 



Bans on some uses and 
applications of asbestos 
under the Clean Air Act 
were briefly described 
in Chapter 1. In July 1989, under the Thxic Substances 
Control Act (TSCA), ER\ promulgated an Asbestos Ban 
arid Phaseout Rule. The complete rule was published in 
the Federal Register on July 12, 1989 

Beginning in 1990 and taking effect in three stages, the 
rule prdiibits the importation, manufacture, and proc- 
essing of 94 percent of all remaming asbestos products 
in the United States over a period of seven years. 



37 



r5> 





Demolition 


Renovation 


AMOUNT* 

(in 1 yr.) 


>260 bit. 
or > 160 sq. ft. 


<260 b.ft. 
or <160 sq.ft. 


>260 b ft. 
or 3= 160 sq. ft 


<260 ta. ft. 
<160 sq. ft. 


NOTIFICATION 


YES 


YES 


YES 


NOT 
REQUIRED 


HOW FAR IN ADVANCE* 


10 DAYS 


20 DAYS 


AS SOON 
AS POSSIBLE 


NOT REQUIRED 


EMISSION CONTROLS 
(Work Practices) 


YES 


NOT 
REQUIRED 


YES 


NOT 
REQUIRED 


DISPOSAL 
STANDARD 


YES 


NOT 
REQUIRED 


YES 


NOT 
REQUIRED 


*M)y be chinKcd on promul)talion of Revised NESHAP Rule in 1990 




A variety of federal, state, and local regulations govern the way building owners must deal with ACM 
in their Polities. State and local regulations may be more stringent than federal standards and often 
change rapidly. Building owners should periodically check with the appropriate Federal, State, and 
local authorities to determine whether any new asbestos regulations ha^ been developed or Aether 
current regulations have been amended. Specific federal regulations that may affect asbestos-related 
tasks and/or woricers are highlighted here: 



O OSHA Construction Industry Standard for 
Asbestos (29 CFR 1926.58). 

O OSHA General Industry Standard for Asbestos 
(29 CFR 1910.1001). 

O OSHA Respiratory Protection Standard 
(29 CFR 1910.134). 

O EPA yhrker Protection Rule (40 CFR 763 
Subpart G). 



O EPA National Emission Standards for Haz- 
ardous Air Pbllutants (NESHAP) (40 CFR 61 
Subpart M), 

O EPA Asbestos Hazard Emergency Response 
Act (AHERA) Regulations (40 CFR 763 Sub- 
part E). 

O EPA Asbestos Ban and Phaseout Rule (40 CFR 
763 Subpart 1). 



ERLC 



38 



29 



Appendix A. 



Glossary of Terms 

ACM 

Asbestos Program Manager 
Air Plenum 
Asbestos Abatement 

Delamlnatlon 
EPA 

Friable Asbestos 

Glovebag 

HEPA Filter 
Industrial Hyglenlst 
Medical Surveillance 

Miscellaneous ACM 

NESHAP 
NIOSH 

Personal Air Samples 

Prevalent Level Samples 
Surfacing ACM 

TSI 

TWA 



Asbestos-Containing Material. Any material containing more than one percent asbestos. 

A building owner or designated representative yfho supervises all aspects of the facility 
asbestos managenient and control program. 

Any space used to convey air in a buildingor structure. The space above a suspended ceiling 
is often used as an air plenum. 

Procedures to control fiber release from asbestos-containing materials in a building or to 
remove it entkely These may involve removal, encapsulation, repair, enclosure, 
encasement, and operations and maintenance programs. 

Separation of one layer from another. 

U.S. Environmental Protection Agency 

Any materials that contain greater than one percent asbestos, and which can be cnmibled, 
puhrerized, or reduced to powder by hand pressure. This may also include previously non- 
friable material which becomes broken or damaged by mechanical force. 

A polyethylene or polyvinjd chloride bag-like enck)sure affixed around an asbestos- 
containing source (most often, TSD so that the material may be removed yMe minimizing 
release of airborne fibers to the surrounding atihosphere. 

High-Effidency Particulate Air Filter. Such filters are rated to trap at least 99.97% of all 
particles 0.3 microns in diameter or larger. 

A professional qualified by education, training, and experience to anticipate, recognize, 
evaluate and develop controls for occupational health hazards. 

A periodic comprehensive review d a worker's health status. The required elements of an 
acceptable medical surveillance program are listed in the Occupational Safety and Health 
Administration standards for asbestos. 

Interior asbestos-containing building material on strurtural components, structural 
members or fixtures, such as floor and ceiling tiles; does not include surfacing material or 
thermal system insulation. 

National Emission Standard for Hazardous Air Pollutants— ER\ Rules under the Clean Air 
Act. 

The National Institute for Occupational Safety and Health, which was established by the 
Occupational Safety and Health Act of 1970. Primary functions of NIOSH are to conduct 
research, issue technical information, and test and certify respirators. 

An air sample taken with a samjtog pump directly attached to ihe worker with the 
collecting filter and cassette placed in the worker's breathing zone. These samples are 
required by the OSHA asbestos standards and the EPA Worioer Protection Rule. 

Air samples taken under normal conditions (also known as ambient background samidesX 

Asbestos^containing material that is sprayed-on, troweled-on or otherwise ai^ed to 
surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural 
members, or other materials on surfaces for acoustical, fireproofing, or other purposes. 

Thermal system insulation — asbestos-containing material applied to pipes, fittings, 
boilers, breeching, tanks, ducts or other interior structural components to prevent heat 
k)ss or gain or water condensation. 

Time-wei^ted Average. In air sampling, this refers to the average air concentration of 
contaminants during a particular sampling period. 



Appondtx B. 

Sample Recordkeeping Forms 

I Form L A sample form for recording information during ACM reassessment. 

Reinspection of Asbestos-Containing IVIaterials 

Location of asbestos-containing material (address, building, room, or general description): 



lype of asbestos-containing material(s): 

1. Sprayed- or troweled-on ceilings or walls 

2. Sprayed- or troweled-on structural members 

3. Insulation on pipes, tanks, or boOer 

4. Other (describe): 



Abatement Status: 

1. The material has been encapsulated , enclosed , neither , removed 

Assessment: 

1. Evidence of physical damage: 



2. Evidence of water damage: 



3. Evidence of delamination or other damage: 



4. Degree of accessibility of the material: 



5. Degree of activity near the material: 



6. Location in an air plenum, air shaft, or airstream: 



7. Other observations (including the condition of the encapsulant or enclosure, if any): 



^'Recommended Action: 



' SignedL 

I- o 
I ERIC 



(evaluator) 



Date: 



Form 2. A sample application form for maintenance mrk approval. 

Job Request Form for iViaititetiance Work 

Name: Datei 



Telephone No Job Request No. 

Requested starting date: Anticipated finish date: 



Address, building, and room number(s) (or description of area) where work is to be performed: 



Description of work: 



Description of any asbestos-containing material that might be affected, if known (include location and type): 



Name and telephone number of requestor: 



Name and telephone number of supervisor: 



Submit this application to: 



(The Asbestos Program Manager) 

NOTE: An application must be submitted for all maintenance work whether or not asbestos-containing material might be 
affected. An authorization must then be received before any work can proceed. 

Granted Qob Request Na ) 

With conditions* 

Denied 

^Conditions: 



41 



Form 3. A sample maintenance ^\•ork authorization form. 

Maintenance Work Authorization Form 

AUTHORIZATION 

Authorization is given to proceed with the following maintenance wx)rk: 



PRESENCE OF ASBESTOS-CONTAINING MATERIALS 

Asbestos-containing materials are not present in the vicinity of the maintenance work. 

ACM IS present, but its disturbance is not anticipated; however, if conditions cha^.^e, the Asbestos Program Manager 

will re-evaluate the work request prior to proceeding. 

ACM is present, and may be disturbed. 

Work Practices If Asbestos-Containing Materials Are Present 

The following work practices shall be employed to avoid or minimize disturbing asbestos:* 



Personal Protection If Asbostos-Contc^^ning Materials Are Present** 

The following equipment/clothes shall be used/worn during the work to protect workers: 



(manuals on personal protection can be referenced) 
Special Practices and/or Equipment Required: 



Signed: - Date: — 

(Asbestos Program Manager) 

o 33 

ERIC 42 



Form 4w A sample work evaluation form 

Evaluation of Work Affecting Asbestos-Containing Materials 

This evaluation covers the foIIo\\ing maintenance work: 

Location of workd (address, building, room numbers), or general description): 



Date(s) of work: 

Description of work: 

Work approval form number: 

Evaluation of work practices employed to minimize disturbance of asbestos: 



Evaluation of work practices employed to contain released fibers and to clean up the work area: 



Evaluation of equipment anH procedures used to protect workers: 



Personal ak monitoring results; (in-house worker or contract?) 

Worker name Results:. 

Worker name Results:. 

Handling or storage of ACM waste: ^ 



Signed: __ Date: . 

(Asbestos Program Manager) 



V 43 
ERIC 



Appendix (X 

iiiusirative Organizaiion Charis 




Rgure L A sample organization for a building owner with 
a large in-house management staff. Shaded boxes indicate 
outside assistance. 



Owners and Managers Who Employ an Extensive In-house Management Staff 



IN-HOUSE STAFF (FIGURE 1) 

Asbestos Program Manager: Has authority and overall 
nssponsibility for the asbestos control program. May develop 
the O&M program. Coordinates all activities. May also 
administer the respiratory protection program. 

Physical Plant Manager: (may also be the Asbestos 
Program Manager) Participates in establishing work practices 
for cleaning aind maintenance activities, and in training 
custodial and maintenance staff to use them. Assists in 
implementing the O&M program and in conducting periodic 
reinspections of the ACM. Ensures that outside contractors 
follow O&M procedures. 

Communications Person: (Public Affairs Officer, Nurse, 
Physician, Industrial Hygienist) Assists in preparation and 
distribution of information about ACM in the building. Person 
should be a good speaker and communiL^ .'r. 

Recordl<eeping Person: (Executive Assistant, Secretary) 
Responsible for maintaining records. 



OUTSIDE ASSISTANCE 

EPA Regional Asbestos Coordinatoi; NESHAP Coor- 
dinator and StateAociri Government Advisors: Pro- 
vide general guidance and answer specific questions. 

O 

ERLC 



OSHA Regional Office: May be helpful in answering 
questions about existing regulations, and providing guidance 
for worker protection. 

Asbestos Consultant(s)*: (Industrial Hygienists, Health 
Professionals, Architects, Engineers, and others) May assist in 
various aspects d the asbestos O&M program, including its 
development and implementation. May also conduct material 
inspections and provide work practice recommendations. 

Lawyer: Provides advice on legal requirements (such as laws 
and statutes) and liability aspects of the program. 

Asbestos Contractor*: May provide services for ACM 
abatement and for building decontamination following a fiber 
release episode. 



*It is important for owners and Asbestos Program Manager's to 
consider potential "conflict of interest" issues pertaining to those 
persons or firms used to sample, inspect, assess, analyze, recom- 
mend response actions, design response actions, and conduct 
asbestos response actions. 



44 



Figure 2. A sample organization for owners of buildings 
where services are provided by cx)ntract. Shaded boxes 
indicate outside assistance. 



Owners and Managers Who Contract For Services 



IN-HOUSE STAFF (FIGURE 2) 

Asbestos Program Manager: Has overall responsibility 
for the asbestos control program. May develop and implement 
the O&M program. Establishes training and experience re- 
quirements for contractor's workers. Supervises and enforces 
woric practices with assistance of woric crew supervisors. 
Conducts periodic reinspections and responsible for rec- 
ordkeeping. This person should be property trained in O&M 
program development and implementation (see Chapter 5). 



OUTSIDE ASSISTANCE 

EPA Regional Asbestos Coordinator and StateAocal 
Government Advisors: Provide general guidance and 
answer specific questions. 

OSHA Regional Office: May be hdpful in answering 
questions about existing regulations and provkling guidance 
for woricer protection. 



Asbestos Consultant(s)*: (Industrial Hygienists, Health 
Professionals, Architects, Engineers, and others) May assist 
Asbestos Program Manager in various aspects d the asbestos 
O&M program, including development and implementation. 
May also conduct the inspection and provide work practices 
recommendations. 

Lawyer: Provides advice on legal requirements (laws and 
statutes) and liability aspects of the prognun. 

Asbestos Contractor*: May provide services for ACM 
abatement and building decontamination following a fiber 
release episode. 

♦It is important for owners and Asbestos Program Manager's to 
consider potential "conflict of interest" issues pertaining to those 
persons or firms used to sample, inspect, assess, analyze, recom- 
mend response actions, design response actions, and conduct 
asbestos response actions. 



45 



APPENDIX D. 

Additional Assistance and Training 

EPA REGIONAL CONTACTS 

Additional assistance can be obtained from your U.S. 
EPA Regional Asbestos Coordinators, NESHAP Re- 
gional Coordinators, and OSHA Regional Offices. Their 
telephone numbers are listed below: 

EPA Region I: (CT,ME,MA,NH,RI,VT) 

Asbestos Coordinator (617) 565-3835 
NESHAP Coordinator (617) 565-3265 

EPA Region II: (NJ,NY,PR,VI) 

Asbestos Coordinator (201) 321-6671 
NESHAP Coordinator (212) 264-6770 

EPA Region III: (DE,DC,MD,PA,VA,WV) 

Asbestos Coordinator (215) 597-3160 
NESHAP Coordinator (215) 597-6550 

EPA Region \V. (AL,FL,GA,KY,MS,NC,SC,TN) 

Asbestos Coordinator (404) 347-5014 
NESHAP Coordinator (404) 347-2904 

EPA Region V: (IL,IN.MlMN,OH,WI) 

Asbestos Coordinator (312) 886-6003 
NESHAP Coordinator (312) 353-2088 

EPA Region VI: (AR,LA,NM,OK,TX) 

Asbestos Coordinator (214) 655-7244 
NESHAP Coordinator (214) 655-7229 

EPA Region VII: (IA,KS,MaNE) 

Asbestos Coordinator (913) 551-7020 
NESHAP Coordinator (913) 551-7020 

EPA Region VIII: (CO,MXND,SD,UT,WY) 
Asbestos Coordinator (303) 293-1442 
NESHAP Coordinator (303) 294-7685 

EPA Region IX: (AZ,CA,HI,NyAS,GU) 

Asbestos Coordinator (415) 556-5406 
NESHAP Coordinator (415) 556-5526 

EPA Region X: (AK,ID,OR,WA) 

Asbestos Coordinator (206) 442-4762 
NESHAP Coordinator (206) 442-1757 

OSHA REGIONAL OFFICES 

Region I - Boston. MA: (617) 223-6710 
Region II - New York, NY: (212) 944-3432 
Region III -Philadelphia. PA: (215) 596-1201 
Region IV- Atlanta. GA: (404) 347-3573 
Region V- Chicago. IL: (312) 353-2220 
Region VI - Dallas. TX: (214) 767 4731 



Region VII - Kansas City, MO: (816) 374-5861 
Region VIII- Denver, CO: (303) 844-3061 
Region IX-Saii Francisco. CA: (415) 995-5672 
Region X- Seattle. WA: (206) 442-5930 



Toxic Substances Cortrol Act (TSCA) 
Assistance Hotline 

Copies of the EPA Guidance Documents, Technical Bulletins, 
and other publications cited here can be obtained by calling the 
TSCA Assistance Hotline, in Washington. D.C, at: (202) 
554-1404. 



Approved IVaining Centers 

Certain training centers and satelbte centers were initially 
funded by EPA to develop asbestos training courses. They, and 
other training providers approved by EPA or states, offer 
courses for professionals such as asbestos inspectors and 
management planners involved with ACM detection and 
control, for asbestos abatement project designers, project 
supervisors and abatement workers, and others. In general, 
qualified professionals trained as inspectors and asbestos 
management planners would be good choices to design an 
O&M plan. Original training centers are located at the 
following sites: 



Tufts University 
Curtis Hall 

Asbestos Information Center 
474 Boston Avenue 
Medfoid, MA 02155 
(617)381-3531 

University of Illinois at Chicago 
Midwest Asbestos Information Center 
Box 6998 
Chicago, IL 60680 
(31^) 996-6904 



Georgia Institute of Technology 
GTRI/EDL/ESTD 
29 O'Keefe Building 
Atlanta, GA 30332 
(404) 894-3806 

University of Kansas 
Asbestos Training Center 
6600 College Blvd. Suite 315 
Overland Park, KS 66211 
(913) 491-0181 

Pacific Asbestos 
Information Center 
University CA/Extension 
2223 Fulton St. 
Berkeley. CA 94720 
(415) 643-7143 



Additional training providers are listed in the Federal Register 
on a regular basis. Call (202) 554-1404 for information. In 
addition, information on how to receive a copy of an O&M 
Course produced by an EPA contractor may be obtained at tlie 
same number. 

OTHER ORGANIZATIONS 

National Conference of State Legislatures (NCSL) 

Denver, CO -(303) 623-7800 
National Institute of Building Sciences (NIBS), 

Washington, DC -(202) 289-7800 
American Board of Industrial Hygiene (ABIH), 

Unsing, MI -(517) 321-2638 
National Institute for Standards and Technology (NIST), 

Gaithersburg, MD — (contact for lab accreditation) — 

(301) 975-4016 



ERIC 



46 



37 



APPENDIX E: 

Respiratory Protection 
Recommendations 

EPA recommends that the following guidelines be followed for 
respiratory protection during various custodial and mainte- 
nance tasks. These guidelines are issued to cover ta^^ks that do 
not always create routine fiber levels high enough to triggei 
OSHA respiratory protection requirements. Therefore, build- 
ing owners should note they go beyond OSHA requirements. 



Routine maintenance where contact with 
ACM is unlikely. No respiratory protection re- 
quired. (Air-purifymg respirator with high-efficiency 
filters should be available if needed; half-face or full 
facepiece). 

Routine maintenance where there is reason- 
able likelihood of ACM disturbance. Air-punfy- 
ing respirator w h high-efficiency filters (half-face or 
full facepiece). 



An industrial hygienist or envircnn-.€ntal/ocr»;pationai health 
professional should assist workers with respirator selection 
and fitting, and train them in respirator use. Fit-testing (which 
means determining whether a particular brand and size of 
respirator properly fits an individual worker) is essential, since 
respirators which leak at the face seal provide significantly less 
protection. OSHA requires fit-testing initially and every six 
months for employees required to wear a negative pressure 
respirator for protection against asbestos, or for individuals 
exposed at or above the OSHA-specified limits. 

A respirators effectiveness is also influenced by how it is 
handled, cleaned, and stored. Custodial and maintenance staff 
should clean their respirators after each u! and disinfect their 
respirators at the end of a day'*, use. This unproves comfort, 
and also reduces the chances of skin irritation or infection. 
After cleaning the respirator, custodial and maintenance staff 
should place the respirator (with the worker's name) m a clean 
and sanitary location and store the unit in a secure place for 
future use. Respirators should be visually inspected by the user 
before and after each use, during cleaning and at least monthly 
when not in use. Inspection records should be maintained 
accordingly When the respirators high-efficiency filters are 
discarded, they should be disposed of as asbestos waste. 



Maintenance or repair involving intentional 
small-scale disturbance of ACM. Powered air- 
purifying respirator with high-tfficiency filters, or air- 
purifying respirator with high-efficiency filters (half- 
face or full facepiece). If glove bags are used to contain 
the ACM during disturbance, either half-face or full 
facepiece air-purifying respirators with high -effi- 
ciency filters may be used. 

Any O&M activity requiring sawing^ cutting, 
drilling, abrading, grinding, or sanding ACM. 

(NOTE: specially equipped tools with local exhaust 
ventilation should be used for these activities. See 29 
CFR 1910.) Pbwered air-purifying respirator with 
high-efficiency filters, or full faceoierc, air-purifymg 
respirator equipped with high-efficiency filters should 
be used. 

Cleanup after a minor asbestos fiber release. 

Air-purifymg respirator wnth high-efficitncy filters 
(half-face or fiill facepiece). 

Cleanup after a major asbestos fiber release. 

Air-supplied respirators, either the "Type C" airline 
respirator equipped with a backup high-efficiency 
filter or SCBA (Self-Contained Breathing Apparatus). 



The U.S. EPA, in collaboration with NIOSH, has issued a 
guidance document. "A Guide to Respiratory Protection for 
tile Asbestos Abatement Industry" which recommends levels 
of respiratory protection for those engaged m large-scale 
asbestos abatement projects that are be>-ond routine 0«&M 
procedures. Air-supplied self-contained, and '"type C" airline 
respirators are the focus of the EPA/NIOSH document. These 
respirators allow workers to breathe fresh air supplied through 
hoses and face masks, and are generally used only by asbestos 
abatement workers engaged m large-scale asbestos removal 
projects. They are usually not considered eitlier practical or 
necessary for most custodial and maintenance jobs. 

O 

ERLC 



APPENDIX F 



Existing EPA Guidance for Each Step That a Building Owner May Take 
to Control ACM 



Action 



Existing EPA Guidance/Regulations* 



Appoint Asbestos Program 
Manager and Develop an 
Organizational Policy, 

Inspect the facility to determine 
if ACM is present. Take bulk 
samples of suspect ACM and 
assess the materials condition. 



Establish an O&M program. 



Implement and Conscientiously 
Manage tlie O&M Program; 
Assess the Potential for 
Exposure to Asbestos and Select 
Response Actions. 



Select and Implement 
Abatement Actions Other Than 
O&M When Necessary 



"Guidance for Controlling Asbestos-Containing Materials in Buildings" C'Purple Book") 
EPA publication number: 560/5-85-024 



"Guidance for Controlling Asbestos-Containing Materials m Buildings" ("Purple Book", 
chapter 2) EPA publication number: 560/5-85-024 

"Simplified Sampling Scheme for Surfacing Materials" ("Pink Book") EPA publication 
number: 560/5-85-030a 

"Asbestos-Containing Materials in Schools; Final Rule and Notice" (Asbestos Hazard 
Emergency Response Act. or AHERA). Federal Register— Ociober 30, 1987. (sections 
763.85 to 763.88) 

Model training course materials for accrediting asbestos building inspectors in accordance 
with AHERA (inspection/assessment materials), 

"Purple Book", Chapter 3 

AHERA regulations, sections 763.91 and 763,92 

EPA Guidance for Service and Maintenance Personnel. EPA publication number 
560/5-85-018 

"Purple Book", Chapter 4 

Model training course materials for accrediting asbestos management planners in 
accordance with AHERA (assessment materials). 

AHERA regulations, section 763.88 and 793.92 

"Purple Book", Chapter 6 

AHERA regulations, section 763.93 (including 763.85 through 763.92) 

AHERA regulation, appendix A; Determniing Completion of Response Actions-Methods. 

"Abatement of Asbestos-Containing Pipe Insulation" U.S. EPA; Asbestos-in-Buildmgs 
Technical Bulletin 1986-2. 

U.S. EPA National Emission Standards for Hazardous Air Pollutants (NESHAP) 
Regulations (40 CFR 61) 

Model training course materials for accrediting asbestos management planners in 
accordance with AHERA (assessment materials). 



♦Most of these guuinnce inatennis are available through KPAs TSCA Assistance Hotline, at (202) 554-M04. 



ERLC 



48 



39 



APPENDIX G: 



Sample List of Suspect Asbestos-Containing Materials 



• Cement Pipes 


• Elevator Brake Shoes 


^ o t. ttf iit_ J 
• Cement Wallboard 


• HVAC Duct Insulation 


• Cement Siding 


• Boiler Insulation 


• Asphalt Floor Tile 


• Breeching Insulation 


• Vinyl Floor Tile 


• Ductwork Flexible Fabric Connections 


• Vinyl Sheet Flooring 


• Cooling Towers 


• Flooring Backing 


• Pipe Insulation (corrugated air-cell, block, etc.) 


• Construction Mastics (floor tile, carpet, ceiling tile, etc.) 


• Heating and Electrical Ducts 


• Acoustical Plaster 


• Electrical Panel Partitions 


• Decorative Plaster 


• Electrical Clotli 


• Textured Paints/Coatings 


• Electric Wiring Insulation 


• Ceiling Tiles and Lay-in Panels 


• Chalkboards 


• Spray-Applied Insulation 


• Roofing Shingles 


• Blown -in Insulation 


• Koonng re it 


• Fireproofing Materials 


• Base Flashing 


• Taping Compounds (thermal) 


• Thermal Paper Products 


• Packing Materials (for wall/floor penetrations) 


• Fire Doors 


• High Temperature Gaskets 


• Caulking/Putties 


• Laboratory Hoods/Table Tops 


• Adhesives 


• Laboratory Gloves ■ 


• \^llboard 


• Fire Blankets 


• Joint Compounds 


• Fire Curtains 


• Vinyl Wall Coverings 


• Elevator Equipment Panels 


• Spackling Compounds 



NOTE: This list does not incVde every produtt/inaterial that iiiav ^.untam asbestos It is intended as «i generdl guidt io show which tvpes of 
materials may contain asbestos. 



APPENDIX H: 

References 

USEPA. 1984. U.S. Environmental Protection Agency Na- 
tional Emission Standards for Hazardous Air Pollutants. 40 
CFR 6L April 5, 1984. 

USEPA. 1985. U.S. Environmental Protection Agency Meas- 
uring airborne asbestos folbwing an abatement action. 
Washington DC: USEPA. EPA 600/4-85-049. ("Silver Book") 

USEPA. 1985. U.S. Environmental Protection Agency As- 
bestos in buildings: Simplified sampling scheme for surfacing 
materials. Washington DC: USEPA. EPA 560/5-85-030A. 
("Pink Book") 

USEPA. 1985 U.S. Environmental Protection Agency Guid- 
ance for controlling asbestos-containing materials in build- 
ings Washington DC: EPA 560/5-85-024. ("Purple Book") 



USEPA. 1985. U.S. Environmental Protection Agency ^45- 
bestos in buildings: Guidance for service and maintenance 
personnel. Washington DC: EPA 560/5-85-018. ("Custodial 
Pamphlet") 

USEPA. 1986. U.S. Environmental Protection Agency Abate- 
ment of asbestos<on taming pipe insulation. Washington DC: 
Technical Bulletin No. 1986-2. 

USEPA. 1986. U.S. Environmental Protection Agency A 
guide to respiratory protection for the asbestos abatement 
industry. Washington DC: EPA 560/OPTS-86-001. 



USEPA. 1987. Asbestos Abatement Projects; Worker Protec- 
tion, Final Rule. 40 CFR 763. February 1987. 

USEPA. 1987. U.S. Environmental Protection Agency As- 
bestos-Containing Materials in Schools: Final Rule and 
Notice. 40 CFR 763. Federal Register, October 30. 1987. 

USEPA. 1988. EPA Study of Asbestos-Containing Materials 
in Public Buildings: A Report to Congress. February, 1988. 

USEPA. 1989. Asbestos Ban and Phaseout Rule. 40 CFR 
763.160 to 763.179. Federal Register, ]u\y 12, 1989. 

USEPA. 1989. Guidelines for Conducting the A HERA TEM 
Clearance Test to Determine Completion of an Asbestos 
Abatement Project. Washington DC: EPA 560/5-89-001. 

USEPA. 1989. Transmts^^ion Electron Microscopy Asbestos 
Laboratories: Quality Assurance Guidelines. Washington DC: 
EPA 560/5-90-002. 

U.S. Department of Labor: OSHA Regulations. 29 CFR 
1910. 1001 - General Industry Asbestos Standardznd 29 CFR 
1926.58 - Construction Industry Asbestos Standard. June 
1986; Amended, September. 1988. 

U.S. Department of Labor: OSHA Regulations. 29 CFR 
1910.134 - Respiratory Protection Standard. June. 1974. 

Keyes, Dale L. and Chesson, Jean. 1989. A Guide to 
Monitoring Airborne Asbestos m Buildings. Environmental 
Sciences, Inc.. 105 E. Speedway Blvd., Tucson, Arizona 85705.