U.S. ENVIRONMENTAL PROTECTION AGENCY
STANDARD METHODS FOR CONDUCTING
ASBESTOS O&M WORK PRACTICES
Office of Administration and Resources Management
Safely, Health, and Environmental Management Division
Washington, D.C.
July, 1994
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Background
EPA’s national safety, health and environmental management program has as its focus
the development, implementation and ongoing management of consistent asbestos-
containing building materials (ACBM) Operations and Maintenance (O&M) Plans for each
facility where ACBM are known or assumed to be present.
EPA’s policy and program (hereinafter the “Program’) have been developed with the goal
of minimizing ambient asbestos fibers levels, economic, socially, technical, and
environmental factors being taken into account.
As an integral part of EPA’s Program for the management of ACBM at EPA facilities,
Standard Operating Practices (SOPs) establish guidance for the general approaches and
work practices, which are implemented at the operations level to effectuate the various
requirements of the program in laboratory, field, and other settings.
The standard methods (SM5) document that follows is maintained under the SOP’s, and
provides detailed guidance for specific procedures and techniques, to be employed in the
conduct of certain work activities. As the core of the SMs document, EPA’s Safety
Health, and Environmental Management Division (SHEMD) has developed a model O&M
Program Document for managing ACBM at EPA occupied or controlled facilities. The
model O&M Plan will aid Asbestos Program Managers (APM) in the development,
implementation and administration of asbestos programs for the management of asbestos
risks on a facility-specific basis.
These SM5 are drawn from, and modeled after, the National Institute of Building
Sciences(NIBS) Guidance Manual: Asbestos Operations & Maintenance Work Practices,
a consensus project conducted according to procedures approved by NIBS Board of
Directors. NIBS Work Practices, Asbestos Program Manager (APM) General Procedures
and Worker General Procedures For In-Place Management of Asbestos are used as the
starting point for developing this O&M plan for EPA occupied or controlled facilities. This
document may also be applicable for use by other federal agencies, and state and local
governments, as well as by private industry.
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Editing this Model O&M Program
This document has been developed to be used in conjunction with EPA’s July 1990
Guidance Document entitled Managing Asbestos In-Place -A Building Owner’s Guide to
Operations and Maintenance Programs for Asbestos-Containing Materials (EPA
publication number 20t-2003), also known as the “Green Book”. This document assumes
that the users have a copy of the Green Book and are familiar with it’s content. It also
assumes that the users have copies of applicable federal, state and local regulations and
are familiar with their requirements.
The designated APM is responsible for the editing of this document to meet the needs
of the facility in which it is intended. These SMs are not intended to be used in an
unedited format . This document is designed to assist the APM in creating an O&M
manual for a specific facility. Introductory blue sheets (like this one) are included at the
beginning of each section to help explain particular aspects of each section. These “blue
sheet” introductions are flç intended to be a part of the facility’s final document, but are
tools in the process of helping the APM in editing this document. Along with the
introductory sections, notes are also found through-out the document referencing
pertinent information that the editor/APM will need to determine and are recognized in the
following formats:
[
or
Editing Information
(to be read, action taken then deleted from final printing)
The following major portions require editing:
1. The cover.
2. The table of contents.
3. Section I, survey/assessment information must be incorporated. If a survey of a
facility has not been performed, efforts should be made to have a thorough survey
completed as soon as possible. An O&M Program for the entire facility cannot be
prepared without a comprehensive survey for ACM.
4. Section I, locations of asbestos-containing building materials (ACBM) (text and
chart).
5. Section II, APM information.
6. Section 0, APM General Procedures.
7. Section Ill, Worker General Procedures.
8. The Work Practices.
9. Add and append appendix sections to reflect the needs of the facility.
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10. Throughout the document reference is made to state and local regulations. Modify
these standard methods as required to comply with applicable and/or more
stringent state and local regulations. Include appendices containing state and/or
local regulations.
Also enclosed is a 3 1/2” high density diskette that contains the unedited model EPA
O&M documentation files in Wordperfect 5.1 format. These files are broken out into
sections for easy accessibility and use. The following will reference the section to the file:
Sections/Title of Section
COVER. Cover of Document
TOC. Table of Contents for the entire document
INTRO. Section I, Introduction
TYPES. Section I, Types & Locations of Asbestos-Containing Building Materials
LOCATION. Locations of Asbestos-Containing Building Materials
VALID. Section I, Validation
O&M-WP. Section I, O&M Work Practices
USE. Section I, Use of O&M Work Practices
APM. Section II, Asbestos Program Manager
WORKER. Section III, Worker General Procedures
SURI-7. Section IV, Surfacing Materials Work Practices (1-7)
SUR8-13. Section IV, Surfacing Materials Work Practices (8-13)
TSI. Section V, Thermal Systems Insulation (TSI) Work Practices
MISC1-8. Section VI, Miscellaneous Materials Work Practices(1-8)
MISC9-15. Section VI, Miscellaneous Materials Work Practices(9-15)
MIS16-23. Section VI, Miscellaneous Materials Work Practices(16-23)
MIS24-28. Section VI, Miscellaneous Materials Work Practices(24-28)
MIS29-34. Section VI, Miscellaneous Materials Work Practices(29-34)
APPENDIX. Appendices A - K
To obtain an original, unedited copy of the version produced and published by the
National Institute of Building Sciences(NIBS) Guidance Manual: Asbestos Operations &
Maintenance Work Practices document you can call or write to:
The National Institute of Building Sciences
Publications Department
1201 L Street, N.W., Suite 400
Washington, D.C. 20005-4014
202/289-7800 FAX 202-289-1092
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To obtain an original, unedited copy of the version produced and published by the
National Institute of Building Sciences(NIBS) Guidance Manual: Asbestos Operations &
Maintenance Work Practices document you can call or write to:
The National Institute of Building Sciences
Publications Department
1201 L Street, N.W., Suite 400
Washington, D.C. 20005-4014
202/289-7800 FAX 202-289-1092
To obtain a copy of the Green Book, Managing Asbestos In Place -“A Building Owner’s
Guide to Operations andMaintenance Programs for Asbestos-Containing Materials” you
can call or write to:
The United States Government Printing Office
Superintendent of Documents
Mail Stop SSOP
Washington, D.C. 20402-9328
202/783-3238
Copies of EPA’s Purple Book and Pink Book , can also be obtained by contracting the
Government Printing Office.
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Standard Methods for Conducting
Asbestos Operations & Maintenance
Work Practices
for
EPA Occupied Space in
I
[ ADDRESS]
[ CITY, STATE, ZIP]
DRAVF
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Table of Contents
Manual Organizalion
Introduction . I
Types and Locations of Asbestos-Containing Building Material (ACBM) 4
O&M Work Practices 6
Validation . 12
Use of O&M Work Practices 16
Asbestos
APM
APM I
APM2
APM3
APM4
APM5
APM6
APM7
APM8
APM9
Program Manager
Checklist
Selection of Personal Protective Equipment &
Decontamination Procedures 4.
Work Scheduling 5
Federal, State and Local Notification 6.
Notification of Personnel 7
Assigning Workers 7
Developing the Air Monitoring Program and Assigning Air
Monitoring Personnel 8
Recordkeeping 11
Confined Spaces 12
Selection of Materials 13.
II.
Table of Contents
1
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W4
W5
W6
W7
W8
W9
Wi 0
Wii
Wi 2
Wi 3
WI 4
Wi 5
Wi 6
Wi 7
Wi 8
Code
Si
S2
S5
S6
S7
S8
Levels
123
23
23
23
Emergency Work and Dry Removal 14
Inspecting Buildings for Asbestos-Containing Building
Materials 15
Table of Contents
‘Name o Facthty
....8
.....9
9
10
11
12
13
12
16
20
23
27
32
34
2
APM IO
APM I1
Ill. Worker General Procedures
Level 1 Checklist 3
Level 2 Checklist 4
Level 3 Checklist 65
Wi Tools, Equipment and Materials
W2 Preparing Amended Water or Removal Encapsulant
W3 Shut-off ‘and Lockout of HVAC and Electrical Systems
Securing Work Area
Putting on Respirators and Performing Fit Checks
Putting on Protective Clothing
Beginning and Conducting Air Monitoring
Precleaning Work Areas and Wet Wiping
Setting up Work Areas
Packaging and Labeling Waste
Applying Lockdown EncapsUlant
Cleaning Tools, Equipment and Work Area
Decontaminating Waste
Worker Decontamination and Removal of Protective Clothing
ándRespirators
Visual Inspection and Completing Air Monitoring
Waste Transportation, Storage and Disposal .‘. ,
Glovebag Removal
Disposal of Contaminated Water
Materials Work Practices
Materials Location Illustration
Description
Moving one non-asbestos-containing ceiling panel
below a plenum space that has exposed surfacing
ACM
Attach component to an ACM finished surface that is
above a non-asbestos-containing ceiling
Work in ceiling plenum space where exposed surfacing
ACM is present
Install wiring in plenum space where exposed surfacing
ACM ‘is present
Attach item to ceiling finished with ACM
Repair or replace item in surface finished with ACM.
Cut or drill hole in surfacing ACM
Replace bulbs in light fixture attached to or in surface
finished with ACM
Clean room with expOsed surfaces finished with ACM
14
17
19
19
20
20
22
23
23
27
IV. Surfacing
Surfacing
23
S3 123
S4 123
1
S9 I
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VI. Miscellaneous Materials Work Practices
Miscellaneous Materials Location Illustration
MI
M2
M3
M4
M5
M6
M7
MB
M9
M1O
Mu
1 2 3 Replacement of resilient asbestos floor tiles
1 2 3 Replacement of vinyl sheet flooring with ACM backing
1 2 3 Penetrate resilient asbestos flooring and subfloor
I Install new resilient flooring or carpet over resilient
asbestos flooring
1 2 Install partition over resilient asbestos flooring.
1 Wet strip floor wax from resilient asbestos flooring
I Dry or spray buffing resilient asbestos flooring
I Cleaning resilient asbestos flooring
1 2 3 Remove carpet over resilient asbestos flooring
1 2 Clean potentially asbestos-contaminated carpet
1 2 3 Remove asbestos-containing ceiling panels in lay-in
ceiling system
5
11
18
22
24
27
29
31
33
38
41
Tabte of Contents
“Name of Fac#ity”
3
Sb 1 2 3
Repair damaged surfacing ACM
36
SI 1 1 2 3
Accessing through an ACM finished surface
40
S12 1 2 3
Painting surfacing ACM 44
S13 2 3
Accessing a contaminated light fixture 48
V.
Thermal Systems
Insulation (FSI) Work Practices
Thermal Systems
Insulation Location Illustration 3
Code Levels
Description
Tb 2 3
Remove asbestos-containing insulation on exposed
T2 23
pipe for maIntenance work
Remove asbestos containiflg insulation on pipe above
ceiling for maintenance work
7
T3 23
Remove asbestos-containing insulation on exposed
pipe in elevated location for maintenance work
10
T4 3
Remove asbestos-containing insulation on pipe in
occupied area for maintenance work
13
T5 2 3
Repair damaged asbestos-containing insulation on a
pipe
15
T6 2 3
Repair damaged asbestos-containing insulation on a
boiler, duct or flue
19
17 2 3
Install device in or access surface of asbestos-
TB 2 3
containing insulation on a pipe, boiler, duct or flue . . .
Remove asbestoscontaining duct insulation above
ceiling for maintenance work
. 23
27
T9 2 3
Remove asbestos-containing insulation inside HVAC
unit for maintenance work
30
Tl0 2 3
Clean up asbestos-containing debris in crawlspace or
Code Levels
Description
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MI 2 2 3 Remove asbestos-containing ceiling tiles attached with
adhesive 45
M13 1 2 3 Remove asbestos-containing ceiling tiles in spline
ceiling system 48
M14 2 3 Cut or drill asbestos cement panels 52
MI 5 1 2 3 Remove asbestos cement panels . 55
M16 1 2 Remove asbestos cement cooling tower louvers 59
M17 1 2 Remove and replace asbestos cemônt roof shingles 62
M18 1 2 Remove and replace asbestos cement siding 65
M19 1 2 3 Remove high-temperature resistant (HTR) asbestos
cement panels. 68
M20 1 2 3 Remove asbestos-containing chalk board . 72
M21 1 2 3 Remove asbestos-containing fire door and/or door
hardware 76
M22 1 2 Remove asbestos-containing built-up roofing 80
M23 1 2 Remove asbestos-containing asphalt shingles 84
M24 2 3 Cut or drill asbestos-containing drywall, plaster or
drywall compound 89
M25 2 3 Remove section of asbestos-containing drywall 93
M26 1 2 3 Remove asbestos-containing flexible duct connector 96
M27 1 2 3 Remove asbestos-containing ductwork taping cloth 100
M28 2 Remove contaminated filters in HVAC unit serving
plenum space with exposed ACM 104
M29 1 2 Clean up debris from minor fiber release 106
M30 1 2 3 Replace asbestos-containing gaskets 109
M31 2 3 Emptying and changing filter in HEPA vacuum or
changing filter in HEPA fan unit 113
M32 1 2 3 Remove asbestos-wrapped wiring 116
M33 1 2 3 Removing asbestos-containing caulking compound 120
M34 1 Clean room that has asbestos-containing dust 124
Table of Contents 4
“Name of Fac ty ”
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Appendices
Appendix A -
Appendix B -
Appendix C -
Appendix D -
Appendix E
Appendix F -
Appendix G -
Appendix H -
Appendix I -
Appendix J -
Appendix K -
Job Request Form for Maintenance Work 1
Maintenance Work Authorization Form 3
Evaluation of Work Affecting Asbestos-Containing
Building Materials 5
Waste Tracking Form 7
Glossary 9
References. 15
General Safety Considerations 20
Definitions of Small-scale, Short-duration Operations ... 28
Regulations 34
Inspecting Buildings for Asbestos-containing building
materials 41
EPA Health and Safety Guidelines for EPA Asbestos
Inspectors (Revised) 59
Index to Illustrations
Figure 1 - Guidelines for 3 Levels of Work Practices
Figure 2 - Work Practices Selection and Use
Figure 3 - Asbestos Program Manger Checklist
Figure 4 - Level I Worker Checklist
Figure 5 - Level 2 Worker Checklist
Figure 6 - Level 3 Worker Checklist
Figure 7 - Surfacing Materials Location Illustration
FigUre 8 - Thermal System Insulation Location Illustration
Figure 9 - Miscellaneous Materials Location Illustration . .
Section I, page 10
Section I, page 18
Section II, page 3
Section III, page 3
Section Ill, page 4
Section Ill, page 6
Section IV, page 3
Section V, page 3
Section VI, page 4
Table of Contents
“Name o FaoThty
5
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I
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Introduction
Information contained on pages 1, 2 and 3 are general in nature and should require the
writer to only add the [ Name of Fa i1ity], where indicated
Specific building data regarding the type and location of Asbestos-containing building
materials (ACBM) must be added at pages 4 and 5. It is important to note, however, that
pages 4 and 5 can only be completed if an asbestos survey has been performed in the
building. Preferably by the building owner, but EPA (as a tenant) may have elected to
conduct the survey for ACBM.
Pages 6 - 19 are of general information or explanation, and should require the writer to
only complete the [ Name of .acmty]
If an asbestos survey has not been performed, this document cannot be completed, and
the writer should contact the EPA representative responsible for the space’s lease.
Guidance in conducting an asbestos survey is provided by the following documents which
are included in the SMs documents which are included in the SMs document as
appendices:
Appendix J: Inspecting Buildings for Asbestos Containing Building Materials
Appendix K: Health and Safety Guidelines for EPA Asbestos Inspectors, revised
March, 1991.
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Section 1
Introduction
General This Asbestos Operations and Maintenance (O&M) Program has been prepared
to provide guidance on worker protection, basic O&M procedures, O&M - prac-
tices, and procedures for r
of 1 aciIity with asbestos-containing building materials (ACBM) This O&M Program has
been adapted from the National Institute of Building Sciences’ (NIBS) “Guidance Manual:
Asbestos Operations and Maintenance Work Practices”.
Scope and Flexibility The O&M practices described in this O&M Program are applicable
to projects qualifying as “small scale/short duration” (SS/SD) as defined by the Occupa-
tional Safety and Health Administration (OSHA) of the U.S. Departments of Labor and
EPA. The work practices are intended to assist in meeting the current OSHA regulations
applicable to O&M work. The current and proposed EPA and OSHA small-scale, short-
duration project definitions are reproduced in Appendix “H” of this manual. Appendix “G”
of OSHA regulation 29 CFR 1926.58 discusses work practices and engineering controls
for small-scale, short-duration renovation and maintenance activities involving ACBM.
Appendix “I” of this O&M Program describes the specific requirements for work practices
and engineering controls for SS/SD renovation and maintenance as discussed in OSHA
Regulation 290FR 1926.88.
Projects larger than SS/SD will not be performed by [ Name o Fa i1ityJ Staff, but will be
undertaken by qualified and trained outside asbestos abatement contractors. O&M work
practices in this O&M Program are not to be used for activities requiring full scale removal
of ACBM.
This O&M Program is intended for use by an Asbestos Program Manager (APM) and
trained workers. The APM is identified in Section II, Asbestos Program Manager General
Procedures. This O&M Program provides checklists and step-by-step work practices
which should be used by an APM and workers for performing O&M work. Because
asbestos in [ Name of Fec lrty] is present under widely varying circumstances including,
but not limited to, its condition, location, material type, friability, and accessibility, a range
of guidance for common operations and maintenance procedures is offered in this O&M
Program. Flexibility is crucial to the efficient and cost effective completion of an O&M
activity, therefore, the ultimate choice of methods is left to on-site personnel who have
first-hand knowledge of the asbestos material, facility conditions, and other pertinent
needs. These work practices were written with the knowledge that there might be
alternate procedures or equipment beyond those in this. O&M Program that will
adequately accomplish O&M objectives. The work practices included in the O&M
Program are based on commonly used practices presently in use. These work practices
are not the only successful methods currently available or in use, but were selected as
applicable for a wide range of common situations.
Different recommendations, referred to as levels, of the same work practice are provided
to accommodate for variations in the type and condition of the asbestos-containing
material to be worked on, the building conditions in which the ACBM is located, and the
skill level of workers (Note The [ Name of aci1ity] APM, at his/her discretion, may
INTRODUCTION
1
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employ outside contractors for any activity.) It is assumed that varying conditions will
require
different work practice levels to accomplish the same basic task. Selection of the
appropriate levels of work practices should be made by the APM for a project based
upon the conditions encountered at each incident. Risk assessments and liability
concerns might also influence the selection of the level for a specific work practices.
Assumptions The O&M Program has been developed on the assumption that all
asbestos O&M work, at a minimum, will be done in accordance with applicable regu-
lations by persons trained in asbestos in general, and O&M methods, in particular.
Related Documents This O&M Program is intended to be used in conjunction with the
guide Managing Asbestos in Place CGreen Book”) issued by the EPA in July, 1990, and
in compliance with all applicable federal, state and local regulations. The Green Book
explains the objectives and administrative proóedures for an O&M Program. This O&M
Work Practices Manual provides detailed procedures for conducting O&M work involving
ACBM, such as maintenance, repair and minor renovation work. It is expected that many
decisions relating to work practice levels might be embodied in the O&M plan for a spe-
cific building. In some circumstances, governing regulations may dictate level selection.
Information presented in the Green Book is not repeated in this guide but is referenced
where appropriate. Additional references might be made to other legal regulations and
guidance documents, including:
Statutory & Regulatory Requirements
1. OSHA’s asbestos construction, construction safety, personal protection and hazard
communication standards
2. OSHA’s construction standard for the asbestos industry
3. National Emission Standards for Hazardous Air Pollutants (NESHAP)
4. Asbestos Hazard Emergency Response Act (AHERA)
5. Asbestos Schools Hazard Abatement Reauthorization Act (ASHARA)
6. EPA Worker Protection Rule (WPR)
EPA Guidance Documents
1. Asbestos in Buildings: Simplified Sampling Scheme for Friable Asbestos Materials.
(“Pink Book”)
2. Guidance for Controlling Asbestos-Containing Materials in Buildings (“Purple Book”)
3. A Guide to Respiratory Protection for the Asbestos Abatement Industry (“White
Book”)
INTRODUCTION
‘Name ot FaCIIIfl!
2
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A list of references, including the above listed regulations and guidance documents, is
given in Appendix “F” of this O&M Program. A summary of the above listed OSHA and
EPA regulations is included in Appendix silu of this O&M Program. State and local
regulations, which - - ‘ nt , or more stririrrnt than federal
r •
I
INTRODUCT ION
“Name ci Facilk
- uld be used ior
not specifically mentioned in these work practices.
‘I I , — —
other aspects of O&M activities
3
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Types and Locations of Asbestos-Containing Building
Materials
Types: The following type s) of ACBM have been found to be present in
.
Locations of ACBM:
Include a brief overview of materials and their location(s.)
Example:
Acoustical ACBM Plaster: A survey has identified approximately 24,000 square feet of friable
ACBM ceilings In this facliity The ceilings with ACBM are located in the following areas:
• Second floor corridors 2200 and 2400.
• First and SeCond floor lobbies.
• Emergency stairwell.
Types of ACM
‘Name ol Fadl ty”
1.
Thermal Systems Insulation (T - - - ‘ -
3. Miscellaneous Material:
4
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‘ACBM LOCA11ONS
ACBM were used in the construction of vailous areas throughout
sted below are the rooms and the areas in the [ Name of ta containing ACBM.
LOCATIONS OF ACM
‘ Name ot Facility”
5
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O&M Work Practices
General The EPA Green Book provides building owners, managers, workers and other
building staff with basic information on how to develop and carry out operations and
maintenance programs.
The O&M work practices in this O&M Program are designed to provide detailed and
specific guidance to the O&M personnel for conducting maintenance, repair and minor
renovation work in accordance with this asbestps O&M program and applicable regula-
tions. The work practices in this O&M Program are designed to reduce or contain
materials, dust, or fiber release resulting from work performed on or near asbestos-con-
taining materials. The work practices are also intended to minimize the extent and impact
of any releases which do occur. Summaries of each work practice and examples of
typical situations that might be encountered are included to assist in the selection of
appropriate work practice levels.
The work practices in this O&M Program address most commonly encountered opera-
tions and maintenance tasks involving asbestos-containing materials. This O&M Program
is not exhaustively complete and does not document or establish a defined procedure for
every possible situation. The O&M Program is formatted to present an array of actual
conditions which might be encountered. It establishes a logical path to be followed in
selecting the most appropriate work practice(s) for a given situation. Staff are often very
familiar with actual building conditions and might provide valuable input to the design of
actual O&M work. They may also offer suggestions for modifications to specific work’
practices after the practices have been employed. Any changes to the work practices
should be reviewed with the APM prior to incorporation.
As a part of the O&M Program, the APM should review building survey information to
determine whether or not a suspect material contains asbestos. If a suspect material
which is to be worked on has not been sampled, it should either be sampled and ana-
lyzed in accordance with the EPA Protocol or be assumed to contain asbestos and treat-
ed accordingly.
O&M Program Assumptions This O&M Program assumes that all elements of an O&M
Program listed below have been considered and applicable elements established. Refer-
ences to related information are included in Appendix “F”.
• APM appointment and training
• Building inspection and assessment (Appendix J)
• Wdtten building-specific O&M program
• Copies of applicable regulations and guidance documents
• Occupant notification/communication program
• O&M worker, supervisor, and competent person assignments and training program
• Work control/inspection/permit system
• Periodic surveillance program
• Recordkeeping program
O&M WORK PRACTICES
F”’ 6
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• Hazard communication program
• Worker protection program
• Respiratory protection program
• Medical surveillance program
• Asbestos fiber release episode response program
• Air monitoring program
• Waste disposal program
• Historical air monitoring data
• Confined space program
• Safety program for other hazards
All O&M related programs should be reviewed periodically and revised if necessary.
Regulatory and guidance documents shouldalso be reviewed periodically to ensure that
they are current.
Organization of Work Practices The O&M work practices in this manual are organized
according to the type of ACBM that will be affected by the work. ACBM are classified in
this manual according to the three (3) categories used by the EPA. This classification
system has been widely used in the asbestos industry since the publication of the
Asbestos Hazard Emergency Response Act rules (AHERA) in 1987. These categories
are:
1.. Surfacing Materials - materials sprayed or troweled onto building surfaces, such
as acoustical, materials or fireproofing.
2. Thermal Systems Insulation ( Sl) Materials - pipe, boiler, tank, duct and other insu-
lation applied to components to reduce heat loss, heat gain or condensation.
O&M WORK PRACTICES
Name o FacTht (
7
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3. Miscellaneous Materials - materials such as floor tile, ceiling tile, roofing, cement
asbestos products and other materials that are not included in categories 1 or 2
above.
Work practices in this O&M Program need to be validated and/or modified for the
location(s) where O&M work will be performed. When work is to be performed, the final
work practices should be given to workers along with other referenced O&M forms.
Repetition of certain steps in different work practice levels is intentional in order to provide
consistent and complete information to a worker for a given work practice level.
Work Practice Levels Up to three levels are included for each work practice to address
different degrees of potential asbestos fiber exposure. These three levels were judged
sufficient (by NIBS in its initial development of the 0 & M Work Practices Manual) to
encompass a broad range of situations involving asbestos control which are likely to be
encountered.
A change of level does not imply a different task to be accomplished. It implies a
changed potential for asbestos fiber exposure, typically related to either the condition of
asbestos or the building context in which the task will be performed.
Examples are provided to assist users in selecting appropriate levels for. specific building
conditions. Higher levels become more protective and hence more difficult, time
consuming and costly to implement. Three levels are not provided for every work prac-
tice. If a work practice level is not included, it was deemed unlikely to be encountered
under typical conditions. An appropriate work practice level must be selected or created
by the APM for each 0&M activity that will occur in a facility.
The three work practice levels are defined as follows:
Level 1: Work practice is usually intended to avoid a disturbance of ACBM and
release of asbestos fibers, but if ACBM are disturbed, it is likely that worker
and building occupant exposures will be minimal.
Level 2: Work practice is likely to, or intended to, disturb small amounts of ACBM for
short periods of time. Worker protection and localized engineering controls
are justified, but the disturbance is unlikely to create building occupant
exposure or impact the building environment.
O&M WORK PRACTICES
“Name Fac f
8
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Level 3:
Work practice is intended to disturb small amounts ‘of ACBM in ways
sufficient to justify engineering controls, and protection of workers, building
occupants and the building environment.
While these activities are most likely to be performed by qualified trained outside asbestos
abatement contractors, this document is intended to set the standard by which either and
outside contractor or in house staff will perform this work. Therefore, all three levels are
defined in this section of the O&M Program.
A disturbance” of ACBM, as used in the level definitions, refers to any activity that
disrupts the matrix of ACBM, or generates visible debris, or disturbs visible debris.
Figure 1: Guidelines for 3 Levels of Work Practices, which follow, summarize the
engineering controls and practices recommended for, each level. The APM should deter-
mine the appropriate level, based on the O&M program objectives, the O&M program ele-
ments, and level of training needed for each level of work practices used in [ Wam of
O&M WORK PRACTICES
1 •Name Of Fac f
9
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Figure 1: Guidelines for 3 Levels of Work Practices
Training (APM5) 2
HVAC System Off (W3)
Vacate Area (W4, APM2 )
Critical Barriers (W4)
DeUneated Work Area (W4)
Respiratory Protection (W5)
Protective Clothing (W6, W14)
initial Monitoring ( dV7)
Periodic Monitoring (W7 )
Preclean (VV8)
Use HEPA Vacuum (W8 )
Wet Methods (W8)
Work Area Protection (W9)
Local HEPA Exhaust (W9 )
Lockdown (W1O)
Area Decontamination (Wi 1)
Visual inspection (W12 )
Air Clearance (W12)
Personal Decontamination (W15)
NOTES
1
Awareness/0&M 3
NO 4
NO
NO
NO
NO 6
NO 8
NO 9 ” 0
N 0 1 °
NO
As Needed 1 ’
As Needed 11
NO 12
NO
NO
NO
NO
NO 14
NO 15
O&M
YES
YES
NO 5
YES
YES 7
YES
YES 9 ” 0
YES
As Neede& ’
YES
YES
Drop Cloth,
Giovebag
As Neede& ’
YES 11
YES
YES
NO 14
YES
O&M
YES
YES
YES
YES
‘YES
YES
YES 9 ’ 10
YES
As Neede&’
YES
YES
Mini-Enclosure,
Negative Pressure
System 13
As Neede& 1
YES 11
YES
YES
YES
YES
The exact meaning of these three levels will vary depending upon the exposure objectives which
are specified In the design of the O&M plan for a specific building (see Design & Validation of An
O&M Plan for further explanation) State of [ name f stata and local requirements may be more
stringent than these guidelines.
2 The general procedures In parentheses provide.additlonal information on the noted item.
3 TraIning should be appropriate to the type of ACBM, building conditions, and the work to be
performed. If ACBM may be or will be disturbed, O&M training may be necessary.
4 Turn off HVAC if work will be performed on HVAC system(s).
5 CrItical barriers may be necessary or be required for specific cases by the APM.
O&M WORK PRACTICES
Name c FacTht f
10
-------
6 The OSHA asbestos standard, Appendix G, states that maintenance staff employees should be in-
structed not to remove ceiling tiles below ACBM without wearing the proper respiratory protection,
clearing the area of other people, and observing asbestos waste disposal procedures. Appendix
•E of the Green Book recommends that respIrators be worn for routine maintenance work where
there Is a reasonable likelihood of ACBM disturbance. For routine maintenance work where contact
with ACBM are unlikely, appendix E recommends uNo respiratory protection required. (Air-purifying
respirators with high-efficiency filters should be available if needed; half-face or full facepiece). EPA
advises buIlding owners that these recommendations go beyond OSHA requirements.
7 RespIratory protection can be deleted if supported by adequate exposure data In accordance with
the OSHA regulations.
8 ProtectIve clothing should be available and Is required by OSHA if exposure Is over permissible ex-
posure limit.
9 Monitoring Is required by OSHA If ACBM are disturbed.
10 Monitoring may be deleted if supported by statistically reliable historical data in accordance with
OSHA regulations.
11 May be recommended - see work practices. Adequate training Is necessary.
12 Drop cloth optional for dirty tools, equipment and/or waste.
13 Work area protection may be revised If alternate methods are used and historic data are available.
14 Air clearance depends on air monitoring program requirements.
15 Personal decontamination may be required by ARM or O&M program.
O&M WORK PRACTICES
M N c Fac ( 11
-------
Validation
OSHA Exposure Requirements Establishing limits on airborne asbestos is necessary
to properly control the exposures to which maintenance workers and building occupants
may be subjected. As a minimum, the requirements of the OSHA regulation must be met.
OSHA requires that air monitoring be performed to determine what level of worker
protection is necessary. OSHA specifies requirements for the determination of airborne
fiber levels and worker exposures in the Code of Federal Regulations (29 CFR 1926.58
(f)). OSHA requires employers to determine initially the level of airborne fibers to which
an employee will be exposed through Initial monitoring” or the use of historical data.
OSHA then requires periodic monitoring unless supplied air respirators are used. Finally,
additional monitoring is required (unless supplied air respirators are used) whenever a
change in workers, the activity, or equipment use occurs which might result in exposures
above the permissible exposure limit, action level and/or excursion limit.
These air monitoring requirements provide building owners and managers with the
information necessary to determine what level of protection is required by the Federal
Government. Regulations do not set precise standards for the protection of building
environments.
Exposure Morutonng at [ ?4ãrnó d1acflit J Exposure monitoring is necessary to validate
that each work practice leve results niirborne asbestos concentrations which are less
than 0.01 f/cm 3 . O&M ‘work practices should be monitored by an air monitoring
consultant (independent of the contractor performing the work practices) to determine
that the 0.01 f/cm 3 level has not been exceeded. Each level of each work practice is to
be monitored on the first three uses of that practice and periodically at every sixth use
thereafter. These air monitoring readings will constitute historical data and will serve to
document that the limit is not being exceeded by the various work practices and levels.
Respirators shall be used until work practices and levels are validated.
Higher levels recorded will require the APM to revise methods, procedures and, possibly,
levels of work practice until the set limit of 0.01 f/cm 3 is not exceeded.
Airborne Asbestos and Levels of Work Practice To fit within the level categories as
defined in O&M Work Practices (page 10), the following must hold true:
Level 1 (No Worker or Area Protection) work practices should not result in
elevated airborne asbestos levels.
Level 2 (Worker Protection, with Minimal Area Protection) work practices may
result in localized elevations of airborne asbestos levels that will only
affect the worker, but not the building environment.
Validation
12
-------
Level 3 (Worker and Area Protection) work practices may, if uncontrolled,
result in elevations of airborne asbestos levels that are sufficient to
require worker protection and isolation of the work area from the rest
of the facility.
Under EPA ’s Monitoring Program, to obtain O&M clearance after Level 2 and 3 work, the
following procedures are proposed:
1. Personal monitoring should consist of samples to obtain an 8 hour time-weighted
average (TWA), if possible, and excursion limit (EL) monitoring samples
2. Analysis by PCM
3. Analysis by TEM of 20% of air tests taken as a validation check.
Full air clearance by TEM as set forth by AHERA is required only for schools, but can be
used in non-school buildings, and is recommended for removal projects involving large
quantities of surfacing material, i.e., fireproofing, acoustical plaster, etc.
Aggressive air sampling techniques should be used only when the test area is contained.
Aggressive disturbance of open areas should be undertaken.
Training The amount and content of worker training should correspond to the type,
condition and quantity of ACBM that the staff will encounter in the course of their work.
Training should emphasize hands-on methods. The workers should learn how to use the
O&M Program as well as to perform specific tasks.
The APM should have training sufficient to evaluate potential exposure, understand
building components, building systems, building usage patterns, designing and
conducting O&M activities, be familiar with cleaning and maintenance tasks, understand
applicable laws and regulations, and be aware of other crucial factors associated with an
O&M Program. The APM must be properly qualified, through training and experience,
and be actively involved in all asbestos control activities. The APM shall attend the
following two courses to fulfill the asbestos safety and management training described
above:
1. Contractor/Supervisors: a 5-day training course that includes at least 14 hours of
hands-on training, individual respirator fit testing, course review, and a written
examination. Hands-on training must permit supervisors to have actual experience
performing tasks associated with asbestos abatement, including O&M activities.
2. Project Designer: a 3-day training course that includes lectures, demonstrations,
a field trip, course review and a written examination.
Validation
Name t Facillt 13
-------
The Asbestos Program Coordinator (APC) shall have training and experience similar to
the APM, and shall attend the following course to fulfill the necessary asbestos safety and
management training described above:
1. Contractor/SuperviSors: a 5-day training course that includes at least 14 hours of
hands-on training, individual respirator fit testing, course review, and a written
examination. Hands-on training must permit supervisors to have actual experience
performing tasks associated with asbestos abatement, including O&M activities.
Asbestos Inspectors shall attend the following course to fulfill the asbestos safety and
management training described above:
1. Inspector: a 3-day inspector training course that includes lectures,
demonstrations, 4 hours of hands-on training, indMdual respirator fit-testing,
course review and a written examination. Where appropriate, audio visual
materials and aids should be used to complement lectures. Hands-on training
should include conducting a simulated building walk-through inspection.
The OSHA Construction Standard for the Asbestos Industry indicates that for asbestos
related work involving 100 square feet or more of asbestos-containing construction
material, a “Certified Supervisor” shall have sufficient experience and authority to take
responsibility for the work and a “Qualified Person” must be available to perform the
abatement work.
Worker training programs should stress the health risks associated with asbestos
exposures. O&M workers need to understand the vital importance of carefully adhering
to these work practices or to others which may be specified at a later time.
Asbestos Workers shall attend the following course to fulfill the asbestos safety and
management training described above:
1. Worker: a 4-day worker training course that includes lectures, demonstrations and
at least 14 hours of hands-on training, individual respirator fit testing, course review
and a written examination. Hands on training must permit workers to have actual
experience performing tasks associated with asbestos abatement, including O&M
activities.
The above training requirements are established and further defined by the Asbestos
Model Accreditation Plan (MAP); Interim Final Rule, which was published in the Federal
Register on Thursday, February 3, 1994. This amended rule replaces the original MAP
found at 40 CFR part 763, Appendix C to Subpart E, in its entirety, and fulfills a part of
the mandate contained in section 15 of the Asbestos School Hazard Abatement
Reauthorization Act (ASHARA). These provisions of ASHARA were enacted on November
28, 1990, and took effect on November 28, 1992. They served to extend asbestos
accreditation coverage to include certain asbestos workers in public and commercial
buildings, and stipulated that the minimum number of training hours required for
accreditation was to be increased.
Validation
•f fty 14
-------
This rule amendment, effective April 4, 1994, establishes new training and accreditation
standards for state accreditation programs and for the providers of accredited training
courses. It further provides for a phased transition to comply with these new standards.
Single copies of this regulation may be obtained by contacting EPA’s Toxic Substances
Control Act (TSCA) Hotline in Washington, D.C. at (202) 554-1404. Questions regarding
the interpretation or application of this rule may be directed to the appropriate EPA
Regional Asbestos Coordinator.
Appendix MON of OSHA standard 29 CFR 1926.58 provides minimum training requirements
for maintenance workers where the employer does not establish full scale negative
pressure enclosures and does not utilize full scale decontamination.
Validation
“Name f Fae lty ” 15
-------
Use of O&M Work Practices
Usts of Work Practices and Work Practice Summaries Lists of the work practices for
[ Name cf àciIit u] are provided in the Table of Contents for this O&M Program and at the
begInning ófèach section of work practices. The first page of each work practice is a
summary of the work practice and lists examples of typical situations, associated general
procedures, related work practices and certain basic information about the practices. A
recommended minimum number of workers is listed for each work practice. A further
discussion of the number of workers for O&M activities is included later in this section.
Selecting Work Practices for a J Ij ] The APM should selc ct work practices
from this manual that are appropriate for the material upon which the work will be per-
formed. The selection of work practices will be based on a variety of factors, including
O&M Plan policies and the selection factors listed in this section. If situations exist that
are not covered by this manual, the APM should develop work practices appropriate to
the situation based on the guidelines in this O&M Program and other applicable sources.
It might be desirable to obtain assistance from sources, such as qualified consultants,
legal counsel, risk managers or insurance companies when selecting appropriate work
practices.
A number of determinations must be made in order to select the appropriate work
practice for a given situation. These include:
1. The level of worker and environmental protection desired based on the O&M
program objectives.
2. Whether O&M work will be performed by staff personnel or an outside contractor.
3. Regulatory compliance issues for the specific facility and personnel who will
perform the work. These include NESHAP, OSHA and EPA requirements for wor-
ker protection, work practices, exposure monitoring, notifications and additional
state or local requirements.
4. Whether exposure monitoring data and work evaluation forms (see Appendix “C)
from past work indicate that a given work practice or work practice level
accomplishes the O&M objectives.
Using the Work Practices The APM will select the work practices to be used. A decision
tree illustrating this selection process is shown in Figure 2 Work Practice Selection.
Guidance for selecting the appropriate work practice level is shown in Figure 1.
The process of using work practices from this O&M Program, or alternatives based on
this manual, for a given situation can be summarized as follows:
1. A Job Request Form (Appendix “A TM ) should be completed for work that could
disturb ACBM. (Note to APMs: If the required work has been performed in the
past, it might not be necessary to complete an APM checklist for each O&M
activity. Past checklists can be reused for the selection of work practices.)
USE OF AN O&M PROGRAM
“ft a Fac f 16
-------
2. The APM should complete an APM checklist (Figure 3 APM Checklist) and
evaluate the work to be performed based upon the information on a completed
Job Request Form, available survey and assessment data, and data on past O&M
activities (if available). When reviewing data and completing the APM checklist, the
following should be determined:
• Whether the job requested is actually an asbestos O&M activity.
• The category(ies) of ACBM that might be encountered during the work.
• The appropriate work practice(s) to address the situation. The work prac-
tice summaries, include a section of “related work practices” that are in-
tended to aid the APM in the selection of the proper work practice.
• The appropriate level of work practice(s) to be used.
• Personal protective equipment 1 if any, for the work.
3. All of the above information shoUld be recorded on a Maintenance Work Autho-
rization Form (see Appendix “B”). The completed APM checklist should be signed,
dated and filed.
4. Copies of information as listed on the APM checklist should be provided to the
workers who will perform the work, along with the appropriate work practice check-
list. If repetitive O&M activities using the same work practices will be performed in
sequence over a short period of time, a single Maintenance Work Authorization
Form may be completed to cover these situations for a single building. Note,
however, that the NESHAP requirements apply to a facility if the combined additive
amount of Regulated Asbestos Containing Material. (RACM) that will be removed
or stripped in repetitive activities exceeds the quantities specified in NESHAP.
Repetitive tasks might increase exposure levels such that more stringent OSHA
worker protection and engineering control requirements are triggered. Caution
should be used to insure each of the repeated O&M activities is a discrete O&M
activity. O&M work procedures are based on disturbing a small amount of material
over a short period of time. Care must be taken to avoid violating the intent by
allowing contiguous activities that add up to a larger scale procedure and a
potential accumulation of contamination. If a number of O&M activities need to
occur at one time in one location, it might be preferable to treat the work as a larg-
er scale, non-O&M activity. The APM can set limits appropriate for a facility and
O&M program that are based on quantities of ACBM to be potentially disturbed in
single and multiple O&M activities. Exposure monitoring procedures and methods
• for repetitive activities might need to be more stringent than for single activities.
The forms used in Appendices “A”, “B” and “C” of this O&M Program are repro-
duced from the EPA Green Book for use or guidance.
USE OF AN O&M PROGRAM
“Naneoflacility M 17
-------
Figure 2
Figure 2 is not on diskette; however, a copy of Figure 2 is provided in the front pouch of
this notebook for your use. A copy of this sheet will need to be sent through the printer
to add the title and footer, which is found in file FIG-2.WPF on the diskette.
-------
Figure 2:
Work Practice Selection
I Surfacing
Select Work Practices
and Proper Level(s)
No Further Asbestos
Action Required
Miscellaneous I
Select Work Practices
and Proper Level(s)
Pre-Work Activities :
- Select Personal Protective Equipment to be
Used
- Complete Maintenance Work Authorization
Form
- Schedule Work and File Notifications
- Notify Personnel Affected by Work
• - Assign Workers/Contractor & Air Monitoring
Person
Give Workers/Contractor Information for
Performing Work:
- Maintenance Work Authorization Form
- Work Practice Checklist
- Work Practice(s)
- Copy of Notifications
- Schedule for Work
- General Procedures
Review Work Practices During Work 1
Finish Work:
-Complete Evaluation of Work Form
- File All Required Records
USE OF AN O&M PROGRAM
Name of Faci1 t
NOTE :
Some steps in this process
may not be necessary for all
work practices. See Figure 2
and individual work practices.
Asbestos Program Manager Tasks:
Work Practice Selection and Use
Receive and Review Job
Request Form
I
YES
Determine ACM
Affected
I
TSI
Select Work Practices
and Proper Level(s)
18
-------
Work Practice Level Selection Factors The work practices included in this O&M Program
are specifically for [ N me f F lilty] The work practice levels do not directly correspond
to any specific regulatory requirement. OSHA regulations are triggered by disturbance
of asbestos, and require that certain engineering controls, work practices, personal pro-
tection and administrative procedures be used depending on whether the permissible
exposure limit (PEL), action level (AL) or excursion limit (EL) will be exceeded, or can
reasonably be expected to be exceeded, during the work. In a facility where the
combined additive amount of RACM to be removed or stripped during a calendar year
exceeds the EPA NESHAP requirements, environmental agencies must be notified and
area and environmental controls are required State of [ name ofstat ] and local
regulations may be more stringent, and will apply. Appendix 9” includes more information
on OSHA and EPA regulations.
Users of this manual might have operations and maintenance program objectives which
are more protective than the minimum regulatory requirements. Accordingly, it might be
appropriate, in the selection of work practice levels, to consider more than just the OSHA
regulated exposure levels. The conditions of the building and the O&M program
objectives will dictate the work practice level necessary.
More specifically, the following are factors for evaluation by a properly trained Asbestos
Program Manager when selecting work practice levels:
• Fiber release potential of material or O&M activity
• Condition and friability of ACBM
• Exposure and. air monitoring data
• Training, skill and experience of workers
• Quantity of ACBM to be disturbed
• Type and percentage of asbestos
• Location and use of ACBM
• Exposure potential for occupants and other personnel
• Federal and state regulations
• O&M and other management policies
• HVAC and ventilation system configurations
• On-site supervision
Definitive quantities of ACBM to be affected have not been specified in the work practice
level examples. This is to provide greater flexibility and to emphasize that other factors
might influence level selection by the APM. The APM’s determination of the appropriate
level should be based, at least in part, upon the quantity of ACBM to be disturbed. The
work practices are generally designed for disturbing small amounts of asbestos as
required to perform O&M tasks.
In instances where ACBM will be disturbed, OSHA requires that personal air monitoring
of workers be performed for work practices unless employee exposures, as indicated by
statistically reliable measurement, are below the OSHA action level and/or permissible
exposure limit (see OSHA regulations for details). O&M workers who could disturb ACBM
should use respiratory protection and other protective measures, unless adequate data
USE OF AN O&M PROGRAM
19
-------
are generated that indicate exposure levels in compliance with the O&M program
objectives.
Validation of the work practices is necessary to determine if a work practice is appropriate
for use under the O&M conditions present in a given facility. Data generated can be used
by the APM during future selection of work practice levels. If O&M activity data are to be
used to qualify for OSHA historical data exemptions or for maintaining OSHA exposure
records, it is necessary that the information be kept in strict accordance with the require-
ments of the OSHA construction standard (29 CFR 1910.20). The employer is
responsible for proving compliance with all applicable Federal, state and local regulations.
Based upon the data obtained, the APM might decide to use a higher or lower level of
work practice for a s e ific task. Substantially more data are required to justify the use
of lower level work practices. Any data indicating higher exposures than anticipated
warrant consideration of moving to higher level work practices. Work practice levels may
be modified as noted in Figure 1 based upon historical air monitoring data (additional
information on historical data is provided in General Procedure APM6).
Number of Workers Each work practice summary includes a recommendation on how
many workers are needed to perform the O&M activity(ies). A number of factors should
be considered when determining how many workers are to be assigned to perform an
O&M activity, such as:
• Regulatory requirements
• The amount of work to be done (quantity of ACBM to be disturbed, or likely to be
disturbed)
• Accessibility to the work area (height, enclosure)
• Worker skill, training and experience
• Weight, size or length of objects involved in the work
• Worker safety or degree of risk
• Work efficiency and cost effectiveness
One worker is recommended where the work practice can be accomplished safely and
effectively with one worker. Two or more workers are recommended for O&M work
practices involving enclosures or where special conditions or other factors complicate the
work. General Procedure APM5 includes additional information on assigning workers.
Work Practice Checklists The work practice selection process outlined above and
additional information related to the selection and use of the work practices are compiled
on the “Asbestos Program Manager Checklist” shown in Figure 3.
Checklists to be used by workers for each level of work practice are shown on “Worker
Checklists” in Figures 4, 5 & 6. A checklist is to be provided to the worker with each
work practice in order to give the worker complete information required to perform the
work.
USE OF AN O&M PROGRAM
20
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II
-------
Section II Asbestos Program Manager (APM)
General Procedures
Designation of the facility’s Asbestos Program Manager (APM) is a most important
element in the development of a comprehensive O&M Program. This person should be
experienced and trained in O&M practices (and abatement) of asbestos-containing
materials.
If, for any reason, the appointed APM must be changed, the following page naming the
APM should be revised, and all interested parties advised in writing.
-------
Section II
Asbestos Program Manager (APM)
General Procedures
The Asbestos Program Manager
is identified as follows:
Name I
Title
Company
Address
(APM) for EPA occupied spaces in
Telephone
Alternate
telephone
After hoUrs
telephone
Emergency
telephone
Ext. [
Ext. [
Ext. [
Ext. [
This person will be referred to in this O&M Program as the APM.
If the lease arrangement for this EPA occupied or controlled facility requires the
appointment of an Asbestos Program Coordinator (APC), EPA’s point of contact in [ Name
is identified as follows:
E 4 in of COrftagt]
[ t t e]
[ DMSIO’n]
[ Organizátt5r J
:‘‘oo&’z ’ ..occ.r.r ‘r . .
[ Name of Có act] will be the point of contact for the APM to the EPA concerning O&M
activities in EPA leased spaces within [
ASBESTOS PROGRAM MANAGER GENERAL PROCEDURES
i4ame of FacJiL P
1
-------
The ARM or a designee should review work practices with the workers who will perform
the work. Workers should be notified to consult with the APM or designated person if
they have any questions during the work, if any problems occur, or if it appears to the
workers that additional precautions might be necessary to safely perform the work.
This section includes detailed procedures for steps that are common to many of the work
practices. These general procedures are referenced in the work practices and in the APM
checklist. The general procedures should be covered in O&M training related to the use
of this manual.
Not all of the general procedures are used in every work practice. The work practices
and checklists refer the user to applicable, general procedures for detailed information on
how to perform a certain portion of the work. Once a user is familiar with the general
procedure requirements, it might not be necessary to review the general procedures each
time an O&M activity is performed. However, the general procedures should be reviewed
periodically by the APM to verify that the proper procedures are being followed.
Users of the O&M Work Practices Manual should also review the General Safety
Considerations information in Appendix UGH.
ARM Checklist (Figure 3) 3
APM I Selection of Personal Protective Equipment & Decontamination
Procedures
APM2 Work Scheduling
APM3 Federal, State and Local Notification
APM4 Notification of Personnel
APM5 Assigning Workers
APM6 Developing the Air Monitoring Program and Assigning Air Monitoring
Personnel 8
APM7 Recordkeeping 11
APM8 Confined Spaces 12
APM9 Selection of Materials 13
APM1O Emergency Work and Dry Removal 14
APM 11 Inspecting Buildings for Asbestos-Containing Building Materials 15
Note: Not all of the general procedures are used in evety work practice.
ASBESTOS PROGRAM MANAGER GENERAL PROCEDURES
“Name o( Facility
2
-------
Figure 3: APM Checklist
Asbestos Program Manager (APM)
Checklist for Operations and Maintenance
Work Practice Use
o Receive and review Job Request Form - See Appendix “A”.
Work to be performed:
o Review or request survey data to determine whether ACBM are affected.
O Complete Maintenance WorkAuthorization Form, including: - See Appendix
o Review historical air monitoring data for work practices to be used.
o Work Practice(s) selected for all ACBM to be encountered -
See Section I - Figures 1, 2.
o Select personnel protective equipment and decontamination
requirements to be used, if needed - See General Procedure APM1.
o Select appropriate materials and review potential hazards (confined
spaces, scaffold use, etc.) - See General Procedures APM8 &
APM9.
o Schedule work when area is not in use or plan developed to isolate area (if
necessary) - See General Procedure APM2.
o Federal, state and local notifications filed f applicable) - See General
Procedure APM3.
O Notify personnel affected by work - See General Procedure APM4.
o Assign workers (or contractor) with appropriate level of training. Verify
currency of training, fit tests, and medical surveillance - See General
Procedure APM5
o Assign trained air monitoring person and determine air monitoring to be
performed (if needed). Record air monitoring requirements on Maintenance
Work Authorization Form - See General Procedure APM6.
o Provide copies to workers/contractor of:
o Maintenance Work Authorization Form
o Work practice checklist for proper work level.
o Work practice(s):
o General Procedure(s)
o Notifications
o Schedule of work
o As practical, review work practices during work for compliance with
requirements and worker general procedures.
o Complete Evaluation of Work Affecting ACBM form - See Appendix UCU
o File all required records in proper files - See General Procedure APM7.
0 Signature: _____________ Date: __________________________________
ASBESTOS PROGRAM MANAGER GENERAL PROCEDURES
3
-------
If information In any of these sections is found not to be applicable in the facility please make the
following notation:
APM [ #1 [ Name of Section] Not applicable.
It Is unlikely, however, that any of these topics would, or should be deleted.
APM I Selectiôh of Personal Protective Equipment & Decontamination Procedures
Selecting personal protective equipment (PPE) for O&M work includes the
selection of respirators, protective clothing, gloves, boots, hardhats, and/or
other equipment that might be necessary for a specific task. The
information in Appendix G” discusses general safety considerations that
may affect equipment selection.
Respirators used for O&M activities must be selected based on the
requirements of regulations and a Respiratory Protection Program devel-
oped in accordance with OSHA standard 29 CFR 1910.134 or the EPA
“Worker Protection Rule” (40 CFR 763.120,121), as applicable, for the O&M
workers. Appendix “E ” of the Green Book includes EPA’s recommendations
on the types of respirators to be used for custodial and maintenance tasks.
Liability concerns, historical data and management policies might also
influence whether respirators are used, and if so, the type of respirators for
O&M activities. NIOSH recommends minimizing occupational exposure to
cancer producing sub-stances, such as asbestos to the lowest feasible
level. In practice, a maximum exposure level for workers of 0.01 fibers per
cubic (0.01 f/cc) centimeter of air inside the respirator is commonly used
when respirators are selected using protection factors.
OSHA has stated that the OSHA permissible exposure limit was selected as
a technical and economic compromise for industry, and is not designed to
totally prevent cancer causing exposures. The EPA’s White Book and the
Introduction and Section 01562 of the NIBS Asbestos Abatement Guide
Specification contain information regarding respirator selection that might
be helpful to the APM. Review of this additional information is strongly
encouraged.
In certain situations, full face respirators might be desirable to provide
additional eye and face protection for workers. Powered Air Purifying
Respirators (PAPR’s) are preferred by many workers instead of negative
pressure respirators. OSHA regulations 29 CFR 1910.1001 and 29 CFR
1926.58 require that an employer provide a PAPR in lieu of a negative
pressure respirator if an employee chooses to use this type of respirator.
ASBESTOS PROGRAM MANAGER GENERAL PROCEDURES
4
-------
Depending upon the type of work and work practices to be used, combina-
tion respirator filter cartridges or a different type of respirator might be
necessary to protect workers from other contaminants or hazardous
substances. Respiratory protection for asbestos work requires the use of
high efficiency particulate air (HEPA) filter cartridges.
Protective Clothing & Decontamination Procedures Protective clothing for
O&M work typically consists of disposable coveralls, gloves and/or boots.
Protective, clothing for O&M work can be selected by the APM or the
worker, depending upon the O&M procedures. Protective clothing options
that are typically used are discussed. in Worker General Procedure W6. The
protective clothing option selected might depend in part upon the decon-
tamination procedures tO be used and the type of work area preparation or
enclosure.
Decontamination procedures typically used for O&M work include HEPA
vacuuming on a drop cloth, changing in a change room, or showering.
Worker General Procedure W14 explains the decontamination process for
each option.
The APM might also determine whether boots, gloves, hardhats or other
protective equipment is needed for O&M tasks. Protective clothing selec-
tions made by the APM should be recorded on the Maintenance Work
Authorization Form.
APM 2 Work Scheduling Level 2 and 3 work should be scheduled for a time when
the work area will not be in use and can be closed off to anyone other than
trained workers, or other authorized personnel. If an area is always
occupied, plans should be made to isolate the work area from building
occupants using visual and/or physical barriers. If a special work area ar-
rangement is required, it might be beneficial to provide a sketch to the
workers showing how the area is to be set up. If respirators are used for
Level 1 activities, it might be desirable to vacate the area to avoid concerns
resulting from a worker in a respirator working within sight of unprotected
workers/occupants.
Scheduling of work might be affected by notification requirements. All noti-
fication requirements should be met before work is scheduled. Under cer-
tain circumstances, some emergency work can be performed prior to the
filing of a notification. Review regulations and contact federal, state of
and local regulatory agencies concerning notification
requirements for emergency work.
ASBESTOS PROGRAM MANAGER GENERAL PROCEDURES
Thme c aci1tty 5
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Federal, State and Local Notifications The APM, or his designee, should file
all notices required by federal, state of ameofst te) and local regulations
prior to the start of any O&M activities that are governed by these
regulations.
Federal Notifications Federal requirements for notification are set forth in
the National Emission Standards for Hazardous Air Pollutants (NESHAP)
rules and the EPA Worker Protection Rule. OSHA is considering adding
notification requirements to the OSHA regulations. For demolition and
renovation work, the latest NESHAP revisions are contained in. 40 CFR
61.145 (a) and (b). A ten working day federal notification is required for
renovation work if the combined amounts of regulated asbestos-containing
material (RACM - see glossary or NESHAP for definition) to be stripped,
removed, dislodged, cut, drilled or similarly disturbed is over 260 linear feet
(80 linear meters), 160 square feet (15 square meters) or 35 cubic feet (1
cubic meter) for any single project.
Also, if the combined estimated quantities of RACM to be removed or
stripped in individual nonscheduled operations during a calendar year (Jan-
uary 1 through December 31) exceeds the amounts listed above, a
NESHAP notice must be submitted at least ten working days before the end
of the calendar year (e.g. December 15) preceding the year for which notice
is being given. A new written notice must be filed with the . EPA if the start
date for a project is revised (earlier or later) from the date filed in the original
or a previous notice. A notice must be updated if the amount of asbestos
affected changes by 20 percent or more.
If wetting of RACM during removal would unavoidably damage equipment
or present a safety hazard, written approval from the EPA is required for
alternative emission control methods (dry removal).
The NESHAP notification requirements for emergency renovation work are
set forth in 40 CFR 61.145 (a) and (b). More information on emergency
work is included in General Procedure APM1O.
See Appendix “H’ (2.B and 2.D) of this manual and the NESHAP regulations
for details on Federal notification requirements. OSHA’s proposed regula-
tory changes include adding notification requirements in the OSHA regula-
tions Requirements of state of ame qrstJ fé] and local regulations should
also be included in this section.
ASBESTOS PROGRAM MANAGER GENERAL PROCEDURES
ThmecAFacW
6
APM 3
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State and Local Notification Requirements State and local notification requ-
irements vary greatly. Many states and localities have notification require-
ments that are more stringent than the federal requirements. State and
local requirements c - ‘renovation work
must be r€ - - uirements must be
complied with before work is schec......3d . . J. See Appendix
UFII for the EPA Regional Contacts, which provide information on obtaining
copies of state and local regulations.
APM 4 Notiflcátiôn of Personnel Persons who use, occupy, or are affected by
an area where ACBM work will occur should be notified prior to the start of
the work. Proposed changes to the OSHA regulations include mandatory
notification of certain personnel prior to the performance of work regulated
by OSHA. Notification of personnel is usually not necessary for Level I
O&M activities. Personnel should be given information about the specific
work to be performed, the work schedule, precautions being taken, what
will be visible during the work, and that posted warning signs must be
obeyed. Section 4 of the Green Book includes information on occupant,
tenant and worker notification of the presence of ACBM that might be
helpful to the APM.
If O&M work occurs frequently, or for Level I Tasks where notification is
needed, a general notice to affected personnel might be more convenient
than notifying these personnel each time work occurs State of (n me
t J and local regulations may also include personnel notification require-
ments.
APM 5 Assigning Workers assigned to perform O&M work should have training
and experience in the skills and techniques required by this Program for the
type of work to be performed, training in applicable asbestos O&M proce-
dures, the O&M plan for the facility, and site-specific building conditions.
The OSHA construction standard contains minimum training requirements
for construction workers Qncluding maintenance workers) exposed at or
above the action level. Appendix uGh of OSHA standard 29 CFR 1926.58
provides minimum training requirements for maintenance workers where the
employer does not establish full scale negative pressure enclosures, and
ASBESTOS PROGRAM MANAGER GENERAL PROCEDURES
Narne ot Faclhty
7
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does not utilize full scale decontamination.’ State of [ and
local regulations may impose training requirements for O&M activities.
Verify that state of [ raIT &of Ttãt ] and local requirements are met before
scheduling work. Additional training might be desirable for performing
frequent O&M work or certain O&M tasks. Before workers are assigned to
O&M work, the APM should verify that their training, respirator fit tests and
medical surveillance are current and in compliance with regulations (where
applicable) and the requirements of work practices to be used. Appendix
“F” in this manual gives guidance on where to find applicable regulatory
information and Green Book guidance on these topics.
Depending upon applicable regulations (such as NESHAP), a designated
trained or “competent person” might be required to perform or supervise
certain aspects of the work. Section 4 of this manual discusses factors to
consider when determining the number of workers required for an O&M
activity. Once workers are ‘selected for a task, the APM should review the
work practice with the workers, if needed.
Developing the Air Monitoring Program and Assigning Air Monitoring
Personnel
Note: This section is not intended as a substitute for a complete Air
Monitoring Program that is needed for O&M work. This section notes only
general air monitoring issues that the APM needs to address for O&M work.
Owners might choose to use an outside consultant to perform air
monitoring for O&M activities. In certain cases, where frequent O&M
activities are performed, the O&M program might ‘include having one or
more designated trained workers perform air monitoring during O&M activi-
ties. In either case, an Air Monitoring Program should be developed by the
air monitoring personnel or consultant and the APM for O&M activities. The
ASBESTOS PROGRAM MANAGER GENERAL PROCEDURES
Name of Fac1hty
APM6
8
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Air Monitoring Program should specify when air monitoring will be
performed, the types of monitoring (personnel, background, area, clear-
ance, periodic, and/or initial), analysis methods, training requirements for
monitoring personnel, and procedures for maintaining data from O&M activi-
ties, including any data required for OSHA historical data monitoring ex-
emptions. Air monitoring data should be considered when selecting the
type of respirators for activities that use respiratory protection.
Training might be required by the Air Monitoring Program or state or local
regulations, and could include a NIOSH air monitoring course, industrial
hygienetraining or other requirements. Training for persons performing air
monitoring work should include hands-on training with the equipment to be
used. Training for air monitoringthat is currently available consists primarily
of courses meeting the National Institute for Occupational Safety and Health
(NIOSH) 582 requirements.
Air monitoring exemptions Or requirements for a given work practice should
be based on the Air Monitoring Program and stated on the Maintenance
Work Authorization Form.
Exposure monitoring should be addressed in the Air Monitoring Program
and is required for operations covered by OSHA regulations. Review the
applicable OSHA standards in detail when developing air monitoring proce-
dures for O&M work. Sections O&M work include those on initial monitor-
ing, historic data and periodic monitoring:
Initial monitoring is discussed in paragraph (f)(2) of OSHA standard 29 CFR
1926.58:
“Initial monitoring. ) Each employer who has a workplace or work
operation covered by this standard, except as provided for in para-
graphs (f)(2)(ii) and (f)(2)(iii) of this section, shall perform initial
monitoring at the initiation of each asbestos, tremolite, anthophyllite,
actinolite job to accurately determine the airborne concentrations of
asbestos, tremolite, anthophyllite, or actinolite to which employees
may be exposed.”
Data generated by exposure monitoring performed in accordance with
OSHA requirements may be used for historical data initial monitoring exe-
mptions. The OSHA requirements for exposure monitoring data under the
Construction Industry Asbestos Standard (29 CFR 1926.58) are specified
in paragraph (f)(2) ii):
“Where the employer has monitored each asbestos, tremolite,
anthophyllite, or actinolite job, and the data were obtained during
work operations conducted under workplace conditions closely
resembling the processes, type of material, control methods, work
ASBESTOS PROGRAM MANAGER GENERAL PROCEDURES
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practices, and environmental conditions used and prevailing in the
employers current operations, the employer may rely on such earlier
monitoring results to satisfy the requirements of paragraph (f)(2)-(i)
of this section.” (Paragraph (f)(2)(i) is the initial monitoring re-
quirement.)
OSHA then requires periodic monitoring unless supplied air respirators are
used. Periodic monitoring is discussed in paragraph (f)(3) of OSHA stan-
dard 1926.58:
“Periodic monitoring within regulated areas. The employer shall
conduct daily. monitoring that is representative of the exposure of
each employee who Is assigned to work in a regulated area.
Exception: When all employees are equipped with supplied-air
respirators operated in the positive pressure mode, the employer
may dispense with the daily monitoring required by this paragraph.”
Termination of monitoring is discussed in (0(4) of OSHA standard 1926.58:
uTermination of monitoring. If the periodic monitoring required by
paragraph (0(3) of this section reveals that employee exposures, as
indicated by statistically reliable measurements, are below the action
level, the employer may discontinue monitoring for those employees
whose exposures are represented by such monitoring.”
Once data are generated for a certain work practice in a given facility, the
APM should be able to judge whether that level of work practice is appropri-
ate for O&M work in that facility and whether more air monitoring is neces-
sary. In certain situations (i.e. removals of resilient floor coverings using
manufacturer’s recommended practices), OSHA has allowed the use of data
generated by third party manufacturers to support a claim for an exemption
from initial air monitoring. Personal air monitoring is required following
changes in work practices, employees, employee skill levels, or other
pertinent factors which could lead to the OSHA action level or exposure
limits being exceeded. Validation of the work practices using air monitoring
data applies only when the OSHA monitoring requirements listed above are
met. Personal monitoring should consist of samples to obtain an 8 hour
time- weighted average (1WA), if possible, and excursion limit (EL)
monitoring samples. All analysis for OSHA compliance should be by phase
contrast microscopy (PCM). Transmission electron microscopy (TEM)
analysis will distinguish asbestos fibers from other fibers and might also be
used if desired, although PCM data is required by OSHA. TEM data cannot
substitute for OSHA required PCM data unless approved by the local OSHA.
office. The use of TEM analysis or settled dust sampling to evaluate the
need for precleaning prior to an O&M activity might be considered. Neither
method is required by current regulations.
ASBESTOS PROGRAM MANAGER GENERAL PROCEDURES
Name FacW 10
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This document does not take a position on the efficacy of settled dust sam-
pling, nor advocate its use. It is presented here as an available analytical
tool that might be used. Settled dust sampling can also be used during
O&M activities to document disturbances during the activity. Settled dust
sampling might be used as part of a clearance protocol for O&M work. No
regulatory standards for dust sampling exist at this time. The APM might
want to consult with an experienced laboratory or consultants regarding the
latest settled dust sampling procedures and protocols Procedures
commonly in use include microvacuuming, surface wipe samples, and tape
lift methods.
APM 7 Recordkeeping The following records of O&M work shall be retained in
permanent files:
• Inspection and Assessment Reports
• A copy of the O&M Program (initial program and all updated
versions)
• The Work Practices Used
• Respiratory Protection Program
• Fiber Release Reports
• Job Request Forms
• Maintenance Work Authorization Forms
• Evaluations of Work Affecting ACBM
• Reinspection/Periodic Surveillance Reports
For employers with employees engaged in asbestos-related work, federal
regulations require that the employer retain:
• Personal Air Sampling/Exposure Monitoring Records
• Historical Data (used to qualify for exemptions from OSHA’s initial
monitoring requirements)
• Medical Records (for employees subject to a medical surveillance
program)
• Employee Training Records
• Fit Test Records (for employees that use respirators)
This O&M Program also requires that records be maintained for:
• Waste Tracking and Disposal - See Appendix “D”.
• Air Monitoring Data
• Qualifications and Performance Records for Outside Contractors
performing O&M work
If settled dust sampling is used it is advisable to maintain these records
also.
ASBESTOS PROGRAM MANAGER GENERAL PROCEDURES
11
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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
& 1926.59). Also see the OSHA Asbestos Construction Rule (29 CFR
1926.58), the EPA Worker Protection Rule (40 CFR 763 Subpart G) and the
Green Book for details on recordkeeping requirements.
Note that state of and local regulations may require that
additional information be recorded and retained.
The building owner shall make available all written elements of the O&M
program to the building’s O&M staff as well as to tenants and building
occupants, if applicable. Building owners are also encouraged to consult
with their legal counsel concerning appropriate recordkeeping strategies as
a standard part of their O&M programs.
Confined Spaces Confined spaces are often encountered in O&M work.
Probably the most common areas encountered are crawlspaces, utility and
pipe tunnels, manholes and chases. Special precautions are necessary for
working in confined spaces. A confined space program, including an entry
permit system, must be developed for use when confined spaces must be
entered. The APM or another staff person should be able to identify and
assess hazards associated with confined spaces. Procedures should be
developed to address potential confined space hazards. NIOSH publication
number 87-113 (July 1987), entitled “Guide to Safety in Confined Spaces”,
includes a checklist for safe entry into confined spaces, as well as general
information on confined space issues.
Confined space hazards include, but are not limited to:
• Low oxygen content
• Toxic atmospheres (gases, vapors and dusts)
• Hazardous chemicals
• Explosive atmospheres
• Heat stress
• Fire
• Retention of dust and smoke
• Insufficient lighting
ASBESTOS PROGRAM MANAGER GENERAL PROCEDURES
Name Facihty
APM8
12
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• Flooding
• Electrical shock hazards
• Noise
Program elements should include:
• Entry and exit procedures
• Standby/emergency rescue procedures
• Head protection (from bumps, scrapes, cuts, abrasions)
• Worker communication procedures
• Entry. permit system
• Atmosphere monitoring
• Ventilation
• Isolation
Respiratory protection
Depending upon the hazards present, monitoring and special precautions
might be needed during the work to maintain a safe work area. As of
September 1992, OSHA had developed draft regulations (29 CFR 1910.146)
concerning work in confined spaces. The preamble to the proposed rules
discussed the types of hazards that will be covered by these regulations.
The user of this manual might wish to obtain and review a copy of these
proposed rules if confined spaces will be encountered in O&M work.
Appendix “G” includes general information on safety considerations that
should be reviewed if work will take place in confined spaces.
ARM 9 Selection of Materials The ARM should be responsible for the selection of
certain materials used for O&M activities. This O&M Program will not
attempt to give guidance on the selection of all materials needed for O&M
work. Information on selection of the following materials is provided:
• Polyethylene
• Lockdown encapsulants
Guidance on the selection of other materials should be obtained in training
courses, or from reference materials, such as the NIBS Guide Specifications
for Asbestos Abatement.
Polyethylene Various thicknesses, colors and types of polyethylene are
available. The most common thicknesses used for asbestos related work
are 4 mil and 6 mil State of a f tit ] or local regulations may re-
quire that certain thicknesses, nümberof layers or types of polyethylene be
used.
ASBESTOS PROGRAM MANAGER GENERAL PROCEDURES
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Two mit polyethylene is also available, but is not widely used since it tears easily.
Polyethylene is also available in fire retardant and anti-static types. Fire retardant
polyethylene does not support flame as readily as standard polyethylene.
However, some tests have shown only minimal differences in flame spread time be-
tween standard and fire retardant poly.. Anti-static polyethylene should be used
around equipment sensitive, to static electricity.
Lockdowñ Encapsulants Lockdown encapsutants selected should be
appropriate for the intended use. Use high temperature rated encapsulants
for heating system components such as piping, boilers & flues. Lockdowns
should also be compatible with any replacement materials, such as new
flooring adhesive. Compatibility should be verified prior to the start of work.
Lockdowns are available in clear or colored mixtures. Clear mixtures should
be used where a colored encapsulant would be objectionable for ap-
pearance reasons. Colored encapsulants should be used (where possible)
with a color chosen to indicate that an area has been locked down. The
color also allows a worker to see where encapsulant has been applied
during the application.
Emergency Work and Dry Removal O&M activities sometimes require that
regulated asbestos O&M work be performed immediately to maintain opera-
tions and prevent other health or safety hazards. Emergency work is ack-
nowledged in regulations and is permitted under certain conditions. The
NESHAP regulations specify that a notification for ordered emergency
renovation operations must be postmarked or delivered “as early as possi-
ble before, but not later than, the following working day” (see regulation for
full text) State of (name o state] or local regulations may have additional
requirements.
Emergency work might involve activities (such as work around activated
electrical equipment) where the use of wetting would result in equipment
damage or a safety hazard. NESHAP permits work without wetting
regulated ACBM under certain conditions (see regulation for details). For
ASBESTOS PROGRAM MANAGER GENERAL PROCEDURES
NName 1 acIlk
APM 10
14
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facilities where dry removal work might be required, the APM should review
regulatory requirements in advance with authorities having jurisdiction over
the facility.
APM 11 Inspecting Buildings for Asbestos-Containing Building Materials No O&M
Plan can be implemented until the presence of ACBM have been confirmed
through a visual inspection of the facility including the’ collection and
analysis of bulk samples. In all likelihood, an inspection and survey have
already been performed at facilities occupied or controlled by EPA. GSA
procedures require that such an inspection, including collection and analysis
of suspect ACBM, be performed before occupancy by federal agencies,
including EPA.
Conducting an inspection and survey to identify and locate ACBM is
normally performed by the building owner, but a times may be assigned to
a tenant (i.e. GSA, EPA or other federal agency) or operator of the facility.
At other times, a tenant or operator may collect samples of suspect
material(s) not previously sampled in the facility-wide inspection.
Asbestos School Hazard Abatement Reauthorization Act (ASHARA)
regulations require that anyone collecting samples for purposes of
determining the presence of asbestos must be an AHERA certified Asbestos
Inspector.
Appendix J generally discusses conducting an inspection and survey per
AHERA regulations, and other EPA guidance documents. AHERA
inspection procedures are, by regulation, required only for schools.
ASHARA requires certification and training only, not adoption of the
sampling and inspection procedures.
Form and format of inspections and surveys vary greatly. All properly
conducted inspection will have located and sampled all suspect surfacing,
TSI and miscellaneous materials. The facility’s full inspection and survey
report should be made a part of the facility’s O&M Plan to clearly identify
ACBM locations. The inspection report should also describe the condition
of all asbestos materials so selection of the proper response action and
O&M procedures can be implemented.
Any O&M Plan is based upon the facility’s inspection and survey report. If
one has not been conducted, or it ‘is determined that current inspection
maybe inadequate, conducting a proper inspection for ACBM is strongly
encouraged.
ASBESTOS PROGRAM MANAGER GENERAL PROCEDURES
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III
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Section III Worker General Procedures
This section includes detailed procedures for steps that are common to many of the work
practices. These general procedures are referenced in the work practices and in worker
and APM checklists. The general procedures should be reviewed in detail by all
personnel using this work practices manual. If possible, the general procedures should
be covered in O&M training related to the use of this manual.
The work practices and checklists refer the user to applicable general procedures for
detailed information on how to perform a certain portion of the work. Once a user is
familiar with the general procedure requirements, it might not be necessary to review the
general procedures each time an O&M activity is performed. HoWever, the general
procedures should be reviewed periodically by all workers and the APM to verlfy that the
proper procedures are being follOwed.
Workers should report any suggestions or problems regarding these work practices to
their supervisor, the APM or the APM’s designee.
Users of the O&M Work Practices Manual should also
Considerations information in Appendix G” of this Manual.
review the General Safety
10
11
WORKER GENERAL PROCEDURES
Name c Fac (
Level
Level
Level
Wi
W2
W3
W4
W5
W6
1 Checklist
2 Checklist
3 Checklist
Tools, Equipment and Materials
Preparing Amended Water or Removal Encapsulant
Shut-off and Lockout of HVAC and Electrical Systems
Securing Work Area
Putting on Respirators and Performing Fit Checks
Putting on Protective Clothing
..3
.6
8
.9
.9
.9
1
-------
W7
W8
W9
WI 0
Wil
WI 2
Wi 3
Wi 4
WI 5
Wi 6
W17
WI 8
12
13
14
17
19
19
..20
.20
22
23
23
27
Beginning and Conducting Air Monitoring
Precleaning Work Areas and Wet Wiping
Setting up Work Areas
Packaging and Labeling Waste
Applying Lockdown Encapsulant
Cleaning Tools, Equipment and Work Area
Decontaminating Waste
Worker Decontamination and Removal of Protective Clothing and
Respirators
Visual Inspection and Completing Air Monitoring
Waste Transportation, Storage and Disposal
Glovebag Removal
Disposal of Contaminated Water .
Note: Not all of the worker general procedures are used in every work practice.
WORKER GENERAL PROCEDURES
“Name oFacTh* f
2
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Figure 4: Level 1 Worker Checklist
Operations and Maintenance Work
Practices
Pre-Work Activities
0 Obtain and review copies from Supervisor or Asbestos Program Manager of:
o Completed Maintenance Work Authorization Form
o Work practice(s) to be used including personal protective equipment
options
o Work Notification(s) (as applicable)
o Schedule for work
o Review work practices and General Procedures Wi, W5, Wi 0, WI 2, Wi 4, Wi 5
and any other general procedures used in work practice.
o Inspect work area for visible dust or debris. If present, stop work and notify APM.
o Obtain recommended tools, equipment and materials as described in General
Procedure Wi, work practice(s) item 2, and Maintenance Work Authorization Form.
o Move tools, equipment and materials to work area.
o Shut off and lock out any HVAC or electrical systems to be worked on.
o If required, on Maintenance Work Authorization Form, put on respirators and
perform fit checks - See General Procedure W5.
Work
Practices
0
Perform work per steps in work practice(s).
Clean-Up and Tear-Down
o Remove lockout tags (if used) & restart any HVAC/electrical system(s) that were
shut off.
o Return tools, equipment and remaining materials to storage area.
o Notify Asbestos Program Manager or supervisor that work is completed & return
documents to APM.
WORKER GENERAL PROCEDURES
Th edEac r 3
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Figure 5: Level 2 Worker Checklist
Operations and Maintenance Work
Practices
Pre-Work Activities
0 Obtain and review copies from Supervisor or Asbestos Program Manager of:
o Completed Maintenance Work Authorization Form
O Work practice(s) to be used Including personal protective equipment options
0 Work Notification(s) (as applicable)
o Schedule for work
0 Review work practices and referenced general procedures ‘used in work practice(s).
iJ Obtain recommended tools, equipment and materials - See General Procedure WI and work
practice(s) item 2.
I] Obtain required respirators as listed on Maintenance Work Authorization Form.
o Move tools, equipment and materials to work area.
iJ Shut dif and lock out HVAC and electrlcai systems serving work area - See Generai Procedure W3.
o Vacate and secure work area, such as by locking doors and/or setting up temporary barriers - See
General Procedure W4.
o Put on respirators and perform fit checks - See General Procedure W5.
o put on protective clothing - See General Procedure W6.
0 Air monitoring personnel begins air monitoring work (if required) - See General Procedure W7.
o Preclean work area if visible dust or debris is present - See General Procedure W8.
Work
0
Area
Set up work area as required
by work practice item 3 - See General
Procedure W9.
Work
Practices
0
Perform work per steps in wo
rk practice(s).
Clean-Up and Tear-Down
O Package and label asbestos waste for disposal - See General Procedure WIC.
O Apply lockdown encapsulant, where required, using garden sprayer, to surfaces
where ACBM were removed or disturbed - See General Procedure Wi 1.
O Perform ceiling panel replacement work or ceiling repair work if needed.
O clean tools, equipment and work area using wet wiping and HEPA vacuuming as appropriate and
return tools and equipment to outside work area - See General Procedure W12.
o Decontaminate packaged waste & move waste to.outside work area - See General Procedure Wi 3.
o Workers decontaminate and remove protective dothing and respirators. if contaminated, dispose
of protective clothing as ACBM - See General Procedure W14.
O Complete visual inspection. Complete air monitoring work - See General Procedure W15.
o If feasIble, get APM or designee to complete Evaluation of Work Form.
o Transport waste to designated asbestos waste storage area - See General Procedure Wi 6.
O Remove drop cloth.
O Return decontaminated tools, equipment and remaining materials to storage area.
WORKER GENERAL PROCEDURES
“ .ts msi r F v-il f ,” 4
-------
o Remove lockouttags ‘and restart HVAC/electrlCal system(s).
o Restore normal accessibility to work area.
o Notify Asbestos Program Manager or Supervisor that work Is completed & return documents to
APM.
WORKER GENERAL PROCEDURES
5
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Figure 6: Level 3 Worker Checklist
Operations and Maintenance Work
Practices
Pre-Work Activities
0 Obtain and review copies from Supervisor or Asbestos Program Manager of:
o Completed Maintenanbe Work Authorization Form
o Work practice(s) to be used including personal protective equipment options
o Work Notification(s) (as applicable)
o Schedule for work
o RevIew work practices and referenced general procedures used In work practice(s).
o ObtaIn recommended tools, equIpment and materials - See General Procedure Wi and work
practIce(s) Item 2.
o ObtaIn required respirators as listed on MaIntenance Work Authorization Form.
o Move tools, equipment and materials to work area.
o Shut off and lock out HVAC and electrical systems serving work area - See General Procedure W3.
o Vacate and secure work area, such as by locking doors and/or setting up temporary barriers -See
General Procedure W4.
o Put on respirators and perform fit checks - See General Procedure W5.
0. Put on protective clothing - See General Procedure W6.
o Air monitoring personnel begins air monitoring work (if required) - See General Procedure W7.
o Preclean work area if visible dust or debris Is present - See General Procedure W8.
Work
o
Area
Set up work area and decontamination facilities as required
by work practice item 3 - See General
Procedure W9.
Work
Practices
.
0
Perform work per steps In work practice(s).
Clean-Up and Tear-Down
o Package and label asbestos waste for disposal - See General Procedure W1O.
o Apply lockdown encapsulant, where required, using garden sprayer, to surfaces
where ACBM were removed or disturbed - See General Procedure Wi 1.
o Perform ceiling panel replacement work or ceiling repair work if needed.
o Clean tools, equipment and work area using wet wiping and HEPA vacuuming as appropriate and
return tools and equipment to outside work area - See General Procedure W12.
0 Decontaminate packaged waste & move waste to outside work area - See General Procedure W13.
o Workers decontaminate and remove protective dothing and respirators. if contaminated, dispose
of protective clothIng as ACBM - See General Procedure W14.
o Complete visual Inspection. Complete air monitoring work- See General Procedure Wi 5.
o If feasible, get APM or designee to complete Evaluation of Work Form.
o Transport waste to designated asbestos waste storage area - See General Procedure W16.
o Remove drop cloth and/or mini-enclosure.
o Return decontaminated tools, equipment and remaining materials to storage area.
WORKER GENERAL PROCEDURES
6
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o Remove lockout tags and restart HVAC/electrlcal system(s).
o Restore normal accessibility to work area.
o Notify Asbe tos Program Manager or Supervisor that work Is completed & return documents to
APM.
WORKER GENERAL PROCEDURES
7
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W-1 Tools, EqUipment and Materials The following is a list of tools, equipment
and materials that are referenced in the work practices and are
recommended to perform the work practices. Tools, equipment or
materials that are unique to a certain work practice are listed under item 2
in each work practice. For frequent O&M work, it might be helpful to
maintain an “O&M cart” containing the necessary tools, equipment and
materials.
Tools and Equipment
• Utility knife
• GroUnd fault circuit interrupters (GFCI’s), Extension cords and
adapters - GFCI’s should be used on any electrical equipment or
tools used in O&M work where water might be in use or present in
the work area.
• Lockout tags
• Temporary work lights
Ladder or scaffold for elevated work
• Wet wipes or bucket with clean water for wet wiping
• Smoke test bulb and tubes
• Bone saw
• Wire cutters
• Tin snips
• Safety glasses
Abatement Equipment and Materials
• Polyethylene sheet
• Duct tape
• Disposal bags with labels
• High efficiency particulate air (HEPA) vacuum with hose, attachments
and proper HEPA filter (wet/dry type needed for some work
practices)
• Respirators (if required)
• Disposable coveralls (if required)
• Disposable towels or wet wipes
• Asbestos barrier tape
• Warning signs
• Garden sprayer with amended water or removal encapsulant (Level
2 and 3 practices) See general procedure W2.
• Aerosol cans or garden sprayer with lockdown encapsulant (Level 2
and 3 practices)
• Air monitoring pumps, cassettes and calibration equipment (if
required)
• Frame for mini-enclosure or prefabricated mini-enclosure (Level 3
practices)
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• Negative pressure machine (HEPA filtered exhaust fan) as required
for size of enclosure (level 3 practices - could be negative pressure
machine or additional HEPA vacuum)
• Manometer (if pressure differential measurements are desired)
• Glovebags (if required)
W-2 Prepanng Amended Water or Removal Encapsulant Amended water or
removal encapsulant solutions are prepared by mixing a measured amount•
of surfactant or encapsulant with clean water in accordance with the
manufacturer’s instructions. Surfactants and encapsulants materials might
be considered hazardous. substances. Containers of amended water or
removal encapsulant should be labeled to identify the con ônts in
accordance with the OSHA Hazard Communication Standard (29 CFR
1910.1200). Review and comply with Material Safety Data Sheet (MSDS)
before mixing and using these materials. Amended water or removal
encapsulant should be mixed in a labeled garden sprayer unit prior to the
start of an O&M activity.
Some practitioners have reported that liquid dishwashing detergent might
be used as a surfactant for O&M work. They have used a mix of 8 parts
water to one part detergent.
W-3 Shut-off and Lockout of HVAC and Electrical Systems Any electrical
systems that might be worked on or affected by O&M activities should be
shut off, locked and tagged with electrical lockout tags at the circuit breaker
panel or disconnect switch. Affected systems include systems that could
create electrical hazards during O&M activities that involve wetting.
HVAC systems in a work area, systems that serve a work area, or systems
that will be worked on should be shut down during O&M activities. Level
1 activities usually do not require HVAC shut down unless a work will occur
on a system or a disturbance of asbestos will occur. Any air-handling
systems (supply, return and exhaust) required to be shut down should be
shut off, locked, and tagged with electrical lockout tags at the circuit
breaker panel or disconnect switch.
Lockout tags should note when and why power is shut down and the
personnel performing the lockout. There should only be one key for each
lock used on lockout tags to prevent accidental reactivation of equipment.
W-4 Securing Work Area When asbestos fibers might be released, work areas
should be vacated and secured (where feasible) by scheduling, locking
doors (from inside the area if possible) or other means. Installing
polyethylene critical barriers over all openings into the work area. If this is
not feasible, access to the work area should be restricted, such as by
WORKER GENERAL PROCEDURES
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asbestos barrier tape around the perimeter of the work area. If barrier tape
is used to denote a work area, it should be placed 5 to 10 feet (1.5 to 3
meters) outside of any polyethylene protection used in the work area.
Install barrier tape by taping or tying it to fixed objects.
Do not block access to any emergency exits, and when asbestos fibers
might be released, post OSHA required ‘ 1 danger” signs at all entrances to
the work area. For such projects, it might be desirable to have a visual
barrier installed several feet in front of warning signs to avoid having
warning signs readily visible to occupants. A ukeep out of construction
area” sign should be posted on visual barriers. A visual barrier would be
arranged so that a person who goes past the visual barrier will then see
required warning signs.
W-5 Putting on Respirators and Performing Fit Checks The procedures
described below are based on the assumption that workers wearing
respirators have been trained in the use of respirators and, for negative
pressure respirators, fit tested, and enrolled in a medical surveillance
program as part of a Respiratory Protection Program. Respirators used
should be approved by NIOSH and/or MSHA. These procedures are not
a substitute for a Respiratory Protection Program in accordance with OSHA
standard 29 CFR 1910.134 or regulatory requirements regarding respirators.
Putting on Respirator Wearers should inspect their respirators before each
use of the respirator. Respirators must not be damaged, have missing
parts or be deformed in any way. The straps must be intact and well
attached. Proper filter cartridges for the hazards to be encountered must
be installed. Verify that filters have been replaced in accordance with the
Respiratory Protection Program. Batteries for powered respirators should
be fully charged. The respirator should also be cleaned if it was not
cleaned after the last use. If any problems exist, the respirator should be
repaired or replaced in accordance with the Respiratory Protection Program.
When putting on a respirator, the straps should be loosened before it is put
on. Filter caps (such as those used on some Powered Air Purifying
Respirators) should be taped to the filter body or stored where it will not be
lost. Powered respirators should be turned on and flow checked before the
facepiece is put on. The respirator should be put on and then the straps
tightened as recommended in the manufacturer’s information provided with
the respirator. Fit checks should then be performed.
Fit Checks Fit checks should be performed in accordance with the
Respiratory Protection Program by each worker each time they put on a
respirator. Both positive and negative pressure fit checks should be
performed. When feasible, powered respirators should be checked with the
motor unit turned off. A negative pressure fit check is done by donning the
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respirator and pulling the respirator straps so the unit fits snugly. Inhale
gently while placing hands over filters to block off inhalation side.
Respirator should pull to face and no air should leak in around face seal.
A positive pressure fit check is done by exhaling gently (without breaking
respirator seal to face) breathing normally while blocking off the exhalation
valve. The face piece should then expand away from face while exhaling.
Adjust respirator straps as needed to obtain a good seal of the facepiece
to the face.. If a. good seal cannot be obtained 1 obtain a new respirator and
perform fit tests again.
W-6 Putting on Protective Clothing Protective clothing for workers typically
consists of disposable coveralls, gloves and boots. Coveralls should have
hoods and booties attached. They should provide complete coverage of
the body with the exception of hands and face. Cloth coveralls that are
cleaned by a facility equipped to launder asbestos contaminated clothing
might also be used. Do not modify coveralls.
Protective Clothing Options Available for O&M Work Include If potential for
exposure to asbestos-containing dust and debris is low and localized, use:
1. One disposable coverall with no street clothes, or
2. One disposable coverall over street clothes.
If potential for exposure to asbestos-containing dust and debris is moderate
or dispersed, use:
1. Two disposable coveralls with no street clothes, or
2. Two disposable coveralls over street clothes.
If street clothes could become contaminated, two coveralls should be worn,
or the street clothes should be removed before the start of work.
When possible, street clothes should be removed in a changing area before
protective clothing is put on. Protective clothing should be put on after
respirators. The coverall hood should. cover respirator straps.
Workers are encouraged to wear protective gloves that are duct taped at
the cuffs to the protective coveralls. Eye, hearing, and head protection
should also be used where needed. Rubber slip-resistant boots are
recommended for work areas where slip hazards might occur (protective
booties should cover feet inside the boots). Steel-toed boots should be
used in areas where foot hazards exist. Do not use coveralls with loose
foot coverings for activities that involve climbing ladders or working on
scaffold.
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W-7 Beginning & Conducting Air Monitoring
Note: This section is not intended as a substitute for a complete Air
Monitoring Program and specific protocols needed for O&M work. This
section notes air monitoring issues that need to be addressed by the air
monitoring person.
Air monitoring during O&M activities can consist of personal monitoring,
area monitoring and clearance monitoring. Air monitoring required for the
work practice being performed should be listed on the Maintenance Work
Authorization Form and be conducted in accordance with applicable
regulations (such as 29 CFR 1926.58 Appendix A), the O&M Plan and Air
Monitoring Program. All air monitoring work should be conducted by a
trained air monitoring person assigned by the APM.
The air monitoring person should calibrate, adjust, and record the flow rate
of all air monitoring pumps to be used before air monitoring is started for
an O&M activity. General procedure WI 5 covers visual inspections and the
• completion of air monitoring at the end of the work.
Personal Monitoring To perform personal monitoring, attach a personal air
monitoring pump to a belt .worn by the worker. Attach an air sampling
cassette to the hose from the pump. Route the hose up the worker’s back
and tape the hose to the worker’s protective coveralls using duct tape. The
cassette should be located with the open end facing downwards at
approximately a forty-five degree angle in the worker’s “breathing zone” at
about collar level. Turn the pump on and record start time. The air
monitoring person will retrieve or change the cassette when necessary, or
when work is completed.
Area Monitoring Area monitoring is usually performed using high volume
air sampling pumps. Place pumps inside the work area and outside the
work area in occupied areas or areas where occupants could be exposed
if fibers are released from the work area. Pumps should be located where
they obtain meaningful measurements of potential worker exposure during
monitoring. Attach sampling cassettes to the hoses from the pumps and
attach the cassettes to the top of tripod stands or other stable structures
(but not the pumps themselves) to locate the sample at four to five feet (1.2
to 1.5 meters) above the floor. These cassettes should be located with the
open end facing downwards at approximately a forty-five degree angle. The
air monitoring person will retrieve or change cassettes as needed or when
the work is completed.
If any samples analyzed during the work exceed predetermined “stop work
levels” specified in the O&M program, productive work shall be stopped, the
area cleaned and additional engineering controls implemented, as
necessary.
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W-8 Precleaning Work Areas and Wet Wiping Precleaning of work areas prior
to the start of work is done to remove accumulated debris that could be
disturbed during the work. Precleaning might include picking up dust and
debris with a HEPA vacuum, wet wiping non-porous surfaces, HEPA
vacuuming surfaces that cannot be wet wiped, and cleaning any carpeted
surfaces using steam extraction equipment. Precleaning might reduce the
extent of cleaning required after the work and for clearances (if required).
Wet Wiping The procedures to be used for wet wiping are as follows:
1. Immerse disposable towel in bucket containing amended water.
2. Wring out towel and fold into quarters.
3. Wipe surface and refold to have a clean face exposed. Do not place
towel back• into bucket or water will become contaminated and will
need to be replaced.
4. Repeat step 3 until all faces of towel have been used’. Obtain a clean
towel if more
wiping is needed.
5. Dispose of used towels in disposal bags.
6. Dispose of contaminated water as required by applicable regulations
-See general procedure W18.
HEPA Vacuuming The procedures to be used for HEPA vacuuming are as
follows:
1. For floors, use a floor attachment with rubber floor seals and
adjustable floor-to-attachment height. For furniture, fabrics or other
surfaces use an upholstery attachment or brush attachment.
2. Vacuum hard or smooth surfaces with attachment about 1/16” (2
mm) above the surface.
3. Vacuum carpet or fabrics with attachment just touching the surface.
4. Vacuum all surfaces in parallel passes with each pass overlapping
the previous one by one-half the width of the attachment.
5. Once surfaces are cleaned in one direction, clean a second time at
right angles to the first cleaning.
6. Use crevice brush or other tools to clean irregularly shaped surfaces.
Steam Cleaning Carpet The procedures to be used for steam cleaning
carpet are as follows:
1. Steam clean carpet using carpet tool.
2. Steam clean all surfaces in parallel passes with each pass
overlapping the previous one by one-half the width of the attachment.
3. Once surfaces are cleaned in one direction, clean a second time at
right angles to the first cleaning.
4. Water from cleaning process should be treated in accordance with
applicable regulations - See W18.
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W-9 Setting up Work Areas
Note: Polyethylene work area protection is not to be used in place of other
engineering controls and good work practices. Work practices such as
wetting ACBM, careful handling, local collection by HEPA vacuum and local
exhaust ventilation should be the primaiy means of fiber control during O&M
work. Polyethylene protection, glovebags, andmini-enclosures are intended.
as a secondary means of protection during the work State of [ añ ’&d
t t J or local codes might require that fire retardant polyethylene be used
for asbestos related work.
The NIBS Asbestos Abatement and Management in Buildings: Model Guide
Specifications Section 01527 ‘Regulated Areas’ provides information on the
preparation of ‘a regulated area’ for small scale, short duration work.
Section 01529 ‘Small-Scale Short-Duration Work’ of the NIBS specifications
provides information on the set up of a mini-enclosure. Review of this
additional information is encouraged.
Preparation of work areas for O&M activities typically involves the use of a
polyethylene drop cloth or mini-enclosure. Other techniques, such as the
use of a glovebag taped over a self-supporting framework might also be
used as a substitute for the specified methods where appropriate. For small
amounts of removal work (such as several floor tile or a cutting a hole in
asbestos-containing drywall) where an enclosure is desired or needed, a
glovebag can often be used in lieu of a full mini-enclosure.
Polyethylene Drop Cloth Preparing a work area with a drop cloth requires
that a single layer of polyethylene be spread on the floor of the work area
and taped or weighted in place. Do not use more than one layer if ladders
(or similar equipment) will be used, unless a hard surface, such as plywood
is laid over the drop cloth. If floor is a soft material, such as carpet, use
caution to prevent tearing of polyethylene under equipment. Th.e drop cloth
should cover an area large enough to catch falling debris. If work is to be
performed at an elevated level, the drop cloth should be placed on the work
platform, or extended at ground level beyond the immediate work location
to catch any debris that might be generated. Note that the use of a drop
cloth introduces potential slip hazards in the work area. Non-slip foot
coverings are recommended where drop cloths are used.
Mini-Enclosure A mini-enclosure is usually a polyethylene enclosure around
a work area. Mini-enclosures are sealed enclosures used as a secondary
means to help, or attempt to, contain fibers or debris generated during the
work.
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Mini-enclosures also serve to provide a visual barrier between the workers
and any other personnel around the work area. As noted above, careful
work practices should be the primary means of fiber control during the work
in order to prevent gross contamination of the mini-enclosure.
It is sometimes appropriate to extend mini-enclosures above ceilings, such
as by using polyethylene sheet and framing taped together to provide
enclosure around the work area. The mini-enclosure should not contact
ACBM covered surfaces. The construction will vary depending on whether
the enclosure will be attached to pipes, conduit, metal hangers, or some
other form of existing construction.
There are a variety of commercially available types of mini-enclosures,
including prefabricated pop-up boxes and adjustable framework assemblies
to permit different sizes of enclosures to be constructed. Disposable liners
for mini-enclosures (to facilitate set up and dismantling of the enclosure) are
available from some manufacturers. It might be beneficial to construct or
purchase a portable mini-enclosure unit that works for the typical conditions
found in a given faciIity
It is recommended that two workers be used to set up and operate mini-
enclosures. To construct a mini-enclosure, erect a framework of wood,
PVC piping or metal framing that will enclose the work area and be large
enough for one person to work inside. The minimum width and depth of
the enclosure should be at least 3 feet (1 meter). The height of the
enclosure will vary depending upon the work to be performed and the
height of the work area. A larger enclosure is preferable where space
permits. However, if the enclosure is too large, the final cleaning process
will require more time. A mini-enclosure can include a separate 3 foot by
3 foot by 7 foot (1 x 1 x 2.1 meters) change room, with curtain doorways,
attached to the mini-enclosure for changing and removing protective
clothing.
If an entire room will be enclosed for performing work, the framework is
usually not necessary, unless wall surfaces will be damaged by tape used
to support polyethylene. A room can be enclosed for O&M work by
installing one layer of polyethylene sheet on the walls and floor of the room.
If the work to be performed is in an elevated location, the enclosure (and
change room, if used) should be erected on a scaffold platform large
enough to support the enclosure, change room (if used), and a step off
area outside the enclosure.
Refer to OSHA regulations 29 CFR 1910.28 and 29 CFR 1926.451
concerning scaffold requirements. Any ladders and/or scaffolds used must
be built and used in conformance with the OSHA construction standards,
and applicable state and local standards. See Appendix G of this manual.
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Cover the floor and the framework for the enclosure and change room with
one layer of polyethylene attached using duct tape. A second layer of
polyethylene laid on the floor might facilitate clean up work, or reduce the
possibility of tearing the polyethylene if equipment is used (do not use two
layers under the legs of ladders). Construct curtain doorways between the
change room and the enclosure and between the change room and the
area outside the change room. A curtain doorway is made of three
overlapping sheets of polyethylene. Attach sheets to framework at top and
one side. The middle sheet should be attached on one side, and the inner
and outer sheets attached on the other side. A sheet of polyethylene
approximately ‘5 feet by 5 feet (1.5 meters by 1.5 meters) or larger should
be installed outside the thange room for use as a step off area and as’ a
place to put decontaminated materials removed from the work area.
Mini-enclosures should be constructed with a ceiling of polyethylene if work
will not be performed above the enclosure. If work is to be performed
above the enclosure and the ceiling is not ACBM, the enclosure should
extend to and be sealed to the ceiling or grid system. If the enclosure is
below an ACBM finished surface, use one of the following methods:
1. If ACBM cannot be contacted, the enclosure should be separated
from the ceiling by a narrow space.
2. If ACBM will withstand contact without damage and are in good.
condition, foam tape (1 U (25mm) or thicker) can be placed on the top
edge of the enclosure. Gently lift enclosure into place until sufficient
contact is made to provide a seal to the surface.
After enclosure is in place, check for, and clean up any debris generated
by enclosure installation.
Mini-enclosures should’ be set up with a negative pressure system as
described below to reduce the possibility of fibers being released from the
enclosure and to filter the air inside the enclosure.
Negative Pressure System and HEPA Filtered Local Exhaust Ventilation;
Note: Certain configurations of negative pressure systems (pressure
differential systems) are covered by ‘patents. The APM should review
applicable patent in formation regarding use of these systems. This manual
uses the term “negative pressure system” as a synonym for “pressure
differential system”.
Mini-enclosures should be provided with a negative pressure system to
reduce the possibility of fibers being released from the enclosure during the
work, and to filter inside air discharged from the enclosure. Negative
pressure inside mini-enclosures is commonly provided by a High Efficiency
Particulate Air (HEPA) filtered vacuum or by negative pressure machines,
WORKER GENERAL PROCEDURES
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depending upon the size of the enclosure. The NIBS Asbestos Abatement
and Management in Buildings: Model Guide Specifications Section 01513
‘Temporary Pressure Differential & Air Circulation System” gives guidance
on pressure differential systems and suggested rates of air circulation in
terms of air changes per hour. A HEPA vacuum will usually provide
sufficient negative pressure for a small enclosure. Larger enclosures might
require a small negative pressure machine (H EPA filtered fan unit) to
achieve a negative pressure inside the enclosure.
A negative pressure system for a mini-enclosure most commonly locates
the HEPA vacuum or negative pressure machine outside the enclosure.
The intake side of the unit Is ducted to the enclosure through the vacuum
hose or flexible duct material taped to a hole in the enclosure on the side
opposite from the change room or as close as. possible to where the work
will be performed. The filtered exhaust-side of the unit should be ducted to
the outside if possible. However, most vacuum units do not provide a
connection for an exhaust duct, and are commonly exhausted to the inside.
Additional protection might be desirable for an area where air is exhausted
inside a building. A work practice is provided for changing filters in HEPA
vacuums and negative pressure machines (H EPA filtered exhaust fans)
when needed. Filters should not be changed without following these work
practices.
When HEPA filtered local exhaust ventilation is used in a work practice, this
can be in addition to, or in place of, a negative pressure system. A HEPA
filtered local exhaust ventilation system might replace a negative pressure
system if the ventilation system provides adequate negative pressure in the
work area. Some work practices use HEPA filtered local exhaust ventilation
for fiber control where an enclosure is not used. A HEPA ventilation system
can use a HEPA vacuum or negative pressure machine. The hose attached
to the HEPA unit should be kept as close as possible to the location where
ACBM might be, or is, disturbed.
W-10 Packaging and Labeling Waste Asbestos-containing waste material from
O&M activities should be adequately wet in accordance with the NESHAP
requirements (40 CFR 61.150). Verify waste packaging and other waste
disposal requirements with the landfill that will receive the asbestos waste.
Pre-labeled asbestos disposal bags should be used for asbestos waste
disposal where possible, appropriate and permissible. Disposal bags
should be collapsed by evacuating the air from the bag with a HEPA
vacuum in the work area or enclosure. Once collapsed, twist the bag to
form a neck and wrap it tight with duct tape. Fold neck of bag over to form
a loop, then again wrap duct tape around neck and loop.
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Although not a federal regulatory requirement, asbestos waste is often
placed into second disposal bag and sealed as described above. Label
disposal bags as required by applicable NESHAP, OSHA and DOT
regulations.
Asbestos waste that does not fit into disposal bags should be wrapped
leak-tight in one or two layers of 6 mu (0.15 mm) polyethylene sheet. Each
layer should be sealed tightly with duct tape. Label outer layer as required
by regulations.
Sharp objects that might puncture polyethylene (such as floor tile) should
be placed into cardboard boxes before wrapping in one or twclayer of 6
mu (0.15 mm) polyethylene.
All waste should be labeled as required by federal, state and local
regulations. Federal regulations requiring labeling of waste include OSHA
regulations 29 CFR 1910.1200, 1910.1001 and 1926.58, EPA’s NESHAP
regulation 40 CFR 61.150, and the Department of Transportation’s
Hazardous Materials Regulations 49 CFR 171 and 180. ACBM packaging,
with some exceptions, must meet general DOT and EPA requirements and
be protective, marked and labeled. See Appendix I for further information.
Review current labeling requirements with APM and disposal site. The
OSHA requirements apply regardless of the amount of waste or measured
exposure levels (see 29 CFR 1926.58(l).
Labels Requirements Include:
OSHA 29 CFR 1926.58(k)(2) requirement:
DANGER
• CONTAINS ASBESTOS FIBERS
AVOID CREATING DUST
CANCER AND LUNG DISEASE HAZARD
Department of Transportation (DOT) requirement DOT’s shipping paper
and marking format, used with some exceptions (see Appendix I) is:
RQ, (Reportable Quantity, if over 1 lb (.4 kg) friable asbestos)
WASTE (For transportation of waste material, if applicable)
WHITE ASBESTOS (or BLUE or BROWN)
(Shipping name; asbestos descriptions; see below)
MIXTURE (For asbestos mixed with a binder or filler, etc.)
9, (Class 9, Miscellaneous Hazardous Materials, includes asbestos)
UN2590 (or UN2212, or UN2212), (United Nations Identification numbers
for the 3 DOT asbestos descriptions)
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PG I II (or H or II), (Packaging Groups for the 3 DOT asbestos
descriptions; II and III are medium and minor; use II if mixed shipment)
LTD QTY, (Limited quantity, if applicable)
20 OZ (.6 kg) (Total quantity of material described; may abbreviate unit)
DOT defines chrysotile, actinolite, anthophyllite and tremolite asbestos as
“white asbestos,” crocidolite asbestos as “blue asbestos,” and amosite
and mysorite asbestos as “brown asbestos.”
NESHAP requirement NESHAP requires that readily visible and legible
warning labels as specified by OSHA under 29 CFR 1910.1001 U)(2) or
1926.58 (k)(2)(iii) be used on waste c ntahiers or wrapped materials (this
is the same as the OSHA 29 CFR 1926.58 label listed above). Waste
material to be transported off the facility site must also be labeled with
the name of the waste generator and the location at which the waste was
generated.
W-1I Applying Lockdowri Encapsulant A lockdown encapsulant should be
applied to areas where ACBM are removed. Lockdown encapsulants
used should be tested per 1978 Battelle/EPA report “Tests for the
Evaluation of Encapsulants for Friable Asbestos-Containing Materials”.
Encapsulants should be water resistant after curing and be Class “A” fire
rated per ASTM 84-81A “Standard Method for Surface Burning
Characteristics of Building Materials.
Lockdowns need to be compatible with any materials that will be installed
over the encapsulant. Note that many lockdown encapsulants will act as
an adhesive and could be objectionable on some surfaces when dry.
Care should be taken to avoid gethng encapsulant on or in HVAC units,
HEPA vacuums, and negative pressure machines.
Lockdown is typically applied for O&M work using a garden sprayer. It
should be applied in accordance with the manufacturers’
recommendations in two tight coats sprayed from opposite directions to
seal all portions of surfaces including any exposed edges of remaining
ACBM.
W-1 2 Cleaning Tools, Equipment, and Work Area Clean tools and equipment
using HEPA vacuuming and/or wet wiping procedures. Special attention
should be given to cleaning extension cords, equipment wheels, vacuum
hoses and other items that could pick up debris during the work. Tools
and equipment should be placed outside of the work area as soon as
cleaning is completed. Drop cloths and mini-enclosures can be cleaned
or disposed of as ACBM. Any items that cannot be fully cleaned (such
as boots or tools) that might be used in another O&M activity should be
placed into disposal bags, sealed and labeled as ACBM. These bags
WORKER GENERAL PROCEDURES
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should be wet wiped and then placed outside of the work area with the
other tools and equipment. Do not open bags containing contaminated
tools, or open equipment such as a HEPA vacuum, except during
another O&M activity or in a designated work area. HEPA vacuum
hoses can be sealed with tape over both ends if the outside of the hose
is clean.
Cleaning of the work area where an O&M activity is conducted consists
of HEPA vacuuming and/or wet wiping (as appropriate) all surfaces in
the area. HEPA vacuuming and wetwiping shall be performed as
described in general procedure W8 above.
W-13 Decontaminating Waste Packaged waste should be HEPA vacuumed
and wet wiped before it is moved out of the work area. Use the. wet
wiping and HEPA vacuuming procedures in general procedure W8.
Packaged waste should be placed on a sheet of polyethylene when it is
moved outside of the work area. This polyethylene can be the outer
portion of a drop cloth, if a drop cloth is being used.
W-14 Worker Dec ntamination and Removal of Protective Clothing and
Respirators
Removal of Protective Clothing (if used) Decontamination and removal of
protective clothing following O&M activities should use the applicable
procedure(s) described below:
Removal of Protective Clothing When Drop Cloth Work Area Protection,
or no Work Area Protection, is Used HEPA vacuum all parts of
protective clothing while standing at perimeter of drop cloth. Leaving
respirator in place, remove protective clothing and fold inside out as it is
removed. Place clothing, if contaminated, into a disposal bag and label
as ACBM waste.
Removal of Protective Clothing If A Mini-Enclosure and Change Room is
Provided HEPA vacuum all parts of protective clothing while inside work
area enclosure. .
If two disposable coveralls are used, remove outer coveralls in work area
while leaving respirator in place. Fold coveralls inside out as they are
removed. Move to change room, HEPA vacuum protective clothing, and
remove second set of coveralls in the same manner.
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If only one set of disposable coveralls is worn, remove in change room
while leaving respirator in place. Fold coveralls inside out as they are
removed.
Place protective clothing, if contaminated, into a disposal bag and label
as ACBM waste. Wash hands, face and surface of respirator with clean
water and disposable towels. Use caution to avoid breaking seal
between respirator facepiece and face. Place disposable towels into a
disposal bag. Remove respirator and follow procedures specified in
Respiratory Protection Program for cleaning and storing respirator.
Change respirator filters if needed or required and dispose of used filters
as ACBM. Put street clothes on and exit change room.
Removal of Protective Clothing if a Shower is Available If a shower with
waste water filtering for ACBM are available, follow the applicable clothing
removal procedure described above. Remove protective clothing in work
area and put on a clean set of protective coveralls. Proceed to shower
with respirator still in place. At shower facility, remove protective
coveralls, folding inside out during removal. Place clothing, if
contaminated, into a disposal bag and label as ACBM waste. Shower
completely, and remove and clean respirator while showering as
described below.
Street Clothes If street clothes are worn under protective clothing and
are contaminated during the work, the street clothes should be HEPA
vacuumed, removed during decontamination and placed into a labeled
disposal bag. These street clothes should then be disposed of as ACBM
or taken to a facility that has equipment designed for cleaning asbestos-
contaminated clothing.
Removal of Respirator (if used) The procedures described below are
based on the assumption that workers wearing respirators have been
trained in the use of respirators and, for negative pressure respirators, fit
tested, and enrolled in a medical surveillance program as part of a
Respiratory Protection Program.
Remove respirator after removing protective clothing (if used). Before
removing respirator, wash hands, face and surface of respirator with
clean water and disposable towels. Use caution to avoid breaking seal
between respirator facepiece and face. Avoid getting water into filter
cartridges of respirator. Place disposable towels into a disposal bag.
Remove respirator and follow procedures specified in Respiratory
Protection Program for cleaning and storing respirator.
WORKER GENERAL PROCEDURES
21
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W-1 5 Visual Inspection and Completing Air Monitoring
Visual Inspection The APM should develop building-specific protocols for
visual inspections following O&M work. A visual inspection should be
conducted prior to the completion of air sampling to verify that all visible
dust or debris has been cleaned up. The person performing the
inspection can be a worker. If the APM or another person makes this
inspection, they should wear the same type of personal protective
equipment worn by the workers. ‘If visible dust or debris remains, it must.
be cleaned up using wet wiping and/or HEPA vacuuming before
clearance sampling is started. The EPA’s Purple Book and the American
Society for Testing and Materials (ASTM) “Standard Practice for Vist ial
Inspection of Asbestos Abatement ProjectsN (Document E1368-90)
provide visual inspection procedures that might be helpful in developing
O&M inspection procedures..
Because the ASTM (Document E 1368-90) is copyrighted material, it
cannot be full included and reprodcued as a part of this O&M document.
Copies may be obtained by contacting ASTM at the following address:
ASTM
1916 Race Street
Philadelphia, Pennsylvania 19103-1187
Telephone: 215/299-5585
Telefax: 251/977-9679
Air Samples Complete air monitoring work in accordance with Air
Monitoring Program and requirements noted on a Work Authorization
Form. Verify that removal areas have been encapsulated (“locked
down”), that the work area, tools, and equipment have been cleaned,
and that the area has passed a visual inspection. When air sampling
cassettes are retrieved, the air monitoring person should record the stop
time for the samples and check and record the flow rate of the air
monitoring pumps. Samples should be analyzed on-site (for PCM
analysis) if possible, or sent to a laboratory for analysis. When sample
results are received, compare results to Air Monitoring Program criteria
for work release or clearance. If sample results exceed criteria, the work
area should be recleaned, reinspected, and then additional air samples
should be obtained. If samples are equal to or below release criteria,
tear down work can proceed. Collect air sampling pumps and
equipment from work area and other locations when air sampling work is
completed.
WORKER GENERAL PROCEDURES
22
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W-16 Waste Transportation, Storage and Disposal Transport asbestos waste
from O&M activities to a designated storage area or an approved landfill
after the work is completed. Workers transporting waste should follow
Respiratory Protection Program recommendations concerning respirator
requirements for transporting asbestos waste. Do not drag packaged
waste. All waste should be lifted and carried, or transported in wheeled
carts, when moved from one area to another. Packaged waste should
be placed, not thrown or dropped, into vehicles, storage areas and the
landfill.
Any asbestos waste that is not taken to a landfill should be stored in a
secure, lockable area. Signage in accordance with NESHAP should be
posted at the storage area and on vehicles used to transport asbestos-
containing waste material during:loading and unloading. When asbestos
waste in the storage area is taken to a landfill, it should be transported in
accordance with all applicable federal, state and local regulations.
Asbestos waste shipment records should be completed in accordance
with the requirements in NESHSAP Section 61.150.
The workers conducting the O&M activity should fill out part 1 of the
waste tracking form included in Appendix D or an equivalent form. Once
part I is completed and the waste is stored or taken to a landfill, the
form should be turned over to the APM to complete part 2 and file with
O&M records. NESHAP waste shipment records must also be
completed (where applicable) and filed with waste disposal records.
W-17 Glovebag Removal (Also includes other types of prefabricated removal
enclosures) Remove asbestos-containing material inside a glove bag
according to the following procedures. Glovebags should be used only
once and should not be moved to another location to perform additional
removal work, or reused in any way. Glovebags are available in many
different sizes, shapes and configurations to accommodate the variety of
removal situations that might be encountered. Glovebags are available
for use in horizontal, vertical or other special applications. Since
standard glovebags will melt if used on surfaces over 120-1 50 degrees
Fahrenheit (50-65 degrees Celsius), special types of glovebags are
available for use on high temperature piping or other surfaces.
Other types of prefabricated removal enclosures include “glovebox” type
enclosures, multiple glovebag assemblies, glovebags with self-supporting
frames, and glovebags that funnel waste into standard disposal bags.
Check with equipment suppliers for information on these enclosures.
As discussed in W9, glovebags might be used with a framework for O&M
work on flat areas such as surfacing materials. Note that significant
asbestos exposures to workers can result from the improper use of
WORKER GENERAL PROCEDURES
23
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glovebags. Workers should obtain information on current regulatory
requirements on glovebag use from the APM.
Procedure A. Glovebag Removal Procedures Check area where the
work will be performed. If damaged ACBM are present (broken lagging,
hanging, etc.), wrap in polyethylene and cover polyethylene with strips of
duct tape for reinforcement. Place one layer of duct tape around the
removal area where the glove bag will be attached. Also protect any
damaged ACBM outside the glovebag area that could be disturbed
during the work.
Slit top of the gove bag open (if necessary) and cut down the sides to
accommodate the removal area.
Place necessary tools into pouch located inside glove bag (or into a
sleeve turned inside out). Tools needed typically include: scraper, bone
saw, utility knife, disposable towels, nylon brush, abrasive pads, wire
cutters, tin snips and pre-wetted lag cloth. Cut lag cloth to sizes needed
to cover any ACBM that will remain after glovebag work is completed.
Place one strip of duct tape along the edge of the open top slit of glove
bag for reinforcement.
Place the glove bag around area to be worked on and staple top
together through reinforcing duct tape. Provide 8-12” (200-300 mm) of
space inside glovebag between removal surface and glovebag for
working room. Secure glovebag to duct tape previously installed around
removal area.
Use smoke tube and aspirator bulb to test seal. Place tube into water
sleeve (two-inch [ 50 mm] opening to glove bag) squeezing bulb and
filling bag with visible smoke. Remove smoke tube and twist water sleeve
closed. While holding the water sleeve tightly, gently squeeze glove bag
and look for smoke leaking out, (especially at the top and ends of the
glove bag). If leaks are found, tape closed using duct tape and re-test.
If a negative pressure glovebag with a supporting framework and HEPA
filtered makeup air port is being used, attach hose from an operating
HEPA vacuum to glovebag to provide negative pressure in glovebag.
Follow equipment manufacturer’s instructions on use of negative
pressure equipment.
Insert wand from garden sprayer with amended water through water
sleeve. Duct tape water sleeve tightly around the wand to prevent
leakage.
Insert arms into glovebag sleeves.
WORKER GENERAL PROCEDURES
“Nae FacThty” 24
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Remove any metal jacketing or covering over the area where removal is
required using tin snips and/or wire cutters. Fold in any sharp edges to
avoid cutting the bag. Pierce any painted coverings to permit water to
soak into the ACBM.
Adequately wet material to be worked on with amended water and allow
to soak in. Wet adequately to penetrate and soak material through to
substrate.
Cut insulation section to be removed using bone saw or utility knife. Use
caution to avoid cutting glovebag. Lift glovebag away from cutting area if
necessary. Throughout this process, spray amended water or removal
encapsulant on the cutting area to keep dust to a minimum.
Remove insulation using scraper or other tools. Place pieces in bottom
of bag without dropping. Rinse all tools with amended water inside the
bag and plàcé back into pouch or a sleeve of the glovebag turned inside
out.
Using nylon brush, scrub pads, disposable towels and amended water,
scrub and wipe down the removal area.
• Seal exposed ACBM around removal area using pre-wetted lag cloth or
encapsulate with a bridging encapsulant. Encapsulate removal area with
an appropriate lockdown encapsutant. Use suitable high temperature
encapsulants for hot piping.
Wash down inside of glovebag with amended water and wipe as
necessary to move all debris and residue to lower part of glovebag
(below where bag will be twisted and cut).
Remove water wand from water sleeve, twist water sleeve closed and
seal with duct tape.
From outside the bag, pull the tool pouch or sleeve away from the bag
and twist pouch to seal it from rest of bag. Place duct tape over twisted
portion and then cut the tool bag from the glove bag, cutting through the
twisted/taped seCtion.
Contaminated tools might then be placed directly into another glove bag
without cleaning. Alternatively, tool pouch with the tools can be placed in
a bucket of water,opened underwater, and tools cleaned and dried.
Discard disposable towels and nylon brush with asbestos waste.
Dispose of contaminated water as set forth in general procedure WiB
below.
WORKER GENERAL PROCEDURES
N ediFac if 25
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Evacuate air from glovebag using HEPA vacuum. With HEPA vacuum
operating and removed insulation in the bottom of the bag, twist the bag
several times and tape it to keep the material in the bottom during
removal of the glove bag from the removal area.
Slip a 6 mil (0.15 mm) disposal bag over the glove bag (still attached to
removal area). With the hose of an operating HEPA vacuum inserted in
the upper part of glovebag, remove tape or cut bag and open the top of
the glove bag and fold it down into disposal bag.
Procedure B. Use of a Glovebag with Self-Supporting Frame Glovebags
on self-supporting frames can be used for some O&M activities on
surfacing materials, and might be able to be adapted for other types of
ACBM. The general procedures for using these units are as follows:
Construct a rectangular or square frame of 1 1/2” (38mm) diameter PVC
or ABS pipe. Supporting legs can be made of lengths of pipe and fittings
as needed to achieve the required height. Proprietary frames with
telescoping legs are available.
To install glovebag on the frame, fold top edge of bag over the frame
sides and extend the open edge of the bag at least 10” (25 cm) beyond
the frame.’ Secure the open edges to the rest of the bag using duct
tape. Place tools and supplies needed (see glovebag procedure above)
in tool pouch inside glovebag.
Place frame and glovebag assembly below work location so that frame is
close to, but not touching, ACBM. Location and proximity of frame to
ACBM should allow for some movement without disturbing ACBM during
the work.
Insert wand of garden sprayer with amended water into bag and seal in
place.
Cut hole in glovebag for negative pressure equipment hose. Negative
pressure equipment could be a HEPA vacuum or small negative pressure
machine. Install hose and seal in place. A prefilter might be needed to
prevent any gross ACBM debris from being drawn into the negative
pressure device.
Install a hose from an operating HEPA vacuum into the bag in a position
where it can be used during the work.
Turn on negative pressure device and smoke test all sides of glovebag
frame unit to verify that negative pressure is present. If sufficient
negative pressure is not present, reduce clearance between ACBM and
frame (if possible), or add additional negative pressure device(s).
WORKER GENERAL PROCEDURES
26
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Insert hands into glove arms and wet ACBM where work is required.
Perform work as needed. Caution: If bag is overloaded with tools or
other materials, bag might break or release from frame.
HEPA vacuum and wet wipe tools and inside of bag. Adequately wet
any ACBM debris in glovebag.
Slowly lower frame to allow tools to be removed from bag.
Gently remove glovebag from frame and twist to form a neck. Evacuate
air from bag using HEPA vacuum and tape bag closed.
Remove garden sprayer wand, negative pressure device hose, and
HEPA vacuum hose and seal holes with duct tape.
Place glovebag into, a labeled 6 mil (0.15 mm) asbestos disposal bag and
seal bag.
W-18 Disposal of contaminated water Contaminated water from O&M activities
should be disposed of in accordance with all applicable federal, state and
local regulations. Filtering might be required. If filtering is required, water
should typically be filtered through a maximum 5 micron (5 m) water
filter before discharging water into a sanitary sewer system, if permitted.
If a filter unit is not available at the work location, contaminated water can
be put into Ieaktight drums and transported to a location with filtering
equipment. If a portable shower unit with filtering equipment is available,
contaminated water can be emptied into the shower and filtered through
the shower filter system. The NIBS Asbestos Abatement and
Management in Buildings: Model Guide Specifications Section 01563
“Decontamination Units” includes a specification for filtering equipment.
WORKER GENERAL PROCEDURES
“Name of FacThty” 27
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Iv.
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Section IV Surfacing Materials Work Practices
Delete work practices that have been deemed not applicable to this report according to specific
conditions in the facility. This may mean deleting only parts of the section or could require deletion
of whole sections.
Example:
53 1 2 3 Work In ceiling plenum space where exposed surfacing
ACM Is present . NOT APPUCABLE
Read all work practices carefu!Iy and revise accordingly.
When Information is deleted in one section, make certain it is deleted through-out the manual and
any other practices.
Also, edit page numbering to reflect these changes, if applicable. DO NOT renumber any
procedures or practices.
Surfacing Materials Location Illustration 3
Code Levels Description
Si 1 2 3 Moving one non-asbestos-containing ceiling panel below a
plenum space that has exposed surfacing ACM 4
S2 2 3 Attach component to an ACM finished surface that is above
a non-asbestos-containing ceiling 8
S3 1 2 3 Work in ceiling plenum space where exposed surfacing ACM
is present 12
S4 1 2 3 Install wiring in plenum space where exposed surfacing ACM
is present 16
S5 2 3 Attach item to ceiling finished with ACM 20
S6 2 3 Repair or replace item in surface finished with ACM 23
S7 2 3 Cut or drill hole in surfacing ACM 27
SB I Replace bulbs in light fixture attached to or in surface finished
with ACM 32
S9 1 Clean room with exposed surfaces finished with ACM 34
Sb 1 2 3 Repair damaged surfacing ACM 36
Si 1 1 2 3 Accessing through an ACM finished surface 40
S12 1 2 3 Painting surfacing ACM 44
S13 2 3 Accessing a contaminated light fixture 48
The accompanying illustration depicts typical applications of the above work practices.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
Name of Facihty 1
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The following general notes should be reviewed by users of the surfacing work practices:
1. Appendix G of OSHA standard 29 CFR 1926.58 states that “maintenance staff
employees should be instructed: Not to remove ceiling tiles below asbestos-
containing materials without wearing the proper respiratory protection, clearing the
area of other people, and observing asbestos waste disposal procedures.”
2. Alternative equipment that might be used for c&tain operations include:
A. Self-supporting glovebag/frame assemblies as described in General
Procedure W9. These provide additional control for level 2 activities, or
might be used instead of a mini-enclosure for some small level 3 operations.
B. A funnel with a HEPA vacuum attached to the small end of the funnel might
be used in some cases to contain debris.
3. Three primary types of surfacing ACM were identified in developing work practice
examples:
A. Acoustical Plaster
B. Decorative Texture Finish
C. Fireproofing
Definitions of all three are included in the glossary in Appendix E.
4. Careful work practices should be the primary means used to prevent releases of
• asbestos fibers during O&M work. Such practices include control measures such
as wetting and local exhaust that control or collect fibers at the source. The goal
of all asbestos O&M work should be to prevent any exposure of the worker and
unnecessary contamination of the work area, drop cloths, mini-enclosures and
other secondary control devices. Mini-enclosures should never be used to excuse
sloppy work or creation of “bigger” messes.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
‘Name of FacIIit 2
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Figure 7
The following illustration of O&M work practices for surfacing materials is an excellent
reference document in determining relevant practices for your specific building. As stated
elsewhere in this manual, if any work practice is deleted, do not renumber the remaining
list; just note “not applicable”. Such a foot note could also be made to the following
illustration.
This illustration is not on diskette. However a copy of Figure 7 is provided in the’ front
pouch of this notebook for your use. A copy of this sheet will need to be sent through
the printer to add the title and footer which is found on the first page of the SUR1-7.wpf
file.
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Figure 7:
Surfacing Materials Location Illustration
SURFACING ACM. ASBESTOS O&M WORK PRACTICES
3
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Work Practices (for EPA Standard Methods )
As particular building conditions warrant, the following work practices of the EPA Standard
Methods should be modified. Modifications maybe as great as deleting the entire section
because surfacing type materials are not present in the building. It may be only
necessary to delete a particular practice, or to add or delete a recommended level for the
practice. One suggested modification is to revise or add examples that are specific to the
facility to better orient O&M workers to the building’s O&M program.
Modifications are encouraged as a means of tailoring this master guidance document to
your specific facility.
Modifications to “Related Work Practices” and “Worker Recommendations” of the NIBS.
document may also be necessary.
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Si . Summary
Moving one non-asbestos-containing ceiling panel below a
plenum space that has exposed surfacing ACM.
Summary This work practice covers situations where you need to look into the plenum
above a non-asbestos-containing ceiling which is installed below exposed
surfacing ACM or situations where you need towork on a non-ACM ceiling
system below exposed surfacing ACM. This is for individual small
maintenance activities and should not be used for work such as replacing
all ceiling panels in a room.
Such ceilings may be contaminated by dust and/or debris from damaged•
surfacing ACM.
Note: Appendix G of OSHA standard 29 CFR 1926.58 states that
“maintenance staff employees should be instructed: Not to remove ceiling
tiles below asbestos-containing materials without wearing the proper
respirator,’ protection, clearing the area of other people, and observing
asbestos waste disposal procedures”. Personnel performing this work
should be properly trained and protected.
Examples Level 1: A. Move one non-ACM ceiling panel in a lay-in ceiling
below exposed surfacing ACM in good condition to
make observations.
Level 2: A. Install or replace an HVAC diffuser in non-ACM ceiling
where plenum space contains exposed surfacing ACM
in good or fair condition.
B. Move or replace non-ACM ceiling panels in a lay-in
ceiling below exposed surfacing ACM in good or fair
condition.
Level 3: A. Install or replace light fixture in non-ACM ceiling where
plenum space contains exposed surfacing ACM in
poor condition.
B. Move non-ACM ceiling panels to access plenum area
where dust and/or debris from surfacing is present on
top of ceiling.
Related Work Practices
S2 - Attach item to an ACM finished surface that is above a ceiling.
S3 - Work in ceiling plenum space where exposed surfacing ACM is present.
S4 - Install wiring in plenum space where exposed surfacing ACM is present.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
“Nane Fac ty 4
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Si . Level 1
Moving one non-asbestos-containing ceiling panel
plenum space that has exposed surfacing ACM
Work Practice
1. Perform Pre-work actMties on Level 1 Worker Checklist.
2. See General Procedure Wi for standard tools, equipment and materials list.
3. Place ladder or scaffold In work area.
4. Carefully lift up ceiling panel. if lifting Is obstructed by wires, ducts,
conduit, etc., move to another panel. Keep panel as flat as possible while
lifting panel. Lift panel slightly above grid system and slowly slide panel to
one side, leaving panel on top of an adjacent panel.
5. Wet wipe or HEPA vacuum the underside of the panel which was moved.
Carefully replace ceiling panel and complete applicable steps on Level 1
Worker Checklist to complete work.
below a
Example
Level 1: A. Move a non-ACM ceiling panel in a lay-in ceiling below
exposed surfacing ACM in good condition to make
observations.
Notes
This work practiàe must be used in conjunction with General
.
Procedure Wi and• a Level 1 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun. .
Appendix G of OSHA standard 29 CFR 1926.58 states that “maintenance
staff employees should be instructed: Not to remove ceiling tiles below
asbestos-containing materials without wearing the proper respiratory
protection, clearing the area of other people, and observing asbestos waste
disposal procedures”.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
5
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Si . Level 2
Moving one non-asbestos-containing ceiling panel below a
plenum space that has exposed surfacing ACM
Examples
Level 2: A. install or replace an HVAC diffuser in non-ACM ceiling
where plenum space contains exposed surfacing ACM
in good or fair condition.
B. Move or replace non-ACM ceiling panels in a lay-in
ceiling below exposed surfacing ACM in good or fair
condition.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Appendix G of OSHA standard 29 CFR 1926.58 states that “maintenance
staff employees should be instructed: Not to remove ceiling tiles below
asbestos-containing materials without wearing the proper respiratory
protection, clearing the area of other people, and observing asbestos waste
disposal procedures”.
Work Practice
1. Perform Pre-work activities on Level 2 Worker checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equIpment and materials list).
Tools and materials needed for work on ceiling
3. Prepare work area with drop cloth. See General Procedure W9.
4. Place tools, equipment and materials needed onto drop cloth.
5. Carefully lift up ceiling panel while HEPA vacuuming around edges of
panel. Keep panel as flat as possible while lifting panel. Lift panel slightly
above grid system and slowly slide panel to one side, leaving panel on top
of an adjacent panel.
6. Lightly mist top side of ceiling where work wiil occur using garden sprayer
with amended water.
7. Pick up any bulk debris on top of ceiling panels where work will occur and
place Into disposal bags.
8. HEPA vacuum ceiling suspension system and top side of ceiling where
work will occur.
9. Wet wipe or HEPA vacuum the underside of the panel which was moved.
Carefully replace ceiling panel and perform work required and clean-up
and tear-down steps on Level 2 Worker Checklist to complete work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
‘Name of I acility
6
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Si. LeveI3
Moving one non-asbestos-containing ceiling panel below a
plenum space that has exposed surfacing ACM.
Examples
Level 3:
A.
Install or replace light fixture in
non-ACM ceiling where
plenum space contains exposed surfacing ACM in
poor condition.
.
B.
Move non-ACM ceiling panels
to access plenum area
.
where dust and/or debris from
top of ceiling.
surfacing is present on
Notes
This work pradtice must be used in conjunction with General
Procedures Wi, W9 and a Level 3 Worker Checklist The worker
checklist includes tasks that must be performed before these work
practices are begun.
Appendix G of OSHA standard 29 CFR 1926.58 states that ‘maintenance
staff employees should be instructed: Not to remove ceiling tiles below
asbestos-containing materials without wearing the proper respiratory
protection, clearing the area of other people, and observing asbestos waste
disposal procedures”.
Work Practice
1. Perform P re-work activities on Level 3 Worker Checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Tools and materials needed for work on ceiling
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system and/or HEPA filtered local exhaust ventilation.
See General Procedure W9.
4. Place tools, equipment and materials needed Into enclosure. Include a
HEPA vacuum inside enclosure for vacuuming areas above ceiling.
5. Carefully lift up ceiling panel while HEPA vacuuming around edges of
panel. Keep panel.as flat as possible while lifting panel. Lift panel slightly
above grid system and slowly slide panel to one side, leaving panel on top
of an adjacent panel.
6. Lightly mist top side of ceiling where work will occur using garden sprayer
with amended water.
7. Pick up any bulk debris on top of ceiling panels where work will occur and
place into disposal bags.
8. HEPA vacuum ceiling suspension system and top side of ceiling where
work will occur.
9. Wet wipe or HEPA vacuum the underside of the panel which was moved.
Carefully replace ceiling panel and perform clean-Up and tear-down steps
on Level 3 Worker Checklist to complete work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
7
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S2. Summary
Attach component to an ACM finished surface that is above a
non-asbestos-containing ceiling.
Summary This work practice covers the procedures for attaching components to an
ACM finished surface (such as spray-applied fireproofing) that is located
above a non-asbestos-containing ceiling. This surface can be above an
ACM or non-ACM ceiling.
Examples Level 2: A. Removing a small area of ACM fireproofing using a
negative pressure glovebag frame unit.
Level 3: A. Attaching a pipe, ceiling or duct hangerto a deck or
beam covered with ACM fireproofing, insulation or
overspray.
B. Attaching a pipe, ceiling or duct hanger to an old
acoustical plaster ceiling above a lay-in ceiling system.
Related Work Practices -
Si - Moving one non-asbestos-containing ceiling panel below a plenum space that has
exposed surfacing ACM.
S5 - Attach component to ceiling finished with ACM.
S7 - Cut hole in surfacing ACM.
Worker Recommendations
One worker is usually sufficient for Level 2. Two workers for Level 3. More workers may
be needed for Level 2 and Level 3 to increase efficiency or for additional health and/or
safety considerations. A person with air monitoring training might be required. This
person can be a worker.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
Name of Fadllit
8
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S2. Level 2
Attach component to an ACM finished surface that is above a
non-asbestos-containing ceiling.
Example
Level 2: A. Removing a small area of ACM fireproofing using a
negative pressure glovebag frame unit.
Notes
This work practice must be used in conjunction with General
Procedures WI, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Coordinate work with proper. 0 & M work practice for accessing type of
M25.
.
ceiling present in work area. See Work Practices Mu, M13 or
Work Practice
1. Perform P re-work actMties on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment & materials list).
Negative pressure glovebag frame unit
Scraper 2-3” (50-75 mm) wide stiff blade
Stiff nylon bristle brushes
Maintenance item(s) to be attached to surface
Non-ACM surfacing repair material
3. Prepare work area with drop cloth. See General Procedure W9.
4. Place tools, equipment and materials needed into work area. Include a
HEPA vacuum for use with negative pressure glovebag frame unit.
5. Obtain access through ceiling using 0 & M work practice selected (see
note above step I).
6. HEPA vacuum area above ceiling within reach from access hole.
7. Install glovebag frame unit under area where ACM removal is needed. Do
not contact ACM with frame.
8. Insert wand of garden sprayer with amended water through giovebag and
adequately wet area of surfacing to be removed. Allow water to soak in
for several minutes. Wet removal area frequently during removal of bulk
material and residual material. Using glovebag procedures (see General
Procedure Wi 7), scrape off ACM to at least 3” (75 mm) beyond area where
item will be attached. When bulk material is removed, wet newly exposed
areas and use scraper and nylon brush to remove remaining visible
residual ACM. Place removed ACM Into disposal bags.
9. Perform maintenance work, repair area with new non-ACM surfacing, and
perform clean-up and tear-down steps on Level 2 checklist to complete
work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
“Name of F ctlIty
9
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S2. Level 3
Attach component to an ACM finished surface that Is above a
non-asbestos-containing ceiling.
Examples
Level 3: A. Attach a pipe, ceiling or duct hanger to a deck or
beam covered with ACM fireproofing or insulation.
B. Attach a pipe, ceiling or duct hanger to an old
acoustical plaster ceiling above a lay-in ceiling system.
Notes
This work practibe ‘must be used in conjunction witl General
Procedures Wi,’ W9 and a Level 3 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Coordinate work with proper 0 & M work practice for accessing type of
ceiling present in work area. See Work Practices Mu, M13 or M25.
Work Practice
1. Perform Pre-work actMties on Level 3 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment & materials list).
Scraper 2-3” (50-75 mm) wide stiff blade
Stiff nylon bristle brushes
Maintenance item(s) to be attached to surface
Non-ACM surfacing repair material
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system and/or HEPA filtered local exhaust ventilation.
See General Procedure W9.
4. Place tools, equipment and materials needed into enclosure. Include a
HEPA vacuum Inside enclosure for vacuuming areas above ceiling.
5. Enter enclosure and obtain access through ceiling using 0 & M work
practice selected (see note above step 1).
6. HEPA vacuum area above ceiling within reach from access hole.
7. Extend mini-enclosure above ceiling, if feasible, using polyethylene sheet
and framing taped together to provide enclosure around the ‘work area
without contacting ACM covered surface. The construction of an extended
mini-enclosure will vary depending on the existing construction above the
ceiling. Polyethylene and framing may be secured to pipes, conduit, and
metal hangers if they are not covered with ACM. If an extended mini-
enclosure Is not feasible, mist area above ceiling and lay a polyethylene
drop cloth below the area where removal Is required. If drop cloth cannot
be used, suspend polyethylene below immediate work area to catch ‘ACM
to be removed. Worker should be located to one side of removal area
(inside enclosure) during removal.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
Name of Facility”
10
-------
S2. Level 3...continued
8. Adequately wet area of surfacing to be removed using garden sprayer
containing amended water and allow water to soak in for several minutes.
Wet removal area frequently during removal of bulk material and residual
material. Using scraper with HEPA vacuum within several inches of
removal area, scrape off ACM to at least 3U (75 mm) beyond area where
Item will be attached. When bulk material Is removed, wet newly exposed
areas and use scraper and nylon brush to remove remaining visible
residual ACM. Place removed ACM Into disposal bags.
9. Perform maIntenance work, repaIr area with new non-ACM surfacing, and
perform clean-up and tear-down steps on Level 3 checklist to comp’ete
work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
Name of Facility 11
-------
S3. Summary
Work in ceiling plenum space where exposed surfacing ACM is
present.
Summary This work practice covers situations where work must be performed in a
ceiling plenum space that has exposed surfacing ACM.
Examples Level I: (If work is likely to disturb ACM, use Level 2)
A. Open or close one valve above ceiling where exposed
fireproofing in good condition is present.
B. Inspect HVAC. mixing box below asbestos-containing
fireproofing in good condition.
Level 2: A. Install new conduit (attached to existing supports) in plenum
space where exposed fireproofing in good condition is
present.
B. Repair leak in non-ACM insulated water line above ceiling
where exposed surfacing ACM is present.
C. Maintain HVAC mixing box below asbestos-containing
fireproofing in good condition.
Level 3: A. Replace HVAC mixing box above ceiling where dust or debris
from surfacing ACM is present.
B. Repair piping below surfacing ACM in poor condition.
Related Work Practices
Si -
Moving one non-asbestos-containing ceiling panel below a
plenum space
that
has exposed surfacing ACM.
S2 -
Attach component to an ACM finished surface that is above
a ceiling.
S4 -
Install wiring in plenum space where ACM is present.
M28 - Remove HVAC filters in unit serving plenum space with exposed ACM.
Worker Recommendations .
One worker is usually sufficient for Level 1 and Level 2. Two workers for Level 3. More
workers may be needed to increase efficiency or for additional health and/or safety
considerations. A person with air monitoring training might be required. This person can
be a worker.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
12
-------
S3. Level 1
Work in ceiling plenum space where exposed surfacing ACM is
present.
Examples
Level 1: A. Open or close one valve above ceiling where exposed
fireproofing in good condition is present.
B. Inspect HVAC mixing box below asbestos-containing
fireproofing in good condition.
Notes
This work practice must be used in conjunction with General
Worker Checklist. The worker
Procedure Wi and a Level
checklist includes tasks that must be performed before these work
practices are begun.
Coordinate work with proper 0 & M work practice for accessing type of
ceiling present in work area. See Work Practices Si, Mu, M13 or M25.
Appendix G of OSHA standard 29 CFR 1926.58 states that “maintenance
staff employees should be instructed: Not to remove ceiling tiles below
asbestos-containing materials without wearing the proper respiratory
protection, clearing the area of other people, and observing asbestos waste
disposal procedures”.
Work Practice 1. Perform Pre-work activities on Level I checklist.
2. Additional tools, equipment and materials: (see General Procedure WI for
standard tools, equipment and materials list).
Maintenance item(s) required to perform work in plenum space
3. Place tools, equipment and materials needed in work area.
4. Obtain access above ceiling using 0 & M work practice selected (see note
above step 1).
5. Perform maintenance work required and complete applicable steps on
Level 1 checklist to complete work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
13
-------
S3. Level 2
Work in ceiling plenum space where exposed surfacing ACM is
present.
Examples
Level 2: A. Install new conduit in plenum space where exposed
fireproofing in good condition is present.
B. Repair leak in ‘water line above’ ceiling where exposed
‘
surfacing ACM is present.
C. Maintain HVAC mixing box below asbestos-containing
fireproofing in good condition.
Notes
This work practice must be used in conjunction with General
Procedures WI, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
‘
Coordinate work with proper 0 & M work practice for accessing type of
ceiling present in work area. See Work Practices Si, Mu, M13 or M25.
,
Appendix G of OSHA standard 29 CFR 1926.58 states that “maintenance
staff employees should be instructed: Not to remove ceiling tiles below
asbestos-containing materials without wearing the proper respiratory
protection, clearing the area of other people, and observing asbestos waste
disposal procedures”.
Work Practice
1. Perform Pre-work activities on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Maintenance item(s) required to perform work in plenum space.
3. Prepare work area with drop cloth. See General Procedure W9.
4. Place tools, equipment and materials needed onto drop cloth.
5. Obtain access above ceiling using 0 & M work practice selected (see note
above step 1).
6. Pick up any bulk debris within reach on top of ceiling and ‘place into
disposal bags.
7. HEPA vacuum top side of ceiling within reach from access area.
8. HEPA vacuum and wet-wipe surfaces that will be contacted or item to be
maintained or repaired.
9. Perform maintenance work required and clean-up and tear-down steps on
Level 2 checklist to complete work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
“Name of Facility”
14
-------
S3. Level 3
Work in ceiling plenum space where exposed surfacing ACM is
present.
Examples
Level 3: A. Replace HVAC mixing box above ceiling where dust or
debris from surfacing ACM is present.
B. Repair piping below surfacing ACM in poor condition.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Lev€i 3 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun..
.
Coordinate work with proper 0 & M work practice for accessing type of
ceiling present in work area; See Work Practices Si, Mu, M13 or M25.
Appendix G of OSHA standard 29 CFR 1926.58 states that “maintenance
staff employees should be instructed: Not to remove ceiling tiles below
asbestos-containing materials withoUt wearing the proper respiratory
protection, clearing the area of other people, and observing asbestos waste
disposal procedures”.
Work Practice
1. Perform P re-work actMties on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Maintenance Item(s) required to perform work In plenum space.
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system. See General Procedure W9.
4. Place tools, equipment and materials needed Into enclosure. Include a
HEPA vacuum Inside enclosure for vacuuming areas above ceiling.
5. Obtain access above ceiling using 0 & M work practices selected (see
note above step 1). Pick up any bulk debris within reach on top of ceiling
and place Into disposal bags.
6. HEPA vacuum top side of ceiling within reach from access area, and HEPA
vacuum and wet-wipe item to be repaired or replaced.
7. Perform maintenance work required and clean-up and tear-down steps on
Level 3 checklist to complete work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
“Name of Facility”
15
-------
S4. Summary
Install wiring in plenum space where exposed surfacing ACM is
present. ____________________________________
Summary This work practice covers situations where small amounts of wiring and/or
conduit are being installed in a ceiling plenum space that has exposed
surfacing ACM. The procedures assume that the ACM will not intentionally
be disturbed during the work.
Examples Level 1: A. Installing new wiring in existing conduit that does not
have overspray ACM on conduit. Movement in conduit
should not disturb ACM.
Level 2: A. Install new conduit attached to existing support
brackets.
B. Reroute conduit that can be attached to existing
support brackets.
Level 3: A. Installing new plenum rated computer or telephone
cables that will lay on top of ceiling.
Related Work Practices
Si
-
Moving one non-asbestos-containing ceiling panel below a plenum space that
has
exposed surfacing ACM.
S2
-
Attach component to an ACM finished surface that is above a ceiling.
S3
-
Work in ceiling plenum space where exposed surfacing ACM is present.
Worker Recommendations
One worker for Level 1 and Level 2. Two workers may facilitate pulling wires between two
locations. Two workers for Level 3. A person with air monitoring training might be
required. This person can be one of the workers.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
“Name of FacLllty 16
-------
S4. Level 1
Install wiring in plenum space where exposed surfacing ACM is
present.
Examp
le
.
Level 1: A. Install new wiring in existing conduit that does not have
overspray ACM on conduit. Movement in conduit
should not disturb ACM.
Notes
This work practice must be used in conjunction with General
Procedure Wi and a Level I Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
.
Coordinate work with proper 0 & M work practice for accessing type of
ceiling present in work area. See Work Practices Si, Mu, M13 or M25.
Work Practice
1. Perform Pre-work activities on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Wiring and related tools
3 Place tools, equipment and materials needed In work area.
4. Obtain access through ceiling using 0 & M work practice selected (see
note above step 1).
5. Run wiring as required. Do not contact exposed ACM surfacing and
minimize disturbance of ceiling system and other components above
ceiling while running wiring.
6. Perform clean-up and tear-down steps on Level 1 checklist to complete
work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
17
-------
1. Perform Pre-work activities on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Wiring and related tools
3. Prepare work area with drop cloth. See General Procedure W9. Set up
multiple work areas if needed.
4. Place tools, equipment and materials needed onto drop cloth.
5. Obtain access through ceiling using 0 & M work practice selected (see
note above step 1). HEPA vacuum top side of ceiling within reach from
access area.
6. Run wiring as required. Do not contact exposed ACM surfacing and
minimize disturbance of ceiling system and other components above
ceiling while running wiring.
7. Perform clean-up and tear-down steps on Level 2 checklist to complete
work.
S4. Level 2
Install wiring in plenum space where exposed surfacing ACM is
present.
Examples
Level 2: A. Install new conduit attached to existing support
brackets.
B. Reroute conduit that can be attached to existing
support brackets.
C. lnstaU new cables that will lay on top of ceiling where
no dust or debris is present.
Notes
This work practice must be used in conjunction with General
Procedures WI, W9 and a Level 2 Worker Checklist; The worker
checklist includes tasks that must be performed before these work
practices are begun.
Coordinate work with proper 0 & M work practice for accessing type of
ceiling present in work area. See Work Practices Si, Ml 1, Mi 3 or M25.
Work Practice
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
“Name of Facility”
18
-------
S4.LeveI3
Install wiring in plenum space where exposed surfacing ACM is
present.
Example
Level 3: A. Install new cables that will lay on top of ceiling where
visible dust or debris is present.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
.
practices are begun.
Coordinate this work with proper 0 & M work practice for accessing type
of ceiling present in work area. See Work Practices Si, Mu, M13. or
M25.
Work Practice
1. Perform P re-work actMties on Level 3 checklist.
2. AdditIonal tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Wiring and related tools
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system. See General Procedure W9. Set up multiple
enclosures if needed.
4. Place tools, equipment and materials needed into enclosure. Include a
HEPA vacuum inside enclosure for vacuuming areas above ceiling.
5. Enter enclosure and obtain access through ceiling using 0 & M work
practice selected (see note above step 1). HEPA vacuum top side of
ceiling within reach from access hole.
6. Mist top side of ceiling in work area where dust or debris is present and
run wiring as required. Do not contact exposed ACM surfacing and
minimize disturbance of ceiling system and other components above
ceiling while running wiring.
7. Perform clean-up and tear-down steps on Level 3 checklist to complete
work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
“Name of FacLI1t
19
-------
S5 . Summary
Attach item to ceiling finished with ACM.
Summary This work practice describes the work required to attach an item to a ceiling
finished with surfacing ACM, such as acoustical plaster or a decorative
sprayed-on surface texture material.
Examples Level 2: A. Attach a battery-powered smoke detector to acoustical
• plaster.
B. Attach track lighting to an ACM finished ceiling where
experience has proven a minimal disturbance will
occur.
Level 3: A. Attach track lighting system to ACM finished ceiling.
B. Install exposed conduit, junction boxes and light
fixtures to ACM finished ceiling.
C. Attach new folding door to acoustical plaster where
structural modifications are not needed for support.
Related Work Practices
SI - Move one non-asbestos-containing ceiling panel below a plenum space that has
exposed surfacing ACM.
S2 - Attach component to an ACM finished surface that is above a ceiling.
S7 - Cut or drill hole in Surfacing ACM.
SB - Replace bulbs in light fixture attached to or in surface finished with ACM.
Worker Recommendations
One worker for Level 2. Two workers for Level 3. More workers may be needed for
certain Level 3 tasks. A person with air monitoring training might be required. This
person can be one of the workers.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
20
-------
S5.LeveI2
Attach item to ceiling finished with ACM.
Examples
Level 2: A. Attach a battery-powered smoke detector to acoustical
plaster.
B. Attach track lighting to an ACM finished surface where
experience has proven a minimal disturbance will
.
occur.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
.
practices are begun.
Appendix G to OSHA regulation 29 CFR 1926.58 states: “The training
program for the maintenance engineering staff should describe methods of
handling asbestos-containing materials as well as routine maintenance
activities that are prohibited when asbestos-containing materials are
involved. For example, maintenance staff employees should be instructed:
Not to hang plants or pictures on structures covered with asbestos-
containing materials.”
Work Practice
to complete
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
“Name of Facility”
1. Perform P re-work actMties on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure WI for
standard toots, equipment and materials list).
Item to be attached to ceiling and related tools
3. Prepare work area with drop cloth. See General Procedure W9.
4. Place tools, equipment and materials needed onto drop cloth.
5. Wet area on ceiling where item will be attached using garden sprayer with
amended water.
6. Using hand tools and HEPA vacuum near attachment location, or power
tools with attached HEPA vacuum, attach item to ceiling. If small holes are
being drilled, they can be drilled through a wet sponge or shaving cream
to control fiber release.
If a wet sponge or shaving cream Is not appropriate or adequate, scrape
away surfacing to at least 1/2” [ 13 mm] beyond where hole Is needed.
Keep the hose of an operating HEPA vacuum within 6” [ 150mm] of where
scraping Is occurring. Adequately wet scraping area and any dust or
debris generated. Drill hole through substrate after ACM Is removed.
Place all debris and sponges Into ACM disposal bags.
7. Perform clean-up and tear-down steps on Level 2 checklist
work.
21
-------
1. Perform Pre-work activities on Level 3 checklist.
2. Special tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Item to be attached to ceiling and related tools
.3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system and/or HEPA filtered local exhaust ventilation.
See General Procedure W9.
4. Place tools, equipment and materials needed into enclosure. Include a
HEPA vacuum inside enclosure for vacuuming areas above ceiling.
5. Enter enclosure and wet area on ceiling where item will be attached using
garden sprayer with amended water.
6. Using hand tools (or power tools with attached HEPA vacuum) attach item
to ceiling. If small holes are being drilled, they can be drilled through a
wet sponge or shaving cream to control fiber release.
If a wet sponge or shaving cream is not appropriate or adequate, scrape
away surfacing to at least 1/2” [ 13 mm] beyond where hole is needed.
Keep the hose of an operating HEPA vacuum within 6” [ 150 mm] of where
scraping Is occurring. Adequately wet scraping area and any dust or
debris generated. Drill hole through substrate after ACM is removed.
Adequately wet any dust or debris that Is generated. Place all debris and
sponges into ACM disposal bags.
7. Perform clean-up and tear-down steps on Level 3 checklist to complete
work.
S5.LeveI3
Attach item to ceiling finished with ACM.
Examples
Level 3: A. Attach track lighting system to ACM finished ceiling.
B. Install exposed conduit, junction boxes and light
fixtures to ACM finished ceiling.
C. Attach new folding door to acoustical plaster where
.
structural modifications are not needed for support.
Notes .
This work practice must be used in conjunctiorb with General
Procedures WI, W9 and a Level 3 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Appendix G to OSHA regulation 29 CFR 1926.58 states: “The training
program for the maintenance engineering staff should describe methods of
handling asbestos containing materials as well as routine maintenance
activities that are prohibited when asbestos-containing materials are
involved. For example, maintenance staff employees should be instructed:
Not to hang plants or pictures on structures covered with asbestos-
containing materials.”
Work Practice
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
Namo of F cLlIty
22
-------
S6. Summary
Repair or replace item in surface finished with ACM .
Summary This work practice covers the procedures for repairing or replacing an item
that is installed in or attached to a surface finished with ACM, such as an
acoustical plaster ceiling or fireproofed deck or beam.
Examples Level 1: A. Replace light fixture in ceiling finished with ACM where
a disturbance of ACM is not expected.
B. Replace venetian blinds attached to a surface finished
with ACM.
Level 2: A. Replacement of ballast in recessed light fixture
attached in acoustical plaster ceiling where ACM may
be disturbed.
B. Diffuser repair in acoustical plaster ceiling.
C. Replace light fixture in ceiling finished with asbestos-
containing decorative textured finish that may be
disturbed.
Level 3: A. Replace electrical panel attached to fireproofed column.
B. Replace abcess panel in ceiling finished with ACM.
C. Replace HVAC unit attached to poor condition
acoustical plaster ceiling.
Related Work Practices
Si - Moving one non-asbestos-containing ceiling
panel below a plenum space that has
exposed surfacing ACM.
.
S5 - Attach item to ceiling finished with ACM.
S7 - Cut or drill hole in Surfacing ACM.
S8 - Replace bulbs in light fixture attached to or
in surface finished with ACM.
Sb - Repair damaged surfacing ACM.
Worker Recommendations
One worker is usually sufficient for Level i and Level 2. Two workers for Level 3. More
workers may be needed to increase efficiency or for additional health and/or safety
considerations. A person with air monitoring training might be required. This person can
be a worker.
SURFACING ACM . ASBESTOS O&M WORK PRAcTIcEs
Name of FacilIty 23
-------
1. Perform P re-work activities on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Repair and/or replacement parts and tools as needed
3. Prepare work area with drop cloth, (if desired). See General Procedure
W9.
4. Place tools, equipment and materials needed in work area or on drop
cloth.
5. LIghtly mist area of surfacing within 6” [ 150 mm] of Item to be repaired or
replaced using garden sprayer containing amended water and allow water
to soak In for several minutes.
6. Wet wipe exposed surfaces of maintenance item to be repaired or
replaced.
7. Carefully perform repair work or remove and replace maintenance item.
If item is to be removed, repaired, and then reinstalled, clean item with
HEPA vacuum and/or wet wiping before reinstalling. If item will be
disposed of, clean (if possible) using HEPA vacuum and/or wet wiping and
dispose of as non-ACM waste. If visible debris is not removed, dispose of
as ACM or as required by applicable regulations.
8. Collect any surfacing debris from repair/replacement work using HEPA
vacuum.
9. Perform clean-up and tear-down steps on Level 1 checklist to complete
work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
‘Name of Facility
S6. Level 1
Repair or replace item in surface finished with ACM.
Examples
Level 1: A. Replace light fixture in ceiling finished with ACM where
a disturbance of ACM is not expected.
B. Replace venetian blinds attached to a surface finished
with ACM.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level I Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Coordinate work with proper 0 & M work practice for accessing type of
ceiling present in work area. See Work Practices Mu, M13 or M25.
,
Work Practice
24
-------
S6.LeveI2
Repair or replace item in surface finished with ACM.
1. Perform Pre-work actMties’on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Repair and/or replacement parts and tools as needed
3. Prepare work area with drop cloth, (if desired). See General Procedure
W9.
4. Place tools, equipment and materials needed In work area or on drop
cloth.
5. Lightly mist area of surfacing within 6” [ 150 mm] of item to be repaired or
replaced using garden sprayer containing amended water and allow water
to soak In for several minutes.
6. Wet wipe exposed surfaces of maintenance item to be repaired or
replaced.
7. Carefully perform repair work or remove and replace maintenance item.
If item is to be removed, repaired, and then reinstalled, clean item with
HEPA vacuum and/or wet wiping before reinstalling. If item will be
disposed of, clean (if possible) using HEPA vacuum and/or wet wiping and
dispose of as non-ACM waste. If visible debris Is not removed, dispose of
as ACM or as required by applicable regulations.
8. Collect any surfacing debris from repair/replacement work using HEPA
vacuum.
9. Perform clean-up and tear-down steps on Level I checklist to complete
work.
Examples
Level 2: A. Replacement of ballast in recessed light fixture
attached in acoustical plaster ceiling where ACM may
be disturbed.
B. Diffuser repair in acoustical plaster ceiling.
C. Replace light fixture in ceiling finished with asbestos-
.
containing decorative texture finish that may be
disturbed.
Notes
This work practice must be used jfl: conjunction: with General
• Procedures W1 W9 and a Level2 Worker Checklist The worker
checklist includes tasks that must be performed before these work
•
practices are begun.
.
Coordinate work with proper 0 & M work practice for accessing type of
ceiling present in work area. See Work Practices Mu, M13 or M25.
Work Practice
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
25
-------
1. Perform Pre-work activities on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Repair and/or replacement parts and tools as needed
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system and/or HEPA filtered local exhaust ventilation.
See General Procedure W9.
4. Place tools, equipment and materials needed Into enclosure. Include a
HEPA vacuum Inside enclosure for use during the work.
5. Enter enclosure and lightly mist area of surfacing within 6” [ 150 mm] of
item to be replaced using garden sprayer containing amended water and
allow water to soak in for several minutes.
6. Wet wipe exposed surfaces of maintenance Item to be repaired or
replaced.
7. Carefully perform repair work or remove and replace maintenance item.
If item is to be removed, repaired, and then reinstalled, clean item with
HEPA vacuum and/or wet wiping before reinstalling. If item will be
disposed of, clean (if possible) using HEPA vacuum and/or wet wiping and
dispose of as non-ACM waste. If visible debris Is not removed, dispose of
as ACM or as required by applicable regulations.
8. Collect any surfacing debris from repair/replacement work using HEPA
vacuum.
9. Perform clean-up and tear-down steps on Level 3 checklist to complete
work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
“Name of Facility”
S6.LeveI3
Repair or replace item in surface finished with ACM.
Examples
Level 3: A. Replace electrical panel attached to fireproofed column.
B. Replace access panel in ceiling finished with ACM.
C. Replace HVAC unit attached to poor condition
acoustical plaster ceiling.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 3 Worker Checklhst. The worker
checklist includes tasks that must be performed before these work
practices are begun.;
Coordinate this work with proper o & M work practice for accessing type
of ceiling present in work area. See Work Practices Mu, M13 or M25.
Work Practice
26
-------
S7 . Summary
Cut or drill hole in surfacing ACM.
Summary This work practice covers the work required to cut or drill a hole through
surfacing ACM, such as acoustical plaster or fireproofing. If possible, ACM
should be removed before holes are drilled. If holes are drilled in an ACM
wall surface with a cavity behind the wall, labels or recordkeeping
information should note that ACM might be present in the cavity.
Examples Level 2: A. Install a few new conduits through flreproofed metal
deck.
B. Drill a hole through asbestos-containing decorative
texture finish.
C. Drill a hole using a drill with HEPA filtered dust
collection.
Level 3: A. Drill or cut hole for pipe or duct chase using tools with
or without HEPA filtered dust collection in an enclosure.
Related Work Practices
SI - Move one non-asbestos-containing ceiling panel below a plenum space that has
exposed surfacing ACM.
S2 - Attach component to an ACM finished surface that is above a ceiling.
S5 - Attach item to ceiling finished with ACM.
S6 - Repair or replace item in surface finished with ACM.
One worker is usually sufficient for Level 2. Two workers for Level 3. More workers may
be needed to increase efficiency or for additional health and/or safety considerations.
A person with air monitoring training might be required. This person can be aworker.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
sNamO of Facility’
27
-------
S7. Level 2
Cut or drill hole in surfacing ACM.
Examples
Level 2: A. Install a few new conduits through fireproofed metal
deck.
B. Drill a hole through asbestos-containing decorative
texture finish.
C. Drill a hole using a drill with HEPA filtered dust
collection.
Notes
This work practice must be used in conjunction with General
ProceduresW1, W9 and a Level 2 Worker Checklist. The worker
checklist: includes tasks that must be performed before these work
practices are begun.
Coordinate work with proper 0 & M work practice for accessing type of
ceiling present in work area. See Work Practices Si, Mu, M13.
:
Appendix G to OSHA regulation 29 CFR 1926.58 states: “The training
program for the maintenance engineering staff should describe methods of
handling asbestos-containing materials as well as routine maintenance
activities that are prohibited when asbestos-containing materials are
involved. For example, maintenance staff employees should be instructed:
Not to drill holes in asbestos-containing materials”.
Work Practice
1. Perform Pre-work actMties on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Scraper (if used)
Hand tools, or power tools with HEPA filtered dust collection as
required to cut hole.
Wet sponge or shaving cream (if used)
3. Prepare work area with drop cloth. See General Procedure W9.
4. Place tools, equipment and materials needed onto drop cloth: If access
above ceiling Is required, obtain access using 0 & M work practice
selected (see note above step 1).
5. If hole Is being drilled through a surface, such as acoustical plaster, where
back side Is Inaccessible, use the procedures in step 6. If hole Is being
drilled through a surface, such as a fireproofed metal deck, where both
sides are accessible, use the procedures In step 7.
6. A. Install polyethylene sheet below removal location to catch any
falling debris.
B. Adequately wet area where hole Is to be drilled.
C. (1) Small holes can be drilled through a wet sponge or
shaving cream. See C(2) for alternative methods. After
drilling, remove shaving cream using wet/dry type HEPA
vacuum.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
t4ame of f aculW’
28
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S7. Level 2...continued
(2) If a wet sponge or shaving cream is not appropriate or
adequate, scrape away surfacing to at least 1/2” [ 13 mm]
beyond where hole Is needed. Keep the hose of an
operating HEPA vacuum within 6” [ 150mm] of where
scraping Is occurring. Adequately wet scraping area and
any dust or debris generated. Drill hole through substrate
after ACM Is removed.
D. Place HEPA vacuum hose near or through hole and run for several
minutes to clean air on backside of surface.
7. A. If hole Is drilled from top side of deck, adequately wet ACM on
underside and install polyethylene sheet or enclosure below ACM
on underside that will catch any falling debris, Including materIal
from hole (such as a concrete cylinder). (If hole Is drilled from
underside, see step B). Drill hole through surface. Adequately wet
drilling area whIle drilling. Wet any debris on drop cloth or In
enclosure on underside, package up debris and drop
cloth/enclosure and dispose of as ACM.
B. If hole is drilled from underside of deck, follow steps 6A, 6B and
6C(2).
8. Perform clean-up and tear-down steps on Level 2 checklist to complete
work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
29
-------
Perform Pre-work activities on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Scraper
Hand or power drill or saw. Power tools shall have HEPA vacuum
attachment.
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system and/or HEPA filtered local exhaust ventilation.
See General Procedure W9.
4. Place tools, equipment and materials needed Into enclosure. Include a
HEPA vacuum inside enclosure for use during the work. IF access above
is required, obtain access using 0 & M work practice selected (see note
above step 1). If surface to be drilled is above a ceiling, extend enclosure
(if feasible) to within approximately 1/2” [ 13 mm] of surfacing ACM.
5. Enter enclosure. If hole is being drilled through a surface, such as
acoustical plaster where back side is inaccessible, use the procedures in
step 6. If hole is being drilled through a surface, such as a fireproofed
metal deck, where both sides are accessible, use the procedures in step
7.
6. A. inside enclosure, Install polyethylene sheet below removal location
to catch any falling debris.
B. Adequately wet area where hole is to be drilled.
C. (1) Small holes can be drilled through a wet sponge or
shaving cream. See C(2) for alternative methods. After
drilling, remove shaving cream using wet/dry type HEPA
vacuum.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
“Name of FacLIIty
S7. Level 3
Cut or drill hole in surfacing ACM.
Example
Level 3: A. Drill or cut hole for pipe or duct chase using toots with
or without HEPA filtered dust collection in an enclosure.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 3 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begUn.
Coordinate this work with proper 0 & M work practice for accessing type
of ceiling present in work area. See Work Practices Si, Mu, M13 or
M25. Appendix G to OSHA regulation 29 CFR 1926.58 states: “The
training program for the maintenance engineering staff should describe
methods of handling asbestos-containing materials as well as routine
maintenance activities that are prohibited when asbestos-containing
materials are involved. For example, maintenance staff employees should
be instructed: Not to drill holes in asbestos-containing materials”.
Work Practice
30
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S7. Level 3...continued
(2) If a wet sponge or shaving cream Is not appropriate or
adequate, scrape away surfacing to at least 1/2” [ 13 mm]
beyond where hole is needed. Keep the hose of an
operating HEPA vacuum within 6” [ 150 mm] of where
surveying Is occurring. Adequately wet, any dust or
debris generated. Drill surveying area and hole through
substrate after ACM Is removed.
D. Place HEPA vacuum hose near or through hole and rim for several
mInutes to clean air on backsIde of surface.
7. A. If hole Is drill d from top side of deck, adequately set ACM on
underside and Install enclosure below ACM on underside that will
catch any falling debris, Including material from hole (such as a
concrete cylinder). (If hole Is drilled from underside, see step B).
Drill hole through surface. Adequately wet drilling, area while
drilling. Wet any debris In enclosure on underside, package up
debris and enclosure and dispose of as ACM.
B. If hole Is drilled from underside of deck, provide an enclosure on
top side where hole will penetrate deck and follow steps 6A, 6B,
6C(2), and 6D.
8. Let HEPA vacuum run for at least 15 minutes to clean air in enclosure.
9. Perform maintenance work and clean-up and tear-down steps on Level 3
checklist to complete work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
“Name of Facility 31
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S8. Summary
Replace bulbs in light fixture attached to or in surface finished with
ACM.
Summary This work practice covers proceduresfor replacing light bulbs in a fixture
attached to a surface finished with ACM. Light fixtures attached to or in
surfaces finished with ACM can cause damage to ACM if the fixtures are
moved during maintenance work.
Examples Level 1: A. Replace bulbs in recessed or pendant mount light
fixtures attached to an asbestos-containing decorative
texture finish or acoustical plaster ceiling where
disturbance of ACM is unlikely.
B. Replace bulbs in fixtures mounted on fireproofed
surface where disturbance of ACM is unlikely.
Related Work Practices
S5 - Attach item to ceiling finished with ACM.
Sb - Repair damaged surfacing ACM.
S13 - Access into contaminated light fixture.
Worker Recommendations
One worker is usually sufficient. Two or more workers may be
efficiency or for additional health and/or safety considerations.
monitoring training might be required This person can be a worker.
needed to increase
A person with air
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
Name of Fadlllty
32
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S8. Level I
Replace bulbs in light fixture attached to or in surface finished
with ACM.
Examples
:
Level
1: A. Replace bulbs in recessed or pendant mount light
fixtures attached to an asbestos-containing decorative
where
texture finish or acoustical plaster ceiling
disturbance of ACM is unlikely.
.
B Replace bulbs in fixtures mounted on fireproofed
surface where disturbance of ACM is unlikely.
Notes
•
This work practice must be used in conjunction with General
Procedure Wi and a Level 1 Worker Checklist. The worker
.
Use
filter
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
needs to be replaced.
Work Practice 1. Perform Pre-work activities on Level 1 checklist.
2. Special tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Replacement bulbs
3. Place tools, equipment and materials needed In work area.
4. Carefully replace light bulbs without Jarring fixture. Clean-up any dust or
debris generated using HEPA vacuum.
5. Perform clean-up and tear-down steps on Level 1 checklist to complete
work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
“Name of Facility’ 33
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S9 . Summary
Clean room with exposed surfaces finished with ACM.
Summary This work practice covers the procedures for cleaning a room with exposed
surfaces finished with ACM. This room has been predetermined to not be
contaminated or has previously been cleaned. This is not the procedure
to use if a fiber release has occurred. See related work practices below.
Examples Level .1: A. Routine cleaning in r
oom with spray-applied acoustical
plaster on walls or
ceilings where there is no visible
dust or debris.
B. Routine cleaning in
mechanical room with exposed
fireproofing in good
condition where there is no visible
dust or debris.
Related Work Practices
.
Sb - Repair damaged surfacing ACM.
T6 - Repair damaged thermal system insulation on
a pipe.
M8 - Clean resilient asbestos flooring.
M29 - Clean up debris from minor fiber release.
Worker Recommendations
One worker.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
34
-------
S9.LeveIl
Clean room with exposed surfaces finished with ACM.
Examples
Level 1: A. Routine cleaning in room with spray applied acoustical
plaster on walls or ceilings where there is no visible
debris.
B. Routine cleaning .in mechanical room with exposed
fireproofing in good condition where there is no visible
debris.
Notes
This work practice must be used in conjunction ‘with General
Procedure Wi and a Level 1 Worker Checklist. The worker
:
checklist includes tasks that must be performed before these work
practices are begun.
If any debris from ACM is found in an area to be cleaned, notify the APM
or your supervisor. The APM will need to determine whether this work
S
practice is appropriate or if more stringent practices are needed.
Work Practice i. Tools, equipment and materials: Standard cleaning equipment and
materials.
2. Clean area using standard cleaning methods. Avoid contact with any ACM
materials that could be damaged during cleaning. The APM will select the
appropriate work practice and personnel to clean up any debris from ACM.
The following precautions should be observed when working around the
ACM:
A). Do not bump ACM with vacuum cleaners, broom handles, mop
handles or similar objects. Do not exhaust vacuum cleaners
toward ACM.
B). Do not brush ACM surfaces with a broom or similar objects to
remove cobwebs or other items attached to ACM.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
‘Name of FacIlity 35
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SlO. Summary
Repair damaged surfacing ACM.
Summary This work practice covers the procedures for repairing small amounts of
damaged surfacing ACM, such as acoustical plaster or fireproofing. The
procedure assumes that the damage is in isolated areas not greater in size
than the OSHA small scale, short duration project limits.
Examples Level 1: A. Repair emaIl hole in acoustical plaster ceiling or ‘wall
without disturbing surrounding plaster.
B. Repair small gouged area in asbestos-containing
decorative texture finish without disturbing surrounding
finish.
Level 2: A. Repair gouge marks in acoustical plaster ceiling where
a small amount of damaged ACM is present.
B. Repair small area of delaminated acoustical plaster in
good condition.
Level 3: A. Install fire rated enclosure over small area of damaged
fireproofing.
B. Trowel-on fireproofing to repair small water damaged
area.
C. Repair delaminated plaster in fair condition.
Related Work Practices
S2 - Attach component to an ACM finished surface that is above a ceiling.
S5 - Attach item to ceiling finished with ACM.
Worker Recommendations
One worker is usually sufficient for Level I and Level 2. Two workers for Level 3. More
workers may be needed to increase efficiency or for additional health and/or safety
considerations. A person with air monitoring training might be required. This person can
be• a worker.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
‘Name of FacIlity’ 36
-------
Sb. Level 1
Repair damaged surfacing ACM.
Examples Level
1: A. Repair small hole in acoustical plaster ceiling or wall
without disturbing surrounding plaster.
•
B. Repair small gouged area in asbestos-containing
decorative texture finish without disturbing surrounding
.
• finish.
Notes
‘
This ‘work practice must be used in conjunction with General
Procedure W1 and a, Level I Worker Checklist... The worker
.
checklist inclUdes tasks that must be performed before these work
prabtices are begun.
Work Practice 1. Perform pre-work activities on Level I checklist.
2. , Additional tools, equipment and materials: (see General
Procedure Wi for standard tools, equipment and materials
list).
Non-ACM caulking materials & tools
3. Place tools, equipment and materials needed in work area.
4. ‘ Repair damaged area using non-ACM caulking without
disturbing ACM. Do not scrape or sand existing ceiling.
5. Perform clean-up and tear-down steps on Level I checklist to
complete work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
37
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SlO. Level 2
Repair damaged surfacing ACM.
Examples Level 2: A. Repair gouge marks in acoustical plaster ceiling
a small amount of damaged ACM is present.
B. Repair small area of delaminated acoustical plaster
good condition.
Notes
This work practice must be used in conjunction with General
Procedures WI, W9and a Level 2 Worker Checklist. The worker
checklist includes. tasks:that must be performed before these work
practices are begun.
Work Practice 1. Perform pre-work actMties on Level 2 checidist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Small stiff-bladed scraper
Non-ACM repair materials & tools
3. Prepare work area with drop cloth. See General Procedure W9.
4. Place tools, equipment and materials needed onto drop cloth.
5. Mist any damaged surfacing using garden sprayer containing amended
water and allow water to soak in for several minutes.
6. With HEPA’vacuum’within several inches of damaged area, remove any
loose material by hand or with scraper. Collect material in disposal bags
as it is removed. Remove material around edges of damaged area until
well-adhered material is found, but do not remove beyond area protected
by drop cloth. Mist removal area during removal of damaged material.
7. Repair damaged area using non-ACM and perform clean-up and tear-down
steps on Level 2 checklist to complete work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
‘Name of FacIlity’ 38
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SlO. Level 3
Repair damaged surfacing ACM.
Examples Level 3: A. Install fire rated enclosure over small area of damaged
fire proofing.
B. Trowel-on fireproofing to repair small water damaged
area.
C. Repair delaminated plaster in fair condition.
Notes This work . practice must be used in conjunction with a Worker
Checklist for Level 3 Work. Practices. General Procedures Wi and
W9 are used.
The checklist includes tasks that must be performed before• these work
practices are used.
Coordinate this work with proper 0 & M work practice for accessing type
of ceiling present in work area. See Work Practices, SI, Mu, M13 or
M25. If ACM is in poor condition, abatement may need to be considered
for the damaged area.
Work Practice 1. Perform pre-work activities on Level 3 checklist.
2. AdditIonal tools, equipment and materials: (See General Procedure WI for
standard tools, equipment and materials list).
Small stiff-bladed scraper
Non-ACM repair materials & tools
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system and/or HEPA filtered local exhaust ventilation.
See General Procedure W9.
4. Place tools, equipment and materials needed Into enclosure. Include a
HEPA vacuum inside enclosure for use during repair work. If access
above ceiling Is required, obtain access using O&M work practice selected
(see note above step 1).
5. Adequately wet area of damaged surfacing using garden sprayer
containing amended water and allow water to soak in for several minutes.
6. With HEPA vacuum within several Inches of damaged area, remove any
loose material by hand or with scraper. Collect material In disposal bags
as It is removed. Remove material around edges of damaged area until
well-adhered material Is found, but do not remove beyond area protected
inside enclosure. Mist removal area during removal of damaged material.
7. Repair damaged area using non-ACM materials.
8. Perform clean-up and tear-down steps on Level 3 checklist to complete
work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
‘Name of FaclIit 39
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S.11 . Summary
Accessing through an ACM finished surface.
Summary This work practice covers the procedures for opening access doors (such
as those used in a wall or ceiling to access valves or dampers) in ACM
finished surfaces such as acoustical plaster or fireproofing.
Examples Level 1: A. Open access door in acoustical plaster ceiling that ha
been opened before. Ceiling or wall is in good
condition and debris’ is not likely on door.
Level 2: A. Open access door in acoustical plaster ceiling where
ACM is in fair’ condition and may be disturbed.
Level 3: A. Open access door that has surfacing material on
flanges that will be disturbed when door is opened.
B. Open access door in acoustical plaster or fireproofed
surface where ACM is in poor condition or a significant
amount of ACM debris may be present on back side of
door.
‘
Related Work Practices
S5 -
Attach
item to ceiling finished with ACM.
S6 -
Repair
or replace item in surface finished
with
ACM.
S7 -
Cut or
drill hole in Surfacing ACM.
Worker Recommendations
One worker for Level 1 work. One or two workers for Level 2 depending upon safety and
efficiency considerations. Two workers for Level 3. A person with air monitoring training
might be required. This person can be a worker.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
NName of FacThty 40
-------
Sli . Level I
Accessing through an ACM finished surface.
Example Level 1: A. Open access door in acoustical plaster ceiling or wall
that has been opened before. Ceiling or wall is in
good condition and debris is not likely on door.
Notes
This work practice must be used in conjunction with General
Procedure Wi and a Level I Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice 1. Perform pre-work actMties on Level 1 checklIst.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Sponge
3. Place tools, equipment and materials needed in work area.
4 Unlatch door and open carefully.
5. Perform maintenance work required above or behind access door and
slowly close door until it is secured In place.
6. Complete applicable steps on Level 1 checklist to complete work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
41
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Sil . Level 2
Accessing through an ACM finished surface.
Example
Level
.
2: A. Open access door in acoustical plaster ceiling where
ACM is in fair condition and may be disturbed.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice 1. Perform pre-work actMtles on Level 2 checklIst.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Sponge
3. Prepare work area with drop doth. See General Procedure W9.
4. Place tools, equipment and materials needed onto drop cloth.
5. Using sponge or sprayer, wet any ACM on access door flanges that may
be disturbed and allow water to soak in for several minutes.
6. Unlatch door and open door 1/4” to 1/2” [ 6mm to 13mm]. HEPA vacuum
around edges of door. Slowly open door and HEPA vacuum any debris
on door or any ACM disturbed while opening door.
7. Perform maintenance work required above or behind access door and then
slowly close door until It Is secured In place.
8. Perform clean-up and tear-down steps on Level 2 checklist to complete
work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
‘Name of } aC1lttV’ 42
-------
SlI , Level 3
Accessing through an ACM finished.
Examples
Level 3: A. Open access door that has surfacing material on
flanges that will be disturbed when door is opened.
B. Open access door in acoustical plaster or fireproofed
surface where ACM is in poor condition or ACM
may be present on back side of door.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 3 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
•
Coordinate this work with proper 0 & M work practice foràccessing type
of ceiling present in work area. See Work Practices Si, Mu, M13 or
M25.
Work Practice 1. Perform pre-work activities on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Sponge
Small stiff-bladed scraper -
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system and/or HEPA filtered local exhaust ventilation.
See General Procedure W9.
4. Place tools, equipment and materials needed Into enclosure. Include a
HEPA vacuum inside enclosure for vacuuming areas above ceiling.
5. Enter enclosure and use sponge or sprayer to wet any ACM on access
door flanges that may be disturbed. Allow water to soak In for several
minutes.
6. If door has not been previously opened, cut around perimeter of door
using utility knife and operating HEPA vacuum within several Inches of
cutting area.
7. Adequately wet any loose ACM on door edges and frame, remove using
scraper, and place ACM and debris Into ACM disposal bags.
8. Perform maintenance work required above or behind access door.
9. Slowly close door until it is secured In place.
10. Perform clean-up and tear-down steps on Level 3 checklist to complete work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
“Name of FacIlity 43
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S12. Summary
Painting surfacing ACM.
Summary This work practice describes the work required to paint small amounts of
surfacing ACM, such as acoustical plaster or a decorative texture finish.
Paint àoats should be as thin as possible to prevent delamination of
• surfacing that may be caused by painting. This work may need to be
treated as abatement work depending upon the type and condition of the
surfacing.
• Depending upon the type, condition and friability of the ACM, this work may
need to be treated as an abatement activity instead of 0 & M work.
Examples Level 1: A. Repaint previously painted asbestos-containing
acoustical plaster in good condition. No preparation of
the surface is required.
Level 2: A. Paint asbestos-containing decorative texture finish that
has not been previously painted.
Level 3: A. Paint asbestos-containing acoustical plaster that has
not been previously painted.
B. Paint asbestos-containing fireproofing.
Related Work Practices
Sb -. Repair damaged surfacing ACM.
Worker Recommendations.
One worker for Level 1 and Level 2. Two workers for Level 3. A person with air
monitoring training might be required. This person can be the worker.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
‘Name otFacThty
-------
S12. Level I
Painting surfacing ACM.
Example
.
Level 1: A. Repaint previously painted asbestos-containing
acoustical plaster in good condition. No preparation of
the surface is required.
Notes
This work practice must be used in conjunction with General
.
Procedure WI, W9 and a Level 1 Worker Checklist. The worker
checklist: includes tasks that must be performed before these work
practices are begun.
Use
filter
Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
needs to be replaced.
Work Practice 1. Perform pre-work aótivities on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard.tools, equipment and materials list).
Paint, rollers or low pressure airless sprayer, and other painting
equipment.
3. Prepa e work area with drop cloth. See General Procedure W9.
4. Place tools, equipment and materials needed on drOp cloth.
5. Paint ceiling using sprayer or rollers. If rollers are used, try to contact
each area of the ceiling only once to avoid damage to ACM.
6. When painting is completed, clean up any loose debris using wet wiping
and/or HEPA vacuuming, and roil up drop cloth. Dispose of paint rollers
as ACM.
7. Perform clean-up and tear-down steps on Level 1 checklist to complete
work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
fflA:thP.fl 1litV ’ 45
-------
S12. Level 2
Painting surfacing ACM.
Example
Level 2: A. Paint asbestos-containing decorative texture finish that
has not been previously painted.
Notes
•
.
This work practice must be used in conjunction with General
Procedures W1,W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice 1. Perform P re-work actMties on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard toots, equipment and materials list).
Paint, rollers or low pressure airless sprayer, and other painting
equipment.
3. Prepare work area with drop cloth. See General Procedure W9.
4. Place tools, equipment and materials needed onto drop cloth.
5. Paint ceiling using sprayer or rollers. If rollers are used, try to contact
each area of the ceiling only once to avoid damage to ACM.
6. When painting is completed, dean up any loose debris using wet-wiping
and/or HEPA vacuuming and roll up drop cloth. Dispose of paint rollers
as ACM.
7. Perform clean-up and tear-down steps on Level 2 checklist to complete
work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
. . 46
-------
S12.LeveI3
Painting surfacing ACM.
Examples
Level 3: A. Paint asbestos-containing acoustical plaster that has
not been previously painted.
B. Paint asbestos-containing fireproofing.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 3 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
•
Coordinate this work with proper 0 & M work practice for accessing type
of ceiling present in work area. See Work Practices Mu, M13 or M25.
Work Practice 1. Perform Pre-work actMties on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools; equipment and materials list).
Paint, and rollers or low pressure airless sprayer, and other
painting equipment.
3. Prepare work area with drop cloth, erect mini-endosure (or enclose entire
room) and set up negative pressure system. See General Procedure W9.
4. Place tools, equipment and materials needed Into enclosure.
5. Enter enclosure and paint ceiling as follows:
A. For acoustical plaster, use rollers or sprayer. If rollers are used,
try to contact each area of the ceiling only once to avoid damage
to ACM. -
B. For fireproofing, use airless sprayer only.
6. When painting Is completed, wet drop cloth with amended water, roll up
and dispose of as ACM. Use HEPA vacuum and/or wet-wiping to clean
up any dust or debris under drop cloth. Dispose of rollers as ACM.
7. Perform clean-up and tear-down steps on Level 3 checklist to complete
work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
UName of FacilIty 47
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S13. Summary
Accessing a contaminated light fixture.
Summary This work practice covers procedures for accessing into a contaminated
light fixture. The fixture might be attached to or in a surface finished with
ACM, or be installed below surfacing ACM. Light fixtures attached to or in
surfaces finished with ACM can cause damage to ACM if the fixtures are
moved during maintenance work.
Examples Level 2: A. Replace bulbs in recessed fixtures where ACM
V surfacing material debris is visible inside fixture.
B. Replace bulbs in pendant mount fixture where ACM
debris is present inside or on top of fixture.
Level 3: A. Replace bulbs in fixtures where surfacing ACM will be
disturbed.
B. Replace bulbs in fixtures recessed in acoustical plaster
ceiling located in a high ceiling public space.
Related Work Practices
‘
S5 -
Attach item to ceiling finished with ACM.’
S8 -
Replace bulbs in light fixture attached to
or in surface
finished
‘
with
ACM.
Sb - Repair damaged surfacing ACM.
Worker Recommendations
One worker is usually sufficient. ‘Two or more workers may be needed to ‘increase
efficiency or for additional health and/or safety considerations. A person with air
monitoring training might be required. This person can be a worker.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
“Name of FacUlty 48
-------
S13. Level 2
Accessing a contaminated light fixture.
Examples
Level 2: A. Replace bulbs in recessed fixtures where ACM
surfacing material debris is visible inside fixture.
B. Replace bulbs in pendant mount fixture where ACM
debris is present inside or on top of fixture.
Notes
This work practice must be used in conjunction with General
Procedures Wi , ‘W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice 1. Perform Pre-work actMties on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Replacement Bulbs
3. Prepare work area with drop cloth. See General Procedure W9.
4. Place tools, equipment and materials needed on drop cloth.
5. Wet wipe exposed surfaces of fixture.
6. Carefully replace light bulbs without Jarring fixture. clean up any dust or
debris generated using HEPA vacuum.
7. Perform clean-up and tear-down steps on Level 2 checklist to complete
work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
Name of FacThty 49
-------
S13. Level 3
Accessing a contaminated tight fixture.
Examples
Level
3: A. Replace bulbs in recessed fixtures where surfacing
ACM will be disturbed.
•
B. Replace bulbs in fixtures recessed in acoustical plaster
ceiling located in a high ceiling public space.
Notes
.
:
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 3 Worker Checklist; The worker
checklist includes tasks that must be• performed before these work
practices are begun.
Work Practice 1. Perform Pre-work actMties on Level 3 checklist.
2. AdditIonal tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Replacement bulbs
3. Prepare work area with drop cloth and set up HEPA filtered local exhaust
ventilation. See General Procedure W9.
4. Place tools, equipment and materials needed into work area.
5. Wet wipe the exposed surfaces of the fixture.
6. With HEPA filtered local exhaust ventilation operating, carefully replace light
bulbs without Janing fixture. clean up any dust or debris generated using
HEPA vacuum and/or wet wiping.
7. Perform clean-up and tear-down steps on Level 3 checklist to complete
work.
SURFACING ACM . ASBESTOS O&M WORK PRACTICES
50
-------
V
-------
Section V. Thermal Systems Insulation (TSI)
Work Practices
Delete work practices that have been deemed not applicable to this report according to specific
conditions lnthefaclIity This may mean deleting only parts of the section or ould require deletion
of whole sections.
Example
110 23 Clean up asbestos-containing debris In crawispace
ortunnel .. * ...... . NOTAPPUCABLE
Read all work practices carefully and revise accordingly
When Information Is deleted in one section 1 make certain It Is deleted through-out the n ànuaI and
any other practices. . . . . . . .. . . .
Also, edit page numbering to reflect these changes, If applicable. DO NOT renumber any
procedures or practices. . .
Work Practices Location Illustration . . . 3
Code Levels Description
TI 2 3 Remove asbestos-containing insulation on exposed pipe for
maintenance work 4
T2 2 3 Remove asbestos-containing insulation on pipe above ceiling
for maintenance work 7
T3 2 3 Remove asbestos-containing insulation on exposed pipe in
elevated location, for maintenance work 10
T4 3 Remove asbestos-containing insulation on pipe in occupied
area for maintenance work 13
T5 2 3 Repair damaged asbestos-containing insulation on a pipe ... 15
T6 2 3 Repair damaged asbestos-containing insulation on a boiler,
ductorflue 19
17 2 3 Install device in or access surface of asbestos-containing
insulation on a pipe, boiler, duct or flue 23
T8 2 3 Remove asbestos-containing duct insulation above ceiling for
maintenance work 27
T9 2 3 Remove asbestos-containing insulation inside HVAC unit for
maintenance work 30
T10 2 3 Clean up asbestos-containing debris in crawispace or
tunnel 33
The accompanying diagram illustrates typical applications of these work practices.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
1
-------
The following general notes should be reviewed by users of the TSI work practices:
Users should review General Procedure Wi 7 (glovebag removal procedures) and
be properly trained in the use of glovebags. Glovebags are used in most of the
TSI work practices. Glovebags used should be the appropriate type for the size
of the task, orientation of piping (or other materials), temperature of surface and
other relevant factors. Other types of prefabricated contaminant devices that may
be used in place of glovebags are briefly discussed in Wi 7.
2. Materials that have had TSI removed should be sprayed with a lockdown
encapsu!ant in accordance with General Procedure WI 1.
3. Many of the TSI work practices recommend the use of two workers. Safety
considerations for many activities, as well as efficiency considerations will often
necessitate the use of two workers. Two workers are recommended for work
practices using mini-enclosures. The 0 & M program may also require that two
workers be used for glovebag removal work.
4. General Procedure APMIO discusses emergency work and/or dry removal that
might be necessary under certain conditions, such as removing insulation adjacent
to an activated power panel to make emergency repairs on a critical piece of
equipment. Review and comply with all applicable regulatory requirements.
5. Some of the TSI Work Practices specify attaching a glovebag over duct tape
applied around a pipe. If the pipe insulation surface is smooth, a flexible metal
sleeve might be wrapped around the pipe in lieu of duct tape if an adequate seal
can be obtained. This allows removal of the metal sleeve at the end of the work
rather than leaving duct tape in place around the pipe (duct tape is recommended
to be left in place because removal of duct tape can damage ACM insulation).
6. Careful work practices should be the primary means used to prevent releases of
asbestos fibers during O&M work. Such practices include control measures such
as wetting and local exhaust that control or collect fibers at the source. The goal
of all asbestos O&M work should be to prevent any exposure of the worker and
unnecessary contamination of the work area, drop cloths, mini-enclosures and
other secondary control devices. Mini-enclosures should never be used to excuse
sloppy work or creation of “bigger” messes.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
c i c ihj’ 2
-------
Figure 8
The following illustration of O&M work practices for thermal systems insulation materials
is an excellent reference document in determining relevant practices for your specific
building. As stated elsewhere in this manual, if any work practice is deleted, do not
renumber the remaining list; just note “not applicable”. Such a foot note could also be
made to the following illustration.
This illustration is not on diskette. However a copy of Figure 8 is provided in the front
pouch of this notebook for your use. A copy of this sheet will need to be sent through
the printer to add the title and footer which is found on the first page of the TSI.wpf file.
-------
Figure 8:
Thermal Systems Insulation Location Illustration
THERMALSYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
3
-------
Work Practices (for EPA Standard Methods )
As particular building conditions warrant, the following work practices of the EPA Standard
Methods should be modified. Modifications maybe as great as deleting the entire section
because thermal systems insulation type materials are not present in the building. It may
be only necessary to delete a particular practice, or to add or delete a recommended
level for the practice. One suggested modification is to revise or add examples that are
specific to the facility to better orient O&M workers to the building’s O&M program.
Modifications are encouraged as a means of tailoring this master guidance document to
your specific facility.
Modifications to “Related Work Practices” and “Worker Recommendations” of the NIBS
document may also be necessary.
-------
TI . Summary
Remove asbestos-containing insulation on exposed pipe for
maintenance work.
Summary This work practice covers the procedures for removing small amounts of
asbestos-containing insulation on an exposed pipe in an unoccupied area
such as a boiler or mechanical room. The procedure assumes that the pipe
insulation is accessible from a ladder or scaffold less than 10 feet (3 m) in
height.
Examples Level 2.: A. Removal of I standard glovebag of insulation in good
condition to make a new connection to an existing
pipe. . -
B.. Removal of insulation in good condition to replace a
valve.
Level 3: A. Removal of pipe insulation in poor condition, or metal
or waterproofed jacketed insulation.
B. Removal of pipe insulation that will not fit in a glovebag,
or removal work on hot piping (>120°).
C. Work on hot piping may be reduced to Level 2 with the
use of specialized or high-temperature glovebags or
chambers.
Related Work Practices .
T2 - Remove asbestos-containing insulation on pipe above panel ceiling for
maintenance work
T3 - Remove asbestos-containing insulation on exposed pipe in elevated location for
maintenance work
T4 - Remove asbestos-containing insulation on pipe in occupied area for maintenance
work
T5 - Repair damaged system insulation on a pipe
17 - Install device in asbestos-containing insulation on a or excess surface of, pipe,
boiler, duct or flue
Worker Recommendations
Two workers. A person with air monitoring training might be required. This person can
be a worker.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
1 t’ilth? 4
-------
Ti . Level 2
Remove asbestos-containing insulation on exposed pipe for
maintenance work.
Examples
Level 2: A. Removal of I standard glovebag of insulation in good
condition to make a new connection to an existing
pipe.
B. Removal of insulation in good condition to replace a
valve.
Notes
This work practice must be used in conjunction with General Procedures
Wi, W9, W17 and a Level 2 Worker Checklist. The worker checklist
includes tasks that must be . perIormed before these work ‘practices are
begun.
Work Practice 1. Perform P re-work activities on Level 2 checklist
2. Additional tools, equipment and materials: (see general procedure Wi for
standard tools, equipment and materials list).
Glovebags
Replacement non-ACM insulation If required
Pipe repair materials and tools
3. Prepare work area with drop cloth. See general procedure W9.
4. Place tools, equipment and materials needed onto drop cloth.
5. Place all needed tools Inside of giovebag and attach glovebag to area of
pipe ‘Insulation to be removed. See general procedure Wi 7.
6. Remove ACM using glovebag procedures. Adequately wet removal area
frequently during removal of the bulk mateiial. Seal exposed ends of
Insulation before removing glovebags.
7. Perform maintenance work and clean-up and tear-down steps on Level 2
checklist to complete work.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
5
-------
Ti . Level 3
Remove asbestos-containing insulation on exposed pipe for
maintenance work.
Examples Level 3:
A.
Removal of pipe insulation in poor condition, or metal
or waterproofed jacketed insulation.
B.
C.
•
Removal of pipe insulation that will not fit in a glovebag,
or removal work on hot piping (>1200).
Work on hot piping may be reduced to Level 2 with the
use of specialized or high-temperature glovebags or
chambers.
Notes
This work practice must be used in conjunction with General Procedures
Wi, W9, W17 and a Level 3 Worker Checklist. The worker checklist
includes tasks that must be performed before these work practices are
begun.
Work Praclice
1. Perform Pre-work actMtles on Level 3 checklist.
2. AdditIonal tools, equipment and materials: (See general procedure WI for
standard tools, equipment and materials list).
Glovebags
Replacement non-ACM Insulation, if required
Pipe repair materials and tools
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system. See general procedure W9.
4. Place tools, equipment and materials needed Into enclosure. Include a
HEPA vacuum InsIde enclosure for vacuuming areas above ceiling.
5. Enter enclosure and place all needed tools inside of giovebag, (if pipe will
fit in a glovebag) and attach giovebag to area of pipe Insulation to be
removed. Remove ACM using glovebag procedures. See general
procedure W17. If pipe is hot or will not fit in a glovebag, set up HEPA
filtered local exhaust ventilation and follow glovebag removal sequence
Inside of mini-enclosure.
6. Perform maintenance work and clean-up and tear-down steps on Level 3
checklist to complete work.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
uName ot Fac f
6
-------
T2. Summary
Remove asbestos-containing insulation on pipe above ceiling for
maintenance work.
Summary This work practice covers the procedures for removing small amounts of
asbestos-containing insulation on a pipe located above a lay-in panel
ceiling.
Examples Level 2: A. RemOve pipe insulation above lay-in panel ceiling
where insulation is in good condition, e.g., pipe leak.
B. Repair pipe leak above a non-ACM plaster or drywall
ceiling.
C. Attach branch line to existing steam line above non-
• ACM plaster ceiling.
Level 3: A. Remove section of pipe insulation in poor condition for
fitting replacement.
B. Remove section of pipe insulation in poor condition, or
with metal jacket, or waterproofed to replace a section
of pipe.
C. Remove ACM insulation which is damaged and in poor
condition from steam line above non-ACM plaster
ceiling.
0. Remove insulation in poor condition on a pipe to repair
leak above a non-ACM drywall ceiling.
Related Work Practices
S2 - Observation or work in ceiling plenum space where exposed surfacing ACM is
present
T3 - Remove asbestos-containing insulation on exposed pipe in elevated location for
maintenance work
Ml I - Replace asbestos-containing ceiling panels in lay-in ceiling system.
M12 - Replace asbestos containing ceiling tiles attached with adhesive
M13 - Replace asbestos containing ceiling tiles in spline ceiling system
M29 - Clean up debris from minor fiber release
Worker Recommendations
Two workers. A person with air monitoring training might be required. This person can
be a worker.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
7
-------
T2. Level 2
Remove asbestos-containing insulation on pipe above lay-in
panel ceiling for maintenance work.
Example
Level 2: A. Remove pipe insulation above lay-in panel ceiling
where insulation is in good condition, e.g., pipe leak.
Notes
This work practice must be used in conjunction with General Procedures
Wi, W9, W17 and a Level 2 Worker Checklist. The worker checklist
includes tasks that must be performed before these work practices are
begun.
Coordinate work with proper 0 & M work practice for accessing type of
ceiling present in work area. See Work Practice Mu, M13, or 1
M25.
Work Practice
1. Perform Pre-work activities on Level 2 checklist.
2. Additional tools, equipment and materials: (see general procedure Wi for
standard tools, equipment and materials list).
Scraper (2-3 [ 50-75 mm] wide stiff blade)
Stiff nylon bristle brushes
Replacement non-ACM insulation if required
Pipe repair materials and tools
Giovebags
3. Prepare work area with drop cloth. See general procedure W9.
4. Piace tools, equipment and materials needed onto drop cloth.
5. ObtaIn access above ceiling using 0 & M work practice selected (see note
above step 1).
6. Pick up any bulk debris withIn reach on top of ceiling and place into
disposal bag. HEPA vacuum top side of ceiling within reach from access
hole.
7. Place all tools needed Inside giovebag and attach glovebag to area where
pipe Insulation will be removed. See general procedure W17.
8. Remove ACM using giovebag procedures. Adequately wet removal area
frequently during removal of the bulk material.
9. Perform maintenance work and clean-up and tear-down steps on Level 2
checklist to complete work.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
8
-------
T2. Level 3
Remove asbestos-containing insulation on pipe above lay-in
panel ceiling for maintenance.
Examples
Level 3: A. Remove section of pipe insulation in poor condition for
fitting replacement.
B. Remove section of pipe insulation in poor condition, or
with metal jacket, or waterproofed to replace a section
of pipe.
Notes
This work practice must be used in conjunction with General Procedures
Wi, .W9 and W17 and a Level 3 Worker Checklist The worker checklist
includes tasks that must be performed before these work: practices are
begun.
Note: Coordinate this work with proper 0 & M work practice for accessing
type of ceiling present in work area. See Work Practice Mu, M13, M25.
Work Practice
1. Perform Pre-work actMties on Level 3 checklist.
2. Additional tools, equipment and materials: (See general procedure Wi for
standard tools, equipment and materials list).
Tools and Equipment:
Scraper (2-3 [ 50-75 mm] wide stiff blade)
Stiff nylon bristle brushes
Replacement non-ACM Insulation If required
Pipe repair materials and tools
Glovebags
3. Prepare work area with drop cloth, erect mIni-enclosure and. set up
negative pressure system. See general procedure W9.
4. Place tools, equipment and materials needed into enclosure. Include a
HEPA vacuum Inside enclosure for vacuuming areas above ceiling.
5. Enter enclosure and obtain access above ceiling using 0 & M work
practice selected (see note above step 1.)
6. Pick up any bulk debris within reach on top of ceiling and place into
disposal bag.
7. HEPA vacuum top side of ceiling within reach from access hole.
8. If present, remove any metal Jacket material over Insulation to be removed.
9. Place all tools needed Inside glovebag and attach glovebag to area of pipe
Insulation to be removed. See general procedure W17.
10. Remove ACM using glovebag procedures. Adequately wet removal area
frequently during removal of the bulk material.
ii. Perform maintenance work and clean-up and tear-down steps on Level 3
checklist to complete work.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
9
-------
T3 . Summary
Remove asbestos-containing insulation on exposed pipe in
elevated location for maintenance work.
Summary This work practice covers the procedures for removing small amounts of
asbestos-containing insulation on exposed piping in elevated locations
(approximately 10 feet [ 3 m] or more above floor level). This procedure
uses a scaffold as a work platform to reduce the safety hazards from
working from a tall ladder.
Examples Level 2: A. Repair. small pipe• leak in boiler room
B. Install flew ceiling mounted hot water heating unit in
warehoUse space fed from existing piping. -.
Level 3: A. Remove insu!ation on 1281 (305 mm) fitting in poor
condition, 15 feet (4.5 m) above floor level to repair
leak in steam line.
B. Remove insulation on pipe adjacent to steel grate
catwalk 30 feet (9 m) above floor in boiler room.
C. Work practice may be Level 2 if fitted or specialty
glovebags are used.
Relat
ed Work Practices
T2 -
Remove asbestos-containing insulation
on
pipe above panel
ceiling for
maintenance work
.
T4 -
Remove asbestos-containing insulation on
pipe
in occupied area for
maintenance
work
Worker Recommendations
• Two workers. A person with air monitoring training might be required. This person can
be a worker.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
10
-------
T3. Level 2
Remove asbestos-containing insulation on exposed pipe in
elevated location for maintenance work.
Examples
Level 2: A. Repair small pipe leak in boiler room
B. Install new ceiling mounted hot water heating unit in
warehouse space fed from existing piping.
Notes
This work practice must be used in conjunction with General Procedures
WI, W9, W17 and a Level 2 Worker Checklist. The worker checklist
includes tasks that must be performed before these work practices are
begun.
Work Practice 1. Perform Pre-work activities on Level 2 checklIst.
2. Additional tools, equipment and materials: (see general procedure Wi for
standard tools, equipment and materials list).
Scraper (2-3 [ 50-75 mmj wide stiff blade)
Stiff n 1on bristle brushes
Replacement non-ACM Insulation if required
Pipe repair materials and tools
Glovebags
Non-slip drop cloth
3. Prepare work area with drop cloth. See general procedure W9. Erect
scaffold system using proper OSHA procedures. Care should be taken not
to disturb the ACM.
4. Place tools, equipment and materials needed onto non-slip drop doth on
scaffold system.
5. Place all tools needed inside glovebag and attach giovebag to area where
pipe Insulation will be removed. See general procedure W17.
6. Remove ACM using giovebag procedures. Adequately wet removal area
frequently during removal of the bulk material.
7. Perform maintenance work and clean-up and tear-down steps on Level 2
checklist to complete work.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
NName of FacTht f 11
-------
T3. Level 3
Remove asbestos-containing insulation on exposed pipe in
elevated location for maintenance work.
Examples
Level 3: A. Remove insulation on I 2 (305 mm) fitting in poor
condition, 15 feet (4.5 m) above floor level to repair
leak in steam line.
B. Remove insulation on pipe adjacent to steel grate
catwalk 30 feet (9 m) above floor in boiler room.
C. Work practice may be reduced to Level 2 if fitted or
specialty glovebags are used.
Notes
This work practice must be used in conjunction with General Procedures
Wi, W9, W17 and a Level 3 Worker Checklist. The worker checklist
includes tasks that must be performed before these work practices are
begun.
Work Practice 1. Perform Pre-work activities on Level 3 checklist.
2. Additional tools, equipment and materials: (See general procedure Wi for
standard tools, equipment and materials list).
Scraper (2-3 (50-75 mm] wide stiff blade)
Stiff nylon bristle brushes
Replacement non-ACM Insulation If required
Pipe repair materials and tools
Glovebags
Non-slip drop cloth
3. Prepare work area with drop cloth. Erect scaffold system using proper
OSHA procedures. Care should be taken not to disturb the ACM. Erect
mini-enclosure on top of scaffold system and set up negative pressure
system. See general procedure W9. The top floor layer In enclosure
should be a non-slip drop cloth material.
4. Place tools, equipment and materials needed into enclosure. Include a
HEPA vacuum inside enclosure for vacuuming areas above ceiling.
5. Enter enclosure, place all tools needed inside giovebag and attach
glovebag to area where pipe insulation will be removed. See general
procedure W17.
6. Remove ACM using glovebag procedures. Adequately wet removal area
frequently during removal of the bulk material.
7. Perform maintenance work and clean-up and tear-down steps on Level 3
checklist to complete work.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
Thm dFacU f 12
-------
T4 . Summary
Remove asbestos-containing insulation on pipe in occupied area
for maintenance work.
Summary This work practice covers the procedures for removing small amounts of
asbestos-containing pipe, insulation inside a mini-enclosure located in an
occupied area. This procedure assumes that maintenance work must occur
immediately in an occupied area or work area is occupied 24 hours a day.
Examples Level 3: A. Repair l ak in pipe riser of occupied computer room.
B. Replace damaged insulation on piping in manufacturing
plant during working hours.
Related Work Practices
T2 - Remove asbestos-containing insulation on pipe above ceiling for maintenance work
T3 - Remove asbestos-containing insulation on exposed pipe in elevated location for
maintenance work
Worker Recommendations
Two workers. A person with air monitoring training might be required. This person can
be a worker.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
13
-------
T4.LeveI3
Remove asbestos-containing insulation on pipe in occupied area
for maintenance work.
Examples
Level 3: A. Repair leak in pipe riser of occupied computer room.
B. Replace damaged insulation on piping in manufacturing
plant during working hours.
Notes
This work practice must be used in conjunction with General Procedures
Wi, W9, W17 and a Level 3 Wo&er Checklist. The worker checklist
includes tasks that must be performed before these work practices are
begun
•
If access above ceiling is needed, coordinate this work with proper O&M
work practice for accessing type of ceiling present in work area. See Work
Practices Mu, M13 or M25.
Work Practice 1. Perform Pre-work activities on Level 3 checklist.
2. Additional tools, equipment and materials: (See general procedure Wi for
standard tools, equipment and materials list).
Scraper (2-3 [ 50-75 mm] wide stiff blade)
Stiff nylon bristle brushes
Replacement non ACM insulation If required
Pipe repair materials and tools
Glovebags.
3. Prepare work area with drop cloth, erect mini.enclosure and set up
negative pressure system. See general procedure W9.
4. Place tools, equipment arid materials needed into enclosure. If work must
occur above ceiling, include a HEPA vacuum Inside enclosure for
vacuuming areas above ceiling.
5. Enter enclosure and place all tools needed Inside glovebag. If access
above ceiling is required, obtain access above ceiling using 0 & M work
practice selected (see note above step I). Attach glovebag to area where
pipe Insulation will be removed. See general procedure W17..
6. Remove ACM using glovebag procedures. Adequately wet removal area
frequently during removal of the bulk material.
7. Perform maintenance work and clean-up and tear-down steps on Level 3
checklist to complete work.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
Naui ofFac ity ” 14
-------
T5 . Summary
Repair damaged asbestos-containing insulation on a pipe.
Summary This work practice covers the procedures for repairing small areas of
damaged asbestos-containing insulation.
Examples
Level
2:
A.
Repair small area of impact damage on pipe insulation
B.
in good condition.
Repair minor damage to insulation on a pipe fitting.
Level
3:.
A.
B.
Repair damaged pipe insulation adjacent to operating
HVAC..
Repairdelaminated pipe Insulation in an occupied area.
Related Work Practices
T3 - Remove asbestos-containing insulation on exposed pipe in elevated location for
maintenance work
M29 - Clean up debris from minor fiber release
Worker Recommendations
One worker - Leve! 2. Two workers - Level 3. A person with air monitoring training
might be required. This person can be a worker.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
Fad lky TM 15
-------
T5. Level 2
Repair damaged asbestos-containing insulation on a pipe.
Examples
Level 2: A. Repair small area of impact damage on pipe insulation
in good condition.
B. Repair minor damage to insulation on a pipe fitting.
Notes
This work practice must be used in conjunction with General Procedures
Wi and W9 and a Level 2 Worker Checklist. The worker checklist includes
tasks that must be performed before these work practices are begun.
•
If access above ceiling is needed, coordinate work with proper 0 & M work
practice for accessing type of ceiling present in work area. See Work
.
Practices Mu, M13 or M25.
Work Practice
1. Perform Pre-work actMtles on Level 2 checklist.
2. AdditIonal tools, equipment and materials: (see general procedure WI for
standard tools, equipment and materials list).
Sponge
Non-ACM Insulation patching material
Putty Knife
Lag cloth.
3. Prepare work area with drop cloth. See general procedure W9.
4. Place tools, equipment and materials needed onto drop cloth. If access
above ceiling is required, obtain access above ceiling using 0 & M work
practice selected (see note above step I).
5. Adequately wet area of Insulation to be repaired where appropriate. HEPA
vacuum damaged area to be repaired and any loose debris.
6. Fill In repair area with non-ACM patching material. Dip lag cloth Into water
and squeeze out excess water. Apply lag cloth to area of insulation being
repaired and smooth out using a wet sponge.
7. Perform clean-up and tear-down steps on Level 2 checklist to complete
work.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
16
-------
T5.LeveI3
Repair damaged asbestos-containing insulation on a pipe.
Examples
Level 3: A. Repair damaged pipe insulation adjacent to operating
HVAC.
B. Repair delaminated pipe insulation in an occupied area.
Notes
This work practice must be used in conjunction with General Procedures
WI, W9, WI7 and a Loyal 3 Worker Checklist. The worker checklist
includes tasks that must be performed before these work practices are
begun.
If access above ceiling is needed, coordinate this work with proper 0 & M
work practice for accessing type of ceiling present in work area. See Work
Practices Mu, M13 or M25.
Work Practice
1. Perform Pre-work activities on Level 3 checidlst.
2. Additional tools, equipment and materials: (See general procedure Wi for
standard tools, equipment and materials list).
Scraper (2-3 [ 50-75 mm] wide stiff blade)
Stiff nylon bristle brushes
Sponge
Non-ACM Insulation patching material
Putty Knife
Lag cloth
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system. See general procedure W9.
4. Place toots, equipment and materials needed into enclosure. If work must
occur above ceiling, include a HEPA vacuum inside enclosure for
vacuuming areas above ceiling.
5. Enter enclosure. If access above ceiling Is required, obtain access above
ceiling using 0 & M work practice selected (see note above step 1).
6. If work can be done with a glovebag method, follow procedures below:
A. Install duct tape around area to be repaired.
B. Place tools, equipment and other materials Into glove bag. Attach
giovebag to duct tape using more duct tape.
c. Remove all loose or damaged insulation using giovebag
procedures. See general procedure W17.
D. Remove glovebag leaving duct tape from step 6b above.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
“Name of Fac f
17
-------
T5. Level 3...continued
7. If a glovebag method cannot be effectively utilized, follow procedures
below:
A. Adequately wet material at area to be repaired.
B. Cut out damaged TSI, trimming edges so straight square clean
edges remain. This procedure must only be performed on
adequately wet material, and with a HEPA vacuum nozzle adjacent
to the cutting tool so that any debris or fibers are captured by the
HEPA vacuum.
8. FIll in repair area with non-ACM patching material. Dip lag cloth Into water
and squeeze out excess watqr. Apply lag cloth to area of insulation being
repaired and smooth out using a wet sponge.
9. Perform clean-up and tear-down steps on Level 3 checklist to complete
work.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
18
-------
T6. Summary
Repair damaged asbestos-containing insulation on a boiler, duct
or flue.
Summary This work practice covers the procedures for repairing small amounts of
damaged asbestos-containing thermal systems insulation. The procedures
assume that the area to be repaired is within the OSHA short-scale/short-
duration project limits.
Examples Level 2: A. Repair small area of impact damaged insulation on
duct or flue in good condition.
B. Repair minor damage to boiler insulation
access hatch.
Level 3: A. Repair badly damaged flue or duct insulation.
B. Repair area of water damaged insulation on hot water
tank or boiler.
Related Work Practices
T3 - Remove asbestos-containing insulation on exposed pipe in elevated location for
maintenance work
M29 - Clean up debris from minor fiber release
Worker Recommendations
One worker -
be required.
Level 2. Two workers - Level 3. A person with air monitoring training might
This person can be a worker.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
NName d Fac (
19
-------
T6.LeveI2
Repair damaged asbestos-containing insulation on a boiler, duct
or flue.
Examples
Level 2: A. Repair small area of impact damaged insulation on
duct or flue in good condition.
B. Repair minor damage to boiler insulation around
access hatch.
Notes
This work practice must be used in conjunction with General Procedures
Wi and W9 and a Level 2 Worker Checklist. The worker checklist includes
tasks that must be performed before these work practices are begun.
if access above ceiling is needed, coordinate work with proper 0. & M work
practice for accessing type of ceiling present in work area. See Work
Practices Ml I, M13 or M25.
Work Practice 1. Perform Pro-work actMties on Level 2 checklist.
2. Additional tools, equipment and materials: (see general procedure Wi for
standard tools, equipment and materials list).
Sponge
Non-ACM Insulation patching material
Putty Knife
Lag cloth
3. Prepare work area with drop cloth. See general procedure W9.
4. Place tools, equipment and materials needed onto drop cloth. If access
above ceiling Is required, obtain access above ceiling usIng 0 & M work
practice selected (see note above step 1).
5. Adequately wet area of Insulation to be repaired where appropriate. HEPA
vacuum damaged area to be repaired and any loose debris.
6. Fill in repair urea with non-ACM patching material.
7. Dip lag cloth Into water and squeeze out excess water. Apply lag cloth to
area of insulation being repaired and smooth out using a wet sponge.
8. Perform clean-up and tear-down steps on Level 2 checklist to complete
work.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
20
-------
T6. Level 3
Repair damaged asbestos-containing insulation on a boiler, duct
or flue.
Examples
.
Level 3: A. Repair badly damaged flue or duct insulation.
B. Repair area of water damaged insulation on hot water
tank or boiler.
Notes
This work practice must be used in conjunction with General Procedures
WI, W9, and W17 and a Level 3 Worker Checklist. The worker checklist
includes tasks that must be performed before these work practices are
begun.
If access above ceiling is heeded, coordinate this work with proper 0 & M
work practice for accessing type of ceiling present in work area. See Work
Practices Ml I, M13 or M25.
Work Practice 1. Perform Pre-work activities on Level 3 checklIst.
2. AdditIonal tools, equipment and materials: (See general procedure WI for
standard tools, equipment and materials list).
Scraper (2-3 (50-75 mm] wide stiff blade)
Stiff nylon bristle brushes
Sponge
HEPA vacuum, hose and attachments
Putty Knife
Giovebags
Lag cloth
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system. See general procedure W9.
4. Place tools, equipment and materials needed into enclosure. If work must
occur above ceiling, include a HEPA vacuum inside enclosure for
vacuuming areas above ceiling.
5. Enter enclosure, If access above ceiling is required, obtain access above
ceiling using 0 & M work practice selected (see note above step 1).
6. If work can be done with a glovebag method, follow procedures below:
A. install duct tape around area to be repaired.
B. Place tools, equipment and other materials into glove bag. Attach
giovebag to duct tape using more duct tape.
C. Remove all loose or damaged insulation using giovebag
procedures. See general procedure Wi 7.
D. Remove giovebag leaving duct tape from step 6b above.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
21
-------
T6. Level a..conzinued
7. if a glovebag method cannot be effectively utilized, follow procedures
below:
A. Adequately wet material at area to be repaired.
B. Cut out damaged TSI, trimming edges so straight square clean
edges remain. This procedure must only be performed on
adequately wet material, and with a HEPA vacuum nozzle adjacent
to the cutting tool so that any debris or fibers are captured by the
HEPA vacuum.
C. Place ACM debris Into disposal bags.
8. Remove glovebag and fill in repaIr area with non-ACM patching material.
9. Dip lag cloth Into water and squeeze out excess water. Apply lag cloth to
area of insulation being repaired and smooth out using a wet sponge.
10. Perform clean-up and tear-down steps on Level 3 checklist to complete
work. Leave duct tape Installed in step 6 in place.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
22
-------
T7 . Summary
Install device in, or access surface of, asbestos-containing
insulation on a pipe, boiler, duct or flue. ___________________
Summary This summary covers the removal of small amounts of ACM as required to
install a device (such as a temperature sensor or damper control) in, or
simply to access, the surface of an ACM insulated pipe, boIler, duct or flue.
Examples Level 2: A. Remove ACM in good condition in order to install
energy management system sensors and co ’itrols.
Level 3: A. Drill through insulation using power tools to attach heat
sensor directly on metal flue.
B. Remove damaged insulation in order to attach heat
sensor directly on metal flue.
Related Work Practices
TI - Remove Asbestos-containing insulation on exposed pipe for maintenance work
T4 - Remove Asbestos-containing insulation on pipe in occupied area for maintenance
work
T5 - Repair damaged asbestos-containing insulation on a pipe
Worker Recommendations
One worker. A person with, air monitoring training might be required. This person can
be the worker.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
23
-------
T7.LeveI2
Install device in, or access surface of, asbestos-containing
insulation on a pipe, insulated boiler, duct or flue.
Example
Level 2: A. Remove ACM in good condition in order to install
energy management system sensors and controls.
Notes
This work practice must be used in conjunction with General Procedures
Wi, W9, and W17 and a Level 2 Worker Checklist. The worker checklist
includes tasks that must be performed before these work practices are
begun.
If access above ceiling is. needed, coordinate work with proper O..& M work
practice for accessing type of ceiling present in work area. See Work
Practices Mu, M13 or M25.
Work Practice
I. Perform Pre-work actMties on Level 2 checklist.
2. Additional tools, equipment and materials: (see general procedure WI for
standard tools, equipment and materials list).
Scraper (2-3” [ 50-75 mm] wide stiff blade)
Stiff nylon bristle brushes
Hand drill and drill bits or hole saw
Non-ACM replacement insulation or patching material (if required)
Device to be Installed and related tools
Glovebags
3. Prepare work area with drop doth. See general procedure W9.
4. Place tools, equipment and materials needed onto drop cloth, If access
above ceiling is required, obtain access using 0 & M work practice
selected (See note above step 1).
5. Attach duct tape around area where device will be installed.
6. Place tools needed into glovebag and attach glovebag to duct tape.
7. Remove or penetrate ACM as required using glovebag procedures. See
general procedure W17. Adequately wet removal area frequently during
removal of the bulk material.
8. Install device or perform maintenance. Perform clean-up and tear-down
steps on Level 2 checklist to complete work. Leave duct tape installed In
step 5 in-place.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
24
-------
1. Perform Pre-work activities on Level 3 checklist.
2. Additional tools, equipment and materials: (See general procedure Wi for
standard tools, equipment and materials list).
Scraper (V [ 25 mm] wide blade)
Stiff nylon bristle brushes
Wire cutters
Power drill with HEPA attachment
Hole saw or drill bits
Glovebags
Non-ACM replacement Insulation or patching material (if required)
Device to be Installed and related tools
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system. See general procedure W9.
4. Place tools, equipment and materials needed Into enclosure. If work must
occur above ceiling, include a HEPA vacuum inside enclosure for use
during the work.
5. Enter enclosure. if access above ceiling Is required, obtain access above
ceiling using 0 & M work practice selected (see note above step 1).
6. If work can be done with a glovebag method, follow procedures below:
A. Install duct tape around area to be penetrated or removed.
B. Place tools, equipment and other materials Into glove bag. Attach
giovebag to duct tape using more duct tape.
C. Remove all loose or damaged insulation using giovebag
procedures. See general procedure W17.
D. Remove glovebag leaving duct tape from step 6b above.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
Name c Fac f
T7.LeveI3
Install device in, or access surface of, asbestos-containing
insulation on a pipe, boiler, duct or flue.
Examples
Level 3: A. Drill through insulation using power tools to attach heat
sensor directly on metal flue.
B. Remove damaged insulation in order to attach heat
sensor directly on metal flue.
Notes
This work practice mL.st be used in conjunction with General Procedures
Wi, W9, and W17 and a Level 3 Worker Checklist. The worker checklist
Includes tasks that must be performed before these work practices are
begun.
If access above ceiling is needed, coordinate this work with proper 0 & M
work practice for accessing type of ceiling present in work area. See Work
Practices Mu, M13 or M25.
Work Practice
25
-------
17. Level 3...continued
7. If a glovebag method cannot be effectively utilized, follow procedures
below:
A. Adequately wet material at area to be penetrated or removed.
B. Carefully remove or penetrate ACM. This procedure must only be
performed on adequately wet material, and with a HEPA vacuum
nozzle adjacent to the removal or penetrating tool so that any
debris or fibers are captured by the HEPA vacuum.
8. Install device and perform clean-up and tear-down steps on Level 3
checklist to complete work. Leave duct tape Installed In step 6 In place.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
26
-------
T8 . Summary
Remove asbestos-containing duct insulation above ceiling for
maintenance work.
Summary This work practice describes the procedures for removing small amounts
of asbestos-containing duct insulation above a ceiling. Ceiling might be
ACM or non-ACM. Ceiling might be plaster, drywall or lay-in.
Examples Level 2: A. Remove small amount of damaged insulation around
damper control to permit insulation repair.
B. Replace Variable Air Volume (VAV) box on ACM
insulated duct.
Level 3: A. Remove damaged duct insulation so that new branch
lines can be tied to existing duct system for sub-
divided office space.
B. Remove delaminating duct insulation above lay-in
ceiling.
C. Remove delaminating duct insulation above plaster or
drywall ceiling.
Related Work Practices
T6 - Repair damaged asbestos-containing insulation on a boiler, duct or flue
M25 - Remove section of asbestos-containing drywall or plaster.
Worker Recommendations
Two workers. A person with air monitoring training might be required. This person can
be a worker.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
27
-------
Ta. Level 2
1. Perform Pre-work activities on Level 2 checklist.
2. Additional tools, equipment and materials: (see general procedure Wi for
standard tools, equipment and materials list).
Scraper (2-3 [ 50-75 mml wide stiff blade)
Stiff nylon bristle brushes
Non-acm replacement duct insulation
Glovebags
3. Prepare work area with drop cloth. See general procedure W9.
4. Place tools, equipment and materials needed onto drop cloth.
5. Obtain access above ceiling using 0 & M work practice selected (see note
above step 1).
6. Pick up any bulk debris within reach on top of ceiling and place into
disposal bag.
7. HEPA vacuum top side of ceiling within reach from access hole.
8. Install duct tape around area to be removed.
9. Place all tools needed Inside glovebag and attach glovebag to duct tape
around area of duct Insulation to be removed.
10. Remove ACM using glovebag procedures. See general procedure W17.
Adequately wet removal area frequently during removal of bulk material.
11. Perform maintenance work and clean-up and tear-down steps on Level 2
checklist and ceiling access work practice to complete work. Leave duct
tape Installed in step 9 in place.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
of FacTht (
Remove asbestos-containing duct insulation above ceiling for
maintenance work.
Examples
Level 2: A. Remove small amount of damaged insulation around
damper control to permit insulation repair.
B. Replace Variable Air Volume (VAV) box on ACM
insulated duct.
Notes
This work practice must be used in conjunction with G3neral Procedures
WI, W9, and W17 and a Level 2 Worker Checklist. The worker checklist
includes tasks that must be performed before these work practices are
‘
begun.
Coordinate work with proper 0 & M work practice for accessing type of
ceiling present in work area. See work practices MIl, M12, M13 and M25.
Work Practice
28
-------
T8.LeveI3
Remove asbestos-containing duct insulation above ôeiling for
maintenance work.
Examples
Level 3: A. Remove damaged duct insulation so that new branch
lines can be tied to existing duct system for sub-
divided office space.
B. Remove delaminating duct insulation above lay-in
ceiling.
C. Remove delaminating duct insulation above plaster or
dyrwall ceiling.
Notes
This work practice must be used in conjunction with General Procedures
Wi, W9, and W17 and a Level 3 Worker Checklist The worker checklist
includes tasks that must be perlormed before these work practices are
begun.
Coordinate work with proper 0 & M work practice for accessing type of
ceiling present in work area. See work practices Ml 1, M12, M13 and M25.
Work Practice 1. Perform Pre-work actMties on Level 3 checklIst.
2. Additional tools, equipment and materials: (See general procedure Wi for
standard tools, equipment and materials list).
Scraper (2-3 (50-75 mml wide stiff blade)
Stiff nylon bristle brushes
Non-ACM replacement duct Insulation
Glovebags, size and configuration as required
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system. See general procedure W9.
4. Place tools, equipment and materials needed Into enclosure. Include a
HEPA vacuum inside enclosure for use during the work.
5. Obtain access above ceiling using 0 & M work practices selected (see
note above step 1).
6. Pick up bulk debris within reach on top of ceiling and place Into disposal
bag.
7. HEPA vacuum top side of ceiling within reach from access hole.
8. Install duct tape around area to be removed.
9. Place all tools needed Inside glovebag and attach glovebag to duct tape
around area of duct Insulation to be removed.
10. Remove ACM using glovebag procedures. See general procedures W17.
Adequately wet removal area frequently during removal of bulk material.
11. Perform maintenance work and clean-up and tear-down steps on Level 3
checklist and ceiling access work practice to complete work. Leave duct
tape Installed In step 8 In place.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
29
-------
T9 . Summary
Remove asbestos-containing insulation inside HVAC unit for
maintenance work.
Summary
This work practice describes the procedures to be used to remove small
amounts off asbestos-containing duct or pipe insulation inside an HVAC
unit.
Note: If a flexible connector must be removed, see Work Practice M26.
Examples
Level 2: A. Remove small amount of pipe insulation in good
condition using glovebag procedures to replace
cooling or heating coil.
Level 3: A. Remove ACM pipe insulation in poor condition inside
HVAC unit.
B. Remove small amount of duct insulation as required to
replace flexible connector.
Related Work Practices
T3 - Remove asbestos-containing insulation on exposed pipe in elevated location for
maintenance work -
T4 - Remove asbestos-containing insulation on pipe in occupied area for maintenance
work
T5 - Repair damaged asbestos-containing insulation on a pipe
T6 - Repair damaged asbestos-containing insulation on a boiler, duct or flue
S6 - Remove asbestos-containing flexible duct connector
Worker Recommendations
Two workers. A person with air monitoring training might be required. This person can
be a worker.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
Name 0 j 30
-------
T9.LeveI2
Remove asbestos-containing insulation inside HVAC unit for
maintenance work.
1. Perform Pre-work activities on Level 2 checklIst.
2. Additional tools, equipment and materials: (see general procedure Wi for
standard tools, equipment and materials list).
Scraper (2-3 [ 50-75 mmj wide stiff blade)
Stiff nylon bristle brUshes
Non-ACM replacement insulation
Glovebags
3. Prepare work area with drop cloth. See general procedure W9.
4. Place tools, equipment and materials needed onto drop cloth.
5. Install duct tape around Insulation to be removed.
6. Place all tools needed Inside of glovebag and attach glovebag to duct tape
around area where insulation will be removed.
7. Remove ACM using glovebag procedures. See general procedure W17.
Adequately wet removal area frequently during removal of bulk materials.
8. Perform maIntenance work and clean-up and tear-down steps on Level 2
checklist to complete work. Leave duct tape Installed In step 5 In place.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
“Name of Fack)(
Example
Level 2: A. Remove small amount of pipe insulation in good
condition to replace cooling or heating coil.
Notes
This work practice must be used in conjunction with General Procedures
.
Wi, W9, and Wi7 and a Level 2 Worker Checklist. The worker checklist
includes tasks that must be performed before these work practices are
begun.
Work Practice
31
-------
T9.LeveI3
Remove asbestos-containing insulation inside HVAC unit for
maintenance work.
Note:
If a flexible connector must be removed, see Work Practice
M26.
1. Perform Pre-work actMties on Level 3 checklist.
2. AdditIonal tools, equipment and materials: (See general procedure Wi for
standard tools, equipment and materials list).
Scraper (2.3 [ 50-75 mml wide stiff blade)
Stiff nylon bristle brushes
Non-ACM replacement duct insulation
Giovebags.
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative-pressure system where feasible. See general procedure W9.
4. Place tools, equipment and materials needed into enclosure. Include a
HEPA vacuum Inside enclosure for use during the work.
5. If work can be done with a glovebag method, follow procedures below:
A. Enter enclosure and install duct tape around area to be removed.
B. Place tools, equipment and other materials into glove bag. Attach
glovebag to duct tape using more duct tape.
C. Remove all loose or damaged insulation using. glovebag
procedures. See general procedure W17.
D. Remove giovebag leaving duct tape from step 5b above.
6. If a glovebag method cannot be effectively utilized, follow procedures
below:
A.
B.
C.
install duct tape around Insulation to be removed.
Adequately wet Insulation to be removed.
Remove ACM while wetting removal area frequently with amended
water. Keep hose of an operating HEPA vacuum adjacent to the
removal area to capture any debris or fibers generated.
7. Perform clean-Up and tear-down steps on Level 3 checklIst to complete
work. Leave duct tape Installed in step 5 or 6 in place.
THERMAL SYSTEMS INSULAJION . ASBESTOS O&M WORK PRACTICES
Name of FacTht (
Examples
Level 3: A. Remove ACM pipe insulation in poor condition inside
HVAC unit.
B. Remove duct insulation required to replace flexible
. connector.
Notes
This work practice must be used in conjunction with General Procedures
WI, W9, and W17 and a Level 3 Worker Checklist. The worker checklist
includes tasks that must be performed before these work practices are
begun.
Work Practice
32
-------
T1O . Summary
Clean up asbestos-containing debris in crawispace or tunnel.
Summary This work practice describes the work required to clean up small amounts
of asbestos-containing debris (below the small-scale, short-duration project
limits) found in a crawlspace area or tunnel.
Examples Level 2: A. Clean up several pieces of pipe insulation debris in
crawispace
B. Clean up small amount of insulation debris in tunnel
Level 3: A. Clean up of ACM debris in a tunnel that is used as a
plenum for the HVAC system.
B. Clean-up of delaminated duct insulation or fallen pipe
insulation in an area where maintenance work will be
performed.
Related Work Practices
Ti - Remove asbestos-containing insulation on exposed pipe for maintenance work
T5 - Repair damaged asbestos-containing insulation on a pipe
T6 - Repair damaged asbestos-containing insulation on a boiler, duct or flue
Worker Recommendations
Two workers due to confined space safety concerns. A person with air monitoring
training might be required. This person can be a worker.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
33
-------
T1O. Level 2
1. Perform Pre-work actMtles on Level 2 checklist.
2. See general procedure Wi for standard tools, equipment and materials list.
3. Place tools, equipment and materials
needed Into work area. One worker should remain outside to
communicate with inside worker and handle rescue arrangements, if
needed.
4. Adequately wet floor area and debris in work area.
5. Starting near entry to area and working toward rear of area, pick up pieces
of debris and place Into disposal bags.
6. Adequately wet areas where debris was removed. Use HEPA vacuum to
remove any remaining debris. Place debris into disposal bags. HEPA
vacuum floor after gross debris Is removed.
7. Perform maIntenance work and clean-up and tear-down steps on Level 2
checklist to complete work.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
‘Name otFac (
Clean up asbestos-containing debris in crawispace or tunnel.
Examples
Level 2: A. Clean up several pieces of pipe insulation debris in
crawlspace
B. Clean up small amount of insulation debris in tunnel
Notes
This work practice must be used in conjunction with General Procedures
WI and a Level 2 Worker Checklist. The worker checklist includes tasks
that must be performed before these work practices are begun.
.
Review confined space requirements with APM before start of work. See
general procedure APM 8. S
Work Practice
34
-------
T1O.LeveI3
Clean up asbestos-containing debris in crawlspace or tunnel.
Examples Level 3: A.
B.
Clean up of ACM debris in a tunnel that is used as a
plenum for the HVAC system.
Clean-up of delaminated duct insulation or fallen pipe
insulation in an area where maintenance work will be
performed.
Notes This work practice must be used in conjunction with General Procedures W i and
W9 and a Level 3 Worker Checklist. The worker checklist includes tasks that
must be performed before these work practices are begun.
Review confined space requirements with APM before start of work. See
general procedure APM 8.
Work Practice
1. Perform Pre-work actMties on Level 3 checklist.
2. See general procedure Wi for standard tools, equipment and materials list.
3. One worker should remain outside to
communicate with Inside worker and handle rescue arrangements if
needed. Prepare work area with mini-enclosure (without floor) and set up
negative pressure system and/or local exhaust ventilation. See general
procedure W9.
4. Place tools, equipment and materials needed into enclosure. Include a
HEPA vacuum inside enclosure.
5. Adequately wet floor area and debris inside enclosure.
6. Starting near entry to area and working toward rear of area, pick up pieces
of debris and place Into disposal bags.
7. Adequately wet areas where debris was removed. Use HEPA vacuum to
remove any remaining debris. Place debris into disposal bags. HEPA
vacuum floor after gross debris is removed.
8. Perform maintenance work and clean-up and tear-down steps on Level 3
checklist to complete work.
THERMAL SYSTEMS INSULATION . ASBESTOS O&M WORK PRACTICES
Name FacIlk)(
35
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VI
-------
Section VI.
Miscellaneous Materials Work Practices
Work Practices Location Illustration
Code
MI
M2
M3
M4
M5
M6
M7
M8
•M9
MlO
Mu
23
2
23
Levels
123
123
123
I
12
I
1
I
I
1
1
23
123
12
12
1 2
123
M12 23
M13 123
M14
M15
M16
M17
M18
M19
Description
Replacement of resilient asbestos floor tiles 5
Replacement of vinyl sheet flooring with ACM backing 11
Penetrate resilient asbestos flooring and subfloor 18
Install new resilient flooring or carpet over resilient asbestos
flooring 22
Install partition over resilient asbestos flooring . 24
Wet strip floor wax from resilient asbestos flooring 27
Dry or spray buffing resilient asbestos flooring 29
Cleaning resilient asbestos flooring 31
Remove carpet over resilient asbestos flooring 33
Clean potentially asbestos-contaminated carpet 38
Remove asbestos-containing ceiling panels in lay-in ceiling
system 41
Remove asbestos-containing ceiling tiles attached with
adhesive 45
Remove asbestos-containing ceiling tiles in spline ceiling
system 48
Cut or drill asbestos cement panels 52
Remove asbestos cement panels 55
Remove asbestos cement cooling tower louvers 59
Remove and replace asbestos cement roof shingles 62
Remove and replace asbestos cement siding 65
Remove high-temperature resistant (HTR) asbestos cement
panels 68
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
Thme c i Fac f
4
1
-------
M20 1 2 3 Remove asbestos-containing chalk board 72
M21 1 2 3 Remove asbestos-containing fire door and/or door
hardware 76
M22 1 2 Remove asbestos-containing built-up roofing 80
M23 1 2 Remove asbestos-containing asphalt shingles 84
M24 2 3 Cut or drill asbestos-containing drywall, plaster or drywall
compound 89
M25 2 3 Remove section of asbestos-containing dryvvall . 93
M26 1 2 3 Remove asbestos-containing flexible duct connector 96
M27 1 2 3 Remove asbestos-containing ductwork taping cloth 100
M28 2 Remove contaminated filters in HVAC unit serving plenum
space with exposed ACM
M29 1 2 Clean up debris from minor fiber release 106
M30 1 2 3 Replace asbestos-containing gaskets 109
M31 2 3 Emptying and changing filter in HEPA vacuum or changing
filter in HEPA fan unit 113
M32 1 2 3 Remove asbestos-wrapped wiring 116
M33 1 2 3 Removing asbestos-containing caulking compound 120
M34 1 Clean room that has asbestos-containing dust 124
The accompanying diagram illustrates typical applications of the above work practices.
The following general notes should be reviewed by users of the miscellaneous ACM work
practices:
1. Resilient floor tile and vinyl sheet are based on work practices developed by the
resilient floor covering manufacturers (RFCM) for the removal of asbestos and non-
asbestos-containing resilient floor covering materials. Work practice levels that
incorporate the RFCM practices are noted as (RFCM Procedures).
In accordance with terminology used by the RFCM, the term “vinyl” is used only
to refer to sheet flooring. The term “resilient” is used to refer to both floor tile and
sheet flooring, since many tile products contain resilient binder materials other than
vinyl.
The RFCM have submitted to OSHA airborne exposure data on removal of resilient
floor tile, asphaltic cutback materials, and sheet vinyl flooring. OSHA has stated
that it will accept the RFCM data for consideration as historical data to support a
claim for an exemption from the need to conduct initial air monitoring under the
OSHA regulation 29 CFR 1926.58(f) (2) (i). Historical data exemptions
notwithstanding, if applicable OSHA exposure limits are exceeded other provisions
and requirements of the OSHA asbestos regulation remain in full force and effect.
In considering the initial air monitoring exemption claim, the local OSHA
compliance officer determines whether the recommended work practices are being
strictly followed, the work conditions at the job site are similar to those in the study,
and OSHA’s field data (if any) are below OSHA’s action level and excursion limit.
Resilient floor covering is classified by the EPA NESHAP as Category 1 non-friable
ACM. If Category 1 ACM has become friable, or will become friable, or has been
MISCELLANEOUS ACM . ASBESTOS 0&M WORK PRACTICES
FacIlity” 2
-------
subjected to sanding, grinding, cutting or abrading, it is defined as Regulated ACM
by NESHAP. The user should consider the use of Levels 2 or 3 to perform O&M
activities under such conditions. Information in the NIBS Asbestos Abatemen
Guide Specifications sections 02085 and 02087 discusses the removal of resilient
floor covering.
2. Careful work practices should be the primary means used to prevent releases of
asbestos fibers during O&M work. Such practices include control measures such
as wetting and local exhaust that control or collect fibers at the source. The goal
of all asbestos O&M work should be to prevent any exposure of the worker and
unncoessary contamination of the work area, drop cloths, mini-enclosures and
other secondary control devices. Mini-enclosures should never be used to excuse
sloppy work or creation of ubigger messes.
The following dust suppression tools & techniques should be used where
appropriate for work on miscellaneous ACM:
A. A wet sponge can be used where small holes must be drilled in ACM. The
sponge can be held over the location where the hole is needed and the
hole can be drilled through the wet sponge. The sponge should help to
keep any dust or debris wet.
• B. The hose of an operating HEPA vacuum can be placed near the cutting
point of a drill bit or other tools.
C. Shaving cream can be sprayed over an area where ACM will be cut or
drilled to contain dust or debris. Any shaving cream used in this manner
should be disposed of as ACM after use.
0. Tools with HEPA filtered dust collection attachments.
3. Glovebag removal procedures as described in General Procedure Wi 7 may be
appropriate for use in certain small O&M tasks involving miscellaneous ACM, such
as the removal of a small area of floor tile where an enclosure is desired, changing
the bag in a HEPA vacuum or removing a small amount of ductwork taping cloth.
4. If the O&M activity involves work on materials (such as asbestos cement board)
that might have chemical residue present, any residue should be properly removed
prior to the start of the O&M work. Cleaning might be necessary to reduce the
possibility of a chemical reaction that could be caused by water, surfactants
and/or other substances mixing with chemical residues during O&M work.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
TM NameofFac %tY
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Figure 9
The following illustration of O&M work practices for miscellaneous materials is an excellent
reference document in determining relevant practices for your specific building. As stated
elsewhere in this manual, if any work practice is deleted, do not renumber the remaining
list; just note “not applicable”. Such a footnote could also be made to the following
illustration.
This illustration is not on diskette; however, a copy of Figure 9 is provided in the front
pouch of this notebook for your use. A copy of this sheet will need to be fed through the
printer to add the title and footer, which are found on the first page of the MISC1-8.WPF
file.
-------
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Work Practices (for EPA Standard Methods )
As particular building conditions warrant, the following work practices of EPA’s Standard
Methods should be modified. Modifications maybe as great as deleting the entire section
because miscellaneous type materials are not present in the building. It may be only
necessary to delete a particular practice, or to add or delete a recommended level for the
practice. One suggested modification is to revise or add examples that are specific to the
facility to better orient O&M workers to the building’s O&M program.
Modifications are encouraged as a means of tailoring this master ç uidance document to
your specific facility.
Modifications to “Related Work Practices” and “Worker Recommendations” of the NIBS
document may also be necessary.
-------
Ml . Summary
Replacement of resilient asbestos floor tiles .
Summary This work practice covers the O&M procedures for removing small amounts
of asbestos-containing floor tile and/or mastic. The Level 1 work practice
is based on the RFCM procedures.
Examples Level 1: A. . . Replacement of several floor tiles that are loose or can
be removed with minimal or no breakage, and tile
arid/or riiastic does not become friable.
B. Remove well-adhered tile and/or, mastic that is not
likely to.become friable.
Level 2: A. Replacement of an area of tiles that are sufficiently
damaged that the tile and/or mastic will become friable
during removal. •0
Level 3: A. Remove tile and mastic with an aggressive mechanical
method which renders it friable. :
Related Work Practices
M3 - Penetrate flooring covered with ACM
Worker Recommendations
One worker for Level 1 work. One or two workers for Level 2 depending upon safety and
efficiency considerations. Two workers for Level 3. A person with air monitoring training
might be required. This person can be a worker.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
5
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Ml. Levell
Replacement of resilient asbestos floor tiles.
Examples
Level 1: (RFCM Procedures see page 144)
A. Replacement of several floor tiles that are loose or can be removed
with minimal or no breakage, and tile and/or mastic does not
become friable.
B. Remove well-adhered tile and/or mastic that is not likely to become
friable.
Notes
This work practice must be. used in conjunction with General
.
. Procedure Wi and a. Level I Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Use Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
filter needs to be replaced. .
Warning: Do not sand flooring or backing.
Work Practice
Perform Pre-work activities on Level 1 checklIst.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Weighted scraper with long handle
Wall scraper 2-3 (50-75 mm) wide stiff blade w/short handle
CommercIal-type hand-held hot air blower or radiant heat source
Safety glasses
Weighted scraper with long handle
Wet/dry type HEPA vacuum with hose and attachments with metal
floor tool
Garden sprayer with amended water
Hammer
Crushed dry Ice (for procedure 5B) - approximately 1 lb (0.5 kg)
per sq.ft. (0.1 m 2 )
3. Place tools, equipment and materials needed In work area.
4. RFCM removal procedure Is described In step 5A. An alternative non-
RFCM procedure using dry ice Is described In step 5B.
5. Clean the affected floor area with a wet/dry type HEPA vacuum and a
metal floor attachment (no brush). Do not sweep.
6. A. Start the removal by carefully wedging the scraper in the seam of
two adjoIning tiles and gradually lifting the edge of the tile up and
away from the floor. Try not to break pieces of the tile but
continue to work the balance of the tile up by working the scraper
beneath the tile and exerting both a forward pressure and a
twisting action on the blade to promote release of the tile from the
adhesive and the floor. Some tiles will release quite easily while
others require varying degrees of force. When the adhesive is
spread heavily or the tile Is bonded tightly, it may easier to force
the scraper through the tightly adhered areas by striking the
scraper .
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
‘Wamo of Facility’
6
-------
M l. Level l...continued
handle with a hammer using blows of moderate force while
maintaining the scraper at 25 to 30 degree angle to the floor. If
you encounter areas where even the above methods will not
remove the tile, the removal procedure can be simplified by
thoroughly heating the tiles with a hot-air blower or a radiant heat
source until the heat penetrates through the tile and softens the
adhesive. Caution: Heating resIlient tile or mastic might produce
toxic vapors and a respirator with organic vapor cartridges might
be needed.
B. Dry ice tile removal procedures
Caution: The use of dry ice produces carbon dioxide that can
result In an oxygen deficiency in the work area. Dry ice can also
cause frostbite to workers and damage building• matetials.
Spread crushed dry Ice over tiles to be removed. Let dry Ice
freeze mastic and release tile. Use short-handled scraper to pry
up tiles.
7. When the tile is removed, place it, without breaking It, in disposal bags or
containers which will be used for disposal. Removed tiles can be placed
in empty tile cartons first and then placed in the disposal bags. To prevent
tearing of the bag, place a maximum of one full carton of removed tile in
a bag.
8. If new resilient floor tile is to be installed over a concrete subfloor using an
asphaltic adhesive, the residual asphaltic “cutback” adhesive (mastic) must
be left so that no ridges or puddles are evident and what remains is a thin,
smooth film. This can be accomplished by wet-scraping the residual
adhesive as follows:
A. Start by adequately wetting the area where tile(s) were removed
using amended water. Wet-scrape with a stiff-biaded wall or floor
scraper, removing ridges and any loose adhesive.
B. Place loosened adhesive residues into disposal ba s or other
containers.
C. Wet vacuum standing water with the HEPA vacuum cleaner.
D. Continue steps A through C until what remains of the residual
asphaltic “cutback” adhesive Is a thin, smooth film.
9. Clean the affected floor area with the HEPA vacuum cleaner, using the
metal floor tool to remove debris before applying new asphaltic adhesive
or installing new resilient floor tile.
10. Perform required clean-up and tear-down steps on Level 1 checklist to
complete work.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
“Name of Fac1l1t 7
-------
Ml . Level 2
Replacement of resilient asbestos floor tiles.
Examp
le
Level 2: A. Replacement of an area of badly damaged tiles that
are sufficiently damaged that the tile and/or mastic will
become friable during removal.
Notes
.
This work practice must be •used in conjunction with General
Procedures WI, W4 and a Level 2 Worker Checklist. The worker
checklist includestasks that must be pe.formed before these work
practices are begun.
Use
caution to prevent a fire in the work area if heat sources are used.
Work Practice
Perform Pre-work actMties on Level 2 checklist.
.2. Special tools, equipment and materials: (see General Procedure WI for
standard tools, equipment and materials list).
Commercial-type hand-held hot air blower or radiant heat source
Safety glasses
Heavy duty scraper with 4 (100 mm) blade and 6’-8’ (2 m) handle
Weighted scrapper with long handle
Wet/dry type HEPA vacuum with hose and attachments
Hammer
3. Establish work area with baffler tape. See General Procedure W4. A
plastic drop cloth may be used for dirty tools and bagged waste. if desired.
4. Place tools, equipment and materials needed in work area.
5. Clean the affected floor area with a wet/dry type HEPA vacuum and a
metal floor attachment (no brush). Do. not sweep.
6. Start the removal by carefully wedging the scraper In the seam of two
adjoining tiles and gradually forcing the edge of the tile up and away from
the floor. Try not to break off pieces of the tile but continue to force the
balance of the tile up while working the scraper beneath the tile and
exerting both a foiward pressure and a twisting action on the blade to
promote release of the tile from the adhesive and the floor. Some tiles will
release quite easily while others require varying degrees of force. When
the adhesive is spread heavily or the tile is bonded tightly, it may prove
easier to force the scraper through the tightly adhered areas by striking the
scraper handle with a hammer, using blows of moderate force while
maintaining the scraper at a 25 to 30 degree angle to the floor. If you
encounter areas where even the above methods will not remove the tiles,
the removal procedure can be simplified by thoroughly heating the tiles
with a hot-air blower or a radiant heat source until the heat penetrates
through the tile and softens the adhesive. Caution: Heating resilient tile
or mastic might produce toxic vapors and a respirator with organic vapor
cartridges might be needed.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
“Name of Føcllity’
8
-------
Ml. Level 2...continued
7. When the tile is removed, place it, without breaking it, in disposal bags or
containers which will be used for disposal. Removed tiles can be placed
In empty tile cartons first and then placed in the disposal bags. To prevent
tearing of the bag, place a maximum of one full carton of removed tile in
abag.
8: If new resilient floor tile Is to be installed over a concrete subfloor using an
asphaltlc adhesive, the residual asphaltic cutback ’ adhesive must be left
so that no ridges or puddles are evident and what remains is a thin,
smooth film. This can be accomplished by wet-scraping the residual
adhesive as follows:
A. Start in the removal area farthest from the entrance door and
adequately wet an area approximately 3’ x 10’ (im x 3m) with
amended water to aid in wetting the adhesive. Wet-scrape with a
stiff-bladed wall or floor scraper removing ridges and any loose
adhesive.
B. Place loosened adhesive residues into disposal bags or other
impermeable containers.
C. Wet vacuum standing water with the HEPA vacuum cleaner.
D. Continue steps A through C until what remains of the residual
asphaltic cutback ’ adhesive is a thin, smooth film.
9. Clean the affected floor with the HEPA vacuum cleaner using the metal
floor tool to remove debris, followed by wet wiping, before applying new
asphaltic adhesive or Installing new resilient floor tile.
10. Install new floor tile and perform required clean-up and tear-down steps on
Level 2 checklist to complete work.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
9
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Ml . Level 3’
1. Perform Pre-work activities on Level ‘3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Safety glasses
Heavy duty scraper with 4 (100 mm) blade and 6’-8’. (2m) handle
Weighted scraper with long handle
Wet/dry type HEPA vacuum with hose and attachments
Low speed floor grinder (190 RPM or less)
3. Prepare work area with mini-enclosure (without floor) and set up negative
pressure system. See General Procedure W9. A giovebag may be used
as an enclosure for small areas.
4. Place tools, equipment and materials needed Into enclosure.
5. Adequately wet floor areas where tile and/or mastic will be removed.
6. Grind down high spots with floor grinder. Adequately wet any dust or
debris generated by grinding.
7. HEPA vacuum affected floor area and wet wipe smooth portions of floor.
Place disposable towels and debris Into ACM disposal bags.
8. Perform clean-up and tear-down steps on Level 3 checklist to complete
work.
Replacement of resilient asbestos floor tiles.
Example Level
.
3: A. Remove tile and mastic with an aggressive mechanical
method which renders it friable.
Notes
,
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 3 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
‘
‘practices are begun.
Work Practice
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
‘Name of Facility’
10
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M2 . Summary
Replacement of vinyl sheet flooring with ACM backing.
Summary This work practipe covers the O&M procedures for the replacement of small
amounts of vinyl sheet flooring with ACM backing. Wet scraping of residual
felt is included in all three Levels.
Examples Level 1: A. Replacement of loose or perimeter-adhered vinyl sheet
flooring with ACM backing.
B. Replacement of adhered vinyl sheet flooring with ACM
backing that can be removed using non-aggressive,
primarily’ manual methods . Some separation of
backing and wear layer will occur.
Level 2: A. Replacement of vinyl sheet flooring with ACM backing
which is sufficiently damaged to be friable.
Level 3: A. Remova! of vinyl sheet flooring with ACM backing using
an aggressive mechanical method which renders the
material friable.
Related Work Practices
‘
M l -
M4 -
M9 -
‘ Replacement of resilient asbestos floor tiles
Install new resilient flooring or carpet over resilient
Remove carpet over resilient asbestos flooring
asbestos
‘
flooring
Worker Recommendations
Two workers. A person with air monitoring training might be required. This person can
be a worker.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
i’ ‘r : 11
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M2.LeveIl
Replacement’ of vinyl sheet flooring with ACM backing.
Examples
Level 1: (RFCM Procedures see page 144)
A. Replacement of loose or perimeter-adhered vinyl sheet flooring with
ACM backing.
.
B. Replacement of adhered vinyl sheet flooring with ACM backing that
can be removed using non-aggressive, primarily manual methods.
Some separation of backing and wear layer will occur.
Notes
This work practice must be used in conjunction- with General
Procedure.. Wi and a Level 1 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Warning: Do not sand flooring orbacking.
Use Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
filter needs to be replaced.
Work Practice
Perform Pre-work actMties on Level ‘1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Garden sprayer with amended water
Stiff bladed wall or floor scraper
Hook knife
Wet/dry type HEPA vacuum with hose and attachments with metal
floor toot
3. Place toots, equipment and materials needed in work area..
4. Removal Procedure:
A. Remove any binding strips or other restrictive moldings from
affected area.
B. Clean the affected floor area with the HEPA vacuum cleaner using
the metal floor tool.
C. Make a series of parallel slices 4” to 8” (100-200 mm) apart
through the flooring to be removed.
0. Removal: Pry up the corner of a strip of flooring. As the strip is
being removed, adequately wet (using amended water) the
removal point to minimize any airborne dust particles. When done
propetly, the floor and the back of the strip should be adequately
wet. Do only one three-strip area at a time. Stand on the
remaining floor covering or dean, floor (do not stand on the felt).
The sliced strip should be rolled around a core which will control
the stripping angle to create a uniform tension. Tie or tape the
removed material securely and place In disposal bags or
containers for disposal.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
“Name of Facility
12
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M2. Level 1...continued
E. Remove and dispose of each strip in the above manner. Avoid
walking on the exposed felt as much as possible.
F. Occasionally, parts of the flooring will ‘stick to the subfloor. This
can often be eliminated, by peeling in the opposite direction. The
stiff-bladed scraper may aid In the removal or peeling of the
flooring. If any residual felt backing remains on’ the subfloor,
remove it using wet scraping methods set forth in step 66.
6. Wet-scraping residual felt:
1. Adequately wet the residual felt with amended water. Wait
for a few minutes to allow the amended water to soak into
the felt.
2. Use the stiff-bladed scraper to scrape up the wet felt.
3. Rewet the felt if the amended water has not completely
penetrated, If drying occurs, or if dry felt is exposed
during scraping. Pick up the scrapIngs as they are
removed from the floor and place in disposal bags or
containers. Wet-scrape felt from affected floor area.
4. When this floor area has been cleaned free of felt, vacuum
up any dirt using the HEPA vacuum cleaner with the metal
floor tool. Position the vacuum cleaner so that the
discharge air does not blow on the area being cleaned.
5. If HEPA vacuum filter or bag needs to be changed, use
work practice M31.
6. Allow substrate to dry before installing new flooring.
5. Perform required clean up and tear-down steps on Level 1 checklist to
complete work.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
13
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Perform Pre-work activities on Level 2 checklist.
2.. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Stiff bladed wall or floor scraper
Hook knife
Wet/dry type HEPA vacuum with hose and attachments
3. Install drop cloth If desired for dirty tools and bagged waste. See General
Procedure W9.
4. Place tools, equipment and materials needed into work area.
5. Removal Procedure, Adhered Resilient Sheet Flooring:
A. Remove any binding strips or other restrictive moldings from
affected area.
B. Clean the affected floor area with the HEPA vacuum cleaner using
the metal floor tool.
C. Make a series of parallel slices 4” to 8” (100-200 mm) apart
through the flooring to be removed.
D. Removal: Pry up the corner of a strip of flooring. As the strip is
being removed, adequately wet (using amended water) the
removal point to mInimize any airborne dust particles. When done
properly, the floor and the back of the strip should be adequately
wet. Do only one three-strip area at a time. Stand on the
remaining floor covering or clean floor (do not stand on the felt).
The sliced strip should be rolled around a core which will control
the stripping angle to create a uniform tension. Tie or tape the
removed material securely and place In disposal bags or
containers for disposal.
E. Remove and dispose of each strip in the above manner. Avoid
walking on the exposed felt as much as possible.
F. Occasionally, parts of the flooring will stick to the subflóor. This
can often be eliminated by peeling in the opposite direction. The
stiff-bladed scraper may aid In the removal or peeling of the
flooring. If any residual felt backing remains on the subfloor,
remove it in accordance with step 6G.
M2.LeveI2
Replacement of vinyl sheet flooring with ACM backing.
Example
Level
2: A. Replacement of vinyl sheet flooring with ACM backing
which is sufficiently damaged to be friable.
Notes
This work practice must be used in conjunction with General
Procedures WI, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Warning: Do not sand flooring or backing.
Work Practice
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
“Name f Facility
14
-------
M2. Level 2...continued
G. Wet-scraping residual felt:
1. Adequately wet the residual felt with amended water. Wait
for a few minutes to allow the amended water to soak Into
the felt.
2. Stand on the remaIning floor covering (not the felt) and
use the stiff-bladed scraper to scrape up the wet felt.
3. Rewet the felt if the amended water has not completely
penetrated, If drying occurs, or If dry felt Is exposed
during scraping. Pick up the scrapings as they are
removed from the floor and place In disposal bags or
containers. Wet-scrape felt from affected floor area before
proceeding further.
4. When floor area has been cleaned free of felt, vacuum up
any dirt using the HEPA vacuum cleaner with the metal
floor tool.. Position the vacuum cleaner so that the
discharge air does not blow on the area being cleaned.
5. If HEPA vacuum filter or bag needs to be changed, use
work practice W31.
6. Allow substrate to dry before Installing hew flooring.
6. Perform required clean up and tear-down steps on Level 2 checklist to
complete work.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
“Name of PacllitV ’ 15
-------
M2. Level 3
Perform Pre-work activities on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Stiff bladed.wall or floor scraper
Hook knife
Wet/dry type HEPA vacuum with hose and attachments
3. Prepare regulated area with mini-enclosure (or by enclosing room) and set
up negative pressure system. See General Procedure W9.
4. Place tools, equipment and materials needed into enclosure.
5. Enter enclosure and remove flooring per procedures under step 6.
6. Removal Procedure, Fully Adhered Resilient Sheet flooring:
A. Remove any binding strips or other restrictive moldings from
affected area.
B. Clean the affected floor area with the HEPA vacuum cleaner using
the metal floor tool;
C. Make a series of parallel slices 4” to 8” (100-200 mm) apart
through the flooring to be removed.
D. Wear layer removal: Pry up the corner of a strip of flooring,
separating the backing from the wear layer. As the strip is being
removed, adequately wet (using amended water) the delamination
point to minimize any airborne dust particles. When done
properly, the felt remaining on the floor and on the back of the
strip should be thoroughly wet. Stand on the remaining floor
covering or clean floor (do not stand on the felt). The sliced strip
should be peeled from the backing by pulling or rolling around a
core which will control the stripping angle to create a uniform
tension (some resilient flooring wear layers might not be readily
strippable and might require wet-scraping). Tie or tape the
removed material securely and place in disposal bags or
containers for disposal.
E. Remove and dispose of each succeeding strip in the above
manner. Avoid walking on the exposed felt as much as possible.
Replacement of vinyl sheet flooring with ACM backing.
Example
Level
3: A. Removal of vinyl flooring with ACM backing using an
aggressive mechanical method which renders the
material friable.
Notes
This work practice must be used in conjunction with General
Procedures WI, W9 and a Level 3 Worker Checklist. The worker
checklist includes tasks th it must’be performed before these work
practices are begun.
•
Warning: Do not sand flooring or backing.
Work Practice
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
‘Name of I ac1IIty ”
16
-------
M2. Level 3...continued
F. Occasionally, parts of the top layer will stick to the backing. This
can often be eliminated by peeling In the opposite direction. The
stiff-bladed scraper might aid in the removal or peeling of the wear
layer.
G. Wet-scraping residual felt backing:
i. Adequately wet the resIdual felt with amended water. Wait
for a few minutes to allow the amended water to soak Into
the felt.
2. Stand on the remaining floor covering (not the felt) and
• use the stiff-bladed scraper to scrape up the wet felt.
3. Rewet the felt if the amended water has not completely
penetrated, if drying occurs, or. if dry felt is exposed
during scraping. Pick up the scrapings as they are
removed from the floor and place In disposal bags or
containers. Wet-scrape felt from affected floor area.
4. When floor area has been cleaned free of felt, vacuum up
any dirt using the HEPA vacuum cleaner with the metal
floor tool. Position the vacuum cleaner so that the
discharge air does not blow on the area being cleaned.
5. If HEPA vacuum filter or bag needs to be changed, use
work practice W31.
6. Allow substrate to dry before installing new flooring.
7. Perform clean-up and tear-down steps on Level 3 checklist to complete
work.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
17
-------
M3. Summary
Penetrate resilient asbestos flooring and subfloor.
Summary This work practice covers the procedures for drilling or cutting holes in
resilient asbestos flooring and the subfloor below. If the flooring is badly
damaged it may be advisable to remove it, rather than drilling holes in it.
Note: AHERA states that maintenance staff employees should be instructed
not to drill holes in ACM. Only properly trained employees should
undertake such activities.
Examples Level 1: A. Remove small amounts of resilient asbestos flooring
covering to drill hole(s) in subfloor to attach object to
floor or install a pipe or conduit.
Level 2: A. Drill or cut a few hole(s) in resilient asbestos flooring to
install pipe or conduit.
Level 3: A. Drill or cut multiple holes in badly damaged resilient
asbestos floàring.
B. Cut hole in resilient asbestos flooring with power saw
for square duct.
Related Work Practices
Ml - Replacement of resilient asbestos floor tiles
M2 - Replacement of vinyl sheet flooring with ACM backing
M9 - Removal carpet over resilient asbestos flooring
Worker Recommendations
One worker for Level 1 work. One or Two workers for Level 2 depending upon safety
and efficiency considerations. Two workers for Level 3. A person with air monitoring
training might be required. This person can be a worker.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
“Name of Facility 18
-------
M3.LeveIl
Penetrate resilient asbestos flooring and subfloor.
Example
.
Level 1: A. Remove small amount of resilieht asbestos floor
covering to drill hole(s) in subfloor to attach object to
floor or install a pipe or conduit.
Notes
.
Use
filter
This work practice must be used in conjunction with General
Procedure Wi and a Level I Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices ‘are begun.
Work Practice’ M31 if HEPA vacuum needs maintenance, or if bag or
needs to be replaced.
Work PractIce 1. Perform Pre-work actMties on Level 1 checklist.
2. AdditIonal tools, equipment and materials: (See General Procedure WI for
standard tools, equipment and materials list).
Scraper
Drill
Hook Knife
3. Place tools, equipment and materials needed in work area.
4. Cut out a piece of resilient asbestos flooring larger than the hole to be
drilled using utility or hook knife. Use scraper to pry up a piece of flooring.
Place flooring piece Into disposal bag, adequately wet mastic or residual
felt using amended water and scrape up using Ml Level 1 step 7
procedures for tile and M2 Level 1 step 4F for vinyl sheet flooring.
5. Drill hole into subfloor as needed;
6. Clean up dust and debris using HEPA vacuum.
7. Perform maintenance work required and clean-up and tear-down steps on
Level 1 checklist to complete work.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
19
-------
• 1. Perform Pre-work activities on Level 2 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Drill or hole saw with HEPA vacuum attachment
Small stiff-bladed scraper
3. Prepare Work area with drop cloth covering work area except where holes
are being drilled. See General Procedure W9. If hole being drilled or cut
Is to penetrate through floor, an enclosure will be needed on the underside
to catch any dust or debris that may fall to floor below.
4. Place tools, equipment and materials needed onto drop cloth.
5. Adequately wet area where penetration must be made using amended
water and, If desired, cut out a piece of flooring larger than the hole to be
made using utility knife and scraper.
6. UsIng drill or hole saw with wetting or attached HEPA vacuum, perform
drilling or cuttIng operation. Wet all dust or debris generated using
amended water.
7. Clean up dust and debris using HEPA vacuum and/or wet wiping and
place disposable towels into disposal bags.
8. If hole was drilled through floor, wet any debris or dust in enclosure and
underside. Package debris or dust as ACM waste.
9. Perform maintenance work required and cleanup and tear-down steps on
Level 2 checklist to complete work.
M3.LeveI2
Penetrate resilient asbestos flooring and subfloor.
Example
Level 2: A. Drill or cut a few hole(s) in resilient asbestos flooring to
install pipe or conduit.
Notes
This work practice must be used .in conjunction with General
Procedures WI, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices. are begun.
Coordinate work with proper 0 & M work practice for accessing type of
ceiling present in work: area if debris from work may fall on• ceiling below.
See work practices SI, Mu, M13 or M24.
Work Practice
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
‘Name of Facility”
20
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1. Perform Pre-work actMties on Level 3 checklist.
2. AdditIonal tools, equipment and materials: (See General Procedure WI for
standard tools, equipment and materials list).
Drill or saw with HEPA vacuum attachment
Small stiff-bladed scraper
3. Prepare work area with mini-enclosure and set up negative pressure
system or HEPA filtered local exhaust ventilation. Do not cover floor where
holes are to be drilled or cut. See General Procedure W9. If hole being
drilled or cut Is to penetrate through floor, an enclosure will be needed on
the underside to catch any dust or debris that may fall to floor below.
4. Place tools, equipment and materials needed into enclosure.
5. Enter enclosure, and adequately wet area where penetration must be made
using amended water. If desired, cut out a piece of flooring larger than the
hole to be made using utility knife and scraper.
6. Using drill or saw with wetting or attached HEPA vacuum, perform drilling
or cutting operation. Wet all dust or debris generated using amended
water.
7. Clean up dust and debris using HEPA vacuum and/or wet wiping and
place disposable towels into disposal bags.
8. If hole was drilled through floor, wet any debris or dust in enclosure and
underside. Package debris or dust as ACM waste.
9. Perform maintenance work required and clean-up and tear-down steps on
Level 3 checklist to complete work.
M3.LeveI3
Penetrate resilient asbestos flooring and subfloor.
Example
Level 3: A. Drill or cut multiple holes in badly damaged resilient
asbestos flooring.
B. Cut hole in resilient asbestos flooring with power saw
:
for square duct.
Notes
This work practice must be used in conjunction with General
F rocedures Wi, W9 and a Level 3 WorKer Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Coordinate work with proper 0 & M work practice for accessing type of
ceiling present in work area if debris from work may fall on ceiling below.
See work practices, Si, Mu, Mi3 or M24.
Work Practice
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
21
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• M4. Summary
Install new resilient flooring or carpet over resilient asbestos
• flooring. _____________________________________
Summary This procedure covers the work required to prepare resilient• asbestos
flooring for the installation of new resilient flooring or carpet. This procedure
works with work practice M6 for stripping asbestos flooring and assumes
that any damaged flooring has been repaired or replaced using applicable
work practices such as Ml and M2.
Example Lövel I: A. New carpe
asbestos
backing in
t being installed over wel
floor tile or vinyl sheet fi
good condition.
l-adher
ooring
ed resilient
with ACM
Related Work Practices
•
•
Ml - Replacement of resilient asbestos flo
M2 - Replacement of vinyl sheet flooring W
M6 - Wet strip floor wax from resilient asb
M7 - Buffing resilient asbestos flooring
or tiles
ith ACM backing
estos flooring
•
M8 - Cleaning resilient asbestos flooring
•
Worker Recommendations
One worker is usually sufficient. Two or more workers may be needed to increase
efficiency or for additional health and/or safety considerations. A person with air
monitoring training might be required This person can be a worker.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRAGTICES
‘Name of aclIity 22
-------
M4. Level 1
Install new resilient flooring or carpet over resilient asbestos
flooring.
Example
Level 1: A. New carpet being installed over well-adhered resilient
asbestos tile or vinyl sheet flooring with ACM backing
in good condition.
Notes.
This work practice must be used in conjunction with General
.
Procedure Wi and a Level I Worker Checklist The worker
checklist includes tasks that must be performed before these work
practices are begun.
Review manufacturer’s recommendations concerning installation of new
flooring over existing before proceeding with this work. Coordinate this
work with floor stripping work practice M6 as required in step 5.
.
Use Work Practice M31 if HEPA vacuum needs maintenanôe, or if bag or
filter needs to be replaced.
Work Practice
1. Perform Pre-work activities on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Scraper 2-3 (50-75 mm) wide stiff blade
3. Place tools, equipment and materials needed Into work area.
4. HEPA vacuum area where flooring will be Installed.
5. Strip wax/finish from existing floor using O&M work practice M6.
6. Level off any minor high spots on floor using scraper. Do not sand or
grind flooring.
7. Fill any low.areas using manufacturers recommended underlayment or
Leveling compound.
8. Install new flooring or carpet as recommended by manufacturer.
9. Perform clean-up and tear-down steps on Level 1 checklist to complete
work.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
‘Name of 1 ac1Ilty 1 ’
23
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M5 . Summary
Install partition over resilient asbestos flooring.
Summary This work practice describe the procedures for installing a wall over resilient
asbestos flooring that will remain in place. If flooring will be removed for
wall installation, use work practice Ml or M2.
Note: It may be more efficient to remove flooring using Ml or M2 and then
install partition.
Examples Level I: A. Install partition over resilient asbestos flooring that is
well adhered and in good condition.
Level 2: A. Install partition over resilient asbestos flooring that
becomes friable during the partition installation.
Related Work Practices
•
Ml - Replacement of resilient asbestos floor tiles
M2 - Replacement of vinyl asbestos sheet flooring with ACM backing
M3 - Penetrate resilient asbestos flooring and subfloor
M4 - Install new resilient flooring or carpet over resilient asbestos flooring
Worker Recommendations
One worker. Two workers may be beneficial for erecting partition. A person with air
monitoring training might be required. This person can be a worker.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
24
-------
M5. Level I
Install Partition over resilient asbestos flooring.
Example
Level 1: A. Install partition over resilient asbestos flooring that is
well-adhered and in good condition.
Notes
This work practice must be used in conjunction with General
Use
filter
Procedure Wi and a Level I Worker Checklist. The worker
checklist includes tasks that must be performed before these work
p. actices are begun.
Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
needs to be replaced.
Work Practice 1. Perform Pre-work actMtles on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Anchoring devices and equipment
Non-asbestos adhesive
3. Place tools, equipment and materials needed in work area.
4. Install base plate of wall on full bed of adhesive and attach to floor using
appropriate anchoring devices.
5. HEPA vacuum any chips or dust generated during fastening operation.
6. Complete installation of wall.
7. Perform cleanup and tear down steps on Level 1 checklist to complete
work.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
Name ol F ac1llty 25
-------
1. Perform Pre-work actMtles on Level 2 checklist
2. AdditIonal toots, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Anchoring devices/equipment
Non-asbestos adhesive
3.. Prepare work area with drop cloth. Do not install drop cloth where wall will
attach to floor. See General Procedure W9.
4. Place tools, equipment and materials needed onto drop cloth.
5. Using garden sprayer with amended water, adequately wet flooring area
where work is to be done.
6. . Level off any minor high spots on floor using scraper. Do not sand or
grind flooring.
7. Remove any damaged vinyl asbestos flooring in area of work using 0 & M
work practice Mi or M2.
8. Fill any low areas using manufacturers recommended Leveling compound.
9. Install base plate of wall on full bed of adhesive and attach to floor using
appropriate anchoring devices.
10. HEPA vacuum any chips or dust generated during fastening operation.
11. Complete installation of wall.
12. Perform cleanup and tear down steps on Level 2 checklist to complete
work.
M5. Level 2
Install Partition over resilient asbestos flooring.
Example
Level 2: A. Install partition over resilient asbestos flooring that
becomes friable during the partition installation.
Notes
This work practice must be used . in conjunction with General
Procedures WI, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun. .
• It might be more efficient to remove flooring using Ml or M2 and then install
partition.
Work Practice
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
“Name of PaclIIty
26
-------
M6. Summary
Wet strip floor wax from resilient asbestos flooring .
Summary This work practice covers the procedures for stripping floor wax or finish
from resilient asbestos flooring. Do not strip damaged flooring. Any loose
or damaged flooring should be repaired or replaced before stripping is
started. Wet stripping, if performed properly, should not cause damage to
resilient flooring. If any flooring damage occurs during stripping, stop work
and make repairs using applicable work practice(s). Do not dry strip,
scrape, sand, or grind resilient asbestos flooring to remove any blemishes
or imperfections.
This procedure is based on EPA’s recommended Interim Guidance
Memorandum for Maintenance of Asbestos-Containing Floor Coverings,
January 25, 1990.
Example Level 1: A. Stripping floor wax or finish coat from reE
flooring that is well adhered and in good
ent
condition.
Related Work Practices
M l - Replacement of resilient asbestos floor tiles
M4 - Install new resilient flooring or carpet over resilient asbestos flooring
M7 - Buffing resilient asbestos flooring
MB - Cleaning resilient asbestos flooring
:
Worker Recommendations
One worker trained in wet stripping procedures for resilient asbestos flooring. A person
with air monitoring training might be required. This person can be the worker.
• MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
‘Name of P80 11 1W’ 27
-------
1 Perform Pre-work activities on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
M iitjon - Wet Floor” signs
Floor stripping machine
Stripping Pads (least abrasive pad possible)
Buckets with water for rinsing
Mops (for stripping, rinsing and polishing)
Chemical stripper - recommended amount for area to be stripped
Floor wax or finish
Walk-off mats
3. Place tools, equipment and materials needed in work area. Place walk-off
mats where required to prevent tracking of stripping solution to other
areas. Position “ ution -Wet Floor” signs.
4. After proper mixing of stripping chemical, adequately wet floor by mop
applying liberal amounts of the solution. Allow chemical to soak for
amount of time recommended by manufacturer. if areas become dry,
reapply solution to keep floor adequately wet.
5. After wax or finish has softened, strip flooring using least abrasive pad and
low speed setting (175-190 RPM maximum). Keep floor adequately wet.
during machine operation. Do not overstrip. Stop stripping when the old
wax or finish is removed. Work small areas at a time.
6. Remove dirty stripping solution with wet vacuum or “strip” mop.
7. With “rinse” mop, apply liberal amount of clean water to area stripped and
remove water with wet vacuum or mop. Repeat rinse procedures.
8. If some spots of wax or finish remain, restrip those areas.
9. If new flooring will be Installed over the stripped floor, do not apply wax or
finish. When applying new wax or finish, do so according to
marwfacturer’s recommendations.
10. Perform clean-up and tear-down steps on Level 1 checklist to complete
work.
M6.LeveIl
Wet strip floor wax from resilient asbestos flooring.
Example
Level 1: A. Strip floor wax or finish coat from resilient asbestos
flooring that is well-adhered and in good condition.
Notes
This work practice must be used in conjunction with General
Procedure Wi and a Level 1 Worker Checklist. The worker
.
•. checklist includes tasks that must be performed before these work
practices are begun. . .
.
Stripping padsi should be kept wet during use. and rinsed thoroughly
immediately after:. use and prior to storage. . Dispose .. of-.. pads,.. if
.
contaminated, as ACM waste in labeled disposal bags.
Work Practice
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
28
-------
M7.. Summary
Dry or spray buffing resilient asbestos flooring
Summary This work practice covers the procedures for spray buffing the polish to
restore gloss on resilient asbestos flooring. Do not buff damaged flooring.
before
Any loose or damaged flooring should be repaired or replaced
buffing is started. This practice assumes that the floor has adequate coats
the
of polish, and that the flooring itself will not be damaged or contacted by
work
buffing equipment. If any flooring damage occurs during buffing, stop
and make repairs using applicable work practice(s). If polish is in poor
condition, use work practice M6 or MB.
Example Level 1:’ A. Dry or spray buff the polish on resiJient . asbestos
flooring to remove minor surface imperfections and
restore gloss.
Related Work Practices
M6 - Strip floor wax from resilient asbestos flooring
MB - Cleaning resilient asbestos flooring
Worker Recommendations
One worker trained in spray buffing procedures for asbestos flooring. A person with air
monitoring training might be required. This person can be the worker.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
29
-------
M7. Level 1
1. Perform applicable pre-work activities on Level 1 checklIst.
2. AdditIonal tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Caution - Wet Floor” signs
Floor buffing machine
Buffing Pads (least abrasive - tan, red, or equivalent)
Buckets with, mop wringer
Mops (for damp or spot mopping)
Chemical cleaner
Hand-held scraper
Spray buffing compound, appropriately diluted, compatible polish
and restorer chemical
3. Place tools, equipment and materials needed In work area. Position
Caution-Wet Floor” signs.
4. Pick up any large loose debris and place Into disposal bags. Using
scraper and water, remove all foreign matter from the finished surface
(gum, tar, stickers, etc.).
5. Spot or damp mop to remove stains and spills. Mix chemical cleaner or
restorer with water and apply according to manufacturers
recommendations. Spot or damp mop to remove stains and spills. If dry
buffing will be performed, apply restorer chemical as required.’
6. Allow floor to dry thoroughly.
7. A. To spray-buff, spray small area with spray-buff solution and buff
using manufacturer’s recommended pad or brush at
recommended RPM. Repeat procedure until entire area Is spray-
buffed.
B. To dry buff, buff or dry burnish with manufacturer’s recommended
pad or brush at recommended RPM.
8. Perform applicable steps on Level 1 checklist to complete work.
Dry or spray buffing resilient asbestos flooring.
Example
‘
Level 1: (RFCM Procedures see page 144)
A. Dry or spray buff the polish on resilient asbestos flooring to remove
minor surface imperfections and restore gloss.
Notes
This work practice must be used in conjunction with General
‘
Procedure Wi and a Level I Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Dispose of pads, ‘if contaminated, as ACM waste in labeled .dispQsal bags.
.
Work Practice
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
“Name of Pac1lIt
30
-------
M8. Summary
Cleaning resilient asbestos flooring .
Summary This work practice covers the procedures for cleaning (or scrubbing) the
polish on resilient asbestos flooring prior to buffing or application of
additional polish. Do not polish loose or damaged resilient flooring. Any
damage should be repaired before cleaning begins using the applicable
work practice(s). Stop work if any damage occurs during cleaning and
make repairs needed.
Example Level 1: A.
•
Clean or scrub resilient asbestos flooring wit
coats of. floor polish on flooring before
h adequate
buffing or
application of additional polish.
Related Work Practices
.
M6 - Wet strip floor wax from
resilient asbestos flooring
M7 - Dry or spray buffing resilient asbestos flooring
Worker Recommendations
One worker trained in cleaning procedures for asbestos flooring. A person with air
monitoring training might be required. This person can be the worker.
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
1IameofFac1 31
-------
1. Perform Pré-work actMties on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
• tition - Wet Floor signs
Floor scrubbing machine
Pads (least abrasive)
Buckets with mop wringer
Scraper 2-3 (50-75 mm) wide stiff blade
Mops (for scrubbing, rinsing)
Measuring device for mixing chemical cleaner
Walk-off mats
Chemical cleaner
3. Place tools, equipment and materials needed in work area. Place walk-off
mats to prevent tracking of scrubbing solution to other areas. Position
Caution - Wet Floor signs.
4. install polyethylene sheet on adjoining floors for protection from any spilled
cleaning solution.
5. Mix scrubbing chemical with water as recommended by manufacturer and
apply liberal amount (do not flood) using mop. Allow to soak for amount
of time recommended by manufacturer. Keep floor adequately wet by
reapplying cleaning solution if drying occurs. Work small areas at a time.
6. Using floor scrubbing machine, manufacturer’s recommended pads and
operating speed, clean floor to remove embedded dirt and surface marks.
7. Remove spent scrubbing solution with wet vacuum or mop.
8. Rinse area using clean mop and clean rinse water. Remove water with wet
vacuum or mop. Damp mop area to clean up any remaining water or
streaks.
9. Perform applicable steps on Level 1 checklist to complete work.
M8.LeveIl
Cleaning resilient asbestos flooring.
Example Level 1: A. Clean or scrub resilient asbestos flooring with adequate
coats of floor polish on flooring before buffing or
application of additional polish.
Notes
This work practice must be used in conjunction with General
Procedure Wi and a Level 1 Worker Checklist. The worker
work
:
checklist includes tasks that must be performed before
practices are begun.
Work Practice
MISCELLANEOUS ACM . ASBESTOS O&M WORK PRACTICES
‘Name o
32
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M9. Summary
Remove carpet over resilient asbestos flooring.
Summary This work practice describes the procedures to be used for removing a
small area of carpet installed over resilient asbestos flooring for O&M work.
These procedures assume that the carpet adhesive or mastic does not
contain asbestos, and that contamination is not present on the top side of
the carpet. If a large area is involved, the work might require that
abatement procedures be used. If carpet mastic contains asbestos, see
Work Practice Ml. Removal of well-adhered carpet can pull up resilient
asbestos flooring beneath the carpet.
Examples Level I: A. Remove carpet that is non-adhered or weakly adhered
to resilient asbestos flooring.
Level 2: A. Remove carpet adhered to good condition resilient
asbestos flooring where mastic and/or a small number
of ti!es may be pulled up, or flooring may be pulled up
without separation of backing and wear layer. Resilient
flooring mastic may or may not contain asbestos.
Level 3: A. Remove carpet-adhered to poor condition or loose
resilient asbestos flooring and/or mastic that will break,
tear or become friable during removal.
Related Work Practices
Ml -
Replacement
of resilient asbestos floor tiles.
M2 -
Replacement
of vinyl sheet flooring with ACM
backing.
M4 -
Installation of
new resilient flooring or carpet o
ver resilient asbestos
Worker Recommendations
One worker for Level 1 work. One or two workers for Level 2 depending upon
safety and efficiency considerations. Two workers for Level 3.
A person with air monitoring training might be required. This person can be a worker.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
Name D FacilIty’ 33
-------
M9. Level 1
Remove carpet over resilient asbestos flooring.
Example
Level 1: A. Remove carpet that is non-adhered or weakly adhered
Ito resilient asbestos flooring.
Notes
This work practice must be used in conjunction with General
Procedure Wi and a Level I Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Review manufacturer’s recommendation concerning installation of new
carpet over old flooring and/or adhesive before proceeding with this work.
If asbestos-containing adhesive must be removed, refer to wet-scraping
procedures in Work Practice M l.
Use Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
filter needs to be replaced.
Work Practice 1. Perform Pre-work activities on Level I checklist.
2. AdditIonal tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Metal straightedge for use when cutting carpet
Scraper 2 3u (50-75 ‘mm) wide stiff blade
3. Place tools, equipment and materials needed In work area.
4. Find a seam or corner where carpet removal can begin. If no seams or
corners exist; make a cut around the piece to be removed. Cut carpet
using utility knife with a new blade.
5. Pry up corner or seam of carpet using scraper. Pull back a section large
enough (approximately one square foot [ 0.1 m 2 ]) to hang onto while
removing carpet. HEPA vacuum exposed flooring and back of• carpet.
6. Pull carpeting back slowly and HEPA vacuum exposed flooring & back of
carpet. Remove carpet In pieces no larger than 200 square feet (18.6 m 2 ).
7. if carpet and adhesive are non-ACM, roll up carpet and dispose of as non-
ACM waste. if portions of asbestos-containing flooring remain attached to
carpet backing, dispose of carpet as ACM or In accordance with applicable
regulations.
8. HEPA vacuum surface of flooring after carpet is removed. If residual
asbestos-containing adhesive or residual felt backing needs to be removed,
follow wet-scraping procedures In work practice MI or M2, respectively.
Allow substrate to dry before Installing new flooring.
9. Perform clean-up and tear-down steps on Level 1 checklist to complete
work.
MISCELLANEOUS MATERIALS. ASBESTOS O&M WORK PRACTICES
uName of FacIlity’ 34
-------
.M9. Level 2
Remove carpet over resilient asbestos flooring.
Example
Level 2: A. Remove carpet adhered to good condition resilient
asbestos flooring where mastic and/or a small number
full tiles may be pulled up, or flooring might be pulled
.
up without separation of backing and wear layer.
Resilient flooring mastic may or may not contain
asbestos.
Notes
This work practiOe must be used in conjunction with General
ProceduresW1,W4 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun..
Review manufacturer’s recommendation concerning installation of new
carpet over old flooring and/or adhesive before proceeding with this work.
.
If asbestos-containing adhesive must be removed, refer to wet-scraping
procedures in Work Practice Ml. Avoid foot traffic on any exposed mastic.
Work Practice 1. Perform Pre-work activities on Level 2 checklist.
2. AdditIonal tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Scraper 2-3 (50-75 mm) wide stiff blade
Metal straightedge for use when cutting carpet
3. Prepare work area. See General Procedure W4.
4. Place tools, equipment and materials needed into work area.
5. Find a seam or corner wherever carpet removal can begin, If no seams
or corners exist, a cut will need to be made around the piece to be
removed. Wet the areas that need to be cut using amended water. Cut
carpet using utility knife with a new blade.
6. Pry up corner or seam of carpet using scraper. Pull back a section large
enough (approximately one square foot [ 0.1 m 2 J) to hang onto while
removing carpet. Adequately wet flooring and adhesive exposed.
7. Pull carpeting back slowly, and spray amended water on flooring and
adhesive as they are exposed. Remove carpet in pieces no larger than
approximately 200 square feet (18.6 m 2 ).
8. If carpet and adhesive are non-ACM, roll up carpet and dispose of as non-
ACM waste. If portions of asbestos-containing flooring remain attached to
carpet backing, dispose of carpet as ACM. Loose vinyl asbestos flooring
shall be disposed of In disposal bags or containers.
9. HEPA vacuum surface of flooring after carpet is removed. If residual
asbestos-containing adhesive or residual felt backing needs to be removed,
follow wet-scraping procedures in work practice Ml or M2, respectively.
Allow substrate to dry before installing new flooring.
10. Perform clean-up and tear-down steps on Level 2 checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of FacIlity 35
-------
M9.LeveI3
Remove carpet over resilient asbestos flooring.
Example
Level 3: A. Remove carpet adhered to poor condition or loose
resilient asbestos flooring and/or mastic that will break,
tear or become friable during removal.
Notes
This work practice must be used in conjunction with General
Procedures WI, W9 and a Level 3 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Review manufacturer’s recommendation concerning installation of new
carpet over old flooring and/or adhesive before proceeding with this work.
If asbestos-containingresilient flooring adhesive must be removed, refer to
wet-scraping procedures in Work Practice Ml. Avoid foot traffic on any
exposed mastic.
Work Practice 1. Perform Pre-work actMties on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Scraper 2-3 (50-75 mm) wide stiff blade
Metal straightedge for use when cutting carpet
Latex paint In airless sprayer
3. Prepare work area with erect mini-enclosure and set up negative pressure
system. See General Procedure W9.
4. Place tools, equipment and materials needed Into enclosure.
5. If carpet Is, or will be contaminated after removal, spray with latex paint to
encapsulate and discourage reuse.
6. Enter enclosure and find a seam or corner where carpet removal can
begin. If no seams or corners exist, make a cut around the piece to be
removed. Wet the areas that need to be cut using amended water. Cut
carpet using utility knife with a new blade.
7. Pry up corner or seam of carpet using scraper. Pull back a section large
enough (approximately one square foot [ 0.1 m 2 ]) to hang onto while
removing carpet. Adequately wet flooring and adhesive exposed.
8. Pull carpeting back slowly and spray amended water on flooring and
adhesive as they are exposed. Remove carpet In pieces no larger than
area Inside mini-enclosure.
9. If carpet and adhesive are non-ACM, roll up carpet and dispose of as non-
ACM waste. If portions of asbestos-containing flooring remain attached to
carpet backing, dispose of carpet as ACM. Loose vinyl asbestos flooring
shall be disposed of In disposal bags or containers.
10. HEPA vacuum surface of flooring after carpet is removed. If residual
asbestos-containing adhesive or residual felt backing needs to be removed,
follow wet-scraping procedures In work practice Ml or M2, respectively.
Allow substrate to dry before Installing new flooring.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
ame of Pøctl1t 36
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M9.Level a..continued
11. Perform clean-up and tear-down steps on Level 3 checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
i:.
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M1O.Summary
Clean potentially asbestos-contaminated carpet.
Summary This work practice describes the O&M procedures to be used for cleaning
small areas of asbestos-contaminated carpet. If contamination is present
due to a fiber release, see work practice M29.
Note: EPA’S Green Book indicates that routine use of a special cleaning
work practice is’ not required if asbestos-containing dust or debris is not
present and deterioration or daniage to ACM is unlikely. While NIBS is not
recommending its’use as a routine mandatory asbestos control procedure
in this case, the Level .1 work practice is being provided for those
operations and maintenance programs which choose to use it.
Examples Level 1: A. Clean potentially asbestos-contaminated c
has no visible contamination or analytical c
arpet that
onfirmation
of asbestos contamination. ACM in room
is in good
condition.
Level 2: A. Clean carpet that has some visual or
analytical
evidence of asbestos contamination.
Related Work Practices’
M9 - Remove carpet over resilient asbestos flooring. ‘
‘
M4 - Install new resilient flooring or carpet over resilient asbestos flooring.
Worker Recommendations
One worker. A person with air monitoring training might be required. This person can
be the worker.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
‘ Name of Facil y’ 38
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M1O. Level 1
Clean potentially asbestos-contaminated carpet.
Example
Level 1: A. Clean potentially asbestos-contaminated carpet that
has no visib!e contamination or analytical confirmation
of asbestos contamination. ACM in room is in good
condition.
Notes
This work practice must be used in conjunction with General
Procedure WI and a Level I Worker Checklist. . The worker
checklist includes tasks that must be performed before these work
practices are begun.
EPA’s Green Book indicates that routine use of a special cleaning work
practice is not required if asbestos-containing dust or debris is not present
.
and deterioration or damage to ACM is unlikely. While NIBS is not
recommending its use as a routine mandatory asbestos control procedure
in this case, the Level 1 work practice is being provided for those
operations and maintenance programs which choose to use it.
Use Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
filter needs to be replaced.
Work Practice . 1. Perform Pre-work actMties on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Carpet attachment for HEPA vacuum
3. Place tools, equipment and materials needed in work area.
4. HEPA vacuum carpet using carpet attachment.
5. Perform applicable steps on Level 1 checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of FacilIty 39
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M1O..LeveI2
Clean potentially asbestos-contaminated carpet.
Example
Level 2: A. Clean carpet that has some visual or analytical
evidence of asbestos contamination.
Notes
This work practice must be used in conjunction with General
Procedures W1, W4 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice 1. Perform Pre-work actMtles on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
HEPA vacuum with beater bar or carpet steam cleaning
equipment.
3. Prepare work area with critical barriers. See General Procedure W4.
4. Place tools, equipment and materials needed into work area.
5. Clean carpet using one of the following procedures:
A. With HEPA vacuum, vacuum contaminated area In parallel passes
with each pass overlapping the previous by one half the width of
the beater bar. Vacuum the area a second time, in the same
manner, in passes at right angles to the first passes.
B. With steam cleaning equipment, clean carpet in accordance with
manufacturer’s equipment instructions. aean In overlapping
passes in one direction, and then a second time in overlapping
passes at right angles to the first passes. Water from cleaning
operation shall be disposed of In accordance with applicable
regulations. See General Procedure Wi8.
6. Perform clean-up and tear-down steps on Level 2 checklist to complete
work.
MISCELLANEOUS MATERIALS. ASBESTOS O&M WORK PRACTICES
“Name of FacIlity” 40
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Mu . Summary
Remove asbestos-containing ceiling panels in lay-in ceiling
system.
Summary This work practice covers the procedure for removing a small number of
asbestos-containing ceiling panels in a lay-in ceiling system, such as a 2’
x 4’ or 2’ x 2’ (600.x 1200 mm or 600 x 600 mm) suspended ceiling for
O&M work. The practices assume that surfacing ACM is not, present above
the ceiling. If surfacing is present, see work practice Si.
Examples Level I: A. Move one or several panels in good condition that do
not offer resistance to being moved, and where edges
do not abrade.
Level 2: A. Remove several asbestos-containing ceiling panels to
perform maintenance work on or above ceiling where
the panel(s) offer resistance to being moved and/or
the edges are or will be abraded.
Level 3: A. Remove damaged, broken, or soiled asbestos-
containing ceiling panels alone or in conjunction with
maintenance work above ceiling.
Related Work Practices
Si - Move one non-asbestos-containing ceiling panel below a plenum space that has
exposed surfacing ACM.
Ml 2 - Replace asbestos-containing ceiling tiles attached with adhesive.
M13 - Replace asbestos-containing ceiling tiles in spline ceiling system.
Worker Recommendations
One worker for Level 1 work. One or two workers for Level 2 depending upon safety and
efficiency considerations. Two workers for Level 3. A person with air monitoring training
might be required. This person can be a worker.
MISCELLANEOUS MATERIALS. ASBESTOS O&M WORK PRACTICES
‘Name of FaclUt 41
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Mu . Level 1
Remove asbestos-containing ceiling panels in lay-in ceiling
system.
Example
Level I: A. Move one or several panels in good condition that do
not offer resistance to being moved, and where edges
do not abrade.
Notes
This work practice must be used in conjunction with General
Procedure Wi and a Level I Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Coordinate work with 0 & M Work Practice SI if surfacing ACM is present
above ceiling.
Use Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
filter needs to be replaced.
Work Practice 1. Perform Pre-work actMties on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Non-asbestos replacement ceiling panels, If needed.
3. Place tools, equipment and materials needed In work area.
4. Set up ladder or scaffold In work area.
5. If panel will be replaced, remove ceiling panel and place into disposal bag.
If panel will be reinstalled, remove carefully and store for reinstallation.
6. HEPA vacuum area where tile was installed and any suspension system
components exposed where tile was removed.
7. Perform maintenance work and reinstall existing panels or install new
panels.
8. Perform clean-up and tear-down steps on Level 1 checklist to. complete
work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
42
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M11.LeveI2
Remove asbestos-containing ceiling panels in lay-in ceiling
system.
Example
Level 2: A. Remove several asbestos-containing ceiling panels to
perform maintenance work on or above ceiling where
the panel(s) offer resistance to being moved and/or
the edges are or will be abraded.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Coordinate work with 0 & M Work Practice Si if surfacing ACM is present
above ceiling.
Work Practice 1. Perform Pre-work activities on Level 2 checklIst.
‘2. AdditIonal special tools, equipmentand materials: (see General Procedure
Wi for standard tools, equipment and materials list).
Stiff nylon bristle brushes
Non-asbestos replacement ceiling panels, if needed
3. Prepare work area with drop doth. See General Procedure W9.
4. Placo tools, equipment and materials needed onto drop cloth. Set up
ladder or scaffold and adequately wet ceiling panel(s), if panel(s) will be
replaced.
5. If panel(s) will be replaced, remove ceiling panel(s) and place Into disposal
• bag. If panel(s) will be reinstalled, remove carefully and store for
reinstallation.
6. HEPA vacuum area where panel(s) were installed. Wet wipe any
suspension system components exposed where panel(s) were removed.
Use brushes to remove any debris that Is not removed by wet wiping.
Place wet’ wipes and any debris Into disposal bags.
7. Perform clean-up and tear-down steps on Level 2 checklist to complete
work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
‘Name of FacIlity
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M11.LeveI3
Remove asbestos-containing ceiling panels in lay-in ceiling
system.
Example
Level 3: A. Remove damaged, broken, or soiled asbestos-
containing ceiling panels atone or in conjunction with
maintenance work above ceiling.
Notes
This work practice must be used in conjunction with General
Procedures WI, W9 and a Level 3 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Coordinate work with 0 & M Work Practice SI if surfacing ACM is present
above ceiling.
Work Practice 1. Perform P re-work actMties on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Stiff nylon bristle brushes
Non-asbestos replacement ceiling panels, if needed
3. Prepare work area with ereôt mini-enclosure and set up negative pressure
system and/or HEPA filtered local exhaust veAtilation. See General
ProcedureW9.
4. Place tools, equipment and materials needed into enclosure. Enter
enclosure and set up ladder or scaffold Inside enclosure.
5. Adequately wet ceiling panel(s) and remove.
6. HEPA vacuum area where panel(s) were installed. Wet wipe any
suspension system components exposed where panel(s) were removed.
Use brushes to remove any debris that is not removed by wet wiping.
Place wet wipes and any debris into disposal bags.
7. Perform clean-up and tear-down steps on Level 2 checklist to complete
work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
44
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M12 . Summary
Remove asbestos-containing ceiling tiles attached with adhesive.
Summary This work practice covers the O&M procedures for removing a small
number of asbestos-containing ceiling tiles attached with adhesive. These
most commonly are 12’ (13 mm) tiles glued to a substrate such as gypsum
board or plaster. The procedures assume that the tile adhesive does not
contain asbestos.
Examples Level 2: A. Remove ceiling tiles that can be removed a
s whole tiles
without breakage. Small pieces of tile
may remain
attached to adhesive on ceiling.
Level 3: A. Remove ceiling tiles that will break during
removal.
B. Remove badly damaged ceiling tiles.
:
Related Work Practices
Ml I - Remove asbestos-containing ceiling panels in lay-in ceiling system.
M13 - Remove asbestos-containing ceiling tiles in spline ceiling system.
M24 - Remove section of asbestos-containing drywall.
Worker Recommendations
One or two workers for Level 2 depending upon safety and efficiency considerations.
Two workers for Level 3. A person with air monitoring training might be required. This
person can be a worker.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
U 45
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M12. Level 2
Remove asbestos-containing ceiling tiles attached with adhesive.
Example
Level 2: A. Remove ceiling tiles that can be removed as whole tiles
without breakage. Small pieces of tile may remain
attached to adhesive on ceiling.
Notes
•
This work practice must be used in conjunction with General
Procedures W1,W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
:
Work Practice 1. Perform Pre-work actMties on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Non-asbestos replacement ceiling panels and adhesive
Scraper or other tools as needed to remove tiles
3. Prepare work area with drop cloth. See General Procedure W9.
4. Place tools, equipment and materials needed onto drop cloth. Set up
ladder or scaffold on drop cloth.
5. Adequately wet ceiling tiles to be removed.
6. Cut away outer 1/2U (13 mm) of tile on tongue and grove edges. Pry tile
away from substrate to break adhesive bond, remove ceiling tiles and
place Into disposal bags.
7. HEPA vacuum area where tiles were installed. Wet wipe any smooth
finished components exposed where tiles were removed. Use scraper to
remove any remaining adhesive or debris.
8. Install new ceiling tiles and perform clean-up and tear-down steps on Level
2 checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
‘t ame of Fac1lIty
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M12. Level 3
Remove asbestos-containing ceiling tiles attached with adhesive.
Examples
Level 3: A. Remove ceiling tiles that will break during
B. Remove badly damaged ceiling tiles.
removal.
Notes
This work practice must be used in conjunction General
WI and W9 and a Level 3 Worker Checklist.
Procedures
‘.
The checklist includes tasks that must be performed before
practices are used.
these work’
Work Practice 1. Peiform Pre-work activities on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Non-asbestos replacement ceiling panels and adhesive
Scraper or other tools as needed to remove tiles
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system and/or HEPA filtered local exhaust ventilation.
See General Procedure W9.
4. Place tools, equipment and materials needed Into enclosure. Enter
enclosure and set up ladder or scaffold Inside enclosure.
5. Adequately wet ceiling tiles to be removed.
6. Cut away outer 1/2 (13 mm) of tile on tongue and grove edges. Pry tile
away from substrate to break adhesive bond, remove ceiling tiles and
place into disposal bags.
7. HEPA vacuum area where tiles were Installed. Wet wipe any smooth
finished components exposed where tiles were removed. Use scraper to
remove any remaining adhesive or debris. Place wet wipes and debris into
ACM disposal bags.
8. Install new ceiling tiles and perform clean-up and tear-down steps on Level
3 checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
47
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M13. Summary
Remove asbestos-containing ceiling tiles in spline ceiling system.
Summary This work practice covers the O&M procedure for removing small numbers
of asbestos-containing ceiling tiles in a spline ceiling system. Procedures
assume that tile adhesive does not contain asbestos.
Examples Level 1: A. Remove one or several tiles that are designed for easy
removal or have been previously removed. Tiles come
out whole and edges will not be abraded.
Level 2: A. Remove tiles that can be removed as whole tiles
without breakage.
Level 3: A. Remove ceiling tiles that will break during removal.
B. Remove badly damaged ceiling tiles.
Related Work Practices
Ml 1 - Remove asbestos-containing ceiling panels in lay-in ceiling system.
M12 - Remove asbestos-containing ceiling tiles attached with adhesive.
M24 - Remove section of asbestos-containing drywall.
Worker Recommendations
One or two workers for Level 2 depending upon safety and efficiency considerations.
Two workers for Level 3. A person with air monitoring training might be required. This
person can be a worker.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of FaclUt 48
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M13.LeveIl
Remove asbestos-containing ceiling tiles in spline ceiling system.
Example
Level 1: A. Remove one or several tiles that are designed for easy
removal or have been previously removed. Tiles come
out whole and edges will not be abraded.
Notes
This work practice must be used in conjunction with General
Procedure WI and a Level I Worker Checklist.
The checklist includes tasks that must be performed before these work
practices are used.
Coordinate work with 0 & M Work Practice Sl if surfacing ACM is present
above ceiling. Use Work Practice M31 if HEPA vacuum needs
maintenance, or if bag or filter needs to be replaced.
Work Practice 1. Perform Pre-work actMties on Level I checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Non-asbestos replacement ceiling panels and straight pins
3. Place tools, equipment and materials needed in work area.
4. Set up ladder or scaffold.
5. Remove ceiling tiles and place into disposal bags.
6. HEPA vacuum or wet wipe area where tiles were installed and suspension
system components exposed where tiles were removed.
7. Perform clean-up and tear-down steps on Level 1 checklist to complete
work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
‘Name of PacThty°
-------
1. Perform Pre-work activities on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Non-asbestos replacement ceiling panels and straight pins
3. Prepare work area with drop cloth. See General Procedure W9.
4. Place tools, equipment and materials needed onto drop cloth.
5. Set up ladder or scaffold and adequately wet ceiling tiles to be removed.
6. Cut away outer 1/2U (13 mm) of tiles on edges set on splines. Remove
ceiling tiles and place into disposal bags.
7. HEPA vacuum area where tiles were installed. Wet wipe any suspension
system components exposed where tiles were removed.
8. Install new tiles using pins into adjacent tiles to secure in place.
9. Perform clean-up and tear-down steps on Level 2 checklist to complete
work.
M13.LeveI2
Remove asbestos-containing ceiling tiles in spline ceiling system.
Example
Level 2: A. Remove tiles that can be removed as whole tiles
without breakage.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
.
Coordinate work with 0 & M Work Practice Si if surfacing ACM is present
above ceiling.
Work Practice
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
50
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M13.LeveI3
Remove asbestos-containing ceiling tiles in spline ceiling system.
Examples
Level 3: A. Remove ceiling tiles that will break during removal.
B. Remove badly damaged ceiling tiles.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 3 Worker Checklist. ‘The worker
checklist includes’tasks that must be performed before these work
practices are begun.
Coordinate work with 0 & M Work Practice Si if surfacing ACM is present
above ceiling.
Work Practice
1,. Perform Pre-work actMtles on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Non-asbestos replacement ceiling panels and straight pins
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system and/or HEPA filtered local exhaust ventilation.
See General Procedure W9.
4. Place tools, equipment and materials needed Into enclosure. Enter
enclosure and set up ladder or scaffold Inside enclosure.
5. Adequately wet ceiling tiles to be removed.
6. Cut away outer 1/2U (13 mm) of tiles on edges set on spline. Remove
ceiling tiles and place Into disposal bags.
7. HEPA vacuum area where tiles were installed. Wet wipe any smooth’
finished components exposed where tiles were removed.
8. install new tiles using pins into adjacent tiles to secure In place.
9. Perform clean-up and tear-down steps on Level 3 checklist to complete
work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of ac1Ilty
51
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M14. Summary
Cut or drill asbestos cement panels.
Summary This work practice covers the procedures cuthng or drilling asbestos
cement panels.
Examples Level 2: A. Drill asbestos cement board to install a new electrical
panel.
Level 3: A. Cut ‘or drill asbestos cement panel to install a vent
through panel using power tools.
‘
Related Work
Practices
.
M15 - Remove
asbestos
cement.
M23 - Cut or drill asbestos-containing drywall or drywall’compound.
Worker Recommendations ‘ ‘
One worker for Level 2. Two workers for Level 3. A person with air monitoring training
might be required. This person can be a worker. ‘
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
t4am of FacIlity 52
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M14. Level 2
Cut or drill asbestos cement panels.
Example Level 2: A. Drill asbestos cement board to install a new electrical
panel.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice
1. Perform Pre-work actMties on Level 2 checklist.
2. AdditIonal tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Hand or power drill as needed (power tools should have a HEPA
vacuum attachment)
3. Prepare work area with drop cloth. See General Procedure W9. If
accessible, install a drop cloth on the back side of the panel below where
hole will penetrate through panel.
4. Place tools, equipment and materials needed onto drop cloth.
5. Adequately wet both sides of area to be drilled Using garden sprayer with
amended water. Keep water away from any electrical cords or equipment.
6. Drill hole using hand drill or power drill with operating HEPA vacuum
attached. Wet drilling area using amended water.
As options, the following wetting methods/controls may be used:
A. For small holes, a wet sponge can be placed on both sides of the
surface and the hole drilled through the sponges.
B. A HEPA vacuum hose may be used near the bit of a non-HEPA
equipped drill, and on the back side if accessible.
C. Shaving cream can be sprayed on both sides of the drilling area
to control dust and debris. Shaving cream must be wiped up and
disposed of as ACM.
7. Wipe debris off drill using wet disposable towels and place towels into
disposal bag.
8. If back side was enclosed, insert wand of garden sprayer with amended
water into back side enclosure and wet dust or debris. Remove back side
enclosure and place into disposal bag. Wet wipe surfaces that were
exposed inside back side enclosure.
9. Perform maintenance work and clean-up and tear-down steps on Level 2
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
UName of Facility”
53
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1. Perform Pre-work actMties on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Hand or power drill as needed (power tools should have a HEPA
vacuum attachment)
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system and/or HEPA filtered local exhaust ventilation.
See General Procedure W9. If accessible, enclose back side of panel to
catch dust and debris where hole will penetrate through panel.
4. Place tools, equipment and materials needed into enclosure.
5. Enter enclosure and adequately wet both sides of area to be cut or drilled
using garden sprayer with amended water. Keep water away from any
electrical cords or equipment.
6. Cut or drill hole(s) using saw or drill. Power tools should have an
operating HEPA vacuum attached. Wet cutting area during drilling or
cutting using amended water.
As options, the following wetting methods/controls may be used:
A. For small holes, a wet sponge can be placed on both sides of the
surface and the hole drilled through the sponges.
B. A HEPA vacuum hose may be used near the bit of a non-HEPA
equipped drill, and on the back side if accessible.
C. Shaving cream can be sprayed on both sides of the drilling area
to control dust and debris. Shaving cream must be wiped up and
disposed of as ACM.
7. Remove panel piece and wet wipe debris off drill or saw using wet
disposable towels and place towels and debris Into disposal bag.
8. If back side was enclosed, insert wand of garden sprayer with amended
water Into back side enclosure and wet dust or debris. Remove back side
enclosure and place into disposal bag. Wet wipe surfaces that were
exposed Inside back side enclosure.
9. Perform maintenance work and clean-up and tear-down steps on Level 3
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of f tIlt ’
M14. Level 3
Cut or drill asbestos cement panels.
Example Level 3: A. Cut or drill asbestos cement panel to install a vent
through panel using power tools.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 3 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice
54
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M15. Summary
Remove asbestos cement panels.
Summary This work practice covers the procedures for removing a small number of
asbestos cement panels to support O&M work. This procedure can be
used for asbestos cement range hoods.
Examples Level 1: A. Remove corrugated or flat asbestos cement panels that
are painted or in good condition, and have fasteners
that can be easily removed.
Level 2: A. Remove corrugated or flat asbestos cement panels in
fair condition.
Level 3: A. Remove corrugated or flat asbestos cement panels in
poor condition which have become friable and where
dust or powder may be generated during removal.
Related Work Practices
M14 - Cut or drill asbestos cement panels.
Ml 8 - Remove asbestos-containing fire door.
Worker Recommendations
One worker for Level 1 and Level 2. Two workers for Level 3. Panel size may
necessitate two or more workers. A person with air monitoring training might be required.
This person can be a worker.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
55
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M15. Level 1
Remove asbestos cement panels.
Example Level 1: A. Remove corrugated or flat asbestos cement panels that
are painted or in good condition, and have fasteners
that can be easily removed.
Notes
.
This work practice must be used in conjunction with General
Procedure Wi and a Level 1 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
.
practices are begun.
Work Practice 1. Perform Pre-work activities on Level 1 checklist.
2. AdditIonal tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Tools as needed to remove panel fasteners (slatter’s ripper, nail
clipper, screwdriver)
3. Place tools, equipment and materials needed In work area.
4. Adequately wet panels to be removed with amended water. Remove
fasteners holding panel in place. Clean fasteners if they are to be reused.
Dispose of fasteners as ACM If not being reused.
5. Remove panel and wrap In two (2) layers of polyethylene sheet for disposal
as ACM.
6. Perform maintenance work and clean-up and tear-down steps on Level I
checklist to complete work.
MISCELLANEOUS MATERIALS. ASBESTOS O&M WORK PRACTICES
Name 01 Facility 56
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M15. Level 2
Remove asbestos cement panels.
Example
Level 2: A. Remove corrugated or flat cement asbestos panels in
fair condition.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be perfot med before these work
practices are begun.
If activated electrical equipment is in work area, delete wetting (if permitted
by EPA) for this work.
Work Practice i. Perform Pre-work activities on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Tools as needed to remove panel fasteners (slatter’s ripper, nail
clipper, screwdriver)
3. Prepare work area with drop cloth. See General Procedure W9.
4. Place tools, equipment and materials needed onto drop cloth.
5. Adequately wet panel(s) to be removed using garden sprayer with
amended water.
6. Remove fasteners holding panel In place. HEPA vacuum and wet fasteners
as they are removed. Clean fasteners using water If they are to be reused.
Dispose of fasteners as ACM If not being reused.
7. Remove panel and wrap in two (2) layers of polyethylene sheet for disposal
as ACM.
8. HEPA vacuum and wet wipe surfaces to which panel was attached. HEPA
vacuum and wet wipe up any dust or debris from panel removal.
9. Perform maintenance work and clean-up and tear-down steps on Level 2
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of FacilIty’ 57
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M15. Level 3
1. Perform Pre-work actMties ‘on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Tools as needed to remove panel fasteners (slatter’s ripper, nail
clipper, screwdriver)
3. Prepare work area with drop cloth, mini-enclosure and set up negative
pressure system. See General Procedure W9.
4. Place tools, equipment and materials needed into enclosure.
5. Enter enclosure and adequately wet panel(s) to be removed using garden
sprayer with amended water.
6. Remove fasteners holding panel in place. HEPA vacuum and wet fasteners
as they are removed. Clean fasteners using water if they are to be reused.
Dispose of fasteners as ACM if not being reused.
7. Remove panel and wrap In two (2) layers of polyethylene sheet for disposal
as ACM. If panel breaks or chips and small debris results from removal,
collect and dispose of in disposal bags or containers.
8. HEPA vacuum and wet wipe surfaces to which panel was attached. HEPA
vacuum and wet wipe up any dust or debris from panel removal.
9. Perform maintenance work and clean-up and tear-down steps on Level 3
checklist to complete work.
Remove asbestos cement panels.
Example
Level 3: A. Remove corrugated or flat asbestos cement panels in
poor condition which have become friable and where
dust or powder may be generated during removal.
Notes
This work practice must be used in conjunction with General
‘
Procedures Wi, W9 and a Level 3 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
If activated electrical equipment is in work area, delete. wethng (if..permitted
by EPA) for this work. ‘
Work Practice
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
58
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M16. Summary.
Remove cement asbestos cooling towers louvers.
Summary This work practice
tower louvers.
covers the procedures for
asbestos cement cooling
Examples Level 1: A.
Remove asbestos cement
good condition.
cooling
tower louvers
in
Level 2: A.
Remove asbestos cement
poor condition, abraded or
cooling
severely
tower louvers
weathered.
in
Related Work Practices .
.
M15 - Remove asbestos cement
panels.
.
Worker Recommendations
One worker. Two or more for large panels or elevated work areas. A person with air
monitoring training might be required. This person may be a worker.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
NName of Fac1llt 59
-------
M16. Level I
Remove asbestos cement cooling tower louvers.
Example
Level 1: A. Remove asbestos cement cooling tower louvers in
good condition.
Notes
This work practice must be used in conjunction with General
Procedure Wi and a Level I Worker Checklist. The worker
checklist includes tasks that must be performed before these wc rk
practices are begun.
Use
filter
Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
needs to be replaced.
Work Practice 1. Perform Pre-work actMties on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Tools as needed to remove louvers
Non-asbestos replacement louvers
3. Place tools, equipment and materials needed In work area. verify that
cooling tower is shut off and locked out.
4. Remove any fasteners holding louvers In place. HEPA vacuum and wet
fasteners during removal. Clean fasteners for reuse or dispose of as ACM.
5. Remove louvers and place into disposal bags or wrap In polyethylene
sheet for disposal.
6. HEPA vacuum surfaces louvers were contacting and any dust or debris
from louver removal.
7. Perform maintenance work and clean-up and tear-down steps on Level 1
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
‘Name of Facility” 60
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M16.LeveI2
Remove asbestos cement cooling tower louvers.
Example
Level
.
2: A. Remove asbestos cement cooling tower louvers in
poor condition.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be pe 1ormed before these work
practices are begun.
Work Practice 1. Perform Pre-work actMties on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Tools as needed to remove louvers
Non-asbestos replacement louvers
3. Prepare work area with drop cloth. Verify that cooling tower Is shut off
and locked out. See General Procedure W9.
4. Place tools, equipment and materials needed onto drop cloth.
5. Adequately wet louvers to be removed.
6. Remove any fasteners holding louvers In place. HEPA vacuum and wet
fasteners during removal. Clean fasteners for reuse or dispose of as ACM.
7. Remove louvers and place Into disposal bags or wrap In polyethylene
sheet for disposal. Collect any large broken pieces or chips and place into
disposal bags.
8. HEPA vacuum and wet wipe surfaces that louvers were contacting. HEPA
vacuum and wet wipe up any debris or dust from louver removal.
9. Perform maIntenance work and clean-up and tear-down steps on Level 2
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
‘Name of F ac1llty’ 61
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M17 . Summary
Remove or replace asbestos cement roof shingles.
Summary This work practice covers the procedures for removing or replacing a small
number of asbestos cement shingles from the roof of a building to support
O&M work.
Examples Level 1: A. Replace or remove a sñiall number of asbestos cement
roof shingles in good condition that are loose or can
be removed with minimal breakage to perform
patching, repair work, or install new vent or stack.
Level 2: A. Replace or remove asbestos cement root sningies that
are damaged and may become friable during removal.
Related Work Practices
M14 - Cut or drill asbestos cement panels.
M15 - Remove asbestos cement panels.
M18 - Remove and replace asbestos cement siding.
M22 - Remove asbestos-containing built-up roofing.
Worker Recommendations
One worker is usually sufficient. Two or more workers may be needed to increase
efficiency or for additional health and/or safety considerations. A person with air
monitoring training might be required. This person can be a worker.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of FacilIty’ 62
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M17. Level 1
Remove or replace asbestos cement roof shingles.
Example
Level 1: A. Replace or remove a small number of asbestos cement
roof shingles in good condition that are loose or can
be removed with minimal breakage to perform
patching, repair work, or install new vent or stack.
Notes
This work practice must be used in conjunction with General
Procedure WI and a Level I Worker Checklist. The worker
checklist includes tasks that must be. performed before these work
practices are begun.
Usö of a safety harness is strongly recommended for working on. sloped
roofs. Roofing removal work shall be completed before any penetrations
are made in the roof deck.
Use Work Practice M31 if HEPA vacuum needs maintenance; or if bag or
filter needs to be replaced..
Work Practice 1. Perform Pre-work activities on Level 1 checklist.
2. Additional tools, equipment and materials: (see Geheral Procedure Wi for
standard tools, equipment and materials list).
Pry bars, slatter’s ripper and/or nail clipper
Non-slip boots for roofing work
Safety harness
Replacement roofing
Hammer
Spray encapsulant (if used)
3. Place tools, equipment and materials needed In work area. If desired,
spray encapsulant on shingles prior to start of removal.
4. Starting at top of removal area, remove nails, cut nails or pry up edge of
first shingle until edges can be gripped by hand. Remove shingle and
place Into disposal bags or polyethylene lined cardboard boxes and lower
to ground level.
5. Continue removing shingles using procedures in step 4.
6. Clean up any debris or dust using wet wiping or HEPA vacuum.
7. Perform maintenance work and clean-up and tear-down steps on Level I
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of FacllitV’ 63
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M17. Level 2
Remove or replace asbestos cement roof shingles.
Example
Level 2: A. Replace or remove asbestos cement roof shingles that
are damaged and may become friable during removal.
Notes
This work practice must be used in conjunction with General
.
Procedures Wi, W4, W9 and a Level 2 Worker Checklist. The
worker checklist includes tasks that must be performed before these
work practices are begun.
Use of a safety harness is strongly recommended for working on sloped
roofs. Roofing removal work shall. be completed before any penetrations
are made in the roof deck.
Work Practice 1. Perform Pre-work actMties on Level 2 checklist.
2. AddItional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Pry bars, slatter’s ripper and/or nail clipper
Non-slip boots for roofing work
Safety harness
Replacement roofing
Hammer
Spray encapsulant (If used)
3. Prepare work area with barrier tape and drop cloth. See General
Procedures W4 and W9. Drop cloth should be below removal area to
catch any debris generated during removal. Seal any roof penetrations, air
intakes or windows in work area with polyethylene. Do not seal over
plumbing vent stacks.
4. Place tools, equipment and materials needed Into work area.
5. if feasible, safe and desired, encapsulate or adequately wet shingles to be
removed.
6. Starting at top of removal area, remove nails, cut nails or pry up edge of
first shingle until edges can be gripped by hand. Spray amended water on
back of shingle. Remove shingle and place Into disposal bags or
polyethylene lined cardboard boxes.
7. continue removing shingles using procedures in step 6.
8. clean up any debris or dust using HEPA vacuuming and wet wiping.
9. Perform maintenance work and clean-up and tear-down steps on Level 2
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of Fac1lit
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M18.Summary
Remove and replace asbestos-cement siding shingles.
Summary This work practice covers the procedures for removing small amounts of
asbestos cement siding shingles from the exterior of a building to support
O&M work.
Examples Level 1: A. Replace or remove a small number of asbestos cement
siding shingles in good co 1 idition that are loose or can
be removed with minimal breakage to perform
patching, repair work, or to install a new window or
door.
Level 2: A. Replace or remove asbestos cement siding shingles
that are sufficiently damaged and may become friable
during removal.
Related Work Practices
M14 - Cut or drill asbestos cement panels.
M15 - Remove cement asbestos panels.
M17 - Remove and replace asbestos cement shingles.
M22 - Remove asbestos-containing built-up roofing.
Worker Recommendations
One worker is usually sufficient. Two or more workers may be needed to increase
efficiency or for additional health and/or safety considerations. A person with air
monitoring training might be required. This person can be a worker.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
65
-------
M18.Level1
Remove and replace asbestos-cement siding shingles.
Example
Level 1: A. Replace or remove a small number of asbestos cement
siding shingles in good condition that are loose or can
be removed with minimal breakage to perform
patching, repair work, or to install a new window or
door.
Notes
This work practice must be used in conjunction with General
.
Procedure Wi and a Level I Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Use
filter
Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
needs to be replaced.
Work Practice 1. Perform Pre-work activities on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Pry bars, slatter’s ripper and/or nail clipper
Replacement siding, If required
Spray encapsulant (if used)
3. Place tools, equipment and materials needed in work area and set up
ladder or scaffold If needed. If desired, spray encapsulant on siding
panels.
4. Starting at top of removal area, remove nails, cut nails or pry up edge of
first panel until edges can be gripped by hand. Remove panel and place
into disposal bags or polyethylene lined cardboard boxes and lower to
ground level.
5. Continue removing panels using procedures in step 4.
6. Clean up any debris or dust using wet wiping or HEPA vacuum.
7. Perform maintenance work and clean-up and tear-down steps on Leve! 1
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
-------
M18. Level 2
Remove and replace asbestos cement siding shingles.
Example Level 2: A. Replace or remove asbestos cement siding shingles
that are sufficiently damaged and may: become friable
during removal.
Notes
This work practice must be used in conjunction with General
Procedures WI, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice 1. P rform Pre-work activities on Level 2 checklist.
2. AdditIonal tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Pry bars, slatter’s ripper and/or nail clipper
Replacement siding, if required
Spray encapsulant (if used)
3. Prepare work area with drop cloth. See General Procedure W9. Drop
cloth should be below removal area to catch any debris generated during
removal. Set up !adder or scaffold If needed. Seal over any penetrations.
air Intakes or windows In work area with polyethylene. Do not cover over
exhaust vents.
4. Place tools, equipment and materials needed onto drop cloth.
5. Apply spray encapsulant, to or adequately wet siding to be removed.
6. StartIng at top of removal area, remove nails, cut nails or pry up edge of
first panel until edges can be gripped by hand. Spray amended water on
back of panel. Remove panel and place Into disposal bags or polyethylene
lined cardboard boxes and lower to ground level.
7. Continue removing panels using procedures In step 6.
8. Clean up any debris or dust using HEPA vacuuming and wet wiping.
9. Perform maintenance work and dean-up and tear-down steps on Level 2
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
67
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M19 . Summary
Remove high-temperature resistant (HTR) asbestos cement
panels.
Summary This work practice covers the procedures for removing small amounts of
high temperature resistant asbestos panels for maintenance work. These
panels typically have a high asbestos content.
Examples Level 1: A. Remove HTR asbestos cement panels in good
condition that can be removed with minimal breakage.
Level 2: A. Remove HTR asbestos cement panels -that are
damaged and may become friable during removal.
Level 3: A. Remove HTR asbestos cement panels in poor and
friable condition inside a mini-enclosure.
Related Work Practices
M14 - Cut or drill asbestos cement panels.
M15 - Remove asbestos cement panels.
M17 - Remove and replace asbestos cement shingles.
M22 - Remove asbestos-containing built-up roofing.
Worker Recommendations
One worker for Level 1 work. One or two workers for Level 2 depending upon safety and
efficiency considerations. Two workers for Level 3. A person with air monitoring training
might be required. This person can be a worker.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
‘Name of Facility’ 68
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M19. Level 1
Remove high temperature resistant (HTR) asbestos cement
panels.
Example
Level. 1: A. Remove HTR asbestos cement panels in good
condition that can be removed with minimal breakage.
Notes
Use
filter
This work practice must be used in conjunction with General
Procedure WI and a Level I Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
needs to be replaced.
Work Practice 1. Perform Pre-work activities on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Tools needed to remove panels and fasteners
Spray encapsulant (if used)
3. Place tools, equipment and materials needed In work area and set up
ladder or scaffold if needed. If desired, spray amended water or
encapsulant on panels before starting removal.
4. Remove fasteners securing panels In place. Wet fasteners during removal.
Remove panels and place Into disposal bags or wrap In polyethylene.
5. Clean up any debris or dust using wet wiping or HEPA vacuum.
6. Perform maintenance work and clean-up and tear-down steps on Level 1
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of FacThIy” 69
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M19. Level 2
Remove high temperature resistant (HTR) asbestos cement
panels.
Example
Level 2: A. Remove HTR asbestos cement panels that are
damaged and may become friable during removal.
Notes
•
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice 1. Perform Pre-work activities on Level 2 checklist.
2. Additional tools, equipment and materials: .. (see General
Procedure Wi for standard tools, equipment and materials
list).
Tools needed to remove panels and fasteners.
Spray encapsulant (if used)
3. Prepare work area with drop cloth. See General Procedure
W9. Drop cloth should be below removal area to catch any
debris generated during removal. Set up ladder or scaffold if
needed.
4. Place tools, equipment and materials needed onto drop cloth.
5. Adequately wet panels to be removed using spray
encapsulant or amended water.
6. Remove fasteners securing panels in place. Wet or HEPA
vacuum fasteners during removal. Pull panel away slightly,
spray amended water on back of panel, remove panel and
place into disposal bags or wrap in polyethylene..
7. Clean up any debris or dust using HEPA vacuuming and wet
wiping.
8. Perform maintenance work and clean-up and tear-down steps
on Level 2 checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
Name of FacThty’ 70
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M19LeveI3
Remove high temperature resistant (HTR) asbestos cement
panels.
Example Level 3: A. Remove HTR asbestos cement panels in poor and
friable condition inside a mini-enclosure.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 3 Worke: Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice i. Perform Pre-work actMties on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Tools needed to remove panels and fasteners
Spray encapsulant (if used)
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system. See General Procedure W9.
4. Place tools, equipment and materials needed into enclosure. Set up ladder
or scaffold if needed.
5. Enter enclosure and adequately wet panels to be removed using spray
encapsulant or amended water.
6. Remove fasteners holding panels In place. Wet or HEPA vacuum fasteners
during removal. Pull panel away slightly, spray amended water on back
of panel, remove panel and place Into disposal bags or polyethylene lined
cardboard boxes. Spray any loose or broken panel pieces with amended
water and place into disposal bags.
7. Clean up any debris or dust using HEPA vacuuming and wet wiping.
8. Perform maintenance work and clean-up and tear-down steps on Level 3
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of Facility” 71
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M20. Summary
Remove asbestos-containing chalk board.
Summary This work practice describes the work required to remove a chalkboard that
is made of asbestos-containing material.
Examples Level 1:
.
A.
Remove asbestos-contaihing chalkboard that is non-
adhered and easily removed.
Level 2:
A.
Remove asbestos-containing chalkboard that is
adhered or may generate minor debris from removal.
Level 3:
A.
Remove asbestos-containing chalkboard that is in poor
condition or strongly adhered to wall.
Related
Work Practices
•
.
None
Worker. Recommendations .
One worker for small boards or mechanically attached units. Two workers for larger
boards or adhered units. A person with air monitoring training might be required. This
person can be a worker.
MISCELLANEOUS MATERIALS. ASBESTOS O&M WORK PRACTICES
‘ Name ot Fac tlt 72
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M20. Level 1
Remove asbestos-containing chalk board.
Example
Level 1: A. Remove asbestos-containing chalkboard that is non-
adhered and easily removed.
Notes
This work practice must be used •in conjunction with General
Procedure Wi and a Level 1 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
:
practices are begun.
Use Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
filter needs to be replaced.
Work Practice 1. Perform Pre-work activities on Level 1 checklIst.
2. AdditIonal tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Scraper 2-3 (50-75 mm) wide stiff blade
Stiff nylon bristle brushes
3. Place tools, equipment and materials needed in work area.
4. Adequately wet chalkboard unit using garden sprayer with amended water.
Spray water around sides of board and at Joint between wall and top of
board to wet any debris behind board.
5. Remove any fasteners or moldings attaching board to wall and remove
board. Some boards lift up out of a supporting tray or off of supporting
• clips to remove. Wrap board In two layers of polyethylene sheet for
disposal. If board Is adhered to wall, a Level 2 or 3 procedure should be
performed.
6. HEPA vacuum surface that board was attached to.
7. Perform clean-up and tear-down steps on Level 1 checklist to complete
• work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of FacIlity 73
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M20. Level 2
Remove asbestos-containing chalk board.
Example
Level 2: A. Remove asbestos-containing chalkboard that is
adhered or may generate minor debris from removal.
Notes
.
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice i. Perform Pre-work actMties on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Scraper 2-3 (50-75 mm) wide stiff blade
Stiff nylon bristle brushes
Crow bar and screwdrivers
• 3. Prepare work area with drop cloth. See General Procedure W9.
4. Place tools, equipment and materials needed onto drop cloth.
• 5. Adequately wet chalkboard unit using garden sprayer with amended water.
Spray water around sides of board and at Joint between wall and top of
board to wet any debris behind board.
6. Remove any fasteners or moldings attaching board to wall and remove
board. Some boards lift up out of a supporting tray or off of supporting
clips to remove. If board Is adhered to wail, use screwdrivers or crow bar
to remove board. Wet adhesive (using amended water) while prying board
off wall. Wrap board in two layers of polyethylene sheet for disposal.
7. If board was attached with adhesive, wet and scrape remaining adhesive
off wail.
8. Wet wipe and HEPA vacuum surface that board was attached to.
9. Perform clean-up and tear-down steps on Level 2 checklist to complete
work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
‘Name of l aculIty ’ 74
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M20. Level 3.
Remove asbestos-containing chalk board.
Example
Level
.
3: A. Remove asbestos-containing chalkboard that is in poor
condition or strongly adhered to wall.
Notes
.
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 3 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice . 1. Perform Pre-work actMties on Level 3 checklist.
2. AdditIonal tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Scraper 2-3 (50-75 mm) wide stiff blade
Stiff nylon bristle brushes
Crow bar and screwdrivers
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system. See General Procedure W9. Enclosure must
be large enough to lay board on floor and wrap for disposal.
4. Place tools, equipment and materials needed Into enclosure.
5. Enter enclosure and adequately wet chalkboard unit using garden sprayer
with amended water. Spray water around sides of board and at Joint
between wail and top of board to wet any debris behind board.
6. Remove any fasteners or moldings attaching board to wall and remove
board. Some boards lift up out of a supporting tray or off of supporting
clips to remove. If board Is adhered to wall use screwdrivers or crow bar
to remove board. Wet adhesive using amended water while prying board
off wall. Wrap board In two layers of polyethylene sheet for disposal.
7. If board was attached with adhesive, wet and scrape remaining adhesive
off wall.
8. Wet wipe and HEPA vacuum surface that board was attached to.
9. Perform clean-up and tear-dOwn steps on Level 3 checklist to complete
work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of facULty ” 75
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M21.. Summary
Remove asbestos-containing fire door and/or door hardware.
Summary This procedure sets forth the O&M work procedures to remove an
asbestos-containing fire door or door hardware in an asbestos-containing
fire door. Cutting or drilling into asbestos containing doors are included as
Level 3 work.
Examples Level 1: A. Remove asbestos-containing fire door that is in good
condition for replacement.
B. Replace lockset or closer on asbestos-containing fire
door in good condition. Lockset does not penetrate
asbestos core of door.
Level 2: A. Remove asbestos-containing fire door that is damaged.
B. Replace lockset or closer on asbestos-containing fire
door in poor condition. Lockset may penetrate
asbestos core of door.
Level 3: A. Cut a door to install new window.
B. Drill hole for new lockset through asbestos core of
door.
Related Work Practices
None
Worker Recommendations
One worker for Level 1 and Level 2. Two workers may facilitate handling of heavy doors
being removed. Two workers for Level 3. A person with air monitoring training might be
required. This person can be a worker.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
Hame i f Fac1litv 76
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M21 . Level 1
Remove asbestos-containing fire door and/or door hardware.
Examples
Level 1: A. Remove asbestos-containing fire door that is in good
condition for replacement.
.
B. Replace lockset or closer on asbestos-containing fire
door in good condition. Lockset does not penetrate
asbestos core of door.
Notes
This work practice must be used in conjunction with General
Procedure Wi and a Level 1 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Use
filter
Work Practice M31 if HEPAvacuum needs maintenance, or if bag or
needs to be replaced.
Work Practice 1. Perform Pre-work activities on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Screwdriver and tools needed for hardware or door removal
3. Place tools, equipment and materials needed in work area.
4. If door Is equipped with a closer, detach doser arm from door frame.
Remove screws attaching closer to door. HEPA vacuum or wet clean
screws, closer, and area where closer was attached to door. Thoroughly
clean closer and parts if they will be re-used. If closer will not be re-used,
dispose of as ACM waste.
5. Remove iockset from door using procedures used for closer. HEPA or wet
wipe vacuum lockset if it will be re-used or dispose of as ACM waste.
6. Lay two layers of polyethylene sheet on floor for wrapping door.
7. Remove hinge pins or screws attaching hinges to door frame. Lay door
on polyethylene.
8. If hinges are to be re-used, remove from door following procedures used
for closer. If hinges are to be disposed of, leave hinges attached to door.
9. Wrap door for disposal.
10. Perform clean-up and tear-down steps on Level 1 checklist to complete
work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
77
-------
M21 . Level 2
Remove asbestos-containing fire door and/or door hardware.
Examples Level 2: A. Remove asbestos-containing fire door that is damaged.
B. Replace lockset or closer on asbestos-containing fire
door in poor condition. Lockset may penetrate
asbestos core of door.
Notes
This work practice must be used in conjunction with General
Procedures WI, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice i. Perform Pre-work actMtles on Level 2 checklIst.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Screwdrivers and toots needed for hardware and door removal
3. Prepare work area with drop doth. •See General Procedures.
4. Place tools, equipment and materials needed on drop cloth.
5. Wet any damaged areas with amended water.
6. If door is equipped with a closer, detach closer arm from door frame. Wet
closer and area where closer Is attached to door using amended water.
Remove screws attaching closer to door. Wet screws during removal and
area behind closer once all screws are removed. HEPA vacuum and wet
wipe closer and screws If It Is to be re-used. If closer and screws will not
be re-used, dispose of as ACM waste.
7. Remove tockset from door using procedures used for closer. HEPA
vacuum lockset If It will be re-used or dispose of as ACM waste.
8. Lay two layers of polyethylene sheet on floor for wrapping door.
9. Remove hinge pins or screws attaching hinges to door frame. Lay door
on polyethylene.
10. If hinges are to be re-used, remove from door following procedures used
for closer. If hinges are to be disposed of, leave hinges attached to door.
11. Wrap door for disposal.
12. Perform clean-up and tea .down steps on Level 2 checklist to complete
work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
uName Of Iac1IIty 78
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M21 . Level 3
Remove asbestos-containing fire door and/or door hardware.
Examples Level 3: A. Cut a door to install new window.
B. Drill hole for new lockset through asbestos core of
door.
Notes
This work practice must be used in conjunction with General
Procedures Wi W9 and a Level 3 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice 1. Perform Pre-work actMties on Level 3 checklist
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Tools needed to cut or drill door, with HEPA filtered dust collection
attachment If possible.
New lockset or window
3. Prepare work area with drop, erect mini-enclosure and set up negative
pressure system and/or HEPA filtered local exhaust ventilation. See
General Procedure W9. Enclosures can be Installed at door location, or
door can be removed and taken Into an enclosure.
4. Place tools, equipment and materials needed Into enclosure.
5.’ Wet area where hole will be cut or drilled.
6. Cut or drill door as required. Wet cutting or drilling location during work.
7. Place cut piece of door or debris from drilling Into ACM disposal bags.
HEPA vacuum or wet wipe new hole area and clean up any debris.
8. Install window or lockset and perform clean-up and tear-down steps on
Level 3 checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
TM Name of EâcThty 79
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M22 . Summary
Remove asbestos-containing built-up roofing.
Summary This work practice explains the work required to remove a small amount of
asbestos-containing built-up roofing or flashing for maintenance or repair
work.
Examples Level 1: A. Remove small section of damaged asbestos-containing
built-up roofing to perform patching, repair or install
equipment.
Level 2: A. Remove small section of asbestos-containing, built-up
roofing which is damaged to the extent that it has
become friable.
Related Work Practices
M17 - Remove and replace asbestos cement roof shingles.
M23 - Remove asbestos-containing asphalt shingles.
Worker Recommendations
One worker is usually sufficient. Two or more workers may be needed to increase
efficiency or for additional health and/or safety considerations. A person with air
monitoring training might be required. This person can be a worker.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
i’Zame of Fadlllt 80
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M22. Level 1
Remove asbestos-containing built-up roofing.
Example
Level 1: A. Remove small section of damaged asbestos-containing
built-up roofing to perform patching, repair or install
equipment.
Notes
This work practice must be used in conjunction with General
Procedure Wi and a Level 1 Worker CheckliQt. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Use fall prevention measures (including safety harnesses, a warning line
system with safety monitor, and/or a motion stopping system) as required
by OSHA for roofing work. Roofing removal work shall be completed before
any penetrations through the roof deck are made. Coordinate work with 0
& M Work Practice S7 if surfacing is present on underside of deck.
Use Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
filter needs to be replaced.
Work Practice 1. Perform Pre-work activities on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure WI for
standard tools, equipment and materials list).
Safety harness/warning line system and/or motion stopping
system
Hook knife
Garden sprayer with amended water
Scraper 2-3m (50-75 mm) wide stiff blade
Replacement roofing materials and tools
Rope for lowering bags
3. Place tools, equipment and materials needed in work area. If feasible and
safe, adequately wet roofing to be removed. The use of wetting and
amended water for roofing work should limited for the following reasons:
A. Wet roofing can create slip hazards
B. Roofing mastic/cool tar/bitumen will not adhere to wet surfaces.
C. Water can damage materials below the roof membrane.
However, regulations (such as NESHAP) require that RACM be adequately
wet In disposal bags or containers.
4. Cut around area to be removed using hand tools. Note that several layers
may be present.
5. Scrape up roofing and place Into disposal bags. Remove any remaining
roofing debris In removal area using scraper and place into disposed bags.
Lower bags to ground.
6. HEPA vacuum or wet wipe removal area. Use HEPA vacuum where
needed to clean up ACM. It may not be appropriate or necessary to use
HEPA vacuum on non-ACM.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
‘1 ame of Faculty 81
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M22 - Level 1...continued
7. Perform maintenance/repair work and clean-up and tear-down steps on
Level 1 checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
‘Name of FacIlity’ 82
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M22. Level 2
Remove asbestos-containing built-up roofing.
Example
Level 2: A. Remove small section of asbestos-containing built-up
° which is damaged to the extent that it has
become friable.
Notes
This work practice must be used in conjunction with General
Procedures WI, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Use fall prevention measures ncluding safety harnesses, a warning line
system with safety monitor, and/or a motion stopping system) as required
by OSHA for roofing work. Roofing removal Work shall be completed before
any penetrations through the roof deck are made. Coordinate work with 0
& M Work Practice S7 if surfacing ACM is present on underside of deck.
Work Practice i. Perform Pre-work actMtles on Level 2 checklIst.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Safety harness/warning line system and/or motion stopping.
system
Hook knife
Scraper 2-3” (50.75 mm) wide stiff blade
Replacement roofing materials and tools
Rope for lowering bags
3. Prepare work area with barrier tape and seal any windows, HVAC units, air
Intakes or other openings that could allow fibers from work area Into
building - See General Procedure W4. Do not seal any plumbing vents In
work area.
4. Place tools, equipment and materials needed In work area.
5. If feasible and safe, adequately wet roofing to be removed using garden
sprayer with amended water. The use of wetting and amended water for
roofing work should limited for the following reasons:
A. Wet roofing can create slip hazards.
B. Roofing mastic/cool tar/bituman will not adhere to wet surfaces.
C. Water can damage materials below the roof membrane.
However, regulations (such as NESHAP) require that RACM be adequately
wet in disposal bags or containers.
6. Cut around area to be removed using hand tools. Wet cutting area using
amended water. Note that several layers may be present.
7. Scrape up roofing section and place into disposal bags. Wet and remove
any roofing debris In removal area using scraper. Lower bags to ground.
8. HEPA vacuum or wet wipe removal area. Use HEPA vacuum where
needed to clean up ACM. It may not be appropriate or necessary to use
HEPA vacuum on non-ACM.
9. Perform maintenance/repair work and clean-up and tear-down steps on
Level 2 checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of FacIlity 83
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M23 . Summary
Remove asbestos-containing asphalt shingles.
Summary This work practice describes the work required to remove a small number
of asbestos-containing shingles for maintenance or repair work.
Examples Level 1: A. Remove asbestos-containing asphalt shingles to install
a new vent stack.
Level 2: A. Remove asbestos-containing asphalt shingles in poor
condition to repair roof leak. Shingles are damaged to
the extent that they have become friable..
Related Work Practices
M17 - Remove and replace asbestos cement roof shingles.
M22 - Remove asbestos-containing built-up roofing.
Worker Recommendations
One worker is usually sufficient. Two or more workers may be needed to increase
efficiency or for additional health and/or safety considerations. A person with air
monitoring training might be required. This person can be a worker.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
Name f FacTh
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M23. Level 1
Remove asbestos-containing asphalt shingles.
Example
Level 1: A. Remove asbestos-containing asphalt shingles to install
a new vent stack.
Notes
This work practice must be used in conjunction with General
Procedure Wi and a Level 1 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Use fall prevention measures nctuding safety harnesses, a warning line
system with safety monitor, and/or a motion stopping system) as required
by OSHA for roofing work. Roofing removal work shall be completed before
any penetrations are made in the roof deck.
Use Work Practice M31 if HEPA vacuum needs maintenance, or if bag. or
filter needs to be replaced.
Work Practice i. Perform Pre-work actMties on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Garden sprayer with amended water
Scraper 2.3u (50.75 mm) wide stiff blade
Roofing repair materials (shingles, roofing cement, nails)
Hammer
Pry bar
Safety harness/warning line system and/or motion stopping
system
Non-slip boots
Spray encapsulant (if used)
3. Place tools, equipment and materials needed in work area. If feasible and
safe, adequately wet shingles to be removed with amended water or
encapsulant. The use of wetting and amended water for roofing work
should limited for the following reasons:
A. Wet roofing can create slip hazards.
B. Roofing mastic/cool tar/bituman will not adhere to wet surfaces.
C. Water can damage materials below the roof membrane.
However, regulations (such as NESHAP) require that RACM be adequately
wet In disposal bags or containers.
4. Slide scraper under bottom shingle and twist scraper to break shingle seal.
Remove entire shingle or sections of 3-Tab type shingles. Perimeter of
removal area must have clean, straight vertical cuts to allow installation of.
new shingles. Note that several layers may be present.
5. Continue removing shingles one at a time following the steps used for the
first shingle until area needed Is removed. Place all shingles into disposal
bags.
6. Pry up tabs on shingles Immediately above removal area to facilitate
installing new shingles.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of FacTht 85
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M23. Level 1...continued
7. HEPA vacuum or wet wipe removal area. Use HEPA vacuum where
needed to clean up ACM. Do not use HEPA vacuum on fibrous non-
asbestos containing materials (such as fiberglass roof insulation) unless
necessary.
8. Perlorm maintenance work and dean-up and tear-down steps on Level 1
checklist to complete work. Use roofing cement on tabs of existing
shingles to seal them to new shingles.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
Name of FaclliW 86
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M23. Level .2
Remove asbestos-containing asphalt shingles.
Example
.
Level 2: A. Remove asbestos-containing asphalt shingles in poor
condition to repair roof leak. Shingles are damaged to
the extent that they have become friable.
Notes
.
This work practice must be used in conjunction with General Procedures
WI, W9 and a Level 2 Worker Checklist The worker checklist includes
tasks that must be performed before these work practices are begun.
Use fall prevention measures (including safety harnesses, a warning line
system with safety monitor, and/or a motion stopping system) as required
by OSHA for roofing work. Roofing removal work shall be completed before
any penetrations are made in the roof leak.
Work Practice 1. Perform Pre-work actMties on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Scraper 2-3 (50-75 mm) wide stiff blade
Roofing repair materials (shingles, roofing cement, nails)
Hammer
Pry bar
Safety harness/warning line system and/or motion stopping
system
Non-slip boots
Spray encapsulant (if used)
3. Prepare work area with barrier tape and seal .over any windows, HVAC
units, air Intakes or other openings that could allow fibers from work area
Into building. See General Procedure W4. Do not seal over any plumbing
vents in work area.
4. Place tools, equipment and materials needed In work area.
5. If feasible and safe, adequately wet area of shingles to be removed with
amended water or encapsulant. The use of wetting and amended water
for roofing work should be limited for the following reasons:
A. Wet roofing can create slip hazards.
B. Roofing mastic/cool tar/bituman will not adhere to wet surfaces.
C. Water can damage materials below the roof membrane.
However, regulations (such as NESHAP) require that RACM be adequately
wet in disposal bags or containers.
6. Slide scraper under bottom shingle and twist scraper to break shingle seal.
Remove entire shingle or sections of 3-Tab type shingles. Wet underside
of shingles as they are removed. Perimeter of removal area must have
clean, straight vertical cuts to allow installation of new shingles. Note that
several layers may be present.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name c i FaCil ( 87
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M23 - Level 2....continued
7. Continue removing shingles one at a time following the steps
used for the first shingle until area needed is removed. Place
all shingles into disposal bags.
8. Pry up tabs on shingles immediately above, removal area to
facilitate installing new shingles.
9. HEPA vacuum or wet wipe removal area. Use HEPA vacuum
where needed to clean up ACM. It may not be appropriate or
necessary to use HEPA vacuum on non-ACM.
10. Perform maintenance work and clean-up and tear-down steps
on Level 2 checklist to complete work. Use roofing cement
on tabs of existing shingles to. seal them to new shingles.
MISCELLANEOUS MATERIALS. ASBESTOS O&M WORK PRACTICES
88
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M24. Summary
Cut or drill asbestos-containing drywall, plaster or drywall
compound.
Summary This work practice covers the procedures for cutting or drilling of asbestos-
containing drywall or plaster. Joint compounds and tape are also covered
by this procedure.
Examples Level 2: A. Install new electrical receptacle or ceiling junction box
in asbestos-containing drywall or plaster using hand
tools.
B. Drill holes to attach conduit to asbestos-containing
drywall or plaster using non-powered hand tools.
C. Drill holes in asbestos-containing joint compound
where drywall or plaster is non-asbestos.
Level 3: A. Install conduit or ductwork through asbestos-
containing drywall or plaster using power tools.
Related Work Practices
M14 - Cut or drill asbestos. cement panels.
M15 - Remove .asbestos cement panels.
Worker Recommendations
One worker is usually sufficient for Level 2. Two workers for Level 3. Two workers may
be needed to increase efficiency or for additional health and/or safety considerations.
Workers should be trained in working with drywall and asbestos. A person with air
monitoring training might be required. This person can be a worker.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
‘Name of Padlllty ’ 89
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M24. Level 2
Cut or drill asbestos-containing drywall, plaster or drywall
compound.
Examples
Level 2: A. Install new electrical receptacle or ceiling junction box
in asbestos-containing drywall or plaster using hand
tools.
B. Drill holes to attach conduit to asbestos-containing
.
drywall or plaster using non-powered hand tools.
C. Drill holes in asbestos-containing joint compound
where drywall or plaster is non-asbestos.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
It is important that this work practice be validated to determine if it provides
the desired degree of worker and environmental protection. Level 3 might
be necessary to perform this activity. Appendix G to OSHA regulation 29
CFR 1926.58 states: “The training program for the maintenance engineering
staff should describe methods of handling asbestos-containing materials as
well as routine maintenance activities that are prohibited when asbestos-
containing materials are involved. For example, maintenance staff
employees should be instructed: Not to drill holes in asbestos-containing
.
materials .
Work Practice
1. Perform Prework actMtles on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Hand drill or hole saw (as needed). Power tools should have
HEPA filtered dust collection
Maintenance work materials
Wet sponges or shaving cream (if used)
3. Prepare work area with drop cloth. See General Procedure W9. If
accessible, also install a drop cloth on back side of drywall if hole(s) will
penetrate through wall.
4. Place tools, equipment and materials needed onto drop cloth.
5. Mark area to be cut or drilled.
6. Adequately wet area to be cut using garden sprayer with amended water.
As alternate methods, holes can be drilled/cut through a wet sponge or
shaving cream on both sides.
7. cut new hole using utility knife, hand tools or power tools with HEPA
filtered dust collection. Wet the cutting area using amended water during
cutting or drilling.
8. Remove piece of cut drywall and place into disposal bag. If wet sponges
were used, place sponges into disposal bag.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRAGTICES
“Name of 1ac1llt
90
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M24. Level 2...continued
9. HEPA vacuum removal area and areas accessible from hole.
.10. HEPA vacuum and wet wipe up any accessible dust or debris generated
on back side. Wet wipe drop cloth and. surfaces adjacent to area where
hole was cut or drilled. Remove drop cloth and place into disposal bags.
11. Perform maintenance work and clean-up and tear-down steps on Level 2
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of raclftty 91
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M24. Level 3
Cut or drill asbestos-containing drywall, plaster or drywall
compound.
Example
Level 3: A. Install conduit or ductwork through asbestos-
containing drywall or plaster using power tools.
Notes
This work’ pract!ce must be used in conjunction with General
Procedures WI, W9 and a Level 3 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Appendix G to OSHA regulation 29 CFR 1926.58 states: ‘The training
program for the maintenance engineering staff should describe methods of
handling asbestos-containing materials as well as routine maintenance
activities that are prohibited when asbestos-containing materials are
involved. For example, maintenance staff employees should be instructed:
Not to drill holes in asbestos-containing materials.”
Work Practice 1. Perform Pre-work actMties on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Drill or saw (as needed) with HEPA filtered dust collection
attachment
Maintenance work materials.
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system and/or HEPA filtered local exhaust ventilation.
See General Procedure W9. If back side of drywall Is accessible, enclose
area If hole(s) will penetrate through wall. Provide negative air in backside
enclosure if possible. A glovebag may be used as an enclosure for small
work areas.
4. Place tools, equipment and materials needed into enclosure. Include a
second HEPA vacuum for any power tools to be used for cutting’ or
drilling.
5. Enter enclosure and mark area to be cut or drilled.
6. Adequately wet area to be cut using garden sprayer with amended water.
7. Cut new hole using utility knife, hole saw or drill. Power tools must have
an operating HEPA vacuum attached during cutting. Wet the cutting area
using amended water during cutting or drilling.
8. Remove piece of cut drywall and place Into disposal bag.
9. HEPA vacuum removal area and areas accessIble from hole.
10. If dust or debris Is generated on back side, insert wand of garden sprayer
into backside of enclosure and adequately wet any dust or debris present.
Remove back-side enclosure, place Into disposal bags, and wet wipe
surfaces that were exposed inside enclosure.
11. Perform maintenance work and clean-up and tear-down steps on Level 3
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of FacIlity 92
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M25 . Summary
Remove section of asbestos-containing drywall.
Summary This work practice describes the work required to remove a small
area of asbestos-containing drywall, or non-ACM drywall with ACM
joint compound in support of O&M work.
Examples Level 2: A.
•
RemOve small area of asbestos-containing drywall in
good condition using non-powered hand tools. Low
dust Level expected.
Level 3:
A.
Replace damaged section of asbestos-containing
drywall or drywall adhered to studs using hand tools or
power tools with HEPA vacuum dust collection
attachments.
Related Work Practices
.
M24 - Cut or drill asbestos-containing drywall or drywall compound.
Worker Recommendations
One worker is usually sufficient for Level 2. Two workers for Level 3. Two or more
workers may be needed to increase efficiency or for additional health and/or safety
considerations. A person with air monitoring training might be required. This person can
be a worker.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
NamG of FacUlty’ 93
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M25. Level 2
Remove section of asbestos-containing drywall.
Example Level 2: A. Remove small area of asbestos-containing drywall in
good condition using non-powered hand tools. Low
dust Level expected.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice 1. Perform Pre-work activities on Level 2 checklist.
2. AdditIonal tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Hand tools as needed
Pry bars.
3. Prepare work area with drop cloth. See General Procedure W9.
4. Place tools, equipment and materials needed ànto drop cloth.
5. Adequately wet entire area of drywall to be removed using garden sprayer
with amended water.
6. Cut around perimeter of area to be removed using hand tools. Wet cutting
area with amended water during cutting.
7. If drywall remains attached to studs or substrate, use pry bar to pull sheet
out enough so edge can be gripped with hands. Mist cavity behind drywall
and back side of drywall to be removed with amended water.
8. Pull sheet out so sheet folds at fastener line or sheet Is pulled away from
fasteners. Adequately wet fold or holes from fasteners.
9. Repeat step 8 at other attachment points, remove drywall piece, and
package for disposal.
10. Remove fasteners from studs or substrate and place into disposal bags.
Clean any debris left on studs or substrate using amended water and nylon
brush.
11. Pick up any debris and place into disposal bags. HEPA vacuum and wet
wipe up any dust generated.
12. Perform maintenance work and clean-up and tear-down steps on Level 2
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
94
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M25. Level 3
Remove section of asbestos-containing drywall.
Example
Level 3: A. Replace damaged section of asbestos-containing
drywall or drywall adhered to studs using hand tools or
power toots with HEPA vacuum dust collection
attachments.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9 and a Level 3 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice 1. Perform Pre-work actMties on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Tools as needed
Pry bars
3. Prepare regulated area with drop cloth, erect mini-enclosure and set up
negative pressure system. See General Procedure W9. If back side of
drywall. is accessible, enclose and provide negative pressure for enclosure.
4. Place tools, equipment and materials needed into enclosure.
5. Enter enclosure and adequately wet area of drywall to be removed using
garden sprayer with amended water.
6. cut around perimeter of area to be removed using utility knife. Wet cutting
area during cutting.
7. If drywall remains attached to studs or substrate, use pry bar to pull sheet
out enough so edge can be gripped with hands. Mist cavity behind
drywall, and back side of drywall to be removed with amended water.
8. Pull sheet out so sheet folds at fastener line or sheet is pulled away from
fasteners. Adequately wet fold or holes from fasteners.
9. Repeat step 8 at other attachment points, remove drywall piece, and
package for disposal.
10. Remove fasteners from studs or substrate and place into disposal bags.
clean any debris left on studs or substrate using amended water and nylon
brush.
ii. Pick up any debris and place into disposal bags. HEPA vacuum and wet
wipe up any dust generated.
12. Perform maintenance work and clean-up and tear-down steps on Level 3
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“N ath f F th’ ’ 95
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M26. Summary
Remove asbestos-containing flexible duct connector.
Summary This work describes the work required to remove an asbestos-containing
fabric flexible duct connector.
Examples Level 1: A. Remove flexible duct connector with duct work.
B. Remove flexible duct connector in good condition
where connector will not be damaged.
Level 2: A. Remove flexible duct connector where it may be
damaged during removal.
Level 3: A. Remove flexible duct connector in poor condition.
Related Work Practices
TlO - Remove duct insulation above lay-in ceiling for maintenance work.
Ti I - Remove duct insUlation above plaster or drywall ceiling for maintenance work.
M28 - Remove contaminated filters in HVAC unit serving plenum space with exposed
ACM.
Worker Recommendations
One worker for Level 1 and Level 2. Two workers for Level 3. A second worker may be
needed for large connectors. A person with air monitoring training might be required.
This person can be a worker.
MISCELLANEOUS MATERIALS. ASBESTOS O&M WORK PRACTICES
‘Name of FacThty 96
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M26. Level 1
Remove asbestos-containing flexible duct connector.
Examples
Level 1: A. Remove flexible duct connector with duct work.
B. Remove flexible duct connector in good condition where connector
will not be damaged.
Notes
This work practice must be used in conjunction with General
.
Procedure Wi, W4 and a Level I Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Coordinate work with proper 0 & M work practice for removing duct
insulation if needed to access fasteners attaching flexible connector in
place.
Use Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
filter needs to be replaced.
Work Practice i. Perform Pre-work actMtles on Level 1 checklist..
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Scraper 2-3 (50-75 mm) wide stiff blade
Stiff nylon bristle brushes
Manual or power screwdriver with screwdriver bits and hex head
sockets
3. Turn off, lock out and tag out HVAC unit. Install critical barriers In
ductwork or HVAC unit adjacent to both sides of flexible connector (if
possible). See General Procedure W4.
4. Place tools, equipment and materials needed In work area.
5. A. If ductwork will be cut to remove connector, cover flexible
connector with polyethylene on outside, and on inside, if
accessible. If connector is in good condition, follow step 5B
below. Cut away ductwork on both sides of connector and
remove ductwork section with connector In place. Package
connector for disposal as ACM.
B. For connectors In good condition, unscrew all screws holding
flexible connector in place. Place screws Into a disposal bag if
they will not be reused, or clean with water and nylon brushes for
reuse. Slide connector off ductwork, pull out of space between
ducts, and package for disposal as ACM.
6. HEPA vacuum Interior of ducts accessible at both sides where connector
was Installed.
7. Remove critical barriers if installed Inside ductwork or HVAC unit.
8. Perform maintenance work and clean-up and tear-down steps on Level 1
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of FacilIty’ 97
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M26. Level 2
Remove asbestos-containing flexible duct connector.
Example
Level 2: A. Remove flexible duct connector where it may be
damaged during removal.
Notes
This work practice must be used in conjunction with General
.
Procedures WI, W9 and a Level 2 Worker Checklist. The
checklist includes tasks that must be performed before these work
practices are begun.
Coordinate work with proper 0 & M work practice for removing duct
insulation if needed to access fasteners attaching flexible connector in
,
place.
Work Practice 1. Perform Pre-work activities on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
tandard tools, equipment and materials list).
Scraper 2-3 (50-75 mm) wide stiff blade
Stiff nylon bristle brushes
Manual or power screwdriver with screwdriver bits and hex head
sockets
3. Prepare work area with drop cloth. See General Procedure W9. Also,
Install critical barriers In ductwork or HVAC unit adjacent to both sides of
flexible connector (if possible).
4. Place tools, equipment and materials needed Into work area.
5. Adequately wet flexible connector with amended water or removal
encapsulant.
6. Unscrew all screws holding flexible connector In place. Place screws into
disposal bag If they will not be reused. If screws are to be reused, clean
with water and nylon brushes.
7. Rewet connector and metal flanges of flexible connector and slide off of
ductwork. Pull connector out of space and package for disposal as ACM.
8. HEPA vacuum surfaces where flanges were attached and interior of ducts
accessible at both sides where connector was Installed.
9. Remove critical barriers if Installed Inside ductwork or HVAC unit.
10. Perform maintenance work and clean-up and tear-down steps on Level 2
checklist to complete work.
MISCELLANEOUS MATERIALS. ASBESTOS O&M WORK PRACTICES
“Name of FacIlity 98
-------
M26. Level 3
Remove asbestos-containing flexible duct connector.
Example
Level 3: A. Remove flexible duct connector in poor condition.
Notes
This work practice must be used in. conjunction with General
Procedures WI, W9 and a Level 3 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
.
Coordinate work with proper 0 & M work practice for removing duct
insulation if needed to access fasteners attaching flexible connector in
place.
Work Practice 1. Perform Pre-work actMties on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Scraper 2-3 (50.75 mm) wide stiff blade
Stiff nylon bristle brushes
Manual or power screwdriver with screwdriver bits and hex head
sockets
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system and/or HEPA filtered local exhaust ventilation.
Enclosure must allow access to all screws attaching connector in place.
See General Procedure W9. Also install critical barriers in ductwork or
HVAC unit adjacent to both sides flexible connector to be removed (if
possible).
4. Place tools, equipment and materials needed Into enclosure.
5. Adequately wet flexible connector with amended water or removal
encapsulant.
6. Unscrew all screws holding flexible connector in place. Place screws into
disposal bag if they will not be reused. If screws are to be reused, clean
with water and nylon brushes.
7. Rewet connector and metal flanges of flexible connector and slide off of
ductwork. Pull connector out of space and package for disposal as ACM.
8. HEPA vacuum and wet wipe surfaces where flanges were attached and
interior of ducts accessible at both sides where connector was installed.
9. Remove critical barriers if Installed Inside ductwork or HVAC unit.
10. Perform maintenance work and clean-up and tear-down steps on Level 3
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
‘Name of FacilIty” 99
-------
M27. Summary
Remove asbestos-containing ductwork taping cloth.
Summary This work practice covers the steps required to remove small amounts of
asbestos-containing duct tape from ductwork for maintenance work.
Examples Level 1: A. Remove ductwork taping cloth with duct section.
B. Remove loose pieces of ductwork taping cloth.
Level 2: A. Remove a small amount of ductwork taping cloth in
good condition to install new duct attached to existing
ducts.
Level 3: A. Replace damaged section of ductwork.
B. Remove asbestos-containing paper-type duct wrap in
poor condition.
Related Work Practices
M26 - Remove asbestos-containing flexible duct connector .
Worker Recommendations
One worker is usually sufficient for Level I and Level 2. Two workers for Level 3. Two
or more workers may be needed to increase efficiency or for additional health and/or
safety considerations. A person with air monitoring training might be required. This
person can be a worker.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
Namo of FacilIty 100
-------
M27. Level 1
Remove asbestos-containing ductwork taping cloth.
Examples
Level 1: A. Remove ductwork taping cloth with duct section.
B. Remove loose pieces of ductwork taping cloth.
Notes
.
Use
filter
This work practice must be used in conjunction with General
Procedure Wi and a Level I Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
needs to be replaced.
Work Practice 1. Perform Pre-work activities on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Tin snips
3. Place tools, equipment and materials needed In work area.
4. Using garden sprayer with amended water or removal encapsulant,
adequately wet any loose pieces of taping cloth to be removed.
5. If taping cloth will be removed, with duct section, follow step 5A. If loose
pieces will be removed, follow step 5B.
A. cover taping cloth with duct tape or polyethylene taped in place.
Using tin snips, cut away ductwork on both sides of connector (do
not cut through taping cloth) and remove ductwork section.
Package for disposal as ACM.
B. Pick up wet pieces of taping cloth and place Into disposal bag.
6. HEPA vacuum and/or wet wipe up any visible debris.
7. Perform maintenance work and clean-up and tear-down steps on Level 1
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
i ” fr : . 101
-------
M27. Level 2
Remove asbestos-containing ductwork taping cloth.
Example Level 2: A. Remove a small amount of ductwork taping cloth in
good condition to install new duct attached to existing
ducts.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9, Wi 7 and a Level 2 Worker Checklist. The
worker checklist includes tasks that must be performed before these
work practices are begun.
Work Practice 1. Perform Pre-work actMties on Level 2 checklist.
2. AdditIonal tools, equipment and materials: (see General Procedure WI for
standard tools, equipment and materials list).
Toots and materials needed for duct work
Glovebags
Scraper 2-3 (50-75 mm) wide stiff blade
Stiff nylon bristle brushes
3. Prepare work area with drop cloth. See General Procedure W9.
4. Place tools, equipment and materials needed onto drop cloth.
5. Insert toots needed into glovebag. Install glovebag over taping cloth to be
removed.
6. Insert wand of garden sprayer with amended water or removal encapsulant
into glovebag and adequately wet taping cloth to be removed.
7. Using scraper Inside glovebag, remove taping cloth using glovebag
procedures. See General Procedure W17. Wet removal area during
removal.
8. Ciean remaining visible debris off ductwork using scraper and nylon
brushes.
9. HEPA vacuum and wet wipe area where tape was removed.
10. Seat and remove glovebags from ductwork and dispose of as ACM waste.
11. Perform maintenance work and clean-up and tear-down steps on Level 2
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
Name f FacllLtr 102
-------
M27. Level 3
Remove asbestos-óontaifliflg ductwork taping cloth.
Examples
Level
B.
3: A. Replace damaged section of ductwork.
Remove asbestos-containing paper-type duct wrap in poor condition.
Notes
This work practice must be used in conjunction with General
Procedures Wi, W9, W17 and a Level 3 Worker Checklist. The
worker checklist includes tasks that must be performed before these
work practices are begun.
Work Practice 1. Perform Pre-work actMtles on Level 2 checklist.
2. AdditIonal toots, equipment and materials: (see General Procedure Wi for
standard toots, equipment and materials list).
Toots and materials needed for duct work
Scraper 2-3 (50-75 mm) wide stiff blade
Stiff nylon bristle brushes
Giovebags
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system and/or HEPA filtered local exhaust ventilation.
See General Procedure W9.
4. Place tools, equipment and materials needed into enclosure.
5. Enter enclosure and insert tools needed into giovebag. Install glovebag
over taping cloth to be removed.
6. Insert wand of garden sprayer with amended water or removal encapsulant
into glovebag (if used) and adequately wet ACM to be removed.
7. UsIng scraper, remove taping cloth using glovebag procedures. See
General Procedure W17. Wet removal are during removal.
8. Clean remaining visible debris off ductwork using scraper and nylon
brushes.
9. HEPA vacuum and wet wipe area where tape was removed.
10. Seal and remove glovebags from ductwork and dispose of as ACM waste.
11. Perform maintenance work and clean-up and tear-down steps on Level 3
checklist to complete work.
• MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
f ’tIth 103
-------
M28 . Summary
Remove contaminated filters in HVAC unit serving plenum space
with exposed ACM.
Summary This
conta
work
minate
practice
d filters in
covers
HVAC u
the
nit se
procedures
rving plenum
for
spac
removing
e with expo
asbestos
sed ACM.
Examples Level 2: A. Remove prefabricated slip-in type filters’ from HVAC
unit in mechanical room.
B. Replace filters in HVAC unit in mechanical room with
roll-type filters. -•
Related Work Practices
None
Worker Recommendations
One worker. A second worker may be needed for large, roll-type filters. A person with
air monitoring training might be required. This person can be a worker.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
‘Name of FacIlity 104
-------
M28. Level 2
Remove contaminated filters in HVAC unit serving plenum space
with exposed ACM.
Examples
Level, 2: A. Remove prefabricated slip-in type filters from HVAC
.
unit in mechanical room.
B. Replace filters in HVAC unit in mechanical room with
roll-type filters.
Notes
This work practice must be used in conjunction with General
.
Procedures Wi, W9 and a Level 2 Worker Checklist. The worker
checklist includes tasks that must be performed before these work
practices are begun.
Coordinate work with proper 0 & M work practice for accessing type of
ceiling present in work area. OSHA standard 29 CFR 1926.58 Appendix G
states employees should be instructed to not remove ventilation system
filters dry and not to shake ventilation system filters.
Work Practice 1. Perform Pre-work activities on Level 2 checklist;
2. Additional tools, equipment and materials: (see General
Procedure Wi for standard tools, equipment and materials
list).
Scraper 2-3” (50-75 mm) wide stiff blade
Stiff nylon bristle brushes
Replacement filter material, if needed
3. Prepare work area with drop cloth. See General Procedure
W9. Verify that HVAC unit is shut off and locked out.
4. Place tools, equipment and materials needed onto drop cloth.
5. Adequately wet filters to be removed.
6. Remove filters and dispose of as ACM. Cut away exposed
portions of roll type filters, wrap in polyethylene sheet and
dispose of as ACM.
7. Wet any dust or debris on drop cloth, and fold up drop cloth
and dispose of as ACM.
8. HEPA vacuum and wet wipe area where filters were installed
and accessible surfaces in filter chamber.
9. Roll new filter material into place and cover remaining filter
material. Perform clean-up and tear-down steps on Level 2
checklist to complete work.
MISCELLANEOUS MATERIALS . ASBESTOS O&M WORK PRACTICES
“Name of PacThtV ’ 105
-------
M29. Summary
Clean up debris from minor fiber release.
Summary This work practice describes the procedures to be used to clean up a minor
fiber release generated by surfacing, TSI or miscellaneous ACM. If a major
fiber release occurs, the APM or an asbestos designer should develop
cleanup procedures for the particular location and circumstances. Some
regulations, such as AHERA, define maximum quantities for this activity.
Regulations may also require that a fiber release report be prepared and
made available to affected personnel. If fiber release needs Level 3 work
practices, it should be treatöd as an abatement project, not as O&M work.
Examples Level 1: A. Pickup small amount of ACM debris that will stick to a
small piece of duct tape.
Level 2: A. Clean up a small amount of debris from délaminated,
abraded or damaged surfacing.
B. Clean up a small amount of debris from damaged pipe
insulation.
C. Clean. Up a small amount of debris from damaged
drywall.
Relat
ed Work
Practices
.
Sb - Repair
damaged
surfacing
ACM.
17 -
Repair
damaged
thermal system insulation on a boiler, duct or flue.
Worker Recommendations
One worker. A person with air monitoring training might be required. This person can
be the worker.
MISCELlANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
106
-------
M29. Level 1
Clean up debris from minor fiber release.
Example
.
Level 1: A. Clean up small amount of ACM debris that will stick to
a small piece of duct tape.
Notes
This work practice must be used in conjunction with General Procedure Wi
and a Level I Worker Checklist. The worker checklist includes tasks that
must be performed before these work practices are begun.
Coordinate work with proper 0 & M work practice to repair cause of fiber
release if repair is necessary.
Work Practice 1. Perform Pre-work activities on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure WI for
standard tools, equipment and materials list).
None
3. Cover debris with duct tape and press to adhere debris to tape. Repeat
with another piece of tape if needed. Dispose of tape as ACM or in
accordance with applicable regulations.
4. Perform applicable steps on Level I checklist to complete work.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
F acThty 107
-------
M29. Level 2
Clean up debris from minor fiber release.
Examples
Level 2: A. •Clean up a small amount of debris from delaminated,
abraded or damaged surfacing.
B. Clean up a small amount of debris from damaged pipe
insulation.
C. Clean up a small amount of debris from damaged
drywall.
Notes
This work practice must be used in conjunction with General Procedures
WI, W4 and a Level 2 Wotker Checklist The worker checklist includes
tasks that must be performed before these work practices are begun.
Coordinate work with proper 0 & M work practice to repair cause of fiber
release.
Work Practice 1. Perform Pre-work activities on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Scraper 2-3’ (50-75 mm) wide stiff blade
Stiff nylon bristle brushes
3. Prepare work area with critical barriers. See General Procedure W4.
4. Place tools, equipment and, materials needed Into work area.
5. Adequately wet debris to be cleaned up using amended water.
6. Pick up any large pieces of debris and place into disposal bags. Use
HEPA vacuum and wet wipIng to clean up small debris and dust.
7. Wet wipe and HEPA vacuum all surfaces in contaminated area.
8. Perform any required repair work using appropriate work practice. Perform
clean-up and tear-down steps on Level 2 checklist to complete work.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
108
-------
M30. Summary
Replace asbestos-containing gaskets.
Summary This work practice describes the work required to replace ACM gaskets or
ACM valve packings for O&M work.
Examples Level I: A. Replace small non-adhered ‘gasket that can be
removed intact.
Level 2: A. Replace small valve packing.
B. Replace gasket between two small or medium size
pipe flanges.
C. Replace small damaged gasket.
Level 3: A. Replace large pipe flange gasket.
B. Replace gasket on boiler door.
C. Replace well-adhered gasket.
Ret
at
ed Work Practices
S
.
TI
-
Remove insulation
on
exposed
pipe
for maintenance work.
T4
-
Remove insulation
on
exposed
pipe
in elevated location for
maintenance
work.
17
-
Repair damaged thermal system ins
ulátion on a boiler, duct
or flue.
Worker Recommendations
One worker for Level 1 and Level 2. Two workers for Level 3. A person with air
monitoring training might be required. This person can be the worker.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
109
-------
M30. Level I
Replace asbestos-containing gaskets.
Example
Level 1: A. Replace small non-adhered gasket that can be
removed intact.
Notes
This work practice must be used in conjunction with General Procedure Wi
and a Level I Worker Checklist The worker checklist includes tasks that
must be performed before these work practices are begun.
Coordinate work with proper 0 & M work practice if other ACM must be
removed prior to gasket replacement.
Work Practice 1. Perform Pre-work actMtles on Level I checklist.
2. Additional tools, equipment and materials: (see GeneraiProcedure Wi for
standard tools, equipment and materials list).
Tools required to access gasket
Non-ACM replacement materials
3. Place tools, equipment and materials needed In work area.
4. Disassemble equipment as needed to expose entire gasket.
5. Remove gasket and place Into disposal bag. Wet-wipe flange where
gasket WaS Installed.
6. Install new gasket, reassemble equipment and perform applicable steps on
Level I checklist to complete work.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
Nameo(FacThty 110
-------
M30. Level 2
Replace asbestos-containing gaskets.
Examples
Level 2: A. Replace small valve packing.
B. Replace gasket between two small or medium size
pipe flanges.
C. Replace small damaged gasket.
Notes
This work practice must be used in conjunction with General Procedures
WI, W9, W17 and a Level 2 Worker Checklist. The worker checklist
includes tasks that must be performed before these work practices are
begun.
Coordinate work with proper 0 & M work practice if other ACM must be
removed prior to gasket replacement. If active electrical equipment is in
work area, delete wetting (if permitted by EPA) for this work.
Work Practice 1. Perform P re-work actMties on Level 2 checklIst.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Scraper 2-3 (50-75 mm) wide stiff blade
Stiff nylon bristle brushes
Tools required to access or remove gasket
Non-ACM replacement materials
Glovebag
3. Prepare work area with drop cloth. See General Procedure W9.
4. Place tools, equipment and materials needed into work area.
5. Disassemble equipment as needed to expose entire gasket.
6. A. If entire gasket can be contained In a glovebag, Install glovebag
over gasket. Adequately wet gasket and remove gasket and
debris using glovebag procedures. See General Procedure Wi 7.
B. If gasket cannot be contained In a giovebag, adequately wet
gasket, set up HEPA filtered local exhaust ventilation and remove
gasket and debris. Use nylon brushes and scraper to clean
surfaces to which gasket was attached.
7. HEPA vacuum and/or wet wipe surfaces to which gasket was attached.
8. Install new gasket, reassemble equipment and perform clean-up and tear-
down steps on Level 2 checklist to complete work.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
iii
-------
M30. Level 3
Replace asbestos-contal fling gaskets.
Examples
Level 3: A. Replace large pipe flange gasket.
B. Replace gasket on boiler door.
C. Replace well-adhered gasket.
Notes
This work practice must be used in conjunction with General Procedures
WI, W9, W17 and a Level 3 Worker Checklist. The worker checklist
includes tasks that must be performed before these work practices are
begun.
Coordinate work with proper 0 & ‘M work practice if other ACM must be
removed prior to gasket replaäement. If active electrical equipment is in
work area, delete wetting (if permitted by EPA) for this work.
Work Practice
1. Perform Pre-work activities on Level 3 checklIst.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Scraper 2-3 (50-75 mm) wide stiff blade
Stiff nylon bristle brushes
Tools required to access or remove gasket
Non-ACM replacement materials
Glovebag
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system and/or HEPA filtered local exhaust ventilation.
See General Procedure W9.
4. Place tools, equipment and materials needed Into enclosure.
5. Enter enclosure and disassemble equipment as needed to expose entire
gasket.
6. A. If entire gasket can be contained In a glovebag, install glovebag
over gasket. Adequately wet gasket and remove gasket and
debris using glovebag procedures. See General Procedure W17.
B. If gasket cannot be contained in a glovebag, adequately wet
gasket, set up HEPA filtered local exhaust ventilation, and remove
gasket arid debris. Use nylon brushes and scraper to clean
surfaces to which gasket was attached.
7. HEPA vacuum and/or wet wipe surfaces to which gasket was attached.
8. Install new gasket, reassemble equipment and perform maintenance work
required and clean-up and tear-down steps on Level 3 checklIst to
complete work.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
112
-------
M31 . Summary
Emptying and changing filter in HEPA vacuum or changing filter
in HEPA fan unit.
Summary This work practice covers the procedures for changing the bag, filter and/or
cleaning a HEPA vacuum, or changing the filter in a HEPA filtered fan unit.
Examples Level 2:
A.
Empty HEPA vacuum bag using bc
alized engineering
.
B.
C.
controls.
Change filter in HEPA fan unit.
Change filter or bag in HEPA
glovebag.
vacuum using
a
Level 3:
A.
Empty bag, change filter and clean
HEPA vacuum.
:
B.
Change filter in a HEPA fan unit in
a mini-enclosure.
Related Work Practices
.
None
Worker Recommendations
One worker for Level 2. Two workers for Level 3. A person with air monitoring training
might be required. This person can be the worker.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
113
-------
M31 . Level 2
Emptying and changing filter in HEPA vacuum or changing filter
in HEPA fan unit.
Examples
Level 2: A. Empty HEPA vacuum bag using localized engineering
controls.
B. Change filter in HEPA fan unit.
C. Change filter or bag in HEPA vacuum using a
.
glovebag.
Notes
This work practice must be used in conjunction with General Procedures
Wi, W9 and a Level 2 Worker Checklist. The worker checklist includes
tasks that must be performed before these work practices •are begun.
Work Practice 1. Perform Pre-work actMtles on Level 2 checldist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Manufacturers instructions for unit having filter or bag replaced
Tools as needed to remove filter or bag
Replacement filters or bags
Glovebag and hand operated spray bottle
3.. Prepare work area with drop cloth and HEPA filtered local exhaust
ventilation. See General Procedure W9.
4. Place tools, equipment and materials needed onto drop cloth, including
HEPA vacuum or fan unit with filter or bag to be changed. if available,
include an operable HEPA vacuum for cleaning up any dust or debris from
the filter change operation. If filter or bag will be changed using a
giovebag, follow step 5A procedures. If a glovebag will not be used, follow
step 5B procedures.
5. A. Insert new bag or filter, wet wiping cloths, and a hand-operated
spray bottle into glovebag. Seal glovebag to unit to permit access
to filter or bag Inside glovebag. Open unit and adequately wet
filter or bag. Remove filter or bag and place in corner of
glovebag. Wet wipe inside of unit. install new filter or bag. Close
unit and wet wipe inside of glovebag. Put wet wipes in corner of
giovebag. Twist, and tape gtovebág to seal bag/filter/rags from
spray bottle. Cut and remove glovebag from unit. Place glovebag
Into a disposal bag.
B. Carefully disassemble unit as needed to access filter and/or bag.
Adequately wet filter and/or bag, remove from unit and place into
disposal bag. Using operable HEPA vacuum or wet wiping, clean
area where filter or bag was installed.
6. Install new filter and/or bag in unit, reassemble unit and perform clean-up
and tear-down steps on Level 2 checklist to complete work.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
114
-------
M31 . Level 3
Emptying and changing filter in HEPA vacuum or changing filter
in HEPA fan unit.
Examples
Level 3: A. Empty bag, change filter and clean HEPA vacuum.
B. Change filter in HEPA fan unit in a mini-enclosure.
Notes
This work practice must be used in conjunction with General Procedures
.
, W9 and a Level 3 Worker Checklist The worker checklist includes
tasks that must be performed before these work practices are begun.
This procedure may be performed in an existing mini-enclosure, if. available.
Work Practice 1. Perform Pre-work actMtles on Level 3 checklIst.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Manufacturer’s instructions for unit having filter or bag replaced
Tools as needed to remove filter or bag
Replacement filters or bags
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system or HEPA filtered local exhaust ventilation. See
General Procedure W9.
4. Place tools, equipment and materials needed onto drop cloth, including
HEPA vacuum or fan unit with filter or bag to be changed. If available,
Include an operable HEPA vacuum for deaning up any dust or debris from
the filter change operation.
5. Enter enclosure and carefully disassemble unit as needed to access filter
or bag. Adequately wet filter and/or bag, remove from unit and place into
disposal bag.
6. Adequately wet any remaining debris. Pick up debris or empty debris into
a disposal bag.
7. Using operable HEPA vacuum or wet wiping, clean area where filter or bag
was installed.
8. Install new filter and/or bag in unit, reassemble unit and perform clean-up
and tear-down steps on Level 3 checklist to complete work.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
115
-------
M32 . Summary
Remove asbestos-wrapped wiring.
Summary This work practice
asbestos-wrapped
ôovers the work required to remove small amounts of
electrical wiring for O&M work.
Examples Level 1: A.
Remove wiring in good condition on single stage
•
spotlight.
Level 2: A.
Remove wiring in good condition on several stage
spotlights.
B.
Remove, asbestos wrapped wiring located in
underground electrical vaults where wrapping is in
good condition. See APM8 regarding’ confined space
precautions.
Level 3: A.
Remove damaged wiring in poor condition.
B.
Remove asbestos wrapped wiring located in
underground electrical vaults where wrapping is in poor
condition. See APM8 regarding confined space
precautions.
Related Work Practices
.
None
.
Worker Recommendations
One worker for Level 1 and Level 2. Two workers are recommended for Level 3 and/or
if work occurs in a confined space. Workers should be trained electricians with asbestos
training to perform this work. A person with air monitoring training might be required.
This person can be the worker.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
116
-------
M32. Level I
Remove asbestos-wrapped wiring.
Example
Level 1: A. Remove wiring in good condition on single’ stage
spotlight.
Notes
This work practice must be used in conjunction with General Procedure Wi
and a Level I Worker Checklist. The worker checklist includes tasks that
must be performed before these work practices are begun.
Verify that approval has been received from the EPA if wetting will not be
used for removing asbestos-containing electrical wiring.
Use Work Practice M31 ‘if HEPA vacuum needs maintenance, or if bag or
filter needs to be replaced.
Work Practice 1. Perform Pre-work actMties on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Electrician’s Insulated gloves
Screwdrivers
Wire cutters
Voltmeter
Soldering Iron for soldered connections
3. Place tools, equipment and materials needed In work area. Verify that
electrical power to wiring is shut off and locked out. Test circuits using
voltmeter.
4. Put on insulated gloves and cut out exposed wiring to be removed. Roil
up wiring and place Into disposal bags.
5. Open any Junction boxes or equipment as needed to remove wiring back
to screw terminals or soldered connections.
6. Cut or disconnect wiring from terminals or connections. Place wiring into
disposal bags. HEPA vacuum any surfaces that were in contact with
wiring.
7. Perform maintenance work and clean-up and tear-down steps on Level I
checklist to complete work.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
117
-------
M32. Level 2
Remove asbestos-wrapped wiring.
Examples
Level 2: A. Remove wiring in good condition on several stage
spotlights.
B. Remove asbestos wrapped wiring located in
underground electrical vaults where wrapping is in
good condition. See APM8 regarding confined space
precautions.
Notes
This work practice must be used in conjunction with General Procedures
Wi, W9 and a Level 2 Worker Checklist. The worker checklist includes
•
tasks that must be performed before these work practices are begun.
Verify that approval has been received from the EPA if wetting will not be
used for removing asbestos-containing electrical wiring.
Work Practice 1. Perform Pre-work actMties on Level 2 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Electricians insulated gloves
Screwdrivers
Wire cutters
Voltmeter
Soldering Iron for soldered connections
3. Prepare work area with drop cloth. See General Procedure W9. Verify
that electrical power to wiring is shut off and locked out. Test circuits
using voltmeter.
4. Place tools, equipment and materials needed onto drop cloth.
5. Put on insulated gloves and cut out exposed wiring to be removed. Roll
up wiring and place into disposal bags.
6. Open any junction boxes or equipment as needed to remove wiring back
to screw terminals or soldered connections.
7. Disconnect remaining wiring from terminals or connections. Place wiring
Into disposal bags.
8. HEPA vacuum any surfaces that were In contact with wiring.
9.. Perform maintenance work and clean-up and tear-down steps on Level 2
checklist to complete work.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
118
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M32. Level 3
Remove asbestos-wrapped wiring.
Examples
Level 3: A. Remove damaged wiring in poor condition.
.
B. Remove asbestos wrapped wiring located in
underground electrical vaults where wrapping is in poor
condition. See APM8 regarding confined space
precautions.
Notes
This work practice must be used in conjunction with General Procedures
Wi, W9 and a Level 3 Worker Checklist The worker checklist includes
tasks that must be performed before these work practices are begun.
Verify that approval has been received from the EPA if wetting will not be
used on electrical wiring to be removed.
Work Practice 1. Perform Pre-work actMties on Level 3 checklist.
2. Additional tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Electricians insulated gloves
Screwdrivers
Wire cutters
Voltmeter
3. Prepare work area with drop cloth, erect mini-enclosure and set up
negative pressure system and/or HEPA filtered local exhaust ventilation.
See General Procedure W9. Verify that electrical power to wiring Is shut
off and locked out. Test circuits using voltmeter.
4. Place tools, equipment and materials needed into enclosure.
5. Enter enclosure, put on insulated gloves and cut out exposed wiring to be
removed. Roil up wiring and place into disposal bags.
6. Open any Junction boxes or equipment as needed to remove wiring back
to screw terminals or soldered connections.
7. cut or disconnect wiring from terminals or connections. Place wiring into
disposal bags.
8. HEPA vacuum any surfaces that were in contact with wiring and any
suspect visible debris.
9. Perform maintenance work and clean-up and tear-down steps on Level 3
checklist to complete work.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
119
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M33 . Summary
Remove asbestos-containing caulking compound.
Summary This work practice
of asbestos-contai
repair work.
describes the procedures for removing small amounts
fling caulking compound as required for maintenance or
Examples Level 1: A.
Remove a small amount of pliable caulking compound.
No sanding will be performed.
Level 2: A.
B.
Reglaze several small window panes. No sanding will
be performed.
Remove small amount of dry caulking compound.
Level 3: A.
Reglaze an entire window or several windows.
Related Work Practices
None
Worker Recommendations
One worker for Level I and Level 2. Two workers for Level 3. A person with air
monitoring training might be required. This person can be the worker.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
NaeC Facthty 120
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M33. Level 1
Remove asbestos-containing caulking compound.
Example
Level 1: A. Remove a small amount of pliable caulking compound.
No sanding will be performed.
.
Notes
This work practice must be used in conjunction with General Procedure Wi
and a Level I Worker Ghecldist. The worker checklist includes tasks that
must be performed before these work practices are begun.
Use Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
filter needs to be replaced.
Work Practice 1. Perform Pre-work actMtles on Level I checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Scraper 2-3 (50-75 mm) wide stiff blade
3. Place tools, equIpment and materials needed In work area.
4. Using utility knife or edge of scraper, cut away caulking and place into
disposal bags.
5. Remove any residual caulking using scraper and knife and place caulking
into disposal bags.
6. HEPA vacuum and/or wet wipe areas where caulking was removed.
7. Perform maintenance work and clean-up and tear-down steps on Level 1
checklist to complete work.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
121
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M33. Level .2
Remove asbestos-containing caulking compound.
Examples
Level 2: A. Reglaze several small window panes. No sanding will
be performed.
B. Remove small amount of dry caulking compound.
Notes
This work practice must be used in conjunction with General Procedures
Wi, W9 and a Level 2 Worker Checklist The worker checklist includes
tasks that must be performed before these work practices are begun.
Work Practice 1. Perform Pre-work activities on Level 2 checklist
2. Additional tools, equipment and materlais: (see General Procedure Wi for
standard tools, equipment and materials list).
Scraper 2-3 (50-75 mm) wide stiff blade
Stiff nylon bristle brushes
3. Prepare work area with drop cioth. See Generai Procedure W9.
4. Place tools, equipment and materiais needed onto drop cloth.
5. Enter work area and adequately wet caulking to be removed using garden
sprayer with amended water.
6. Using utility knife or edge of scraper, cut away caulking and place Into
disposal bags.
7. Remove any residual caulking using scraper, knife and nylon brushes and
place caulking into disposal bags.
8. HEPA vacuum and wet wipe areas where caulking was removed.
9. Perform maintenance work and dean-up and tear-down steps on Level 2
checklist to complete work.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
F adhity” 122
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M33. Level 3
Remove asbestos-containing caulking compound.
Example
Level 3: A. Reglaze an entire window or several windows
Notes
This work practice must be used in conjunction with General Procedures
Wi, W9 and a Level 3 Worker Checklist. The worker checklist includes
tasks that must be performed before these woik practices are begun.
Work Practice 1. Perform Pre-work actMties on Level 3 checklist
2. AdditIonal tools, equipment and materials: (See General Procedure Wi for
standard tools, equipment and materials list).
Scraper (2-3 wide stiff blade)
Stiff nylon bristle brushes
3. Prepare work area with drop doth, mini-enclosure and set up negative
pressure system and/or HEPA filtered local exhaust ventilation on side of
window with exposed caulking compound. See General Procedure W9.
4. Place tools, equipment and materials needed Into enclosure.
5. Enter enclosure and adequately wet caulking to be removed using garden
sprayer with amended water.
6. Using utility knife or edge of scraper, cut away caulking and place into
disposal bags.
7. Remove any residual caulking using scraper, knife and nylon brushes and
place caulking into disposal bags.
8. HEPA vacuum and wet wipe areas where caulking was removed.
9. Perform maintenance work and clean-up and tear-down steps on Level 3
checklist to complete work.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
IIity ’ 123
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M34 . Summary
Clean room that has asbestos-containing dust.
Summary This work practice should be used for routine or special cleaning in rooms
where asbestos-containing dust is present, or is assumed to be present.
The practices include the cleaning of furniture, fixtures, and other surfaces.
Examples Level 1: A. Clean an office area where asbestos-containing dust
has settled on furniture due to’ air distribution from a
supply air plenum with fireproofing ACM.
B. Clean a mechanical room where dust is assumed to
contain ACM from thermal systems insulation present
in room.
Related Work Practices
S9 - Clean room with exposed surfaces finished with ACM
M6 -. Wet strip floor wax from resilient asbestos flooring
M7 - Dry or spray buffing resilient asbestos flooring
MB - Cleaning resilient asbestos flooring
M29 - Clean up debris from minor release
Worker Recommendations
One worker trained in special cleaning procedures. ‘A person with air monitoring training
might be required. This person can be the worker.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
1’’ t’: F”dF’ 124
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M34. Level 1
Clean room that has asbestos-containing dust.
Examples
Level 1: A. Clean an office area where asbestos-containing dust
has settled on furniture due to air distribution from a
supply air plenum with fireproofing ACM.
B. Clean a mechanical room where dust is assumed to
contain ACM from thermal systems insulation present
in room.
Notes
This work practice must be used in conjunction with General Procedures
Wi, W8 and a Level 1 Worker Checklist The worker checklist includes
tasks that must be performed before these work practices are begun.
Use Work Practice M31 if HEPA vacuum needs maintenance, or if bag or
filter needs to be replaced.
Work Practice 1. Perform Pre-work actMties on Level 1 checklist.
2. Additional tools, equipment and materials: (see General Procedure Wi for
standard tools, equipment and materials list).
Dusting materials (cloths, dusters, mops) that are damp or are
treated with catatonic or anti-static dust attractant preparations.
Furniture polish
3. Place Tools, equipment and materials needed In work area.
4. Using damp or treated dusting materials, clean surfaces beginning from the
top of the room and working towards the floor. HEPA vacuum surfaces
that are not easily cleaned with dusting materials. Surfaces that are not
routinely cleaned (such as blinds) shall be wet wiped or washed with
disposable cloths, folding the cloth Inward until it is dirty on all surfaces
and a new cloth is needed. Dispose of all dirty cloths and soiled dusting
materials while still damp in ACM disposal bags.
5. Clean floor with HEPA vacuum. See General Procedure W8.
6. Apply new polish where needed using standard procedures.
7. Perform clean-up and tear-down steps on Level 1 checklist to complete
work.
MISCELLANEOUS MATERIALS ASBESTOS O&M WORK PRACTICES
125
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A
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Appendix A
Job Request Form for MaintenanceWork
(from EPA Green Book)
APPENDICES
1
-------
Job Request Form for Maintenance Work
Name: ___________________________ Date: _________________________________
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:
(rhe 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 (Job Request No. _____
______ With conditions*
______ Denied
*Condjtions:
APPENDICES
Name of Facmty 2
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B
-------
Appendix B
Maintenance Work Authorization Form
(from EPA Green Book)
APPENDICES
‘Name of acThty 3
-------
Maintenance Work Authorization Form No.
AUTHORIZATION
Authorization is given to proceed with the following maintenance work:
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
change, the Asbestos Program Manager will re-evaluate the work request
prior to proceeding.
ACM is present. and may be disturbed.
Work Practice if Asbestos-Containing Materials Are Present
The following work practices shall be employed to avoid or minimize disturbing asbestos:
Personal Protection if Asbestos-Containing 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: _______________________________________ . • .__________________________________
(Asbestos Program Manager)
APPENDICES
4
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c
-------
Appendix C
Evaluation of Work Affecting Asbestos-Containing
Materials
(from EPA Green Book)
APPENDICES
Name of FacHIt ’ 5
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Evaluation of Work Affecting Asbestos-Containing Materials
This evaluation covers the following maintenance work:
Location of work (address, building, room number(s), or general description):
Date(s) of work:
Description of work:
.
.
.
.
Work approval form
number:
.
:
Evaluation of work p
ractices 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 and procedures used to protect workers:
Personal air monitoring results: (in-house worker or contract?)
Worker name _______________________ Results: __________
Worker name _______________________ Results:____________
Handling or storage of ACM waste: ____________________
Signed: __________________________________ Date: _______
(Asbestos Program Manager)
APPENDICES
“Name of Pacllity’ 6
-------
D
-------
Appendix D
Waste Tracking Form
APPENDICES
Name of Facmty 7
-------
Waste Tracking Form
Part 1 - To be completed by workers :
Maintenance World Authorization No.
Work Location: Building:
• Room # or Area: __________
Type of ACM Removed:
Quantity of Waste generated: Bags
• Other containers: _______________________________________________
Waste transported to: _______________________________________________
Transported by:
Tracking Form given to: _______________________________________________
Part 2 - To be completed by Asbestos Program Manager
Waste Properly Packaged & Labeled: Yes _________ No __________________
EXCEPTIONS: ________________________________________
Waste Storage Location: ______________________________________________
Waste Disposal Location: _____________________________________________
Waste Shipment Records Received: ______________________________________
Date:
SIGNED: ______________
ASBESTOS PROGRAM MANAGER
DATE:
APPENDICES
8
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E
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Appendix E
Glossary
Acoustical Plaster Sound absorbing finishing material mill-formulated for application in
areas where a reduction in sound reverberation or noise intensity is desired. These
materials usually are applied in a minimum thickness of 1/2” (13 mm). The finish material
is applied over gypsum plaster, plaster brown coat or other base plaster. The surface
material is usually friable and has a rough surface appearance.
AcOUStiC TiIO Tile-shaped blocks of sound absorbent material used for ceilings or as wall
facing. May be glued to substrate or laid in a rigid grid work.
ACM (ACBM) Asbestos-Containing Material (Asbestos-containing Building Material). Any
material containing more than one percent asbestos.
Adequately Wet Adequately Wet means sufficiently mix or penetrate with liquid to prevent
the release of particulates. If visible emissions are observed coming from asbestos-
containing material, then that material has not been adequately wetted. However, the
absence of visible emissions is not sufficient evidence of being adequately wet.
Air Monitoring The process of measuring the fiber content of a specific volume of air.
Amended Water Water to. which a surfactant has been added for use in wetting ACM to
control asbestos fibers.
Asbestos Chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos,
actinolite asbestos and any of these minerals that has been chemically treated and/or
altered.
ACM Asbestos-Containing Materials. Any material containing more than one percent
asbestos.
ACBM Asbestos-Containing Building Materials. Surfacing materials, thermal system
insulation materials or miscellaneous materials that are found in or on interior structural
members of other parts of a building.
Asbestos-Containing Waste Material Mill tailings or any waste that contains commercial
asbestos and is generated by a source regulated under NESHAP. This term includes
filters from control devices, friable asbestos waste material, and bags or other similar
packaging contaminated with commercial asbestos. As applied to demolition and
renovation operations, this term also includes regulated asbestos-containing waste and
materials contaminated with asbestos including disposable equipment and clothing.
APPENDICES
uName ci Fad y’ 9
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Asbestos debris Pieces of ACBM that can be identified by color, texture, or composition,
or means dust, if the dust is determined by an accredited inspector to be ACM.
Asbestos Hazard Emergency Response Act (AHERA) An EPA regulation published in the
October 30, 1987 Federal Register covering asbestos-containing materials in schools.
AHERA requires local education agencies to identify ACM in their school buildings,
develop an asbestos management plan and implement this plan. An O&M program is
one permitted response action, where appropriate.
Asbestos O&M Work Cleaning, maintenance, repair or renovation work involving
asbestos containing materials where the intent of the activity is not to remove asbestos.
NESHAPrequires that the owner or operator of a demolition or renovation activity conduct
a thorough Inspection of the affected facility or part of the facility where demolition or
renovation will occur.
Asbestos Program Manager (APM) A building owner or designated representative who
supervises all aspects of the facility asbestos management and control program.
Breathing Zone A hemisphere forward of the shoulders with a radius of approximately
6” to 9” (150-230 mm).
Bridging encapsulant An encapsulant that forms a discrete layer on the sUrface of an in
situ asbestos matrix. -
Concealed Suspension or Concealed Spline Ceiling System Presents a monolithic ceiling
surface, unobstructed by the cross-hatching of exposed grid members. Tiles are typically
12” x 12” (305 x 305 mm) or 12” x 24” (305 x 610 mm) with slots or kerfs cut into the
edges of tiles for the purposes of accepting flat or ‘T’ splines to support the tiles.
Confined Space A space that has limited openings for entry and exit, unfavorable hatural
ventilation and/or a space not designed for continuous worker occupancy. Examples
include boilers, furnaces, pits, septic tanks, manholes, silas and utility vautts.
Critical Barrier One or more layers of polyethylene taped in place over openings into a
work area. Openings to be covered include doors, windows, diffusers, and any other
opening that could allow outside air into a work area.
Decorative Acoustic Finish: Finishing material mill-formulated and spray applied up to
about 3/8” (10 mm) thick over gypsum wallboard. Material has a rough surface and is
similar in appearance to acoustic plaster but is not designed for sound absorption.
Delamination Separation of one layer from another.
Disposal Bag Properly labeled 6 mu (0.15 mm) thick (or thicker) leak-tight plastic bags
used for transporting asbestos wéste from work and to disposal site.
APPENDICES
nèclFacky 10
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Drop Cloth A layer of polyethylene on the floor of a work area to protect the floor below
from contamination and to facilitate the clean-up of dust or debris generated during the
work.
Encapsulant A material that surrounds or embeds asbestos fibers in an adhesive matrix,
to prevent release of fibers.
Endosure The construction of an air-tight, impermeable, permanent barrier around
asbestos-containing material to control the release of asbestos fibers into the air.
EPA U.S. Environmental Protection Agency
Excursion Limit (EL) The OSHA term used to define a maximum airborne concentration
of asbestos in fibers per cubic centimeter as averaged over a sampling period of thirty
minutes.
Fiber Release Any uncontrolled or unintentional disturbance of ACBM resulting in visible
emission.
Fireproofing Material applied to structural elements or. systems which provides increased
fire resistance, usually serving no structural function. This material is typically applied
using spray equipment.
Friable Asbestos (See “Regulated ACM”)
Glovebag A polyethylene or polyvinyl chloride bag-like enclosure affixed around an
asbestos-containing source (most often, TSI) so that the material may be removed while
minimizing release of airborne fibers to the surrounding atmosphere.
HEPA Filter High-Efficiency Particulate Air Filter. Such filters are rated to trap at least
99.97% of all particles 0.3 microns (0.3 m) in diameter or larger.
Medical Surveillance A periodic comprehensive review of 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.
Mini-Enclosure An enclosure constructed of polyethylene sheeting used for small scale,
short duration asbestos maintenance or renovation work. Mini-enclosures can be small
enough to restrict entry to the asbestos work area to one worker. Appendix G to OSHA
regulation 29 CFR 1926.58 discusses mini-enclosures and recommends that a change
room be constructed contiguous to the mini-enclosure.
Miscellaneous ACM Interior asbestos-containing building material on structural
components, structural members or fixtures,such as floor and ceiling tiles; does not
include surfacing material or thermal system insulation.
APPENDICES
11
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Negative Pressure System A local exhaust system intended to prevent the escape of
contaminated air to the surrounding environment. It utilizes HEPA filtration capable of
maintaining a pressure differential with a lower pressure inside the Work Area than in any
adjacent area. This system recirculates clean air and/or generates a constant flow of air
from adjacent areas into the work area.
Negative Pressure Respirator A respirator in which the air pressure inside the
respiratory-inlet covering is positive during exhalation in relation to the air pressure of the
outside atmosphere and negative during inhalation in relation to the air pressure of the
outside atmosphere.
NESHAP National Emission Standardfor Hazardous Air Pollutants - EPA Rules under the
Clean Air Act.
NIOSH 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 certify respirators.
Operations & Maintenance (O&M) Program A program of work practices to maintain
ACM in good condition, ensure clean up of asbestos fibers previously released, and
prevent further release by minimizing and controlling ACM disturbance or damage.
Occupied Area An area where personnel are present and are performing their normal
activities intended for the area (such as in a typical office area from 8:00 to 5:00 p.m.,
Monday through Friday).
OSHA Occupational Health & Safety Administration
Penetrating Encapsulant An encapsulant that is absorbed by the in situ asbestos matrix
without leaving a discrete surface layer.
Personal Air Samples An air sample taken with a sampling pump directly attached to the
• 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 Worker Protection
Rule.
Phase Contrast Microscopy (PCM) A method of analysis using a light microscope, used
to find the concentration of airborne fibers. Does not distinguish among asbestos and
other fibers. Used by OSHA to find personal exposures, and by EPA to find area levels
for AHERA project clearance.
Plenum Any space to convey air in a building or structure. The space above a
suspended ceiling is often used as an air plenum. This term is also used in the work
practices to refer to spaces above a ceiling not used to convey air.
APPENDICES
12
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Po’arized Ught Microscopy (PLM) A method of analysis using a light microscope to find
the chemical or mineral types of samples, including the concentration of asbestos in bulk
materials. Used by EPA for AHERA and NESHAP, and by OSHA to see if asbestos is
involved in a project.
Protection Factor The ratio of the ambient concentration of an airborne substance to the
concentration of the substance inside the respirator at the breathing zone of the wearer.
The protection factor is a measure of the degree of protection provided by a respirator
to the wearer.
Regulated ACM (RACM) As defined by NESHAP in the November 20, 1990 Federal
Register, regulated asbestos-containing material (RACM) means (a) Friable asbestos
material (b) Category I nonfriable ACM that has become friable. (C) Category I nonfriable
ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or (d)
Category II nonfriabte ACM that has a high probability of becoming or has become
crumbled, pulverized, or reduced to powder by the forces expected to act on the material
in the course of demolition or renovation operations regulated by this subpart.
(Note: Regulated ACM is an EPA NESHAP concept. OSHA makes no distinction
between friable and non-friable asbestos).
uctJtungs means to penetrate with a sharp-edged instrument and includes sawing, but
does not include shearing, slicing or punching.
Grinding” means to reduce powder or small fragments and includes mechanical clipping
or drilling.
Friable asbestos material means any material containing more than 1 percent
asbestos as determined using the method specified under AHERA (40 CFR Part
763, Sub-part F, Appendix A, section 1, Polarized Ught Microscopy) that, when
dry, can be crumbled, pulverized, or reduced to powder by hand pressure. If the
asbestos content is less than 10 percent as determined by a method other than
point counting by polarized light microscopy (PLM), verify the asbestos content by
point counting using PLM.
Category I nonfiiable asbestos-containing material (ACM) means asbestos-
containing packings, gaskets, resilient floor covering and asphalt roofing products
containing more than 1 percent asbestos as determined using the method
specified under AHERA.
Category II nonfiiable ACM means any material, excluding Category I nonfriable
ACM. containing more than 1 percent asbestos as determined using the methods
specified under AHERA, when dry, cannot be crumbled, pulverized, or reduced to
powder by hand pressure.
Remove For Operations and Maintenance work on ACM, Hremovelu refers to the removal
of ACM as needed to perform a maintenance or repair 0 & M activity.
APPENDICES
Name C(Fac Jt J M 13
-------
Removal Encapsulant A penetrating encapsulant specifically designed to minimize fiber
release during removal of asbestos-containing materials rather than for in situ
encapsulation..
Repair Returning damaged ACBM to an undamaged condition or to an intact state so
as to prevent fiber release.
Respirator A device designed to protect the wearer from the inhalation of harmful
particulates.
Small-scale, Short-duration (See Appendix H)
Surfacing ACM Asbestos-containing material that is sprayed-on, troweled-on or otherwise
applied to surfaces, such as acoustical plaster on ceilings and fireproofing materials on
structural member, or other materials on surfaces for acoustical, fireproofing, or other
purposes.
Suspended 1’ Bar Ceiling System A false or dropped ceiling composed of acoustic tiles
laid into an inverted metal “T 1 ’ bar grid frame suspended by wires from building framing
members.
Surfactant A chemical wetting agent added to water to improve penetration, thus
reducing the quantity of water required for a given operation or area.
Temporary Barriers One or more layers of 6 mil polyethylene installed to isolate a work
area from other portions of a facility.
Thermal System Insulation ( Sl) Thermal system insulation - asbestos-containing material
applied to pipes, fittings, boilers, breeching, tanks, ducts or other interior structural
components to prevent heat loss or gain or water condensation.
Time Weighted Average (TWA) In air sampling, this refers to the average air
concentration of contaminants during a particular time period.
Transmission Electron Microscopy (FEM) A method of analysis using an electron
microscope, used to find and analyze the concentration. of airborne or bulk asbestos
fibers and structures. Distinguishes among asbestos and other materials; can detect
smaller asbestos fibers than does PCM. Used by EPA to find area concentrations for
large AHERA project clearancf.
Work Area The area where asbestos-related work or removal operations are performed
which is defined and/or isolated to prevent the spread of asbestos dust, fibers or debris,
and entry by unauthorized personnel.
Work Practices Procedures designed to be followed to avoid or minimize fiber release
during activities affecting ACM.
APPENDICES
14
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F
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Appendix F
References
EPA Regulations United States Environmental Protection
Agency, Asbestos Abatement Projects;
Worker Protection; Final Rule (“Worker
Protection Rule) 40 CFR 763.120-126,
Washington D.C., 1987.
United States Environmental Protection
Agency, National Emission’Standards for
Hazardous Air Pollutants (NESHAP) 40
CFR 61.140-1 57, Washington D.C., 1984,
revised 1990.
United States. Environmental Protection
Agency, Asbestos-Containing Materials in
Schools; Final Rule and Notice (Asbestos
Hazard Emergency Response Act -
AHERA) 40 CFR 763.80-99, Washington
D.C., 1987.
EPA Guidance Documents (Order by Calling TSCA Assistance
Hotline in Washington, DC at: (202) 554-
1404).
United States Environmental Protection
Agency, Managing Asbestos in Place
(“Green Book”) EPA Publication #20T-
2003, Washington D.C., 1990.
United States Environmental Protection
Agency, Guidance for Controlling
Asbestos-Containing Materials in
Buildings (“Purple Book”) EPA publication
#560/5-85-024, Washington D.C., 1985.
APPENDICES
15
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United States Environmental Protection
Agency, A Guide to Respiratory
Protection for the Asbestos Abatement
Industry (“White Book) EPA publication
#560-OPTS-86-001, Washington D.C.,
1986.
United States Environmental Protection
Agency, Simplified Sampling scheme for
Surfacing Materials (Pink Book”) EPA
publication #560/5-85-030a, Washington
D.C., 1985.
United States Environmental Protection
Agency, EPA Guidance fOr Service and
Maintehance Personnel, EPA publication
#560/5-85-018, Washington D.C., 1985.
United States Environmental Protection
Agency, Model training course materials
for accrediting Asbestos Building
Inspectors and Management Planners in
accordance with. AHERA, Washington
D.C., 1987.
United States Environmental Protection
Agency, Abatement of Asbestos-
Containing Pipe Insulation, Asbestos-in-
Buildings Technical Bulletin 1986-2,
Washington D.C., 1986.
OSHA Regulations Occupational Safety and Health
Administration, Asbestos Regulations for
the Construction Industry 29 CFR
1926.58, Washington D.C., 1986.
Occupational Safety and Health
• Administration, Respiratory Protection 29
CFR 1910.134, Washington, D.C., 1978.
Occupational Safety and Health
Administration, Hazard Communication
Standard for the Construction Industry 29
CFR 1926.59, Washington D.C., 1987.
APPENDICES •
NName c i FadUty” 16
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U.S. General Services Administration (PMSE) Documentation Package for Asbestos
Operations & Maintenance Programs,
Washington D.C., 1990.
Asbestos Information Center (Air monitoring guidance, etc.)
Miscellaneous References Institute for Environmental Assessment,
433 Jackson Street, Anoka, MN 55303:
1. Suggested Operations and
Maintenance Procedures
2. Guide to Asbestos Personal
Monitoring
3. Recognition o.f Damage,
Deterioration and Delamination
4 . Aerodynamic Characteristics of
Asbestos
Keyes, Dale L and Chesson, Jean.
Guide to Monitoring Airborne Asbestos in
Buildings, Tucson, AZ, 1989.
Health. Effects Institute - Asbestos.
Research, Asbestos in Public and
Commercial Buildings A Literature
Review and Synthesis of Current
Knowledge, Cambridge, MA, 1991.
APPENDICES
“Name ilacilky ” 17
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‘)&M Program Elements References
Element
Regulations & Guidance Document
Green Book
Guidance
APM Appointment & Training
Purple Book, AHERA. White Book
Pgs. 7 & 23-25
Worker Training
Purple Book, AHERA,, White Book
Pgs. 23-25
Bukiing Inspection & Assessment
Purple Book, AHERA, Pink Book
Pg. 7
Occupant Notification &
AHERA
Pgs. 12 - 13, 28 -29
.
.
Hazard Communication Program
OSHA 29 CFR191O.1200 &
OSHA 29 CFR 1926 59.
Pg. 22
.
Worker Protection Program
OSHA 29 CFR 1926.58
Pgs. 17- 18, 38
Respiratory Protection Program
White Book, OSHA 29 CFR 1910.134,
1926.58
Pgs. 17-18
.
Medical Surve Iance
OSHA 29 CFR 1926.58
‘Pg.27
Work Permit System
Pg. 15
S
Waste Disposal
EPA NESHAP 40 CFR 61.145,150 OSHA 29
CFR 1910.1200,
DOT 49 CFR Parts 171 & 180
Pg. 28
.
:
Recordkeeping
AHERA
Pg. 22
Fiber Releases
Purple Book, AHERA
Pgs. 20 -21
.
Periodic Surve iance & Reinspection
Purple Book, AHERA
Pg. 14
Air Monitoring
Purple Book, AHERA
OSHA 29 CFR 1926.58
Pgs. 10, 14 - 15
Confined Spaces
Federal Register June 5, 1989 OSHA
Proposed Rules
•
General Safety Hazards
White Book Appendix D OSHA 29 CFR Part
1926
APPENDICES
18
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ADDITIONAL ASSISTANCE AND TRAINING
EPA REGIONAL CONTACTS
Additional assistance can be obtained from your U.S. EPA Regional Asbestos Coordinators, NESHAP
Regional 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,NYIPR,V )
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 IV: (AL,FLGA,KY,MS,NCPSC,TN)
Asbestos CoordInator (404) 347-5014
NESHAP Coordinator (404) 347-2904
EPA REGION V: (IL 1N,MI ,MN,OH,WI)
Asbestos Coordinator (312) 886-6003
NESHAP CoordInator (312) 353-2088
EPA REGION VI: (AR,LANMPOK.TX)
Asbestos CoordInator (214) 655-7244
NESHAP Coordinator (214) 655-7229
EPA REGION VII: (IAIKS,MO,NE)
Asbestos Coordinator (913) 551-7020
NESHAP CoordInator (913) 551-7020
EPA REGION VIII: (CO,MT,ND,SD,UT,WY)
Asbestos Coordinator (303) 293-1442
NESHAP Coordinator (303) 294-7685
EPA REGION 1X (AZ,CA,HI,NV,AS,GU)
Asbestos CoordInator (415) 556-5406
NESHAP Coordinator (415) 556-5526
EPA REGION X (AKJD,OR,WA)
Asbestos Coordlhator (404) 442-4762
NESHAP Coordinator (206) 442-1757
APPENDICES
“ .ec Fadity t 19
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G
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Appendix G
General Safety. Considerations
(This section is reprinted from Appendix D
of the EPA’s White Book for use by personnel
performing 0 & M activities.)
APPENDICES
Name at Faciftj’ 20
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General Safety Considerations
Ronald L. Stanevich
NIOSH Division of Safety Research
This guide was primarily developed to provide recommendations concerning worker
respiratory protection within the asbestos abatement industry. However, employers must
not lose sight of the safety hazards their employees are exposed to in performance of
their work. Asbestos abatement operations can take place in a variety of industrial,
commercial and public settings. Each has unique potential safety hazards that the
employer must control. However, nearly all abatement operations have• some common
safety hazards. With proper job planning and supervision, the employer can control both
the health hazards and the safety hazards faced by their workers. The more common
safety hazards associated with abatement operations and general recommendations to
control them are discussed below. Sources for more specific safety information are listed
to supplement and support the applicable OSHA regulatory standards.
1. Elevated Work Surfaces
The nature of asbestos abatement tasks usually requires workers to work from ladders.
scaffolds, manlifts, or other elevated surfaces, which creates the potential for fall injuries.
Slips and falls from ladders, scaffolds, and other elevated surfaces result in a major
portion of the construction industry injuries. Many of these can be prevented by
implementing a few control measures:
A. General
(1) Avoid use of makeshift work platforms by providing portable ladders and
scaffolds.
(2) Ensure that job-built elevated work. surfaces are inspected by a competent
person other than the individual who erects it.
(3) Avoid working from elevated surfaces where possible. Consider use of
wands for spraying amended water or scrapers with extended handles.
APPENDICES
21
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B. Ladders
Eighty percent of ladder-related accidents result from improper use or application.
(1) Workers should face the ladder when climbing up, down, or working from
it.
(2) Workers should not carry objects in their hands while ascending or
descending ladders. While working from a ladder they should hold on with
at least one hand.
(3) Ladders should not be used as a substitute for planks,’ runways, or
walkboards.
(4) Ladders should be maintained in good condition. Defective ladders should
be destroyed so that no one uses them by mistake.
(5) Ladders should have safety feet in good condition to keep the ladder from
slipping and cutting through polyethylene floor covers.
(6) Ladder rungs/steps’should be kept free of contaminates such as amended
water and buildup of asbestos waste.
(7) Employees should work no higher than the fourth step/rung from the top
of the ladder.
(8) Employees should not attempt to “reach” distant objects from a ladder;
other platforms should be used.
(9) Wood or fiberglass ladders should be provided to help control exposure to
electrical hazards.
(10) Employees Should not straddle the space between a ladder and another
object.
(11) Employees should’ make a visual inspection of ladders before each shift.
Additional information sources:
“Ladders”,-- publication no. ISBN 0-919465-05-6
Construction Safety Association of ‘Ontario
74 Victoria Street
Toronto. Ontario Canada M5C 2A5
APPENDICES
‘Name c( FaCility’ 22
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“Safety Requirements for Portable Wood Ladders” -- ANSI A14.1 - 1982
“Safety Requirements for Job-Made Ladders” -- ANSI A14.4 - 1979
“Safety Requirements for Portable Reinforced Plastic Ladders” --ANSI A14.5
- 1982
American National Standards Institute, Inc.
1430 Broadway
New York, NY 10018
“Portable Ladders” -- Industrial Safety Data Sheet #665
National Safety Council
444 North Michigan Avenue
Chicago Illinois 60611
Environmental Health and Safety Division
Georgia Tech Research Institute
Georgia Institute of Technology
Atlanta, Georgia 30332
C. Scaffolds
Falls from scaffolds result in about 2,000 injuries per month in the United States. These
can be reduced by
(1) providing guardrails around the perimeter of the work surface regardless of
scaffold height
(2) securing scaffold decks against slippage
(3) keeping scaffold uprights vertical and pinned together when stacked
(4) ensuring vertical members are braced to keep the scaffold plumb and level
(5) decking the entire top portion of the work surface in lieu of using minimum
planking dimensions
(6) extending planks at least 6” (150 mm) over their support and clearing or
restraining them from movement
(7) ensuring that manufacturer built-in ladders are in good condition
APPENDICES
Name cj Fac Jty 23
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(8) maintaining mobile scaffold casters in good condition with position locking
devices secured when employees are working from the scaffold
(9) keeping mobile scaffolding height less than four times the minimum base
dimension and with adequate cross-bracing
(10) never interchanging scaffolding pans from different units
(11) never using defective scaffolding
(12) designating only “Competent TM persons to perform scaffolding repairs.
Additional information sources:
“Manually Propelled Mobile Ladder Stands and Scaffolds” - ANSI A92.1 -
1977
“Manually Propelled Elevating Work Platforms” -- ANSI A92.3 - 1980
“Self-Propelled Elevating Work Platforms” -- ANSI A92.6
American National Standards Institute, Inc.
1430 Broadway
New York, NY 10018
II. Electiical Hazards
Asbestos abatement is often related to renovation or remodeling activities. Normally the
equipment, machinery, overhead lighting fixtures. and auxiliary furnishings are removed
to facilitate the abatement work. However, it is becoming more common that industrial
and commercial buildings remain partially occupied while abatement operations are
performed. In either situation, the abatement operator must take positive actions to
protect employees from accidently coming into contact with energized electrical circuits.
A. General
(1) Perform a pre-work walk-through of the abatement area to look for
pre-existing electrical hazards involved with the work.
• (2) De-energize as many circuits as possible.
(3) Verify that the circuits have been de-energized with a “Field Current Sensing
Device” circuit tester. Either lock out/tag out all de-energized circuits to
prevent them from accidentally being energized.
APPENDICES
“Name j Fac fty ” 24
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(4) Use non-conductive tools such as scrapers and vacuum attachments made
of wood, plastic, or rubber.
(5) Provide workers with non-conductive rubber boots and/or gloves when
work must be done around energized wiring or equipment.
(6) Prohibit accumulation of puddles of water on the floor. Workers should be
trained in the intelligent use of amended water. No water should be used
around energized circuits.
B. Permanent Building Circuitry
(1) Ensure that all permanent circuits are provided with a grounding system.
This can be determined with a portable ground tester.
(2) Ensure that electrical outlets are tightly sealed and taped to avoid water
spray.
(3) Determine what equipment must remain energized during the abatement
process.
(4) Insulate or guard energized equipment and Wiring from employee contact
and other conductive objects.
(5) Avoid damaging permanent building wiring during the work.
(6) Consider dry removal methods in the vicinity of electrical equipment which
must remain energized.
C. Temporary Power
(1) All temporary circuits provided by the abatement operator must be provided
with a grounding system and protected by ground fault ôircuit interrupters.
(2) Avoid stringing temporary wiring across floors
(3) Elevated wiring should not be fastened with staples. nails, or wire.
(4) Use care not to damage the wiring insulation during Installation or
abatement work.
APPENDICES
‘Nwne c( FackIJ” 25
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D. Electrical Cords and Tools
(1) Provide extension cords which have a ground conductor.
(2) Ensure that cords are not damaged, contain no splices, and that the ground
lug on the male plug is intact.
(3) Position extension cords to eliminate stumbling/tripping hazards and to
protect them from damage by moving scaffolds.
(4) Provide electrical tools which are either grounded or of the double-insulated
type
(5) Use shatterproof, guarded bUlbs and heavy duty wiring for temporary
lighting.
(6) Where plugs enter receptacles, ensure that the connection is protected by
use of duct tape or by other means.
Additional information sources:
“National Electrical Safety Code” -- ANSI C2-1984
“National Electrical Code” -- ANSI/NFPA 70-1984
American National Standards Institute, Inc.
1430 Broadway
New York, NY 10018
“Temporary Electric Wiring for Construction Sites” -- Industrial Safety Data
Sheet #515
National Safety Council
444 North Michigan Avenue
Chicago, Illinois 60611
Ill. Housekeeping
Asbestos abatement operations present continuous housekeeping problems. The
accumulation of asbestos and other debris on polyethylene-covered floors create
employee slipping and tripping hazards. It is essential that accumulation of such debris
be bagged and removed from the floor as soon as possible. Even though this activity
may initially require more effort. it will make final cleanup easier and the work area safer.
APPENDICES
26
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Additional information source:
“Supe isors Safety ManuaP ’
National Safety Council
444 North Michigan Avenue
Chicago, Illinois 60611
IV. Emergency Planning
The abatement operator should develop emergency procedures’ for fires or severely
injured employees. Since abatement work areas must be sealed off. thereby blocking
normal exits. the operator must familiarize the workers with procedures for safe exit in
case of fire. Furthermore, the operator should develop plans for obtaining emergency aid
in case of severe employee injury. The plans should be compatible with decontamination
procedures yet provide for quick medical aid.
Additional information source:
Environmental Health and Safety Division
Georgia Tech Research Institute
Georgia Institute of Technology
Atlanta, Georgia 30332
APPENDICES ‘
‘1ameo(Fackv 27
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H
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Appendix H
Definitions of Small-Scale, Short-Duration Operations
This section sets forth the EPA and OSHA definitions of small-scale, short-
duration operations — the scope of work intended under this manual. All
references are to the Code of Federal Regulations (CFR), the Federal
Register (Fed. Reg.), or the OS!-L4 Compliance Manual (OSHA INSTR.)
This manual is intended for use only with. operations qualifying as usmall..scale , short-
duration” projects under OSHA and EPA regulations and regulatory guidelines. A
summary of these regulations and guidelines are set forth below. The-. complete
regulations . should be consulted for full information related to these definitions. The
reader should review this Appendix in its entirety for a complete understanding of the
current regulatory picture, and of the proposed changes to those regulations. The reader
should also consult the regulations at the time of use to ensure that these definitions are
still in place. Local and state guidelines and regulations should also be consulted.’
1. OSI-IA DEF1N ONS ‘
A. Current Definition The definition contained in Appendix G of the
construction asbestos standard (29 C.F.R. 1926.58) is as follows:
For the purposes of this appendix, small-scale, short-duration renovation
and maintenance activities’ are tasks such as, but not limited to:
• Removal of asbestos-containing insulation on pipes:
• Removal of small quantities of asbestos-containing insulation on
beams or above ‘ceilings;
• Replacement of an asbestos-containing gasket or valve;
• Installation or removal of a small section of drywall;
• Installation of electrical conduits through or proximate to asbestos-
containing materials.
29 C.F.R. § 1926.58, App. G.
B. Problems With the Current OSHA Definition OSHA has been under court order
since February, 1988 to amend its definition of its exemption from the negative
pressure enclosure requirement for small-scale, short-duration operations,
because, as the court found, “the exception as now worded seems to erase the
rule.” See Building and Construction Trades Department, AFL-CIO v. Brock, 838
APPENDICES
l4ame c( Fac ty ’ 28
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F.2d 1258, 1279 (D.C. Cir. 1988). OSHA is currently revising its definition as part
of a rulemaking procedure begun in 1990 and is expected to promulgate a new
regulation in 1992. OSHA’s proposal is set forth below at 1.0.
C. Clarifications Contained in OSHA INSTRUC11ON CPL 2-2.40 OSHA has issued
only one compliance directive on the asbestos standard; the directive further
defines small-scale operations as follows:
29 C.F.R. 1926.58(e)(6)Qv)grants exceptions from the requirements of establishing
negative-pressure enclosures and designating a competent person, if the operation
is smal!-scale, short-duration. For the purposes of this standard a °small-scale,
short-duration” operation is defined as:
(1) Maintenance or renovation tasks, where the removal of asbestos-containing
materials is not the primary goal of the job (e.g., repairing a valve which
entails the removal of asbestos, installing electrical conduit which must be
fastened to asbestos cement siding, etc.)
(2) Activities where the employees’ exposures to asbestos can be kept below
the action level via worker isolation techniques, such as glove bags or other
methods described in Appendix G.
(3) An operation which has been, included in the employer’s asbestos
maintenance program (as required in Appendix G) of all employers who are
claiming an exemption from the requirements of 29 C.R.R. 1926.58(e)(6).
(4) Nonrepetitive operations (viz.: not a series of small-scale jobs, which if
performed at one time would have resulted in a large-scale removal).
OSHA Instruction CPL 2-2.40 (September 1, 1987).
0. OSHA’s Proposed Revisions to the Current Definition
NOTE: This sections describes proposed rules that are not legally binding as of
September 1992. OSHA may change this definition in the final rules.
(1) Regulated Areas OSHA has proposed to require regulated area protections
for all maintenance work covered under the construction asbestos standard,
including small-scale, short-duration operations, regardless of measured
exposure levels. (55 Fed. Reg. 23,752 (1990).
APPENDICES
29
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(2) Proposed Definition of Small-Scale, Short-Duration
Operations OSHA’s proposed definition first sets forth general criteria, then
lists specific operations that fall within those crIteria. 55 Fed. Reg. 29,717.)
The general criteria are that the operations are:
• non-repetitive;
• affect small surfaces or volumes of material containing asbestos,
tremolite, anthophyllite, or actinolite; and
• will be completed within one work day; and
• are not expected to expose bystanders to significant amounts of
asbestos.” ( )
The proposal includes the following as illustrations of small-scale, short-
duration operations:
• repair or removal of asbestos on pipes that is less than 21 linear feet
(6.4 m);
• repair or removal of asbestos panel that is less than 9 square feet
(0.8 m 2 );
• pipe valve repair or replacement of pipe valves containing asbestos
gaskets or electrical work that disturbs asbestos that is completed
by one worker in less than four hours;
• removal of drywall which is completed for the facility within an eight-
hour workday;
• renovation projects involving endcapping of pipes and tile removal
that is completed in less than four hours; and
• installation of conduits that is completed within an eight-hour work
shift.
55 Fed. Reg. 29,751 (1990).
2. EPA Delinitions
A. AHERA The EPA definition under AHERA (40 CFR 763 - Appendix B to
Subpart E) repeats the basic OSHA definition (contained in 1 .A., above), but
adds the following clarifications:
Small-scale, short-duration maintenance activities can be further defined, for
the purposes of this subpart, by the following considerations:
(1) Removal of small quantities of asbestos-containing materials (ACM)
only if required in the performance of another maintenance activity
not intended as asbestos abatement.
APPENDICES
neo1Facfl 30
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(2) Removal of asbestos-containing thermal insulation not to exceed
amounts greater than those which can be contained in a single glove
bag .
(3) Minor repairs to damaged thermal system insulation which do not
require removal.
(4) Repairs to a piece of asbestos-containing wallboard.
(5) Repairs, involving encapsulation, enclosure or removal, to small
amounts of friable asbestos-containing material only if required in the
performance of emergency or routine maintenance activity and not
intended solely as asbestos abatement. Such work may not exceed
amounts. greater than those which can be contained in a single
prefabricated minienclosure. ’ Such an enclosure shall conform
spatially and geometrically to the localized work area, in order to
perform its intended containment function.
40 C.F.R. 763, App. B to Subpart E (emphasis added).
B. Worker Protection Rule The EPA Worker Protection Rule (40 C.F.R.
763.121-126) regulates worker protection for those public employees not
covered under the OSHA regulation or under state plan programs, on
abatement jobs other than in schools. The rule covers only abatement jobs
and does not apply to small-scale, short-duration operations.
The implicit cut-off point is in the reporting requirement to EPA: the rule
requires pre-job reporting of abatement projects, except ones that involve
less than either three linear (1 m) or three square feet (0.3 m 2 ) of friable
asbestos ” or an emergency project. 40 C.F.R. § 763.124.
C. Major/Minor Fiber Release Categories Under AHERA EPA also utilizes the
3 square or 3 linear feet cut-off in its regulations covering operations and
maintenance in schools (40 C.F.R. 763.91). Paragraph (f), which regulate
“fiber release episodes,” defines a “major fiber release episode” requiring
a trained abatement worker, as “the falling or dislodging of more than 3
square (0.8 m 2 ) or 3 linear feet (1 m) of friable ACM.” (40 C.F.R.
763.91(0(2).). .
D. NESHAP EPA’s National Emission Standards for Hazardous Air Pollutants
(NESHAP), 40 CFR Part 61, applies to demolition or renovation activities,
and “individual, nonscheduled operations” (such as O&M or emergency
renovation operations work). NESHAP applies if the renovation or
demolition involves more than the following amounts of regulated asbestos-
containing material (RACM) on a single project, or if the combined additive
amount of RACM to be removed or stripped during a calendar year of
January 1 through December 31 exceeded:
APPENDICES
NameofFac tLy’ 31
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(1) At least 80 linear meters (260 linear feet) on pipes or at least 15
square meters (160 square feet) on other facility components, or
(2) At least 1 cubic meter (35 cubic (feet) off facility components where
the length or area could not be measured previously.
NESHAP also requires:
(1) A thorough inspection of the affected facility, or part of the facility
where the demolition or renovation operation will occur, for the
presence of asbestos, Including Category I and Category II non-
friable ACM. (See Appendix E for definitions).
(2) Written notification to the EPA prior to the start of operations
regulated under NESHAP. (40 CFR 61.145 (b)).
3) Wetting RACM when it is stripped from a facility component while it
remains in place in the facility during the stripping operation.
In renovation operations, wetting is not required if:
a. Prior written approval is obtained from the EPA if wetting
would unavoidably damage equipment or present a safety
hazard.
b. A local exhaust ventilation system designed and operated to
capture the particulate asbestos material produced by the
stripping and removal of the asbestos materials.
c. A glovebag system is used.
d. Leak-tight wrapping is used to contain all RACM prior to
dismantlement.
See 40 CFR 61.145 (c) (3) for specific details on these options.
(4) A person trained in the’ NESHAP provisions on-site during stripping,
removal, or other handling or disturbance of ACM in a NESHAP
regulated facility.
(5) RACM handling, waste packaging and waste tracking requirements.
(6) If the asbestos content of a material is determined by Polarized Ught
Microscopy (using 40 CFR Part 763, Section 1, Appendix A, subpart
F method) to be less than 10 percent, verify the asbestos content by
APPENDICES
neciFacifty” 32
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point counting using Polarized Light Microscopy. Alternatively, the
material may be assumed to be, and treated as, ACM.
APPENDICES
“Name FaclIty’ 33
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I
-------
Appendix I
Regulations
Note: This Information is reproduced from chapter 6 Of the Green Book.
Building owners are governed by a variety of federal, state, and local regulations which
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 government agencies, in addition to organizétioñs 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.
OSHA Regulations and the U.S. EPA Worker Protection Rule There are several important
Occupational Safety and Health Administration (OSHA) and EPA regulations that are
designed to protect workers. OSHA has specific requirements óoncerning worker
protection and procedures used to control ACM. These include the OSHA construction
industry standard for asbestos (29 CFR 1926.58), which applies to 0 & M work, and the
general industry asbestos standard (29 CFR 1910 1001) State of
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 where friable ACM is in good condition, applicable OSHA permissible
exposure limits are not likely to be exceeded. However, it is possible that some 0 & M
activities will disturb ACM to such an extent that the OSHA limits are exceeded, unless
good work practices are followed.
The OSHA standards and the EPA “Worker Protection Rule” requires employers to
address a number of items which are triggered by exposure of employees to asbestos
fibers. Exposure is discussed in terms of fibers per cubic centimeter (cc) of air. A cc is
a volume approximately equivalent to that of a sugar cube.
Two main provisions of the regulations fall into the general category of “Permissible
Exposure Limits (PELs)” to airborne asbestos fibers. They are:
APPENDICES
34
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1. 8-hour time-weighted average (TWA) limit - 0.2 fiber per cubic centimeter (f/cc) of
air based on an 8-hour 1WA sampling period. This is the maximum level of
airborne asbestos, on average, that any employee may be exposed to over an 8-
hour period ,(normal work shift).
2. Excursion limit (EL) - 1.0 f/cc as averaged over a sampling period of 30 minutes.
These levels trigger mandatory requirements, which include the use of respirators and
protective clothing, the establishmentof regulated areas,” the posting of dan er signs as
well as the use of engineering controls and specific work practices.
OSHA regulations also establish an TM Action Level’: 0.1 f/cc for an 8-hour TWA.
Employee training is required once the action 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 exposed at or above the action level of a period of 30 days or more in a calendar year,
medical surveillance is required according to OSHA construction industry asbestos
standard.
OSHA also requires medical examinations under its “General Industry Standard” 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” (1.0 f/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
applicable for the workers who carry out the kinds of work discussed in this 0 & M
guidance document. The OSHA construction industry asbestos standard applies .to
demolition and asbestos removal, enclosure or encapsulation projects, as well as to
repair, maintenance, alteration, or renovation if ACM is involved. ACM. spills or
emergency clean-up actions are also covered by this regulation.
According to these regulations, participation in a medical surveillance program is required
for any employee who is required to wear a negative pressure, air-purifying respirator.
Replacement, annual, and termination physical exams are also required for these
employees. However, a termination exam is only necessary under the construction
industry standard (which applies to custodial and maintenance employees) if a physician
recommends it. While not mandatory, EPA and NIOSH recommend physical
examinations, including cardiac and pulmonary tests, for any employee required to wear
a respirator by the building owner. These tests determine whether workers will be unduly
stressed or uncomfortable when using a respirator.
APPENDICES
“Name ci Facky” 35
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Additional requirements of the OSHA asbestos standards, such as the use of air filtration
systems and hygiene facilities, involve procedures which are most applicable to large-
scale asbestos abatement projects. However, these rules also include a number of
recommendations for procedures which might be appropriate for a variety of O&M
programs for buildings.
Small-scale Short-duration Projects (OSHA) Appendix G of OSHA regulation 29 CFR
1926.58, discusses work practices and engineering controls for small-scale, short-duration
asbestos renovation and maintenance activities. The OSHA regulation requires negative
pressure enclosure and full scale decontamination when asbestos is disturbed and either
the OSHA Permissible Exposure Umit or Excursion ‘Umit is exceeded or may reasonably
be expected to be exceeded. Appendix G Is mandatory for small-scale, short-duration
activities that exceed, or may reasonably be expected to exceed, these limits if an
ömployer wishes to be exempt from paragraph (e)(6) (establishing a negative pressure
enclosure) and paragraphs )(1)(i) or U)(2) ) (full scale decontamination) of this
regulation. OSHA states that it expects the engineering and work praôtice controls in
Appendix G to reduce asbestos exposure levels below the Action Level. OSHA has
proposed in its forthcoming rule that Appendix G become mandatory for all small-scale,
short-duration activities and not be based on exceedence of particular asbestos exposure
levels.
Small-scale, short-duration projects are not currently precisely defined in terms of either
size or duration, although their nature and scope are illustrated by examples presented.
in the text of the regulation. Properly trained maintenance workers may conduct these
projects. Examples may include removing small sections of pipe insulation or covering
for pipe repair, replacing valves, installing electrical conduits, or patching or removing
small sections of drywall. OSHA issUed a clarification of the definition of a “small-scale,
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 of a small-scale, short-duration project is maintenance,
repair, or renovation of the equipment or surface behind the ACM - not abatement of
ACM -then the appendix provisions may apply. If the intent of the work is abatement of
the ACM, then the full-scale abatement control requirements apply.
In any event, this appendix section of the OSHA construction standard outlines
requirements for the use of certain engineering and work ‘practice controls such as
glovebags, 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, Appendix B, for SS/SD projects.)
APPENDICES
Nwne o( Fac ity 36
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U.S. PA National Emission Standards for Hazardous Air Pollutants (NESHAP) (40 CFR
61 Subpart M) EPA’s rules concerning the application, removal, and disposal of RACM,
as well as manufacturing, spraying and fabricating of ACM, were issued under the
asbestos NESHAP. The asbestos NESHAP regulation governs asbestos demolition and
renovation projects in all facilities. The NESHAP rule usually requires owners or operators
to have all friable ACM be removed before a building is demolished, and may require its
removal before a renovation. For renovation projects where friable ACM will be disturbed,
the NESHAP rule requires appropriate work practices or procedures for the control of
emissions. It is prudent to note that any ACM which 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 expensive
than removals while the building is still occupied and being used.
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:
1. Name and address of the building owner or manager;
2. Description and location of the building
3. Estimate of the approximate amount of friable ACM present in the facility;
4. Scheduled starting and completion dates of ACM removal;
5. Nature of planned demolition or renovation and method(s) to be used;
6. Procedures to be used to comply with the requirements of the regulation; and
7. Name, address, and location of the disposal site where the friable asbestos waste
material willY be deposited.
The notification requirements do not apply if a building owner plans renovation projects
which will disturb less than the NESHAP limits of 160 square feet (15 m 2 ) of friable ACM
on facility components or 260 linear feet (80 m) of friable ACM on pipes (quantities
involved over a one-year period). For renovation operations in which the amount of
RACM equals or exceeds the NESHAP limits, notification 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 procedures and appropriate
work practices during collection, packaging, transportation or disposal of friable ACM
waste. All RACM must be kept wet until sealed in a leak-tight container that includes the
appropriate label.
Note: The in formation below is based on Department of Transportation (DOT) regulations
and interpretations.
APPENDICES
NNamec Facky 37
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DOT recently revised its hazardous material regulations (HMR; 49 CFR 171-1 80), and will
amend it further as conditions warrant. Packaging of ACM must meet general HMR
requirements and be protective, marked and labeled, except as noted below:
Small quantities: Samples over 1 ounce (30 grams) each are subject to the HMR.
•A “small quantity” shipment of samples is exempt from the HMR if the samples are
each 1 ounce (30 grams) or less in cushioned, securely sealed and packed inner
containers of plastic (at least 8 mil (0.2 mm) thick), glass, metal or earthenware.
The entire, strong package must weigh 64 pounds (29 kg) or less, and be marked
as required.
Umited quantities: A limited quantity” shipment is exempt from marking if it is 66
pounds (30 kg) or less with inner packagings up to 11 pounds (5 kg) each in the
strong outer packaging. It is also exempt from labeling and placarding if it is not
being shipped by air.
Labeling: Packages must generally have a class 9 label, unless excepted.
Marking: Packaging, except for limited quantities, must be marked with “RQ” (for
waste), “waste” or the EPA hazardous waste marking (for waste), the shipping
name, UN identification number, and, usually, the consignee or consignor’s name
and address. See beloW for details.
Placards: Starting October 1, 1994, bulk packaging, freight containers, and
transport vehicles must have “class 9” placards, except for “small quantity” and
“limited quantity” shipments, and motor vehicle or freight container shipments less
than 1001 pounds (454 kg).
Shipping limitations: Shipping “blue” or “brown” asbestos (as defined below), other
than “small quantity” shipments, is forbidden from aircraft or passenger-carrying
railcars, and “white” asbestos is limited to 440 pound (200 kg) shipments by such
modes. The HMR defines chrysotile, actinolite, anthophyllite and tremolite
asbestos as “white asbestos,” crocidolite asbestos as “blue asbestos,” and amosite
and mysorite asbestos as “brown asbestos.”
Vehicle marking: A vehicle transporting asbestos-containing waste must be
marked with asbestos danger signs during loading and unloading of the waste.
APPENDICES
38
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Waste shipment record: The reäord must be completed for each shipment of ACM
waste. A copy signed by the transporter must be given to the building owner or
operator (e.g., maintenance or abatement contractor) when the waste leaves the
building site, and a copy signed by the disposal site must be received in 45 days.
Exceptions: The HMR does not cover asbestos immersed or fixed in a binder
material such as cement, plastic, asphalt, resins or mineral ore (e.g., nonfriable
ACM that has not become crumbled, pulverized or reduced to powder),
manufactured products containing asbestos (e.g., pipe gaskets), and shipments
of less than 1 pound of friable ACM. Packaging of ACM must conform to specific
requirements, but need not meet HMR performance oriented packaging
specifications for Packaging Groups II and Ill.
Shipping papers and marks: Entries used in the hazardous material description
on shipping papers and marks are:
RQ, (Reportable Quantity, if 1 lb or more of
friable asbestos)
WASTE (For transportation of waste material, if
applicable)
WHITE (or BLUE or BROWN) ASBESTOS (Shipping name; the DOT asbestos
descriptions; listed in “shipping
limitations,” above)
MIXTURE (For asbestàs mixed with a binder or
filler, etc.)
9, (Class 9, Miscellaneous Hazardous
Materials, includes asbestos)
UN2590 (or UN221 2, or UN221 2) (United Nations Identification numbers for
the 3 DOT asbestos descriptions)
APPENDICES
NName at l ac itif 39
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PG III (or II, or II), (Packaging Groups for the 3 DOT
asbestos descriptions; I I and Ill are
medium and minor; use II if mixed
shipment)
LTD QTY, (Umited quantity, if applicable)
20 oz (Total quantity of material described; may
abbreviate unit)
When asbestos of two or more DOT descriptions are mixed in a shipment, each is listed,
for example, RQ, Waste blue and white asbestos, 9, UN2212 and UN2590, PG II, Ltd
Oty, 2 lbs.u
Where uncertainty exists in a particular situation, regulatory advice should be obtained.
APPENDICES
E acUk ( 40
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J
-------
Appendix J
Inspecting Buildings for Asbestos-Containing Building
Materials
1. Bulk Sampling of Suspect Materials
This section coverS the aspects for collecting bulk samples from suspect...surIacing,
thermal systörns’ insulation (TSI) and miscellaneous materials. Also included are
procedures for collecting samples, and implementing a quality assurance (QA) program.
No O&M Plan can be implemented until the presence of ACBM have been confirmed
through a visual inspection of the facility, including the collection and analysis of bulk
samples. In all likelihood, an inspection and survey have already been performed at
facilities occupied or controlled byEPA. GSA procedures require that such an inspection,
including collection and analysis of suspect ACM be performed before occupancy by
federal agencies, including EPA.
Conducting an inspection and survey to identify and locate ACBM are normally performed
by the building owner, but at times maybe assigned to a tenant (i.e. GSA, EPA or other
federal agency) or operator of the facility. At other times, a tenant or operator may collect
samples of suspect material(s) not previously sampled in the facility-wide inspection.
Asbestos Sôhool Hazard Abatement Reauthorization Act (ASHARA) regulations require
that anyone collecting samples for purposes of determining the presence of asbestos
must be ar-i AHERA certified Asbestos Inspector.
AHERA inspection procedures are, by regulation, required only for schools. ASHARA
requires certification and training only, not adoption of the sampling and inspection
procedures.
Form and format of inspections and surveys vary greatly. All properly conducted
inspections will have located and sampled all suspect surfacing, TSI and miscellaneous
materials. The facility’s full inspection and survey report shall be made a part of the
facility’s O&M Plan to clearly identify ACBM locations. The inspection report shall also
APPENDICES
41
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describe the condition of all asbestos materials so selection of the proper response action
and O&M procedures can be implemented.
Any O&M Plan is based upon the facility’s inspection and survey report. If one has not
been conducted, or it is determined that the current inspection may be inadequate,
conducting a proper inspection for ACBM Is strongly encouraged.
2. Planning and Designing the Sampling Operation
A. Surfacing Materials
The following discussion isbased largely on a portion of the EPA guidance
document, Asbestos in Buildings: Simplified Sampling Scheme for Friable
Surfacing Materials , (EPA 560/5-85-030a, October 1985), the “Pink Book.”
Health and safety guidelines for EPA Asbestos Inspectors are included in
the SMs document which is a part of this Program.
B. Identifying Sampling Areas
Group friable surfacing material into “homogeneous” sampling areas. A
homogeneous area of surfacing material contains friable material that is
uniform in texture and color and appears identical in every other respect.
Materials installed at different times belong to different sampling areas. If
there is any reason to suspect that materials might be different even though
they appear uniform, assign them to separate sampling areas.
For example, material in different wings of a building, on different floors, or
in special areas such as cafeterias, machine shops, bandrooms, etc.,
should be assigned to separate sampling areas unless there is good reason
based on careful review of reliable historical construction documents to
believe that the materials are identical throughout.
In a large multi-story building, a separate sampling area for each floor may
not always be necessary. If the material appears identical on every floor,
several floors can be grouped into one sampling area. Do not group floors
if it is known that the material was applied at different times, or if there is
some other reason to suspect that the material might not be homogeneous.
APPENDICES
Nw e t c1Fac ty” 42
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The selection of homogeneous sampling areas is a subjective process.
When in doubt, assign materials to separate sampling areas, or collect
representative samples from each and every floor or building area.
C. Preparation of Diagrams
For each sampling area, prepare a diagram approximately to scale showing
all friable materials in the sampling area. Where the suspect material is only.
on horizontal surfaces, a tOs ale floor plan, could be used. A good
diagrammatic floor plan, usually is an 8 1 /2N x 1? size of a fire escape plan.
The sampling area diagram shoUld include:
(1) An identification number;
(2) Brief description of the sampling area;
(3) . Area dimensions and scale;
(4) Name of inspector and date of inspection; and
(5) Date the diagram was prepared.
If the sampling area of a large facility or single floor contains areas of friable
material that are not adjacent, sketch each separate area and place all
sketches on the same graph as close together as possible. The sampling
area may contain areas that are not in one plane; for example, a ceiling and
a wall with the same type of friable material. In this case, sketch each flat
surface and place the sketches on the same graph as close together as
possible. The sampling area diagrams should be retained as part of the
building owner’s permanent asbestos program file.
D. Number of Samples
Nine samples per homogeneous sampling area are recommended by EPA’S
Pink Book.. With nine samples, the likelihood of detecting asbestos when
it is present is very high. Cost or other constraints may limit the number of
samples that can be collected. If nine samples cannot be collected, use the
following table to determine the minimum number as required by the
AHERA Rule. This number depends on the size of the sampling area. In
a very small (much less than I ,000 square feet) sampling area such as a
closet, take only three samples rather than the full nine.
APPENDICES
T1ec Factht (
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EXAMPLE GRID;
132’
4h I I 4L
GYMNASIUM I AUDITORIUM
I I
I. I
.1
I.. I
I
• — — — — — — _l_. — — — — — — —. — — — ‘IF — — — — —
I. .1 60’
I I
I .1
90’ I I
I. I
I I
I I
• — — — — — — —1 •— — — — , — — — — — — — — It — — — — — — — a
I I
I I
.1 I
I I
I _____ I
_________________ ___________________ . — — a — —— — —— ——
60’ 12’-) — 60’ —
Facility _________
Address __________________________ Telephone No. _____________________
Inspector__________________________ Diagram Prepared by ________________
Date of Inspection _________________ Date ____________________________
45
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E. Selection of Sample Locations
In this sampling scheme, sample locations are selected so that they are
representative of the sampling area. When nine samples are collected, they
are distributed evenly throughout the sampling area. If fewer than nine
samples are collected, a random sampling scheme is used to determine
their location. Choosing sample locations according to personal judgment
produces samples which may not be representative and can lead to a
wrong decision about the presence or absence of asbestos. The sampling
scheme described here helps to avoid this problem and can control the
frequency of mistakes.
Divide the sampling area into nine equally sized subareas. This is done by
dividing the length and breadth of the sampling area into three equal
lengths and drawing a grid over the diagram; a ‘Tic-Tac-Toe” diagram. This
can be done carefully by eye. Exact measurements are not needed
If the sampling area does not easily fit into a rectangular shape, parts of the
grid might not be in the sampling area. This is not a problem in most
cases. If, however, a large part of the grid falls outside the sampling area
(for example, if the sample area is L-shaped), it is advisable to divide the
sampling area into two or more separate sampling areas, each of which is
approximately rectangular, and select sample locations by applying the
sampling scheme to each sampling area.
For greatest coverage, one sample from each of the nine regions should be
collected. If fewer samples are to be collected, the random number
diagrams shown on the next page will determine which subareas to use in
order to follow a random sampling scheme. For very large areas, it may be
advisable to locate a grid with the grid to more accurately locate the sample
point.
If three or more samples are needed, take them from the subareas marked
1,2,3,4, and 5, and so on. Take samples from approximately the center of
a subarea or as close as possible to the center if accessibility, presence of
light fixtures, etc., make the center location impractical. If a subarea is
specified that falls entirely outside the sampling area, use the next specified
subarea instead. For example, if subarea three falls outside the sampling
area, take the third sample from subarea 4.
APPENDICES
U. 46
-------
For very irregular-shaped areas, the sampling area may be divided into nine
subareas of approximately equal size that do not necessarily form a
rectangular grid. The diagrams will then need to be adapted to the specific
situation. When adapting sampling diagrams, retain the order of the
numbered subareas from left to right and top to bottom whenever possible.
If you have more than 18 sampling areas, start again at the top of the
random numbers diagram chart to determine sampling locations for
Sampling Area 19, etc.
APPENDICES
“NamedFicmty 47
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RANDOM NUMBER DIAGRAMS
Sampling
Sampling
Sampling
Sampling
Sampling
Sampling
Area
Locations .
Area
Locations
Area
Locations
9
8
1
2
7
6
5•
3
4
8
3
4
6
5
6
1
7
8
9
10
11
12
5
8
1
4
3•
. 6
2
7
9
.
4
9
5
7
6
3
2
8
3.
9.
5
6
4
7
3
8
1
6
2
9
4
5
1
6
3
4
9
7
8
2
APPENDICES
13
14
15
16
17
18
8
5
2
3
6
9
.7
1:
4
1
6
9
7
5
2
5
6
2
8
4
1
8
2
7
4
:5
3
1
9
6
4
2
.7
9
.2
4
I
9
5
I
9
7
I
5
6
8
2
9
5
2
7
6
3
8
3
4
3
8
7
7
4
3
6
1
5
2
9
8
2
8
7
I
4
2
7
8
5
I
3
9
6
I
2
3
4
5
6
48
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F. Identification of Samples
Assign a unique sample ID number to each sample location. This ID
number will be on the sampling container when it goes to the laboratory for
analysis. Record the ID number and sample location on the sampling area
diagram and also on a data sheet (see Adminibbathfe Supplies below). This
must be done carefully so that there is no uncertainty about the location
and identity of each sample. Make sure that no two samples have the
same ID number. Non-sequential numbers are used to prevent the
laboratories from knowing which samples come from the same sampling
areas or the same buildings. The TM blind” procedure helps prevent bias on
the part of the ‘analyst since there is no temptation to assume that the next
sample will be similar to the previous one. On the other hand, non-
sequential ID numbers make organizing the analytical results by
homogeneous area much more difficult. Perhaps on alpha code which
identifies building and area combined with a non-sequential numerical
scheme is best.
Sample ID numbers are assigned to all samples - surfacing, thermal system
insulation and miscellaneous.
G. Thermal System Insulation ‘Material
The concept of homogeneous sampling areas applies equally well to
thermal insulation as to surfacing material. The major difference is that
insulation on thermal systems is likely to be much more varied than
materials on surfaces. A ‘ t typical” building may contain multiple insulated
pipe runs from any combination of the following major categories:
(1) Hot water supply and/or return;
(2) Cold water supply;
(3) Chilled water supply;
Steam supply and/or return (watch for different pressure steam lines);
(1) Roof or system drain;
(2) Chemical or waste transport.
APPENDICES
necfFacilk r 49
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Each of these systems may have been installed or patched/repaired at
different times and insulated with different materials each time. Therefore,
it is best to first identify the building system in question and use this
information in conjunction with the physical appearance of the insulation to
delineate homogeneous sampling areas.
Each “system” may be composed of a variety of materials. For example,
the following list contains nine different types of thermal insulation;
(1) Corrugated cardboard-type pipe wrap
(2) White chalky pipe wrap
(3) Fibrous glass insulation covering a pipe wrap of- unknown
characteristics
(4) Cementitous “mud” around pipe fittings
(5) Hard, canvas-wrapped insulation on pipe elbows
(6) Block insulation on boilers
(7) White batt insulation on boiler breeching
(8) Black batt insulation inside ducts
(9) Rope around pipe sleeves in ceiling and floor slabs
Each of these insulation types should be considered a separate component
of the system, and a separate homogeneous area for sampling purposes.
Fibrous glass, foam glass, rubber, and styrofoam are not suspect materials.
Note, however, that they may also cover up asbestos-containing fireproofing
overspray on piping systems and components.
The number of samples and the sample locations will depend on local
circumstances. Take at least three samples in each sampling area. For
long pipe runs or risers, more samples should be taken, especially if the
piping extends to more than one functional area. Pay special attention to
any change in the appearance of the insulation on long pipe runs. This
would indicate a possible change in insulation type and the need to
delineate a new sampling area. The AHERA Rule requires at least three
random samples for thermal insulation. Exceptions are:
(1) small (less than six linear or square feet) of patched insulation (at least
one sample), and
APPENDICES
0 Name c Facility” 50
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(2) areas of insulating cement (the number of samples tote determined by
the Building Inspector).
Normally, samples should be collected at locations where minimal damage
will be inflicted on the insulation. Choose exposed ends, damaged areas,
or areas where the protective covering or Jacket is missing. This is called
“convenience sampling”. The AHERA Rule requires random sampling.
Thus, samples will have to be taken from intact insulation. Of course, the
building owner always has the option of assuming the insulation contains
asbestos instead of sampling and analyzing for it, and non-school facility
owners are not required to exactly follow AHERA.
H. Miscellaneous Materials
Miscellaneous suspect materials are, for the mOst part, nonfriable (ceiling
tiles are an exception). As such, sampling is more difficult and destructive.
EPA does not recommend sampling these materials. Instead, they should
be identified as suspect and documented as assumed asbestos products
in permanent records.
Some building• owners wish to have miscellaneous materials sampled and
analyzed anyway. Ceiling and floor tiles are probably the most frequently
sampled of materials in the miscellaneous category. If sampling is desired,.
try to identify separate homogeneous areas just as you would for surfacing
material and thermal insulation. (You will probably find that many different
types, colors, and vintages of both floor and ceiling tile can be found in a
building.) Then take a convenience sample in an inconspicuous location.
Very hard materials like Transite wallboard should not be sampled. Not
only is sampling needlessly destructive and hazardous, Transite (or
Transite-type) wallboard can easily be identified.
3. Collecting Samples
A. Personal Protective Equipment
Sinbe inhalation of asbestos fibers during hundreds of inspection and
sampling jobs may pose a serious health hazard, the use of personal
protection equipment by building inspectors is crucial during the sampling
process. As a minimum level of protection, Inspectors should wear a
respirator, either a full or half-face mask with high efficiency disposable filter
APPENDICES
•NathedFac f 51
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cartridges. Full face masks will also prevent eye irritation from dust, fibers,
and debris released during the sampling operation. Disposable clothing
should be worn during sampling if the sampling operation is likely to
dislodge pieces of suspect material or if the environment is extremely dusty
(e.g., crawl space, dirty mechanical room). Inspectors should have plastic
bags, twisters, and labels with them to handle the disposal of cartridges,
protective clothing, wet cloths, and debris. If laboratory reports establish
the presence of asbestos-containing materials, these waste materials should
be disposed of as asbestos-containing wastes.
B. Sampling Equipment
Inspectors will need various tools and aids to accomplish their sampling
tasks:
(1) Ladders (and sometimes man-lifts) and flashlights are needed to
access areas and aid visibility;
(2) Airtight, rigid sampling containers (ag., 35 mm film canisters);
(3) Plastic spray mister bottle(s) with water to spray the areas to be
sampled;
(4) Plastic drop cloths to spread beneath the areas to be sampled;
(5) A knife, linoleum cutter, cork borer, or other tool appropriate for.
extracting samples;
(6) A caulking gun and compound for filling holes once a sample has
been extracted;
(7) Spray acrylic or adhesive to encapsulate sample extractions;
(8) Duct tape for repairing thermal system insulation jackets;
(9) Cloths (premoistened) for cleaning up debris and tools;
(10) A vacuum cleaner equipped with high efficiency particulate air
(H EPA) filters;
(11) Indelible ink pen and adhesive labels for labeling sample containers;
(12) Camera for photographic documentation; and
(13) Adhesive “dots” or labels to clearly mark the collection point with the
sample number and inspector’s initials.
APPENDICES
NName c i FacIlity 52
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C. Administrative Supplies
In addition to sampling area diagrams data forms for bulk samples will be
needed in the field. An example data form is shown on the following page.
This form is intended as guide; you will no doubt want to tailor the form to
your needs and working style. Identification labels for sample containers,
packing enclosure warnings and forms, plastic bags, sturdy cartons, sealing
tape, and writing materials (pens, pencils, clipboard) are also needed.
Given the amount of equipment needed for buk sampling, the inspector will
likely need assistance. A push cart or table on wheels is worth considering
to mobilize the. inspection and sampling operation.
0. Forms
Sample collection forms follow as examples to be used by EPA workers or
by outside consultants:
(1) Checklist Form
(2) Asbestos Building Survey Sheet
APPENDICES
53
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Building Number
CHEO T
Building Type
aintenance Personnel
1. Determine suspect ACBM to be sampled and 2. Dimensions of building verified on drawing?
devise sampling strategy?
3. OSHA labels affixed? 4. Verify building wall layout?
5. Ust homogeneous materials areas? 6. Photograph bulk sample location(s)?
7. Collected bulk samples? 8. Note bulk sample location on field drawings?
.
9. RepaIr bulk sample locations? 10. QuantIfy homogeneous materials areas?
-
11. Label bulk sample locations? 12. Note homogeneous materials areas on field
drawings?
13. Collect OC samples? 14. Note condition and assess hazard rankings?
15. Assign access code/homogeneous area? 16. Collect equIpment/vacate building?
17. Lock building? 18. Return key?
Special Conditions- (Description — I.E Access problems, no maintenance person, Incorrect drawings, etc.) V
Person notified Total Time Involved
Unsafe Conditions No Yes V
Description
Person notified Time Notified
Total time Involved
Inspector’s signature Date
II
APPENDICES
54
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v4SPECTOR _______
ASBESTOS BUILDII G SURW EY SH i
PAGE OF____________
BUILDING___________
DATE.
A. ACCESS CODE B. CONDiTiON C. DAMAGE CATEGORIES E. ASSESSMENT CATEGORIES (AHERA)
1. Exterior 1. Good 1. AIr Erosion 1. Damaged/Sign. Damaged TS1
2. Public 2. Fair 2. Blistering 2. Damaged friable surfacing material
3. Service Areas 3. Poor 3. Delamination 3. SIgn. Damaged friable surface material.
4. Crawl Space 4. RakIng/Dusting 4. Damaged/Sign. Damaged friable misc.
5. Attic 5. Physical damage 5. Material with potential for damage.
6. Vibration 6. Material with potential for sign. Damage.
7. Water Damage 7. Non-frIable material with potential for
damage/sign. Damage
D. POTENTIAL POR DAMAGE F. FESPONSE ACTIONS
1. Low 1. O&M Program
2. Moderate 2. Repair
3. High 3. Remove
HOMO
AREA
MATL
CODE
MATERIAL
DESCRIPTION
MATERIAL
LOCATION
MA L
OTY
SAMPLE
NUMBER
OC
SAMPLE
LOCATION
A
B
C
D
E
F
II
-
=
=
=
=
=
=
APPENDICES
55
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4. Quality Assurance
Quality assurance (QA) procedures are employed to ensure reliable results for analyses
of bulk samples. The first step is to choose a laboratory that is competent and reliable.
Laboratories should be chosen from the list of laboratories participating in EPA’s quality
assurance (round robin) program.
The second step in a QA program is to monitor the’performance of the laboratory where
samples are being analyzed. EPA recommends that for every 20th bulk samp!es that is
collected, a QA sample be taken immediately adjacent to the 20th samples. Thus the
20th and 21st sample of every group of 20 are side-by-side samples. Many building
inspectors will collect a QA sample for every 10 samples collected for a greater degree
of assurance. Laboratory analyses of these two samples are expected to’ closely agree.
Each sample is labeled independently so, that’ ‘the identity of QA samples cannot be
determined except by reference to records kept by the building inspector.
QA samples can be handled in one of two ways. .They can be sent together with all the
samples to a single laboratory for analysis. Alternatively, they can be sent to a second
laboratory and analyzed independently. The first checks on analytical variability with the
same label. The second checks on variability between labs. Using a second laboratory
is appropriate for large studies.
Laboratory results on the QA samples should not disagree on the presence or absence
of asbestos Q.e., 1% or less vs. more than 1% asbestos). If significant disagreement
occurs, additional samples should be taken and analyzed before declaring the material
to be or not to be asbestos-containing.
There may also be discrepancies in estimating the exact percentage of asbestos in side-
by-side samples. These discrepancies are not as serious as the presence/absence result
since any sample of friable material which contains more than one percent (1%) ‘asbestos
is designated as ACBM. However, the comparison of the asbestos percentage estimated
by the testing laboratory/ies can provide useful information on the reliability of the
analysis. Discrepancies may occur as a result of sample contamination, inconsistent
procedures, differences in technique, or mistakes (e.g., mislabeling of samples). Of
course, some variability in the “true” asbestos content of ACBM would be expected from
one location to another. Ordinarily the percentage for each QA sample as compared with
the percentage for its corresponding regular sample should not exceed ten percent
(10%). ‘
APPENDICES
56
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Any disagreement about the type of asbestos mineral (chrysotile, amosite, crocidolite)
present should be resolved by additional analyses. Information on mineral type may be
important when evaluating alternative methods of managing ACBM, especially if removal
of the ACBM is under consideration.
Procedures to assure the integrity of the samples are also a component of the QA
program. Strict chain-of-custody procedures should be followed.
5. Analytical Techniques for Bulk Samples
Polarized light microscopy (PLM) is the EPA-approved method for analyzing bulk materials
for asbestos This method of analysis is. relatively inexpensive. PLM utilizes a light
microscope equipped with. polarizing filters. The identification of asbestos fiber bundles
is determined by the visual properties displayed when the sample is treated with various
dispersion staining liquids. Identification is substantiated by the actual structure for the
fiber and the effect of polarized light on the fiber, all of which is viewed by the trained
technician. The limit of detection of asbestos by PLM is. about one percent (1%) by area.
Samples containing lower levels of asbestos are not reliably detected by this technique.
Other analytical methods employed to detected the presence of asbestos in bulk samples
include electron microscopy and infrared spectroscopy. Electron microscopy should be
used to detect smaller fibers of asbestos, such as found in fine dusts or to confirm
negative floor tile results. Both techniques are sometimes used to confirm the presence
of asbestos in a sample analyzed by PLM, rather than as routine analytical methods.
6. Laboratory Reporting
A competent, analytical laboratory should provide a detailed bulk sample analysis report
that includes the following information, at a minimum:
A. Client sample identification number;
B. Laboratory sample identification number;
C. Analytical technique used;
0. Laboratory quality control procedures;
APPENDICES
57
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E. Physical description of sample, as received;
F. Type(s) and estimated percentage of asbestos;
G. Types(s) and estimated percentage of non-asbestos fibers;
H. Types(s) (if known) and percentage of other components;
I. Date of analysis;
J. Analyst’s signature
This information, along with data generated in the field (e.g., location of sample, type of
material, photo references, etc.), should be maintained as part of an overall building
inspection, recordkeeping program.
APPENDICES
i4ame c( Fac ity ’ 58
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K
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Appendix K
EPA Health and Safety Guidelines for EPA Asbestos•
Inspectors (Revised)
APPENDICES
‘Name o Fac f 59
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United States Office of Administration March 1991
Environmental Protection and Resources
Agency Management
&EPA Health and Safety
Guidelines for
EPA Asbestos
Inspectors
(Revised)
Ptinted on Recycled Paj
I
Office of Administration
- “ “‘ Environmental Management Division
-------
C UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
_____ WASHINGTON, DC. 20460
+ 4 PRO1c. ’
IIjAR 2 9 I i
OFFICE OF
ADMINISTRATION
AND RESOURCES
NENOR NDUI4 MANAGEMENT
BUB3ECT: Revised Health and Safe y Ui es for Asbestos
Inspectors
PROM: Julius C. Jimeno, Director
Safety, Health and Environm tal Man einent Division
TO: Regional Administrators
- Assistant Administrators
Laboratory Directors
The attached “Health and Safety Guidelines for EPA Asbestos
Inspectors,” revised in March 1991, were developed for use by EPA
employees in carrying out the Agency’s various missions to control
asbestos exposures through inspection activities.
The two primary objectives for the Guidelines are:
to provide for the health and safety of asbestos
inspectors based on the best currently available
information;
o to reduce the likelihood of significant asbestos
exposures to the public through enhanced inspector
guidance.
We will continue to analyze asbestos inspector health and safety
issues and will develop revised guidelines in the future, as
warranted.
The Safety, Health and Environmental Management Division (SHEMD),
Office of Administration, is the lead office for development of
these guidelines. Please keep Howard 0. Wilson, Chief, Technical
Assistance and Evaluation Branch or David Scott Smith, Chief,
Policy and Resources Development Branch, SHEND, advised of your
experiences using the Guidelines. Your constructive comments on
inspector health and safety issues are welcomed, and we encourage
your input as additional experience is gained with our new
guidance. Our FTS number is 382-3640.
Attachment
“Health & Safety Guidelines for EPA Asbestos Inspectors”
cc: Occupational Health and Safety Managers
Printed on Recyded Paper
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HEALTH AND SAFETY. GUIDELINES
FOR EPA ASBESTOS INSPECTORS
Revised March, 1991
Safety, Health and Environmental Management Division
United States Environmental Protection Agency
Headquarters
401 N Street, Southwest
Washington, District of Columbia
20460
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PREFACE
These Guidelines were devioped by the Safety, Health, and
Environmental Management Division for employees of the United
States Environmental Protection Agency. They apply to EPA
employees who manage or supervise EPA asbestos inspectors, and to
EPA employees who perform asbestos inspections.
Beginning in 1989 and continuing through 1990, drafts of
this document were circulated within EPA for internal review and
comment. A number of changes to this document were made in
response to questions and comments received from the reviewers.
EPA Offices which were offered an. opportunity to review and
conunenton the draft Guidelines included:
1) Office of Administration and Resources Management;
2) Office of Air and Radiation;
3) Office of Pesticides and Toxic Substances;
4) Office of Solid Waste and Emergency Response;
5) Office of Enforcement.
In addition, on March 4, 1991 the Environmental Assistance
Division (EAD) (TS-799), Office of Toxic Substances COTS)
-provided further comments about these Guidelines. In response to
EAD’S comments, the the following language is hereby incorporated
into these Guidelines:
“EPA recognizes that its safety and health managers, and
other managers, have a responsibility to establish
protective — yet practical - respiratory protection programs
for their workers who engage in asbestos—related inspection
• activities. EPA managers are expected to: 1) ensure that
EPA’s asbestos inspectors and their supervisors are aware of
their obligations to meet applicable OSHA requirements, and
to ensure that their workers are properly trained,
certified, and equipped; 2) establish respiratory
protection programs for their asbestos inspectors which are
consistent with the EPA asbestos program’s (TS—799) policy,
as described in the NIOSH/EPA “white book.”
EPA managers are encouraged to provide maximum levels of
respiratory protection during asbestos-related work.”
Questions about the Guidelines should be directed to:
Chief, Technical Assistance and Evaluation Branch
Safety, Health, and Environmental Management Division (PM-273)
United States Environmental Protection Agency
• 401 M Street, S.W.
Washington, D.C. 20460
Telephone: (202) 382—3640
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TABLE OF CONTENTS
Health and Safety Guidelines for EPA Asbestos Inspectors
Page
INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
A. GENERAL REQUIR 1EZ1TS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . • • • .1
1. Asbestos Inspector’s Health and Safety Plan..........1
a. Emergency Procedures..... .. . . . . . . . . . .1
b. Personal Protective Equipment..... ....... . . .. . . .2
C. Operational PracticeS......... .. .. ........ . .. . . .2
2 . Evaluation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
3. IncidentReportingandReSPonse. ...2
4. Training . . • . . . . . . . . . . . . . . . . .2
5. Medical Monitoring. . . . . . . . .. . . . . . . . . 3
6 . Protective Clothing. . . . :. . . . . . . . . . . . . . 3
7. Respiratory Protective Equipment .. . . . .3
8. Other Personal Protective Equipment. .... . . . . . . .7
9 . Prohibited Practices . . . . . . . . . . 7
10. Personal Hygiene. . . . . 7
B. PROTECTIVE EQUIPMENT GUIDELINES FOR REMOVAL, DEMOLITION,
AND RENOVATION INSPECTIONS . . . . . . . . . . . . . . . . . . . . . . 7
1 . Protective Clothing 7
2 . Respiratory Protection. . . . . . . . . . .. . . . . . 8
a. No Respiratory Protection Required (outside
containment) . . . . . . . . . . . . . . . . . . . . . . . . . . 8
b. No Respiratory Protection Required (inside
containment) . • . . . . a . . . . . . . . . . . . . . . . . . . 8
c. Air—Purifying Respirators.. • ... • .... . 9
d. Self—Contained Breating.:ApparatUS . (SCBA) . . ... . . .9
C PROTECTIVE EQUIPMENT GUIDELINES FOR. ASBESTOS MANUFACTUR-
ING AND FABRICATING INSPECTIONS...............•.••”” 10
1. Protective Clothing. . . . . . . . . . . . . . . . . . . . • . . . . . . . . • . . .10
2. Respiratory Protection....... . ... .• • . ... .10
D. PROTECTIVE EQUIPMENT AND PROCEDURAL GUIDELINES FOR
COLLECTING BUI..K SAMPLES. . . . . . . . . . . . . . . . . . • . . . . . . 11
1. Protective Clothing. . . . • . . . . . . 11
2. Respiratory Protection. •.. . .. ..... . . ... . .... . 11
3. Procedural Guidelines. . . • 11
a. Preliminary Steps. • . . . . . . . . . . . . . . . . .11
b . Sampling Procedures. . . . . . . 12
c,. After sampling..... 13
i
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TABLE OF CONTENTS (CONTINUED)
E. PROTECTIVE EQUIPMENT GUIDELINES FOR INSPECTING ASBESTOS
WASTE DISPOSAL AND STORAGE SITE . .. .. .....13
1. Protective Clothing. . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
2. Respiratory Protection...... . ... ... .. . . ... .. . . .. . . . .14
a. No Respiratory Protection Required....... .. ... .14
b. Air—purifying RespiratOrS........ . . .. . . . . . . . . . .14
c. Self-Contained Breathing Apparatus (SCBA)......14
F. PROTECTIVE EQUIPMENT GUIDELINES FOR INSPECTING EMERGENCY
REMOVALOPERATIONSATSUPERF D TES....... . 14.
1 . Protective Clothing. . . . . . . . . . . . . . . . . . . . . . . . . . 14
2. Respiratory Protection....... . . . .. .. . . .15
a. No Respiratory Protection Required. 15
b. Air Purifying Respirators...... . .. . . . . . . . 15
‘C. Self-Contained Breathing Apparatus (SCBA) 15
G. PROTECTIVE EQUIPMENT GUIDELINES FOR INSPECTING AN
AB DONED BUILDING...... .. . . . . .. . . . . . . . . . . . . . . . . . . ...... .16
1. Protective clothing. . . . . . . . . . . . . . . . . . . . . . . . . 16
2. .RespiratoryProtectiOn.........”....””” 16
a. . No Respiratory Protection Required.... 16
b. Air Purifying Respirators...... ... .... . . 16
H. OPERATIONAL PRACTICES FOR ENTERING AND EXITING SITES.... .16
1. wearing SCBA When a Three-Stage DecontaTaination Systeitt
is Present. . . . . . . . . . . . . . . . . . . 16
2. wearing an SCBA when a Shower is Not Present 19
3. Wearing’ an Air-Purifying Respirator When a Three-Stage
Decontamination System is Present.... 20
4. wearing an Air-Purifying Respirator When a Shower is
— Not Present. .. .‘.. . . .. .. .. . . . . . . . . . . . . . .‘. 22
3 -3 .
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Health and Safety Guidelines for EPA Asbestos Inspectors
INTRODUCTION
These Guidelines are based on good health and safety
practices and are designed to minimize the likelihood of illness
or injury to EPA’S asbestos inspector.S.’: No set of guidelines can
anticipate every situation or substitute for the sound judgment
of properly trained professionals. However, these guidelines can
be an effective tool for assuring that the Agency’s mandate to
conduct asbestos inspections is safely conducted.
Asbestos inspections are performed to determine compliance
withenvironmental regulations including th3 National Emissions
Standards for Hazardous Air Pollutants (NESHAP), Asbestos-in-
School Toxic Substance Control Act (TSCA), and Worker Protection
(TSCA). EPA inspectors who perform asbestos inspections may be
involved in a variety of activities including: inspecting
removal, demolition, distribution and abatement sites; inspecting
manufacturing and fabricating operations; collecting bulk
samples; inspecting emergendy removals at Superfund sites; and
inspecting abandoned buildings, among others.
These guidelines were prepared by the EPA’s Safety, Health
and Environmental Management Division (SHEMD) for EPA employees
who are involved with EPA asbestos inspections. The SHEND has no
authority ‘over contractors, contractor agents, assigns or
employees; State agents, assigns or employees; or local
government agents, assigns or employees in matters pertaining to
asbestos exposures. However, the SHEMD encourages EPA program
offices to include these Guidelines as minimum conditions of
health and safety terms for contracts pertaining to asbestos
•inspection services, and as recommended guidelines for
collaborating State and local government asbestos inspectors.
A. GENERAL REQUIREMENTS I
1. Asbestos Inspector’s Health and Safety Plan . A. general
Asbestos Inspector’s Health and Safety Plan must be prepared by
each EPA Regional Office and’ other EPA organizations involved in
asbestos inspections. At a minimum, the Plan must inc] ude
emergency procedures, personal protective equipment, and
operational practices. The Plan must be. transmitted to the
appropriate safety committee for review and approval and then to
the safety program manager and senior management official (e.g.,
the Regional Administrator) for their review and approvals.
a. Emergency Procedures . The Plan must include procedures
to be followed in: 1) medical emergencieS, 2) accidental
releases of asbestos, and 3) other emergency situations.
For medical emergencies, the Plan must include the locations
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and telephone numbers of the nearest medical emergency
facilities and ambulance services. For asbestos releases,
the plan must include procedures for notifying responsible
building officials, as well as affected building occupants.
For other emergency situations, the Plan must include
provisions for identifying the emergency and non—emergency
local phone numbers for the police department, the local
fire department, and the nearest 24-hour poison control
center. In all cases, the location of the nearest phone
should be included to make the general plan site specific.
The use of an inspection kit containing cards with phone
numbers should be considered.
b. Personal Protective Eaui ment . The Plan must specify
protective equipment requirements, including respiratory
protection and protective clothing. The protective
equipment required may vary depending on the type of
inspection. For example, an inspector performing a NESHAP
inspection at an abatement site may be required to wear
self-contained breathing apparatus (SCBA) and a full body
disposable suit. On the other hand, an inspector performing
an Asbestos—in—Schools visual walk—through may not be
required to wear any protective equipment because measurable
exposure would be unlikely in situations in which no
asbestos—containing materials (ACM) have been disturbed and
where no asbestos—containing debris is present. The Plan
must specify protective equipment recommendations for each
type of inspection likely to be performed.
c. Operational Practices . The Plan must specify
operational practices for each type of inspection likely to
be performed. The operational practices may vary depending
on the activities performed during the inspections.
2. Evaluation . The senior management official should
assure that these Asbestos Inspectors’. Health and Safety
Plans are reviewed and revised as necessary ‘at least’
annually. ‘ ‘ ‘ ‘:
3. Incident Reportinc and Response . The appropriate.
program ‘manager must coordinate the reporting and, response’
to any incidents involving injury or illness, from asbestos
for EPA’S asbestos inspectors. Chapter 3 of the EPA’s
Occupational Health and Safety Manual details these
reporting requirements and procedures [ EPA #1440).
4. Training . All EPA employees engaged in asbestos-
related field inspection activities must receive a minimum
of 24 hours of approved basic occupational health and safety
training; must accompany an experienced asbestos inspector
for at least three days of directly supervised field
activities; and must receive eight hours of approved, formal
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refresher training annually. These, and additional
requirements are described in EPA Order 1440.2, “Health and
Safety Requirements for Employees Engaged in Field
Activities.” All EPA employees required to wear respirators
must receive six hours of approved respiratory protection
training, must be fit—tested at least semi-annually, and
must receive approved refresher training annually, as
described in EPA Order 1440.3. All EPA employees requested
to enter hazardous waste sites or Superfund sites must
receive the necessary training required under OSHA’s
regulation 29 CFR 1910.120.
5. Medical Monitoring . All EPA employees routinely
engaged in field activities which are likely to result in
exposure to toxic substances, or which require the use of
respiratory protective equipment must be included in the
Agency’s occupational Medical Monitoring Program. EPA Order
1440.2 requires that all EPA employees engaged in field
activities be included in the medical monitoring program.
EPA Order 1440.3 requires that all employees who wear
respiratory protection be determined to be medically fit to
wear respiratory protection.
6. Protective Clothing . The protective clothing needed
may vary with the type of inspection and with the level of
anticipated asbestos contamination, personal protective
clothing may not be needed for some inspections, such as a
visual walk—through of a school where no abatement action is
underway. On the other hand, a disposable suit, along with
disposable gloves, head, and foot coverings may be needed
where contamination of clothing is anticipated. Maneuvering
into crawispaces and inspecting asbestos removal operations.
inside the work area are examples of activities requiring
such clothing.
Aft r the inspection, the disposable suit, gloves, and
headand foot coverings should be disposed of própérly. If
the site has ámethod for disposing of contaminated
protective clothing, :ánd.thesite manager.. agrees, disposal
of contaminated clothing can be done at the site.. If the
site does not havean adequate method for disposing of
contaminated materials, or if the site manager. does not
allow the EPA to dispose of materials at the site, then they
must be sealed in properly labeled plastic bags and removed
for proper disposal elsewhere. Disposable protective
clothing must never be reused. Proper disposal of
protective clothing prevents the spread of asbestos
contamination to other areas.
7. Respiratory Protective Eguipment To provide asbestos
inspectors with appropriate respiratory protection,
respirators must be selected on the basis of the anticipated
3
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levels of exposure that meet all OSHA requirements. When an
anticipated exposure level cannot be determined, an unknown
exposure condition exists. Such a situation requires the
use of atmosphere supplying respirators such as a self--
contained breathing apparatus (SCBA). Of currently
available respiratory protective equipment, the SCBA offers
the maximum level of respiratory protection.
Fortunately, much is known about the exposure
conditions encountered at sites that are in compliance with
current OSHA asbestos standards. When such circumstances
are encountered by an inspector, they permit the initial
selection o an air purifying respirator. The lowest
acceptable level of respiratory protection to be used is
that afforded by a NIOSH-approVed full facepiece air-
purifying respirator with HEPA filtration or any approved
tight—fitting (i.e., having a tight face-to-faCePiece seal)
powered air-purifying respirator (PAPR) with High Efficiency
Particulate Air (HEPA) filtration.
To assist in determining when air-purifying respirators can
safely be used in conducting asbestos inspections, a study of
exposure levels at renovation sites was conducted by Alliance
Technology Corporation under contract to EPA. The study reviewed
over 4000 air monitoring samples taken at renovation sites where,
for the most part, OSHA requirements were met. It was undertaken
to determine the parameters that had to be met to ensure that
asbestos inspectors would be provided adequate protection when
using air—purifying respirators.
The results of the study indicated that 95 percent of the
time, when the OSHA asbestos standards for renovations conducted
‘in schools,.residefltial buildings, hospitals, offices, and
industrial buildings were followed, no airborne concentrations in
excess of 0.82 ,f/cc were present in the removal areas during
active abatement i.e., the study that showed ‘that the
concentration would not exceed 0.82 f/cc 95% of. the time. The
data was based on Phase Contrast’MiCrOSCOPY (PCM) anaiyseS. The
OSHA 8—hour time_weighted-average’ (TWA) permissible , exposure
limit is 0.2 f/cc and the NIOSH-recomluended exposure limit is 0 • 1
f/cc. Thus, before entering the envelope, if asbestos inspectors
can make a determination’ of a project’s OSHAcoinpliaflCe, an air—
purifying respirator can be selected as shown in the following
paragraph
The EPA’s recommendations for respirator selections found in
these Guidelines are intended to limit inspectors’ exposures
to asbe’stos to below 0.01 f/cc as an 8-hour time—weighted--
average (TWA). These recommendations are based, in part, on
expected inspection patterns such as not being in the
envelope for more than two hours per day. The use of full
facepiece air-purifying respirators or tight-fitting PAPR5
4
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can provide such protection when used at sites that are in
compliance with the OSHA asbestos standard and when
inspectors spend no more than 2 hours per day inside the
containment envelope. This conclusion is I3ased on the
following assumptions:
o exposures at renovation sites that are in compliance
with the OSHA asbestos standard do not exceed 2.0 f/cc
more than 95% of the time (2.0 f/cc is the maximum
level for which full facepiece APRs can reduce
inspectors exposures to below 0.01 f/cc) lasting no
more than a 2 hour exposure;
o full facepiece air—purifying respirators (and tight-
fitting PAPRs) provide a protection factor of 50X;
o inspectors will not be in the asbestos enclosure
envelope for more than two hours per day.
A 50X protection at a concentration up to 2.0 f/cc for two
hours would result in an 8-hour TWA exposure of 0.01 f/cc.
Actually, most exposures would be far less than 0.01 f/cc, since
most individuals get much more than a 50Xprotection from full
facepiece respirators (and PAPRs), and often they will not be in
the envelope for two hours. Therefore, by following these
recommendations, inspectors will have a high protection level
because their exposure will most often be much less than 0.01
f/cc.
An abatement project’s compliance with the OSHA asbestos
standards can be gauged by findings that:
1) records on or off—site show that all employees have
been trained as required by OSHA standards. When
records are kept off—site, the. inspector will, request
the supervisor to state that proper records exist and
are available for review at a later.date. [ Passing an
approved AHERA class isrdesirable .bu t. not required for
buildings not covered by the AHERA regulations.
Compliance with state and local training requirements
should be checked.];
2) records (that can be made available at a later date)
show that project employees have been given medical
exams, including a determination that they are
medically fit to wear respirators;
3) amended water is being used to wet the asbestos-
containing material (ACM), (check to see thatarnended
water is on-site outside the envelope];
4) no power tools are being used to remove ACM
5
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5) the envelope is secure and no dust or debris appears to
be coming from the removal area;
6) warning signs and adequately labeled containers are
being used to remove the ACM;
7) a permit for disposal has been obtained from the state
or local government;
8) employees are carefully, removing ACM and are not
dropping materials on the floor;
9) decontaminatiOn accommodations, including shower
facilities, ars inplace;
10) existing monitoring data indicates that asbestos fibers
in the work area do not exceed 2.0 f/cc as an 8—hour
TWA;
11) there is a written respiratory protection program and
respirators are being used;
12) a removal plan can be made available for review.
Determining that air-purifying respirators will provide
adequate protection requires a certain degree of judgment. The
ability to make such determinations must be obtained through both
classroom and on—the—job training.
The buddy system is required in situations in which the
SCBA—user is in an atmosphere that is either oxygen-deficient or
is highly toxic and would be jfe-threateniflg in case of a
respirator failure. Activities which would not result in a hf e-
threatening or permanent injury situation would generally not
require using the buddy system. A buddy system or appropriately
outfitted assistant may be required in certain decontamination
procedures. The decision to require a buddy system for
decontaitiiflatiofl would have to:.be.. made on a case-by-caSebaSiS.
A Respirator Protection Program must be established in
accordance with the OSHA standard for respiratory protection, 29
CFR 1910.134, the OSHA standards for asbestos, 29 CFR 1926.58 and
29 CFR 1910.1001, and EPA Order 1440.3 “Respiratory Protection”.
Air—purifying respirators include Powered Air-Purifying
Respirators (PAPR). These guidelines assume that tight-fitting
PAPRs do not provide greater protection than do other air-
purifying respirators due to the possibility that over-breathing
(i.e., inhaling at a rate that is greater than the air supplied
to the facepiece, resulting in a negative pressure in the
facepiece) can occur. This guideline is based on workplace
protection factors for PAPR5 determined by NIOSH. This guideline
6
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is consistent with the NIOSH Respirator DecisiOn Logic of 1987
with respect to the protection offered by PAPRS. Additional PAPR
studies are being planned by NIOSH. If they are shown to have
higher protection factors in the future, appropriate changes will
be made regarding selection of respiratory protection in this
section.
EPA EMPLOYEES MAY NOT WEAR RESPIRATORS UNTIL THEY HAVE BEEN
DETERMINED TO BE MEDICALLY FIT TO WEAR RESPIRATORY PROTECTION.
EPA EMPLOYEES SHOULD USE ONLY EPA-OWNED RESPIRATORY PROTECTIVE
EQUIPMENT THAT THEY HAVE BEEN SPECIFICALLY TRAINED AND FIT-
TESTED TO USE.
8. Other personal Protective Equipment (PPE) . It is
recommended that eye protection be worn at all times in eye
hazard areas (refer to EPA’s Eye Protection Program
Guidelines), safety shoes or hard hat protection must be
used where head or foot injury hazards can occur.
9. prohibited Practices . Smoking, eating, drinking,
chewing gum or tobacco, and applyingIflakeUP are prohibited
in asbestos—contaminated areas.
io. Personal Hygiene . personnel who have been in asbestos—
contaminated areas must remove contaminated clothing, and
other articles. DisposableS should be properly bagged and
discarded in landfills that are equipped to accept
sbestos—cofltaifliflg materials, personnel must wash their
hands and faces thoroughly, or shower as appropriate.
Employees should never eat, drink, apply makeup, chew gum or
tobacco, or smoke before completing the decontamination
process.
B. PROTECTIVE EOUIPMENT GUIDELINES FOR REMOVAL. DEMOLITION, AND
RENOVATION INSPECTIONS .
EPA Asbestos Inspectors are required to inspect removal,
demolition, and renovation sites under the National
Emissions Standards .f or Hazardous Air Pollutants (NESHAP)
and the Asbestos Abatement Worker Protection Rule and other
regulations.
1. Protective Clothing . EPA inspectors entering a
removal, demolition, or renovation area should wear the
following protective clothing:
o a disposable, full—body, hooded, outer coverall (e.g.,
a Saranex—coated Tyvek suit or equivalent). A coverall
with an expandable back should be worn when SCBA is to
be used;
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o a bathing suit (or equivalent) or an inner disposable
coverall (when possible, particularly when a changing
area or decontamination area is available, all street
• clothing should be removed before donning protective
clothing. When clothing is removed, the inspector may
choose to wear a bathing suit under the protective.
clothing. In situations where removing all street
• clothing is not possible, the inspector should roll up
pants legs and sleeves and don an inner disposable
coverall. The outer coverall is then worn over the
bathing suit or inner coverall.);
o disposable gloves (taped to the outer coverall);
o disposable inner booties (e.g., Tyvek or equivalent);
o disposable outer booties (taped to the outer coverall).
2. RespiratorY Protection . EPA inspectors entering a
removal, demolition, or renovation area should select the
appropriate respiratory protection according to the
following locations and conditions:
a. No respiratory protection is required outside of the
asbestos area—enclosing envelope when:
o inspecting office area and other locations outside
the barrier. All barrier seals must be intact,
and all envelope entrances must have at least a
double barrier. No visible airborne dust or
debris that is potentially asbestos-contaminated
should be present on any surface in the area; and
secondary containment is in place during glove
bagging operations. The secondary containment
enclosure must be complete, . and for all but small—
scale, short-duration operations must also be
under negative pressure;
o materials removed from the envelope have been
cleaned and the pathway for removal of bags and
equipment is clear and clean; and
o all ventilation systems in the envelope are off
and sealed (this does not include negative
pressure systems designed for the removal
project); and
o wet methods are being used.
b. No respiratory protection is required inside the
containment envelope when:
8
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o inspecting any restricted area that has already
passed an appropriate clearance test (minimum of
aggressive sampling demonstrating a concentration
below 0.01 f/cc by PCM);
o no removal work has begun and all ACM is intact,
not disturbed, not damaged, and no debris is
present.
c. Full facepiece air-purifying respirators or tight-
fitting PAPRs shall be worn by inspectors when:
o inspecting outside the barrier, and workers
• outside the barrier are wearing air-purifying
respirators;
o inspecting outside the barrier where the barrier
is not complete and/or asbestos—containing debris
is present;
o inspecting inside the envelope when an inspection
of the operation shows it to be in compliance with
the OSHA asbestos standards. If, upon entering
• the envelope, visible emissions are seen or other
evidence suggesting non—compliance is apparent,
the inspector will immediately leave the area.
Prior to returning to the removal area to document
the violations, the inspector shall don SCBA gear;
o inspecting inside the barrier and no active
removal or disturbances have occurred in the past
24’hours and the inspection will not disturb any
ACM.
d. Atmosphere-Supplying Respirators are required when:
o performance of the asbestos abatement project is
not in acáordance with OSHA standards;
o materials are being removed which are not being
properly wetted, or removal causes the generation
of significant levels of dust;
o • monitoring data at the site show levels in excess
of 2.0 f/cc, or the EPA inspection may last for
more than 2 hours;
o others at the site are wearing atmosphere—
supplying respirators.
9
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C. PROTECTIVE EQUIPMENT GUIDELINES FOR ASBESTOS MANUFACTURING
AND FABRICATING INSPECTIONS .
EPA asbestos inspectors are required to inspect asbestos
manufacturing operations under the National Emissions
Standards for Hazardous Air Pollutants (NESHAP).
1. Protective Clothing . The following protective clothing
is recommended for EPA inspectors at manufacturing operations to
prevent contamination of their street clothing:
o a disposable, full body, hooded coverall (e.g., a Tyvek
suit or equivalent) or a disposable, full body, hooded
coverall with an expandable back to cover the air tank
(if SCBA is required);
o disposable shoe coverings;
o a hard hat (if applicable);
o eye protection (when respirators are not used); and
o safety shoes (if applicable).
2. Respiratory Protection . EPA inspectors at
manufacturing and fabricating operations should select
respiratory protection based on employers’ airborne fiber
monitoring data (if available at the site). For exposure levels
up to 2.0 f/cc, full facepiece air—purifying respirators or
tight—fitting PAPRS shall, be used for two hours of
inspection time/day. If monitoring data is not available, the
site is considered to be in violation of the OSHA standards. SCBA
shall be used when the inspector cannot determine that exposures
are likely:to remain below 2.0 f/cc during the inspection.
Situations where excessive exposures may occur include:
o loose asbestos materials are handled outside of an
exhausted enclosure;
o observing the accumulation on walls or surfaces , of any
debris that may consist of friable asbestos-containing
materials;
o uncontrolled dumping, cutting, mixing, bagging,
packaging, grinding operations or any type of
fabrication where asbestos fibers may be emitted into
the general air; and
o in—plant transport of friable asbestos—containing
materials that are not completely sealed.
10
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Not all situations where the potential exists for excessive
emissions of asbestos can be listed. Therefore, the inspector
will have to use professional judgment to determine if an air—
purifying respirator will provide adequate protection.
D. PROTECTIVE EOUIPMENT AND PROCEDURAL GUIDELINES FOR
COLLECTING BULK SAMPLES .
EPA asbestos inspectors are required to collect bulk samples
under the Asbestos—in—Schools Rule, Asbestos Worker
protection Rule, and the National Emissions Standards for
Hazardous Air Pollutants.
1. protective CiothincT . EPA inspectors should wear the
following protective clothing over their street clothes when
collecting bulk samples (Note: when samples can be taken without
any significant chance of releasing fibers, this clothing may not
be necessary. Professional judgment must be used in such unusual
cases.):
— a disposable, full body, hooded coverall (e.g., a Tyvek
suit or equivalent);
— eye protection (if no full facepiece respirator is
used);
— disposable shoe coverings;
— hard hat (if applicable); and
— disposable gloves.
2. Respiratory Protection. EPA inspectors collecting bulk
samples should wear full facepiece air-purifying respirators with
HEPA filter cartridges (this includes NIOSH-approved tight-
fitting PAPRs equipped with HEPA filters).
3. Procedural: Guidelines. These procedural guidelines are
for inspectors who collect bulk samples in non—contaminated areas
(e.g., Asbestos—in—Schools inspectors). These practices should
and occupant
concern.
a. Preliminary Steps .
— Discuss with building officials how the samples
will be obtained and the rationale for selecting
the sampling locations and the number of samples.
Also discuss the advisability of notifying
employees and/or their representatives prior to
the inspection.
11
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— Determine the equipment needed during. the
inspection to adequately access the area, (e.g.,
ladders, scaffolding).
Determine the best time to obtain the samples in
each area selected (i.e., times when few people
are normally in the vicinity or passing through);
— Limit access to the area while samples are being
collected. Post area(s) with appropriate signs or
construct barricades, if necessary. Under no
circumstances should samples taken when school
childr other unprotected individuals are
present ;
Determine the minimum number of people needed in
the affected area during sample collection, and
limit access to that number. [ These individuals
may need to use PPE, depending on the asbestos
inspector’s assessment of the potential for
asbestos fiber release];
— Determine how the area will be decontaminated
should there be an accident (e.g., a piece of
asbestos comes loose and drops to the floor). Be
prepared to isolate the area and to damp wipe/mop
the area, and/or have access to a HEPA vacuum;
— Based on the best information available, determine
what PPE would be required in the event of an
accident, under what conditions it will be worn
and by whom.
b. Sampling Procedures .
Sampling procedures must minimize the amount of.
the inspector’s personal exposure to the asbestos.
Also, these procedures must minimize the amount of
disturbance of the asbestos material.
Don appropriate protective clothing and
respiratory protective equipment.
— Before the sample is collected, place a covering
on the floor under the sample collection area.
Spray the area to be sampled with a water mist or
encapsulant mist prior to sampling to minimize
release of fibers (e.g., use a hand—held plant
mist sprayer).
12
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— Sampling equipment, in most cases, will consist of
plastic containers or empty film canisters and a
sharp instrument such as a knife or scalpel. Once
the samples have been obtained, the sampling
equipment must be wiped thoroughly with a damp
cloth. The outsides of the film canisters must be
damp-wiped before being placed into the plastic
bag. ,Whatever is chosen to wipe the sampling
equipment and sample containers must be properly
disposed of in plastic bags that are properly
labeled. An encapsulant should be used to seal
the hole made by the inspector while extracting
the sample. The sampled surface should not be
left in a worse condition than before sampling was
done.
c. After Sampling .
- Wet-wipe the outside of the coveralls and shoe
coverings. Remove, coveralls, shoe covers, and
gloves and dispose of them and the wipe down
cloths as asbestos—contaminated wastes.
— Spray the respirator and respirator HEPA filters
zith water and dispose of the filters as asbestos
• waste.
— Dispose of all asbestos—contaminated material’s
properly.
— The asbestos samples must be packaged and shipped
in a manner that assures that the sample
containers will not release asbestos during
transportation. [ Make sure the sample vials are
securely taped shut and well—cushioned to prevent
breakage.]
E. PROTECTIVE EOUIPMENT GUIDELINES FOR INSPECTING ASBESTOS
WASTE DISPOSAL AND STORAGE SITES .
EPA Asbestos Inspectors are required to inspect asbestos
waste disposal and storage sites under the National
Emissions Standards for Hazardous Air Pollutants (NESHAP).
Before entering these sites, inspectors must have completed
all OSHA training required as cited in 29 CFR 1910.120.
1. Protective Clothing . EPA inspectors should wear the
following protective clothing over their street clothes when
inspecting asbestos waste disposal and storage sites:
— a disposable, full body, hooded coverall (e.g., Tyvek
or equivalent);
13
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disposable gloves; and
— disposable boots.
2. Respiratory Protection . EPA inspectors at asbestos waste
disposal and storage sites should select respiratory protection
based on the requirements of the approved site safety plan. This
assumes that an approved site safety plan has been implemented.
When no approved site safety plan is in place, the inspector
must have reviewed an appropriate generic site inspection plan
for .the site being inspected.
The absence of a site safety plan should be reported to
appropriate persons in charge and possibly to the local OSHA area
office.
a. No respiratory protection is required when:
— all disposal trenches have been covered for a
minimum of 24 hours, no asbestos—containing
materials are visible at the disposal site.
b. Full facepiece Air-Purifying Respirators or tight-
fitting PAPR should be worn when:
- trenches are being dug at the disposal site and
airborne dust is not visible;
— asbestos materials are visible on the ground or
floor of the site, or bags or drums containing
asbestos are damaged but airborne dust is not
visible; and
- inspecting a storage site, as long as airborne
- dust is not present.
c. Atmosphere-Supplying Respirators (e.g., SCBA or
•supplied air respirators (SAR) should be worn when:
others at the site are wearing atmosphere—
• supplying respirators; or
- airborne dust is visible at the site.
F. PROTECTIVE EQUIPMENT GUIDELINES FOR INSPECITNG EMERGENCY
REMOVAL OPERATIONS AT SUPERFUND SITES .
EPA inspectors are required to inspect emergency removals at
Superfund sites under CERCLA.
1. Protective Clothinct EPA inspectors should wear the
following protective clothing while inspecting emergency removal
14
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operations at Superfund sites:
— a disposable,.. full body, hooded, outer coverall (e.g.,
a Saranex—coated Tyvek suit or equivalent). A coverall
with an expandable back should be worn with SCBA;
— a bathing suit’(or equivalent) or an inner, full body,
inner coverall.. (When possible, particularly when a
changing area or decontamination area is available, all
street clothing should be removed before donning
protective clothing. When clothing is removed, the
inspector may choose to wear a bathing suit under the
protective clothing. In situations where removing all
street clothing is not possible, the inspector should
roll up pants legs and sleeves and don an inner
disposable coverall. The outer disposable coverall is
then worn over the bathing suit or inner coverall;
— disposable gloves (taped to the outer coverall);
• — eye protection (when no full facepiece respirators are
worn) ;
— disposable inner booties;
— disposable outer boots (taped to the outer coverall);
and
— hard hat (if applicable).
2. Respiratory Protection . EPA inspectors at an emergency
removal operation should select the appropriate, respiratory
protection according to the following conditions:
a. No Respiratory Protection is required when:
— in the Support Zone (i.e., the noncontaminated or
clean area)..
b. Air-Purifying Respirators should be worn when:
— in the Exclusion Zone or the Contamination
Reduction Zone, when acceptable to the On-Scene-
Coordinator (OSC) and no airborne dust is visible.
c. • Atmosphere—Supplying Respirators should be worn when:
• — airborne dust is visible, for example during windy
conditions or during operations that disrupt the
asbestos; or
— others at the site are wearing atmosphere—
supplying respirators.
15
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G. PROTECTIVE EQUIPMENT GUIDELINES FOR INSPECTING AN ABANDONED
BUILDING.
1. Protective Clothing . EPA personnel should wear or carry
with them the following protective clothing while inspecting an
abandoned building:
— a disposable, full body, hooded coverall (e.g., a Tyvek
suit or equivalent);
— disposable shoe coverings;
— eye protection (if no full facepiece respirators are
worn);
— disposable gloves; and
— hard hat (if applicable).
If any suspect materials are visible on floors or surfaces,
the protective clothing should be worn.
2. Respiratory Protection . EPA personnel inspecting an
abandoned building should select the appropriate respiratory
protection according to the following conditions:
a. No Respiratory Protection is required when:
— no suspect materials are present;
— intact suspect materials are present and no debris
from those materials is observed.
b. Air—Purifying Respirators should be worn when:
— suspect materials are visible on the floors or
- surfaces;
collecting bulk samples. (See Seátion D for
specific guidelines for collecting bulk samples.)
H. OPERATIONAL PRACTICES FOR ENTERING AND EXITING SITES .
Although the operational practices in this section are aimed
primarily at removal, demolition, and renovation sites,
these practices can be easily modified to fit the conditions
f or other types of inspections.
1. Wearing an SCBA When a Three—Stage Decontamination System is
Present . The three—stage decontamination system discussed here
consists of a clean room, a shower area, and an equipment room
(or equivalent). A detailed description of this type of
16
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decontamination system, commonly used in the asbestos abatement
industry, can be found in the OSHA asbestos regulation, 29 CFR
1926.58, Appendix F.
a. Before entering the Clean Room:
Make sure SCBA is operating properly;
— Make sure you have all materials necessary to
conduct the inspection safely (e.g., duct tape,
disposable towels, protective clothing,
respirator, extra plastic bags, spray bottle,
etc.) All materials that must be carried into the
contaminated area should be sealed in a plastic
bag to minimize contamination;
— If you take a camera into the contaminated area,
precautions must be taken to minimize
contamination or to decontaminate the camera.
Possible solutions include using a waterproof
camera or sealing a conventional camera in an
impermeable clear camera box. Both of these
methods are used by SCUBA divers.
b. In the Clean Room:
— Remove all street clothing including socks and
underwear and store them in a clean, sealed
plastic bag. The bag should be placed in a
secured area. If desired, don a bathing suit (or
equivalent) and inner booties. [ Inspectors may
prefer to have the bathing suit on before going to
the site.);
— With the air flow valve closed, •don SCBA; let the
respirator facepiece hang from the neck with the
aid of a strap;
— Don disposable outer coveralls with expandable
back, but do not zip it;.
— Don disposable outer boots. Use duct tape to
attach the boots to the legs of the outer
coveralls;
— Fit the respirator facepiece to the .f ace, tighten
the facepiece straps, and check seal;
— Connect hose to regulator and turn air valve on;
— Fit the coverall hood snugly around the respirator
facepiece;
17
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Zip up the suit;
Don the disposable gloves. Use duct tape ‘to
attach the gloves to the sleeves of the outer
coveralls;
— proceed to the Shower Area.
c. In the Shower Area:
— Leave disposable towels (sealed in a plastic bag)
near the shower.
— Proceed to the contaminated area and perform
inspection.
d. Before leaving the contaminated area:
— HEPA vacuum (if possible) and wet wipe all visible
• debris from protective clothing. (Use a spray
bottle and disposable towels to wet wipe the
suit.) Proceed to the equipment room.
e. In the Equipment Room:
— Seal all contaminated nondisposable materials in a
• plastic bag and remove them for decontamination at
a later time.
— Remove outer protective clothing including boots,
gloves, and coverall and place them in a proper
container for disposal.
— With SCBA, bathing suit, and inner booties still
on, proceed to the Shower Room.
f. In the Shower Area:
- Thoroughly shower down with the SCBA, bathing
suit, and inner booties still on. Once totally
wet, remove the respirator, turn off the air
supply valve, clean the respirator, and place the
respirator outside the shower on the clean side;
— Continue showering. While in the shower, remove
inner booties and place them in a proper container
for disposal. Next, remove bathing suit,
thoroughly rinse it, and place it in a plastic
bag. Finish showering by thoroughly washing the
entire body with soap and water;
— Proceed to the Clean Room.
18
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g. In the Clean Room:
— Dress into street clothes. All disposables should
be given to the site operator if she/he will
accept them and if they will be disposed of in an
approved landfill. Otherwise, place the
disposables in labeled plastic bags and remove
them for proper disposal.
2. Wearing an SCBA When a Shower is Not Present or Available .
a. Before entering the contaminated area:
— Make sure SCBA is operating properly;
— Make sure materials necessary to conduct the
inspection safely (e.g., disposable towels, extra
plastic bags, spray bottle, etc) are on hand. All
materials that must be carried into the work area
should be sealed in a plastic bag to minimize’
contamination
— If a camera is to be taken into the contaminated
area, precautions must be taken to, minimize
contamination or to decontaminate the camera.
Possible solutions include using a waterproof
camera ‘or sealing a conventional camera in an
impermeable box.. Both of these methods are used
by SCUBA divers;
— Leave all street clothing on. (Short sleeved
shirts and short pants are preferable to long
sleeved shirts and long, pants. If wearing long
pants or long sleeves, roll them up.);
— Don an inner disposable coverall and inner booties
(e.g., a Tyvek suit or ‘equivalent) over street
clothes; . . ‘
- With the air flow valve closed, don the SCBA; let
the respirator facepiece hang from the neck with
the aid of a strap;
— Don disposable outer coverall with expandable
back, but do not zip it up;
— Fit the respirator facepiece to the face, tighten
the facepiece straps and check face seal;
— Connect hose to regulator and turn on air valve;
19
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— Fit the coverall hood snugly around the respirator
facepiece;
- Zip up suit;
— Don the disposable gloves. Use duct tape to
attach gloves to the sleeves of the outer
coverall;
— Proceed to the contaminated area and perform
inspection.
b. Before leaving the contaminated area:
Standing near the exit, HEPA vacuum (if possible)
and wet.wipe all visible debris from the outer
protective clothing. (Use a spray bottle
containing water and disposable towels to wet wipe
the suit; use plenty of water.) Place all
disposable materials in a proper container for
dIsposal. Standing at the doorway inside the work
area, remove outer protective clothing and
immediately step outside the area.
c. Outside the contaminated area:
- Once outside, thoroughly wet wipe and mist spray
the SCBA and inner protective clothing. Move away
from the doorway and remove the SCBA and the inner
protective clothing. Place all disposable
materials in a proper container for disposal.
—: Seal all contaminated nondisposable materials in a
plastic bag and take them with you for decöntam-
ination at a later time.
3 Wearing an Air—Purifying Respirator When a Three-Stage
Decontamination System is Present . The three—stage
decontamination system discussed here consists of a clean room, a
shower area, and an equipment room (or equivalent). A detailed
description of this type of decontamination system, commonly used
in the asbestos abatement industry, can be found in the OSHA
asbestos regulation, 29 CFR 1926.58, Appendix F.
a. Before entering the Clean Room:
— Make sure that all materials necessary to conduct
the inspection safely. (e.g. duct tape,
disposable towels, protective clothing,
respirator, extra plastic bags, spray bottle,
20
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etc.) have been obtained. All materials that must
be carried into the contaminated area should be
sealed in a plastic bag to minimize contamination;
— If a camera is to be taken into the contaminated
area, precautions must be taken to minimize
contamination or to decontaminate the camera.
Possible methods include using a waterproof camera
or sealing a conventional camera in an. impermeable
clear camera box. Both of these methods are used
by SCUBA divers.
b. In the Clean Room:
— Remove all street clothing including socks and
underwear and store them in a clean, sealed
plastic bag. If desired, don a bathing suit (or
equivalent) and inner booties. Inspectors may
prefer to have the bathing suit on before going to
the site;
— Don disposable, full body, hooded coverall. Do
not put the hood on yet. Do not zip up suit, yet.
Don other appropriate protective clothing. Use
duct tape to attach the boots to the outer
coveralls;
— Don respirator. The respirator straps should be
worn under the hood. Perform positive and
negative pressure checks as appropriate;
— Fit the coverall hood snugly around the
respirator; zip up suit; attach gloves with duct
tape;
— Proceed to the Shower Area.
c. in the Shower Area: .
— Leave disposable towels (sealed in a plastic bag)
near the shower..
- Proceed through the equipment room to the
contaminated area and perform the inspection.
d. Before leaving the Contaminated Area:
— HEPA vacuum (if possible) and wet wipe all visible
debris from protective clothing. (Use a spray
bottle and disposable towels to wet wipe the
suit.) Proceed to the equipment room.
21
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e 0 In the Equipment Room:
— Seal all contaminated nondisposable materials, in a
plastic bag and remove them for decontamination at
a later time;
— Remove protective clothing and place it in a
proper container for disposal. Keep wearing the
respirator;
— With respirator on, proceed to the shower area.
f. In the Shower Area’:
— Thoroughly shower down with the respirator and
• bathing suit on. Remove respirator and clean it.
Place it outside the shower on the clEan side.
— Remove inner booties and place them in a proper
container for disposal.
Remove bathing suit, thoroughly rinse it, and
place it in a plastic bag. Finish showering by
thoroughly washing the entire body with soap and
water.
— Dispose of towels as asbestos contaminated waste.
Proceed to the clean, room.
g. In the Clean Room
Dress into street clothes.
— All disposables should be given to the site
operator if she/he will accept them and if they
will be disposed of in an approved landfill.
Otherwise, place the disposables in.labeled
plastic bags and remove them for proper disposal.
4. Wearing an Air-Purifying Respirator When a Shower is
Not Present or Available . Follow the guidelines listed in
section 2, “Wearing a SCBA When a Shower is Not Present”,
substituting appropriate procedures for air-purifying
respirators.
22
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I. References
The following references provide additional information on
the safe handling of asbestos.
1. A Guide to Respiratory Protection for the Asbestos
Abatement Industry . EPA 560-OPTS-86—001, April 1986.
2. Guidance for Controlling Asbestos-Containing Materials
in Buildings . EPA 560/5—85—024, June 1985.
3. Asbestos Fact Book . EPA, A—107/86—002, June 1986.
4. Guidance for Preventing Asbestos Disease Among Auto
Mechanics . EPA, Office of Pesticides and Toxic
Substance, Asbestos Action Program, June 1986.
5. Measuring Airborne Asbestos Following an Abatement
Action . EPA 600/4—85—049, November 1985.
6. Guidance for Controlling Friable Asbestos-Containing
Materials in Buildings . EPA 560/5—83—002, March 1983.
7. Asbestos-Containing Materials in School Buildings: A
Guidance Document Parts 1 and 2 . EPA
8. Quantification of Asbestos Airborne Emissions
Associated with Renovation Prolects . EPA Contract No.
68—02—4465 Alliance Technologies 1988 Draft Final
Report.
23
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If needed, additional appendices. may be added and referenced within the report. A good
example would be to add an appendixto include copies of state and local regulations.
Appendices should be utilized to further inform the users of the manual of any additional
reference material specific to this facility.
APPENDICES
Name c i Fac f 60
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Figure 2:
Work Practice Selection
Asbestos Program Manager Tasks:
Work Practice Selection and Us .
I Surfabing I
Select Work Practices
and Proper Level(s)
Receive and Review Job
Request Form
I
Determine ACM
Affected
TSI
Select Work Practices
and Proper Level(s)
Miscellaneous 1
Select Work Practices
and Proper Level(s)
Pre-Work Activities :
- Select Personal Protective Equipment to be
Used
- Complete Maintenance Work Authorization
Form
- Schedule Work and File NotIfIcatIons
- Notify Per nnel Affected by Work
- AssIgn Worker6/Contractor & AIr MonItoring
Person
— I
Give % I r I(’nnf ,,-f,s. nhnrmntlon for
• fl I S.# JI ti U #tiJI —
Perfnrmlnri Work:
- Maintenance Work Author
izatlon Form
• Work Prectice Checklist
-Work Practice(s)
- Copy of Notifications
- Schedule for Work
.
- General Procedures
I—
Finish Work:
- Complete Evaluation of Work Form
- File All Required Records
Review Work PractIces During Work
NOTE :
Some steps in this process
may not be necessary for all
work practices. See Figure 2
and individual work practices.
USE OF AN O&M PROGRAM
Name ol Facility
1 YES
18
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Figure 7:
Surfacing Materials Location Illustration
SURFACING ACM ASBESTOS O&M WORK PRACTICES
3
-------
Figure 8:
Thermal Systems Insulation Location
Illustration
THERMALSYSTEMS INSULATION ASBESTOS O&M WORK PRAcTICES
Nwne O1FacTht /
3
-------
I.
I
) / I /
—HVAC UN!T
1
0 • 4
I ____
IlL - lUll
J
-€
( I )
w
0
0
c i :
U
(I,Ii
0
I-
(I )
w.
F
I
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