U.S. ENVIRONMENTAL PROTECTION AGENCY
STANDARD OPERATING PRACTICES
FOR
ASBESTOS SAFETY
AND HEALTH PROTECTION PRACTICES
Office of Administration and Resources Management
Safety, 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 fiber levels with economic, social, technical, and
enviror nental factors being taken into account.
This SOP document, developed by EPA’s Safety, Health, and Environmental Management
Division (SHEMD), 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.
This document has been developed to be used in conjunction with EPA’s July 1990
Guidance Document entitled Management 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.
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Editing the Model Standard Operating Practices (SOP)
Manual of Asbestos Safety and Health Protection
Practices
The designated APM is responsible for the editing of this document to meet the needs
of the facility in which it lS intended. This document Is 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 where appropriate. Introductory green sheets Qike this one)
may be included at the beginning of each section to help explain particular aspects of
each section. These green sheeta introductions are j t intended to be a part of the
facility’s final document, but are toots to assist in the process of helping the APM in
editing this document. Along with the Introductory sections, notes may also be found
throughout the document referencing pertinent information that the editor/APM will need
to determine. These notes are recognized in the following formats:
If needed, appendices may be added to the document to reference additional materials
and information.
Also enclosed is a 3 high density diskette that contains the unedited Model Standard
Operating Practices documentation files. The bulk of the document is saved as SOP.518
h WordPerfect 5.1 format. The additional Correll Draw 3.0 files that will need to be edited
are: (1) EPAO.CDR; (2) EPALCDR; (3) GSAO.CDR; (4) GSALCDR; and (5) IAG.CDR.
Revise page numbering to reflect additions and deletions.
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1. Introduction
4
3. Locations and Presence
4.1
4.2
4.3
4.4
4.5
4.6
5.1
5.2
5.3
5.4
5.5
5.6
5
7
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18
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19
20
20
24
24
26
29
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TABLE OF CONTENTS
1.1 Introduction
1.2 Purpose
2. Background
2.1 Asbestos Diseases
2.2 Asbestos Minerals
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1
4
4
5
6
7
3.1 Locations of ACBM in Facility
3.2 Presence of ACBM
4. Program Organization and Responsibilities
Organization of Program
Asbestos Program Manager
Asbestos Program Coordinator
Asbestos Inspector
Asbestos Worker
Qualifications
5. Training Requirements
APM Training Requirements
APC Training Requirements
Asbestos Worker Training Requirements
Asbestos Inspector Training Requirements
Course Examinations
Air Monitoring Training Requirements . . .
6. Inspecting Buildings for Asbestos-Containing Materials
31
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TABLE OF CONTENTS (CONTINUED)
7. Sampling and Analytical Methods Pertaining to
Asbestos-Containing Materials 32
7.1 General 32
7.2 Sampling Methods 32
7.3 Analytical Methods 34
7.4 Sampling Strategies and Procedures for
an Abatement Project 35
8. Personal Protective Equipment and Decontamination Procedures 39
8.1 Respirators 39
8.2 Protective Clothing 40
8.3 Decontamination Procedures 40
9. O&M Plan Purpose and Scope 41
9.1 O&M Plan Purpose 41
9.2 Levels of O&M Projects.... 41
9.3 Work Scheduling 41
9.4 Appointing the APM and APC 42
9.5 Assigning Workers 43
9.6 Elements of an O&M Plan 43
9.6.1 Building Inspection and Assessment 43
9.6.2 Asbestos Safety Training 44
9.6.3 Asbestos Exposure Monitoring 45
9.6.4 Medical Surveillance 49
9.6.5 Notification Program 49
9.6.6 Surveillance and Reinspection ‘. 51
9.6.7 Control System 51
10. Recordkeeping 55
11. Quality Assurance and Quality Control (QA/QC) 56
12. References 57
13. Definitions 58
II
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TABLE OF CONTENTS (CONTINUED)
14. Appendices 66
14.1 Appendix A: Standard Forms
These standard torms are provided tor use and reference. I ney may be edited partially
or in full for this specific facility and incorporated into the document. These forms may
be broken out into individual appendices corresponding to relevant information. This is
detailed in the editor’s notes throughout the document.
Inspection Summary Sheet
Bulk Sample Data Form
Surfacing Assessment Form
TSI Assessment Form
Miscellaneous Assessment Form
Master List of Training Information
Verification of Employee Training
Sample Information Letter to Tenants/Occupants
Occupant Notification Form
Basic and Initial Medical Questionnaire (OSHA)
Periodic Medical Questionnaire (OSHA)
Reinspection Form
Work Control Application Form
O&M Activity Form
Records Request Form
Air Sample Form
Fiber Release Episode Report
Waste Tracking Form and Waste Disposal Record
Initial/Periodic Cleaning Form
Contractor’s Acknowledgment Form
Clearance Inspection Checklist
NESHAP Notification of Demolition and Renovation Form
NESHAP Waste Shipment Record
15. Abbreviations and Acronyms 68
Ill.
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Section 1
Introduction
1.1 Introduction
The Office of Administration and Resources Management, Office of Administration, Safety,
Health, and Environmental Management Division (SHEMD) has established a program for
the Management of Asbestos-Containing Building Materials (ACBM) at EPA occupied or
controlled facilities. The underlying policy for this Program establishes the Agency’s
position concerning protection of Agency workers from the adverse health effects of
exposure to asbestos. The primary goal of this Program is the minimization of ambient
asbestos fiber levels, with economic, technical and environmental factors being taken into
account. The Program defines the managerial and technical framework system through
which this goal is achieved.
These Standard Operating Practices have been developed for Asbestos-Containing
Building Materials (ACBM) that are to be managed in place at:
1.2 Purpose
This document, the “Asbestos Safety and Health Protection Practices”, establishes
Standard Operating Practices (SOPs) to carry out the directives of the EPA’s Program for
the Management of Asbestos-Containing Building Materials at EPA Facilities. This
document is an integral part of the Program; it establishes 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.
As such, it defines requirements and designates protocols and procedures that will ensure
personnel safety where asbestos-containing building materials are used, or where surface
contamination may exist; i.e., in any area that a worker must enter in the performance of
duty and that presents a potential for exposure.
This document contains a set of administrative procedures and work practices to be
utilized for the in-place management and control of ACBM during routine cleaning,
maintenance, renovation and other operational activities at all EPA occupied or controlled
facilities. It has been developed to work 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”. These SOPs assume that the user(s) have a copy of the
Green Book and are familiar with its content. It is also assumed that the users have
copies of applicable federal, state and local regulations and are familiar with their
requirements.
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Federal regulattons may be added as an appendix to this document for quick reference
The objectives of the SOPs are to:
1. maintain ACBM in good condition and minimize the release of asbestos fibers by
controlling activities which may disturb ACBM;
2. minimize airborne asbestos exposure for building occupants,
maintenance/custodial workers and the public;
3. establish procedures for controlling and containing ACBM which have been
disturbed;
4. establish administrative procedures and work practices to achieve the objectives
for the program; and
5. monitor ACBM through periodic visual surveillance.
Standard Methods (SMs), maintained under the SOPs in separate documents, provide
detailed guidance for specific procedures and techniques which are employed in the
conduct of certain work activities.
The Program, and its associated SOPs and SMs, incorporate nationally accepted and
consistent means and methods for identifying, assessing, recording, controlling, and
communicating the potential risks and dangers associated with occupational exposure to
ACBM.
An important aspect of this document, and the accompanying Standard Methods (SMs)
document, is that it is designed to work for the different ownership and lease
arrangements commonly used for EPA facilities. The arrangements addressed by the
manual are:
• EPA owned and managed facility (EPAO);
• EPA leased facility (EPAL);
• EPA facility owned and managed by GSA (GSAO);
• EPA facility leased by GSA (GSAL); including EPA Occupied/EPA
Delegated; and
• EPA facility accessed through an Inter -Agency Agreement (lAG).
This document outlines how the SOPs are organized and shall be handled under each
lease/own arrangement.
A successful asbestos O&M program requires the cooperation and participation of all
occupants. of the facility. Workers performing asbestos O&M work must follow the SOPs
included in this document to achieve the objectives listed above.
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The Program and SOPs apply to any new facilities to be occupied or controlled by the
EPA and shall be made a part of any future space solicitations or lease agreements.
The Documentation Package for Asbestos Operations and Maintenance Programs in U.S.
General Services Administration (GSA) Facilities (dated September 24, 1990), is
referenced in this document and the SMs document, and is utilized to provide consistency
in documentation. Applicable GSA forms are included in the appendices of the document.
This document and the SMs document utilize asbestos-related work practices developed
by the National Institute of Building Sciences (NIBS) in the NIBS document entitled
Operations and Maintenance Work Practices Manual”.
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Section 2 Background
2.1 Asbestos Diseases
Asbestos fibers can cause serious health problems. If inhaled, they can cause diseases
which disrupt the normal functioning of the lungs. Three specific diseases - asbestosis
(a fibrous scarring of the lungs), lung cancer, and mesothelioma (a cancer of the lining
of the chest and of the abdominal cavity) - have been linked to asbestos exposure.
These diseases do not develop immediately after inhalation of asbestos fibers; it may be
20 years or more before symptoms appear.
Whenever the risk posed by asbestos is discussed, it must kept in mind that asbestos
fibers can be found nearly everywhere in our environment (usually at very low levels).
There is, at this time, insufficient information concerning health effects resulting from low -
level asbestos exposure, either from exposures in buildings or from our environment.
This makes it difficult to accurately assess the magnitude of cancer risk for building
occupants, tenants, and building maintenance and custodial workers’. Although in general
the risk is likely to be negligible for occupants, health concerns remain, particularly for the
building’s custodial and maintenance workers. Their jobs are likely to bring them into
close proximity to ACBM, and may sometimes require them to disturb the ACBM in the
performance of maintenance activities. For these workers in particular, a complete and
effective management program can greatly reduce asbestos exposure. This kind of
management program can also minimize asbestos exposures for other building occupants
as well.
2.2 Asbestos Minerals
The term “asbestos” describes six naturally occurring fibrous minerals found in certain
types of rock formations. Of that general group, the minerals chrysotile, amosite, and
crocidolite have been most commonly used in building products. When mined and
processed, asbestos is typically separated into very thin fibers. When these fibers are
present in the air, they are normally invisible to the naked eye. Asbestos fibers are
commonly mixed during processing with a material which binds them together so that
they can be used in many different products. Because these fibers are so small and light,
they may remain in the air for many hours if they are released from ACBM in a building.
When fibers are released into the air they may be inhaled by people in the building.
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3
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Section 3 Locations and Presence
3.1 Locations of ACBM in a Facility
In February 1988, the EPA released a report titled “EPA Study of Asbestos-Containing
Materials in Public Buildings: A Report to Congress”. EPA found that “friable” (easily
crumbled) ACBM can be found in an estimated 700,000 public and commercial buildings.
About 500,000 of those buildings are believed to contain at least some damaged
asbestos, and some areas of significantly damaged ACBM can be found in over half of
them.
According to the EPA study, significantly damaged ACBM are found primarily in building
areas not generally accessible to the public, such as boiler and machinery rooms, where
asbestos exposures generally would be limited to service and maintenance workers.
Friable ACBM, if present in air plenums of the building ventilation system, can lead to
distribution of the material throughout the building, thereby possibly exposing building
occupants. ACBM can also be found in other building locations.
Asbestos in buildings has been commonly used for thermal insulation, fireproofing, and
in various building materials, such as floor coverings, ceiling tile, cement pipe and
sheeting, granular and corrugated paper pipe wrap, and acoustical and decorative
treatment for ceilings and walls. Typically, it is found in pipe and boiler insulation and in
spray-applied uses such as fireproofing or sound-deadening applications.
The amount of asbestos in these products varies widely (from approximately greater than
1 percent to (nearly) 100 percent). The precise amount of asbestos in a product cannot
always be accurately determined from labels or by asking the manufacturer. Nor can
positive identification of asbestos be ascertained merely by visual examination. Instead,
a qualified laboratory must analyze representative samples of the suspect material.
A building survey must be, or have been, conducted and bulk samples of suspect ACBM
obtained and analyzed to determine whether or not materials actually contain asbestos.
Suspect materials shall be assumed to contain asbestos unless bulk sampling indicates
otherwise.
The general location of ACBM in [ has been determined by a building
survey. The survey information is presented in the following report(s):
Give names of reports, surveys, etc.
If needed, an appendix may be added to this document to include survey results.
Remember to include a reference here as well as at the Table of Contents .
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Available survey data must be reviewed when maintenance, repair, renovation or
demolition work is anticipated in any of the facilities to determine if ACBM could be
disturbed.
The survey information for this facility must be reviewed before work on suspect ACBM
are performed. If adequate sampling has not been performed where the work will occur,
additional samples shall be obtained and analyzed, or the suspect materials shall be
assumed to be ACBM and treated accordingly.
3.2 Presence of ACBM
The mere presence of asbestos in a building does not mean that the health of building
occupants or workers is endangered. Intact and undisturbed asbestos-containing
materials do not pose a health risk. ACBM which are in good condition, and are not
damaged or disturbed, are not likely to release asbestos fibers into the air. When ACBM
are properly managed, release of asbestos fibers into the air is prevented or minimized,
and the risk of asbestos-related disease can be reduced to a negligible level.
However, asbestos materials can become hazardous when, due to damage, disturbance,
or deterioration over time, they release fibers into building air. Under these conditions,
when ACBM are damaged or disturbed-for example, by maintenance repairs conducted
without proper controls - elevated airborne asbestos concentrations can create a potential
hazard for workers and other building occupants.
ACBM are classified into the following categories by EPA. These categories have been
used in recent EPA guidance documents on ACBM. The SMs are divided into these
same three categories.
1. Surfacing Material: Examples include ACBM sprayed or troweled onto surfaces,
such as decorative plaster on ceilings or acoustical ACBM on the underside of
concrete slabs or decking, or fireproofing materials on structural members.
2. Thermal System Insulation (FSI) Material: Examples include ACBM applied to
pipes, boilers, tanks, and ducts to prevent heat loss or gain, or condensation.
3. Miscellaneous Material: Examples include asbestos-containing ceiling or floor tiles,
textiles, and other components such as asbestos-cement panels, asbestos siding
and roofing materials.
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4
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Section 4 Program Organization and Responsibilities
4.1 Organization of Program
The chart presented on the next page is a summary of the responsibilities for designated
personnel. The person that implements and oversees the entire asbestos management
program at the facility is the Asbestos Program Manager (APM). If this person is not an
EPA worker, an EPA Asbestos Program Coordinator (APC) shall be designated by EPA
to work with the APM. All work performed as a part of this program shall be subject to
approval by the EPA APM or APC.
The entity that manages the building provides the APM.
An important aspect of this program is that it is designed to work for the different
ownership and lease arrangements commonly used for EPA facilities.
1. EPA owned and managed facility (EPAO).
2. EPA leased facility (EPAL).
3. EPA facility owned and managed by GSA (GSAO).
4. EPA facility leased by GSA (GSAL).
4a. EPA facility leased by GSA (GSAL)
4b. EPA occupied/EPA delegated
5. EPA facility accessed through an Inter-Agency Agreement (lAG).
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Edit the following chart for the applicable arrangement.
Lease/Own Arrangement(s) for
EPAO
EPAL
GSAO
GSAL
lAG
Asbestos
Program
Manager
EPA
Employee
Employee
‘of Owner
GSA
Employee
Employee
of Owner
‘
Employee of
Agency
Asbestos
Program
Coordinator
None
EPA
Employee
EPA
Employee
EPA
Employee
EPA.
Employee
O&M
Workers
EPA
Employees/
Contractors
Owner’s
Employees/
Contractors
GSA
Employees/
Contractors
Owner’s
Employees!
Contractors
Owner’s
Employees/
Contractor
Organizational
Chart ‘
Figure 1
Figure 2
‘
Figure 3
Figure 4/4a
Figure 5
‘
Select one of the following flowcharts that corresponds with the lease/own arrangement
for this facility. The chart should then be placed after the Lease/Own Arrangement(s)
chart in the revised document. These charts are produced on Correll Draw Version 3.0
and are saved on the SOP diskette. The chart files are named according to their
abbreviations found on each chart. The following are the names of the Correll Draw files
to choose from:
EPAO.CDR
EPAL.CDR
GSAO.CDR
GSAL.CDR
IAG.CDR
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• EPA OWNED (EPAO) BUILDINGS
O&M PROGRAM ORGANIZATIONAL CHART
Recordkeeping
EPA Employees
EPA
Regional Asbestos
Coordinator, OS1-IA,
& Local Agencies
Other Building
Tenants
Contractors
EPA Controlled
I
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EPA LEASED (EPAL) BUILDINGS
O&M PROGRAM ORGANIZATIONAL CHART
Building Owner
AirMonitoring
Consultant
Asbestos Program EPA
Asbes 1 tos — Manager Regional Asbestos
..onsu 11 an 1 ___________________ Coordinator, OSHA,
Owners Employee & Local Agencies
Survey Consultant
Other Tenant
APC’s
I I ____________________ I
Contractors Recordkeepung
Owner Controlled Owner Controlled Building Owner
I
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GSA OWNED (GSAO) BUILDINGS
O&M PROGRAM ORGANIZATIONAL CHART
Building Owner
GSA
Air Monitoring
Consultant
__________ [ Asbestos Program
GSA Employee & Local Agencies
Survey Consultant
________ Other Tenant
APC’s
I I _____ I
Contractors Recordkeeping
GSA Controlled GSA Controlled GSA Employee
I
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GSA LEASED (GSAL) BUILDINGS
O&M PROGRAM ORGANIZATIONAL CHART
Building Owner
Air Monitoring
Consultant
Asbestos Program EPA
, Asbes os — Manager Regional Asbestos
donsuIanL __________________ Coordinator, OSHA,
Owners Employee & Local Agencies
Survey Consultant
Other Tenant
APC’s
I I
Contractors Recordkeeping
Owner Controlled Owner Controlled Building Owner
Asbe stos..Program
Coordmator Agency Tenant
APCs
I
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GSA LEASED (GSAL) BUILDINGS
O&M PROGRAM ORGANIZATIONAL CHART
Maintenance &
Custodial Staff
Owner Controlled
F
H
Contractors
Owner Controlled
Asbestos Program
Manager
Asbestos Program
Coordinator (APC)
EPA Employee
Other Tenant
APC’s
I
Air Monitoring
Consultant
Building Owner
Asbestos
Consultant
Survey Consultant
Owner’s Employee
EPA
Regional Asbestos
Coordinator, OSHA,
& Local Agencies
Recordkeeping
Building Owner
Other Federal
Agency Tenant
APC’s
I
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INTER-AGENCY AGREEMENT (lAG) BUILDINGS
O&M PROGRAM.ORGANIZATIONAL CHART
Building Owner
Air Monitoring
Consultant
Asbestos Program EPA
sbestos — Manager Regional Asbestos
SonsuIan ___________________ Coordinator, OSHA,
Owners Employee & Local Agencies
Survey Consultant
Other Tenant
APC’s
Agency Tenant
APC’s
I
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Case Study
Waterside Mall
GSA LEASED (GSAL) BUILDINGS
EPA OCCUPIED EPA DELEGATED
O&M PROGRAM ORGANIZATIONAL CHART
Survey Consultant
I
.b
1-
.1
U C&frdih t iAPC1 U
Air Monitoring
Consultant
Building Owner
(Town Center)
Asbestos
Consultant
Asbestos Program
Manager
Town Center
Employee
EPA
Regional Asbestos
Coordinator, OSHA,
& Local Agencies
Maintenance &
Custodial Staff
Owner Controlled
Other Tenant
APC’s
Contractors
Owner Controlled
I
Recordkeeping
Building Owner
Other Federal
Agency Tenant
APC’s
I
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The following chart summarizes the assigned responsibilities for SOPs. Responsibility for
various elements depends upon the type of lease/own arrangement for a given facility.
Lease/Own Arrangement Tasks for [ Name of Fac liiy]
Delete the columns of this chart that are inapplicable to this facility’s lease/own
arrangement.
TASK *
EPAO
EPAL
GSAO
GSAL
lAG
Notifications:
Initial
Asbestos O&M
Work (APM3&4)
EPA
EPA
EPA
Owner
EPA
GSA
.
EPA
GSA
EPA
Owner
Periodic Surveillance (AHERA)
EPA
Owner
GSA
Owner
Owner
Reinspections (Chpt. 1 & 3, AHERA)
EPA
Owner
GSA
Owner
Owner
Engineering Controls/Worker
Protection (Chpt. 3)
EPA
Owner
GSA
Owner
Owner
Work Permits:
Prepare
Review (Chpt. 2, Append.)
EPA
EPA
Owner
EPA
GSA
EPA
Owner
EPA
Owner
EPA
Work Practices (Chpt. 4-6)
EPA
Owner
GSA
•
Owner
Owner
Recordkeeping (APM 7)
EPA
Owner
GSA
Owner
Owner
Cleaning Work (W12-14)
EPA
Owner
GSA
Owner
Owner
Fiber Releases (APM 10, AHERA)
EPA
EPA
EPA
EPA
EPA
Air Monitoring (APM6,W15)
EPA
Owner
GSA
Owner
Owner
Waste Disposal (W16)
EPA
Owner
GSA
Owner
Owner
Training/Fit Tests (APM5,W5)
EPA
Owner
GSA
Owner
Owner
Bulk Sampling (AHERA)
EPA
Owner
GSA
Owner
Owner
Update Data (Chpt. 2)
EPA
Owner
GSA
Owner
Owner
—— — —
-
fr’n -
(: Items in ‘Y )“ denote location or tonic - in tile ivi s (iuhlance Docu nent or file
,irirj A reputations).
The APM shall designate personnel responsible for each part of the SOPs listed. Under
the EPAO arrangement, the APM shall maintain a current list of the designated personnel.
Under the EPAL, GSAO, GSAL and lAG arrangements, a current list of these personnel
shall be provided to the EPA APC at least every six months.
a
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4.2 Asbestos Program Manager (APM)
Asbestos Program Managers (APM) are responsible for (1) maintaining generic policies,
plans and prOcedures current within the region, (2) providing technical support in the
development of Building O&M plans, (3) serving as a technical resource during site
specific response actions, and (4) conducting investigations of occurrences, accidents,
and major or minor fiber release episodes.
At the regional level, the Program shall be jointly administered with the Safety, Health and
Environmental Management Program (SHEMP) Manager. A good working relationship
is essential for an effective program.
The position of APM is frequently held by the building engineer, ‘superintendent, facilities
manager, or safety and health manager. Regardless of who holds this position, the APM
must be properly qualified, through training and experience, and be actively involved in
all asbestos-control activities. EPA accreditation under the Asbestos Hazard Emergency
Response Act (AHERA) Contractor/Supervisor and Designer are the required training
courses.
If the person selected is not adequately prepared, he or she shall receive’ the training
necessary to develop and manage an asbestos control program prior to beginning the
job.
In general, the APM shall have the authority to oversee all asbestos-related activities in
the building, including inspections and surveys, O&M activities, and other abatement
response actions. The APM will ensure that worker training takes place. In addition, the
APM will oversee the custodial and maintenance staffs, contractors, and outside service
vendors with regard to all asbestos-related activities.
The Asbestos Program Manager (APM) for this facility is:
I’lame
litle [
Corripany
Address
I—
Telephone [ ] Ext [ ]
Alternate telephone [ ] Ext [ ]
After hours telephone [ j Ext [ ]
Emergency telephone { / J Ext ]
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4.3 Asbestos Program Coordinator (APC)
in those lease arrangements where EPA is a tenant, either directly with the buildingowner
or through a GSA lease, EPA shall appoint an EPA worker to the position of Asbestos
Program Coordinator (APC). As EPA’s representative, the APC shall coordinate all tenant
related activities that may disturb known, assumed, or suspected ACBM.
The position of APC shall be held ‘by a .EPA SHEMD representative, or EPA’s
facility/tenant representative who controls or monitors renovation activities that might
disturb ACBM within EPA’s lease premises. The APC must be properly qualified, through
training and experience, and be actively involved in all asbestos-control activities of the
entire building. EPA accreditation under AHERA as a Contractor/Supervisor is the
required training course.
In general, the APC shall have the authority to oversee all asbestos-related activities within
the EPA occupied or controlled portions of the building.
If the lease arrangement for this EPA occupied or controlled facility requires th
appointment of an Asbestos Program Coordinator (APC), EPA’s point of contact in [ Name
pfj aqhty] is identified as follows
I
[ DM$ Qn]
[ Or anizat on]
E G1eI hOne
jNameDfc will be the point of contact for the APM to the EPA concerning O&M
activities in EPA leased spaces within
4.4 Asbestos Inspector
Those persons who engage in, or expect to engage in, work assignments to visually
inspect or collect bulk samples from a building to determine the presence of asbestos,
shall be properly qualified through training and experience. EPA accreditation under
AHERA as an Inspector is the required training course.
An Inspector may be an EPA worker or a worker from another federal agency (i.e. GSA),
or may be a representative of the building owner or an independent contractor.
4.5 Asbestos Worker ‘
Building owner workers/contractors working on O&M activities in this building are the
following: those persons who engage in, or expect to engage in, routine or emergency
work assignments where the potential exists for disturbing ACBM. They shall be properly
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• qualified, through training and experience. EPA accreditation under AHERA as a Worker
is the required training course.
It is EPA policy that all asbestos work be performed by accredited building owner workers
and/or independent contractors.
Accredited building owner workers or contractors working on O&M activities in this
building are the following:
Company [
Address ]
r
L
Telephone [ ] Ext [ ]
Names of [ I
Workers
[
I
4.6 Qualifications
To be designated an APM, APC, Inspector and/or Worker, each EPA worker or
representative must satisfy the following minimum requirements pertaining to training and
experience.
1. Training - specific training in asbestos abatement. At a minimum, each individual
must have successfully completed the respective course(s) designated and
approved by SHEMD. An annual refresher course is required to remain current
with respect to regulations and technology.
2. Experience - one year experience with asbestos-containing building materials.
Additional education specific to asbestos or industrial hygiene practice may be
applied to satisfy, in part, up to fifty percent of the experience requirement.
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5
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Section 5 Training Requirements
Adequate asbestos safety training of all EPA workers and representatives entering areas
of potential asbestos exposure addressed by Chapter 16 of the Safety, Health and
Environmental Management Manual is a Program principle. Included below are the
training requirements for the APM, APC, Inspector(s) and Worker(s) at each EPA
occupied or controlled facility.
The asbestos training program shall be designed for workers with little or no prior
knowledge of asbestos effects and asbestos safety principles. Annual refresher courses
are required.
5.1 APM Training Requirements
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.
Suggested topics include, but are not limited to:
(a) The physical characteristics of asbestos and asbestos-containing materials.
Identification of asbestos, aerodynamic characteristics, typical uses, physical
appearance, a review of hazard assessment considerations, and a summary
of abatement control options.
(b) Potential health effects related to asbestos exposure. The nature of
asbestos-related diseases; routes of exposure; dose-response relationships
and the lack of a safe exposure level; synergism between cigarette smoking
and asbestos exposure; and latency period for diseases.
Employee personal protect We equipment. Classes and characteristics of
respirator types; limitations of respirators; proper selection, inspection,
donning, use, maintenance, and storage procedures for respirators;
methods for field testing of the facepiece-to-face seal (positive and negative-
pressure fit checks); qualitative and quantitative fit testing procedures;
variability between field and laboratory protection factors that alter
respiratory fit (e.g., facial hair); the components of a proper respiratory
protection program; selection and use of personal protective clothing; and
use, storage, and handling of non-disposable clothing; and regulations
covering personal protective equipment.
(d) State-of-the-art work practices. Proper work practices for asbestos
abatement activities, including O&M practices and procedures, descriptions
of proper construction and maintenance of barriers and decontamination
20
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enclosure systems; positioning of warning signs; lock-out of electrical and
ventilation systems, proper working techniques for minimizing fiber release;
use of wet methods; use of negative pressure exhaust ventilation
equipment, use of HEPA vacuums; and proper clean-up and disposal
procedures. Work practices for O&M removal, encapsulation, enclosure,
and repair of ACBM; emergency procedures for unplanned releases;
potential exposure situations; transport and disposal procedures; and
recommended and prohibited work practices. New abatement-related
techniques and methodologies may be discussed.
(e) Personal hygiene. Entry and exit procedures for the work area; use of
showers; and avoidance of eating, drinking, smoking, and ‘chewing (gum’or
tobacco) in the work area. Potential exposures, such as family exposure,
shall also be included.
(f) Additional safety hazards. Hazards encountered during abatement activities
and how to deal with them, including electrical hazards, heat stress, air
contaminants other than asbestos, fire and explosion hazards, scaffold and
ladder hazards, slips, trips, and falls, and confined spaces.
(g) Medical monitoring. OSHA and EPA Worker Protection Rule requirements
for physical examinations, including a pulmonary function test, chest X-rays
and a medical history for each employee. :
(h) Air monitoring. Procedures to determine airborne concentrations of
asbestos fibers, including descriptions of aggressive air sampling, sampling
equipment and methods, reasons for air monitoring, types of samples and
interpretation of results.
(i) Relevant Federal, State and local regulatoty requirements, procedures, and
standards.
(i) Requirements of TSCA Title I I.
(ii) National Emission Standards for Hazardous Air Pollutants (40 CFR
part 61), Subparts A (General Provisions) and M (National Emission
Standard for Asbestos).
(iii) OSHA standards for permissible exposure to airborne concentrations
of asbestos fibers and respiratory protection (29 CFR 1910.134).
(iv) OSHA Asbestos Construction Standard (29 CFR 1926.58). (v) EPA
Worker Protection Rule, (40 CFR part 763, Subpart G).
Q) Respiratory Protection Programs and Medical Monitoring Programs.
(k) Insurance and liability issues. Contractor issues; worker’s compensation
coverage and exclusions; third-party liabilities and defenses; insurance
coverage and exclusions.
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(I) Recordkeeping for asbestos abatement projects. Records required by
Federal, State and local regulations; records recommended for legal and
insurance purposes.
(m) Supervisory techniques for asbestos abatement activities. Supervisory
practices to enforce and reinforce the required work practices and
discourage unsafe work practices.
(n) Contract specifications. Discussions of key elements that are included in
contract specifications.
(o) Course review. A review of key aspects of the training course.
2. Project Designer: a 3-day training course that includes lectures, demonstrations,
a field trip, course review and a written examination.
Suggested topics include, but are not limited to:
(a) Background information on asbestos. Identification of asbestos; examples
and discussion of the uses and locations of asbestos in buildings; physical
appearance of asbestos.
(b) Potential health effects related to asbestos exposure. Nature of asbestos-
related diseases; routes of exposure; dose-response relationships and the
lack of a safe exposure level; the synergistic effect between cigarette
smoking and asbestos exposure; the latency period asbestos related
diseases, a discussion of the relationship between asbestos exposure and
asbestosis, lung cancer, mesothelioma, and cancers of other organs.
(c) Overview of abatement construction projects. Abatement as a portion of a
renovation project; OSHA requirements for notification of other contractors
on a multi-employer site (29 CFR 1926.58).
(d) Safety system design specifications. Design, construction and maintenance
of containment barriers and decontamination enclosure systems; positioning
of warning signs; electrical and ventilation system lock-out; proper working
techniques for minimizing fiber release; entry and exit procedures for the
work area; use of wet methods; proper techniques for initial cleaning; use
of negative-pressure exhaust ventilation equipment; use of HEPA vacuums;
proper clean-up and disposal of asbestos; work practices as they apply to
removal, encapsulation, enclosure, O&M and repair; use of glove bags and
a demonstration of glove bag use.
(e) Field trip. A visit to an abatement site or other suitable building site,
including on-site discussions of abatement design and building walk-through
inspection. Include discussion of rationale for the concept of functional
spaces during the walk-through.
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(f) Employee personal protective equipment. Classes. and characteristics of
respirator types; limitations of respirators; proper selection, inspection;
donning, use, maintenance, and storage procedures for respirators;
methods for field testing of the facepiece-to-face seal (positive and negative-
pressure fit checks); qualitative and quantitative fit testing procedures;
variability between field and laboratory protection factors that alter
respiratory fit (e.g., facial hair); the components of a proper respiratory
protection program; selection and use of personal protective clothing; use,
storage, and handling of non-disposable clothing.
(g) Additional safety hazards. Hazards encountered during abatement activities
and how to deal with them, including electrical hazards, heat stress, air
contaminants other than asbestos, fire and explosion hazards.
(h) Fiber aerodynamics and control. Aerodynamic characteristics of asbestos
fibers; importance of proper containment barriers; settling time for asbestos
fibers; wet methods in abatement; aggressive air monitoring following
abatement; aggressive air movement and negative-pressure, exhaust
ventilation as a clean-up method.
(i) Designing abatement solutions. Discussions of removal, enclosure, O&M
and encapsulation methods; asbestos. waste disposal.
(j) Final clearance process. Discussion of the need for a written sampling
rationale for aggressive final air clearance; requirements of a complete
‘visual inspection; and the relationship of the visual inspection to final air
clearance.
EPA recommends the use of TEM for analysis of final air clearance
samples. These samples shall be analyzed by laboratories accredited
under the NIST Program.
(k) Budgeting/cost estimating. Development of cost estimates; present costs
of abatement versus future O&M costs; setting priorities for abatement jobs
to reduce costs.
(I) Writing abatement specifications. Preparation of and need for a written
project design; means and methods specifications versus performance
specifications; design of abatement in occupied buildings; modification of
guide specifications for a particular building; worker and building occupant
health/medical considerations; replacement of ACBM with non-asbestos
substitutes.
(m) Preparing abatement drawings. Significance and need for drawings, use of
as-built drawings as base drawings; use of inspection photographs and on-
site reports; methods of preparing abatement drawings; diagramming
containment barriers; relationship of drawings to design specifications;
particular problems related to abatement drawings.
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(n) Contract preparation and administration.
(0) Legal/Iiabilities/defenses Insurance considerations; bonding; hold-
harmless clauses; use of abatement contractor’s liability insurance; claims
made versus occurrence policies.
(p) Replacement. Replacement of ACBM with asbestos-free substitutes.
(q) Role of other consultants. Development of technical specification sections
by industrial hygienists or engineers; the multi-disciplinary team approach
to abatement design.
(r) Occupied buildings. Special design procedures required in occupied
buildings; education of occupants; extra monitoring recommendations;
staging of work to minimize occupant exposure; scheduling of renovation
to minimize exposure.
(s) Relevant Federal, State, and local regulator,’ requirements, procedures and
standards, including, but not limited to:
(I) Requirements of TSCA Title II.
(ii) National Emission Standards for Hazardous Air Pollutants, (40 CFR
part 61) subparts A (General Provisions) and M (National Emission
Standard for Asbestos).
(iii) OSHA Respirator Standard found at 29 CFR 1910.134;
(iv) EPA Worker Protection Rule found at 40 CFR part 763, subpart G.
(v) OSHA Asbestos Construction Standard found at 29 CFR 1926.58.
(vi) OSHA Hazard Communication Standard found at 29 CFR 1926.59.
(t) Course review. A review of key aspects of the training course.
5.2 APC Training Requirements
Contractor/Supervisor course as described above for the position of APM, including the
written examination.
5.3 Asbestos Worker Training Requirements
Asbestos Workers shall attend the following course to fulfill the asbestos safety and
management training described above:
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.
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A person who is otherwise accredited as a Contractor/Supervisor may perform in
the role of an Asbestos Worker without possessing separate accreditation as an
Asbestos Worker.
Suggested topics include, but are not limited to:
(a) Physical characteristics of asbestos. Identification of asbestos,
aerodynamic characteristics, typical uses, and physical appearance, and a
summary of abatement control options.
(b) Potential health effects related to asbestos exposure. The’ nature of
asbestos-related diseases; routes of exposure; dose-response relationships’
and the lack of a safe exposure level; the synergistic effect between
cigarette smoking and asbestos exposure; the latency periods for asbestos-
related diseases; a discussion of the relationship of asbestos exposure to
asbestosis, lung cancer, mesothelioma, and cancers of other organs.
(C) Employee personal protective equipment. Classes and characteristics of
respirator types; limitations of respirators; proper selection, inspection;
donning, use, maintenance, and storage procedures for respirators;
methods for field testing of the facepiece-to-face seal (positive and negative-
pressure fit checks); qualitative and quantitative fit testing procedures;
variability between field• and laboratory protection factors that alter
respiratory fit (e.g., facial hair); the components of a proper respiratory
protection program; selection and use of personal protective clothing; use,
storage, and handling of non-disposable clothing; and regulations covering
personal protective equipment.
(d) State-of-the-art work practices. Proper work practices for asbestos
abatement activities, including O&M practices and procedures, descriptions
of proper construction; maintenance of barriers and decontamination
enclosure systems; positioning of warning signs; lock-out of electrical and
ventilation systems; proper working techniques for minimizing fiber release;
use of wet methods; use of negative pressure exhaust ventilation
equipment; use of high-efficiency particulate air (HEPA) vacuums; proper
clean-up and disposal procedures; work practices for removal,
encapsulation, enclosure, O&M and repair of ACBM; emergency procedures
for sudden releases; potential exposure situations; transport and disposal
procedures; and recommended and prohibited work practices.
(e) Persona! hygiene. Entry and exit procedures for the work area; use of
showers; avoidance of eating, drinking, smoking, and chewing (gum or
tobacco) in the work area; and potential exposures, such as family
exposure.
(f) Additional safety hazards. Hazards encountered during abatement activities
and how to deal with them, including electrical hazards, heat stress, air
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contaminants other than asbestos, fire and explosion hazards, scaffold and
ladder hazards, slips, trips, and falls, and confined spaces.
(g) Medical monitoring. OSHA and EPA Worker Protection Rule requirements
for physical examinations, including a pulmonary function test, chest X-rays,
and a medical history for each employee.
(h) Air monitoring. Procedures to determine airborne concentrations of
asbestos fibers, focusing on how personal air sampling is performed and
the reasons for it.
(i) Relevant federal, state, and local regulatory requirements, procedures, and
standards. With particular attention directed at relevant EPA, OSHA, and
State regulations concerning asbestos abatement workers.
(j) Establishment of respiratory protection programs.
(k) Course review. A review of key aspects of the training course.
5.4 Asbestos Inspector Training Requirements
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, individual respirator fit-testing,
course review and a written examination. Where appropriate, audio visual
materials and aids shall be used to complement lectures. Hands-on training shall
include conducting a simulated building walk-through inspection.
(a) Background in formation on asbestos. Identification of asbestos, and
examples and discussion of the uses and locations of asbestos in buildings;
physical appearance of asbestos.
(b) Potential health effects related to asbestos exposure. The nature of
asbestos-related diseases; routes of exposure; dose-response relationships
and the lack of a safe exposure level; the synergistic effect between
cigarette smoking and asbestos exposure; the latency periods for asbestos-
related diseases; a discussion of the relationship of asbestos exposure to
asbestosis, lung cancer, mesothelioma, and cancers of other organs.
(c) Functions/qualifications and role of inspectors. Discussions of prior
experience and qualifications for inspectors; discussions of the functions of
an accredited inspector as compared to those of an accredited asbestos
worker, contractor/supervisor or designer; discussion of inspection process
including inventory of ACBM and physical assessment.
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(d) Legal//abilities and defenses. Responsibilities of the inspector; a discussion
of comprehensive general liability policies, claims-made, and occurrence
policies, environmental and pollution liability policy clauses; state liability
insurance requirements; bonding and the relationship of insurance
availability to bond availability.
(e) Understanding building systems. The interrelationship between building
systems, including: an overview of common building physical plan layout;
heating, ventilating, and air conditioning (HVAC) system types, physical
organization, and where asbestos is found on HVAC components; building
mechanical systems, their types and organization, and where to look for
asbestos on such systems; inspecting electrical systems, including
appropriate safety precautions; reading blueprints and as-built
drawings/record documents.
(f) Public/employee/building occupant relations. Notifying employee
organizations about the inspection; signs to warn building occupants; tact
in dealing with occupants and the press; scheduling of inspections to
minimize disruptions; and education of building occupants about actions
being taken.
(g) Pre -inspection planning and review of previous inspect ion records.
Scheduling the inspection and obtaining access; building record review;
identification of probable homogeneous areas of suspect ACBM from
blueprints or as-built drawings/record documents; consultation with
maintenance or building workers; review of previous inspection, sampling,
and abatement records of a building; the role of the inspector in exclusions
for previously performed inspections.
(h) Inspecting for friable and non-friable ACBM and assessing the condition of
friable ACBM. Procedures to follow in conducting visual inspections for
friable and non-friable ACBM; types of building materials that may contain
asbestos; touching materials to determine friability; open return air plenums
and their importance in HVAC systems; assessing damage, significant
damage, potential damage, and potential significant damage; amount of
suspected ACBM, both in total quantity and as a percentage of the total
area; type of damage; accessibility; material’s potential for disturbance;
known or suspected causes of damage or significant damage; and
deterioration as assessment factors.
(I) Bulk sampling/documentation of asbestos. Detailed discussion of the
“Simplified Sampling Scheme for Friable Surfacing Materials (EPA 560/5-85-
030a October, 1985)”; techniques to ensure sampling in a randomly
distributed manner for other than friable surfacing materials; sampling of
non-friable materials; techniques for bulk sampling; inspector’s sampling
and repair equipment; patching or repair of damage from sampling;
discussion of polarized light microscopy; choosing an accredited laboratory
to analyze bulk samples; quality control and quality assurance procedures.
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EPA’s recommendation that all bulk samples collected from school or public
and commercial buildings be analyzed by a laboratory accredited under the
NVLAP administered by NIST.
EPA workers and representatives shall also be trained in accordance with
EPA’s “Health and Safety Guidelines for EPA Asbestos Inspectors,” revised
March, 1991. This document was developed by EPA for use by its workers
in carrying out the Agency’s various missions to control asbestos exposures
through inspection activities. This document, in its entirety, is included in
the SMs document which is a part of this Program.
(j) Inspector respiratory protection and personal protective equipment. Classes
and characteristics of respirator types; limitations of respirators; proper
selection, inspection; donning, use, maintenance, and storage procedures
for respirators; methods for field testing of the facepiece-to-face seal
(positive and negative-pressure fit checks); qualitative and quantitative fit
testing procedures; variability between field and laboratory protection factors
that alter respiratory fit (e.g., facial hair); the components for a proper
respiratory protection program; selection and use of personal protective
clothing; use, storage, and handling of non-disposable clothing.
(k) Recordkeeping and writing the inspection report. Labeling of samples and
keying sample identification to sampling location; recommendations on
sample labeling; detailing of ACBM inventory; photographs of selected
sampling areas and examples of ACBM condition; information required for
inclusion in the management plan required for school buildings under TSCA
Title II, section 203 (i)(1). Forms for recording the results of inspections in
schools or public or commercial buildings, and the use of these forms shall
be incorporated into the curriculum of training conducted for accreditation.
(I) Regulatory review. The following topics shall be covered: National
Emission Standards for Hazardous Air Pollutants (NESHAP; 40 CFR part 61,
Subparts A and M); EPA Worker Protection Rule (40 CFR part 763, Subpart
G); OSHA Asbestos Construction Standard (29 CFR 1926.58); OSHA
respirator requirements (29 CFR 1910.134); the Friable Asbestos in Schools
Rule (40 CFR Part 763, Subpart F); applicable State and local regulations,
and differences between Federal and State requirements where they apply,
and the effects, if any, on public and non-public schools or commercial or
public buildings.
(m) Field trip. This includes a field exercise, including a walk-through
inspection; on-site discussion about information gathering and the
determination of sampling locations; on-site practice in physical assessment;
classroom discussion of field exercise.
(n) Course review. A review of key aspects for the training course.
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5.5 Course Examinations
An examination after each course will document the individual’s comprehension of the
course material. The examination will be based on the core instructional material and will
contain questions selected by the instructor. A minimum score, as noted below, is
required to pass the examination(s). If a worker fails to attain the ‘minimum score, he/she
will review the material, emphasizing weaknesses identified by the examination, and be
retested until a passing score is attained. This testing requirement is necessary to ensure
the worker’s safety, because only comprehension of the course material, not simply
attending the course, can adequately prepare the individual.
The following are passing score requirements for examination in each discipline based on
‘The Federal Register, Thursday, February 3, 1994, Asbestos Model Accreditation Plan:
Interim Final Rule, 40 CFR, Part 763, Appendix C to Subpart E, Section l.C.2:
Contractor/Supervisor:
100 multiple-choice questions.
Passing score: 70 percent correct.
Project Designer:
100 multiple-choice questions.
Passing score: 70 percent correct.
Asbestos Worker:
50 multiple-choice questions.
Passing Score: 70 percent correct.
Asbestos Inspector:
50 multiple-choice questions.
Passing Score: 70 percent correct.
Each certificate issued to an accredited person must contain the following minimum
information:
1. A unique certificate number.
2. Name of accredited person.
3. Discipline of the training course completed.
4. Date(s) of the training course.
5. Date of the examination.
6. An expiration date of 1 year after the date upon which the person successfully
completed the course and examination.
7. The name, address, and telephone number of the training provider that issued the
certificate.
8. A statement that the person recei ing the certificate has completed the requisite
training for asbestos accreditation under TSCA Title II.
The written test shall be signed by both the instructor and, student, and a copy retained
by, the SHEMP Manager to document a satisfactory level of course material
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comprehension. Each student (worker) shall receive a signed certificate that indicates the
successful óompletion of each course.
The above training requirements are established by and further defined by the ‘Asbestos
Model Accreditation Plan (MAP); Interim Final Rule, which 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 àontained 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.
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.
5.6 Air Monitoring Training Requirements
Training for air monitoring that is currently available consists primarily of courses meeting
the National Institute for Occupational Safety and Health (NIOSH) 582 requirements.
Training for persons performing air monitoring work shall include hands-on training with
the equipment to be used.
Additional training may also be required by state or local regulations, and could include
industrial hygiene training or other requirements, and attendance to courses beyond the
pronram.
City, State Zip
Contact
Air Monitoring Firm:
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6
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Section 6 Inspecting Buildings for Asbestos-
Containing 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 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 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.
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
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.
If needed, an appendix may be added to this document to include inspection forms and
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7
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Sectiofl 7 Sampling and Analytical Methods
Pertaining to Asbestos-Containing
Materials
7.1 General
Sampling and analytical methods are important tools for assessing and monitoring
asbestos-containing materials. The applications of sampling and analyses may range
from bulk sampling of suspect materials; to estimating airborne fiber levels before, during,
and after an abatement project; to checking surfaces for asbestos-containing settled dust.
Collection of reliable data requires a thorough knowledge of the various sampling and
analytical techniques which are available and when a particular technique shall be used.
This general discussion is an introduction only to the types of sampling methods and
various analytical techniques used for ACBM.
7.2 Sampling Methods
1. Air Sampling
Air sampling is conducted to determine airborne fiber concentrations before,
during, and after abatement activities. Sampling is conducted with battery-powered
pumps, which are used to pull low volumes of air (0.5 - 4 liters per minute) and/or
electric pumps which pull high air volumes (4 - 10 liters per minute). Pumps are
calibrated before and after use. A plastic cassette which holds a filter with a very
small pore openings is attached to the pump with flexible tubing. With the front
cover of the cassette removed, air is drawn through the filter by the pump and
particles in the air are collected on the filter surface. The type of filter used for
sampling depends on the technique which will be used for analysis.
The basic types of air sampling are area and personal monitoring and clearance
sampling. Area air samples are taken with a pump that is placed at breathing zone
height at some stationary location. The top cover of the plastic filter holder is
removed and the filter holder is pointed downward (at approximately 45° angle)
to prevent material from falling onto the filter. The pump is turned on and the start
time and sample description are recorded. The pump shall be checked
periodically (every 30 minutes) to make sure it is functioning properly. Being
careful not to disturb the sampling operation, the filter shall also be visibly
inspected for overloading. At the end of the sampling period, the pump is turned
off and the cover of the filter holder is replaced and secured with tape. The stop
time and any other comments about sampling conditions are then recorded.
Personal samples are collected from within the breathing zone (as close to the
nose and mouth area as possible) of an individual, but outside the respirator .
Personal samples are collected in the same manner as area samples except the
pump is hung from a disposable tape belt around the worker’s waist and the filter
holder is attached, pointing downward, to the worker’s lapel or collar.
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Clearance sampling is performed at the completion of a response action to
determine if the quantity of asbestos fibers remaining in the air are below the
established clearance level.
Area air samples can be collected using static or aggressive sampling techniques.
Static sampling implies monitoring an area as it is without creating any additional
disturbance in the air. This method is typically used during the removal phase of
the abatement project. An obvious criticism of this technique for clearance
sampling when no one is in the area is that the fibers that have settled out of the
air are not detected. An alternative sampling technique which addresses this
concern is to create an artificial disturbance in the air during sampling. Aggressive
sampling can be accomplished by using 1 horsepower electrically powered leaf
blowers, electric fans, sweeping, blowers, etc. Aggressive air sampling shall only
be conducted in spaces under containment. NEVER AGGRESSIVELY AIR
SAMPLE AN OPEN OR OCCUPIED AREA .
2. Bulk Sampling
Bulk sampling is the technique used to collect physical samples of suspect
materials such as fireproofing, pipe lagging, boiler insulation, and acoustical spray.
Bulk sampling is usually conducted during the building survey/hazard assessment
phase and provides data for decisions on response actions or control measures.
Collection and laboratory analysis of suspect ACBM are the only conclusive
method to determine the presence of asbestos. Identification by visual observation
is not possible .
A small sample of suspect material is collected and placed in a container (i.e. a 35
mm film canister). Further guidance may be found in Guidance for Controlling
Asbestos-Containing Materials in Buildings , (EPA’s Purple Book) Appendix G, or
Asbestos in Buildings: Simplified Sampling Scheme for Friable Surfacing Material
(Pink Book) (EPA 560/5-85-030a). Anyone taking bulk samples shall wear a
minimum of a half-face cartridge respirator (a Powered Air Purifying Respirator
(PAPR) is preferred) and protective clothing. Bulk samples are analyzed by an
analytical laboratory, typically using polarized light microscopy, to determine if
asbestos is present and the type and percentage of asbestos in the sample. Bulk
samples can also be analyzed by electron microscopy.
All bulk sampling work shall be performed in accordance with EPA’s document
entitled “Health and Safety Guidelines for EPA Asbestos Inspectors,” revised in
March, 1991 or the current version in effect. A copy of this document, in its
entirety, is included in the SMs document which is a part of this program.
3. Settled Dust Sampling
Sometimes, it is beneficial to determine whether the settled dust within a facility
contains asbestos. For instance, during the building inspection/survey when
investigating for the presence of ACBM, an owner may request that the inspector
determine whether asbestos fibers are being released in the building environment.
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In the past, an air sample might have been collected to determine whether airborne
asbestos fibers are present. However, the EPA does not recommend the use of
air sampling for this purpose as it tends to provide only a “snapshot” picture of
building conditions. As an alternative, samples of settled dust may be collected
to indicate fiber release from ACBM.
Sampling settled dust can be accomplished in many ways. Dust can be collected
by scraping an area (with a credit card, for instance) and placing the material in
a small container for analysis as a ubulki sample by polarized light or electron
microscopy. Alternatively, samples can be collected by “vacuuming” an area with
a filter in a cassette which is attached to a battery operated personal sampling
pump. This method is referred to the 0 m cro-vacuuming” technique, and is widely
held to be a more reliable method. The filter is analyzed by electron microscopy.
It is important to note that most settled dust sampling will typically provide only
qualitative results. In other words, dust samples shall only be used to determine
the presence or absence of asbestos fibers in accumulated dust, and not as a tool
to determine the amount of asbestos fibers being released from a particular
material. Also, the absence of asbestos fibers in settled dust does not necessarily
mean asbestos fibers are not being released, just that none were present (or
detected) in that particular accumulation of dust.
7.3 Analytical Methods
The primary analytical techniques used for analyzing airborne fibers collected on filters are
phase contrast microscopy (PCM), and transmission electron microscopy (TEM). Bulk
samples are generally analyzed by polarized light microscopy (PLM), but are in certain
instances also analyzed by TEM.
1. Phase Contrast Microscopy (PCM)
Phase contrast microscopy (PCM) is a technique using a light microscope
equipped to provide enhanced contrast between the fibers and the background.
Samples for PCM are collected on a mixed cellulose ester (MCE) membrane filter
with a 0.8 micrometer pore size. Filters are then cleared with a chemical solution
so that trapped particulate material can be viewed through the microscope at a
magnification of approximately 400X. PCM is inexpensive and can be performed
on the job site in a few hours.
Phase contrast microscopy is frequently referred to as the light microscope
method, the filter membrane method, or the NIOSH method. PCM is the analytical
method specified in the Occupational Safety and Health Administration (OSHA)
Asbestos Standard. PCM was first used to monitor asbestos exposure to workers
in asbestos product manufacturing or milling operations for prevention of
asbestosis. This method does not distinguish between fiber types and only counts
those fibers longer than 5 micrometers and wider than about 0.25 micrometers .
Because of these limitations, fiber counts by PCM typically provide only an index
of the total concentration of airborne asbestos in the environment monitored. As
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the proportion of the airborne fibers which are less than 0.25 micrometers in
diameter increases (i.e., non-industrial settings such as asbestos abatement
projects), PCM becomes a less reliable analytical tool.
2. Transmission Electron Microscopy
Transmission electron microscopy (TEM) is a technique which focuses an electron
beam onto a thin sample. As the beam transmits through certain areas of the
sample, an image resulting from varying density of the sample is projected onto
a fluorescent screen. Air samples are collected on a mixed cellulose ester filter for
TEM analysis. With today’s widespread availability of qualified labs, the analyses
can usually be performed within 24-48 hours.
Transmission electron microscopy is considered the best available analytical
method for identifying asbestos fibers collected on air samples in non-industrial
settings. TEM can identify the smallest fibers and is specific for asbestos.
The TEM final air clearance method is required for schools under AHERA
regulations to determine if an area has cleared, and is available for re-use with
protective equipment.
3. Polarized Light Microscopy (PLM).
Polarized light microscopy (PLM) is the most commonly accepted method for
analyzing bulk materials for the presence of asbestos. This method is inexpensive
and can be performed in a few hours. PLM is based on optical mineralogy using
a light microscope equipped with polarizing filters. Identification of asbestos fiber
bundles is based on the determination of optical properties displayed when the
sample is treated with various dispersion staining liquids (refraction index liquids).
The reliable limit of detection for this method is about one percent asbestos.
Samples of extremely fine dusts, such as brake dust, shall be analyzed by electron
microscopy which can detect the smaller fibers. Negative results for floor tile shall
be verified by a TEM analysis, due to the small fiber sizes.
7.4 Sampling Strategies and Procedures for an Abatement Project
1. Air Sampling Before Abatement Begins
Area air sampling conducted before abatement activities begin to estimate the
existing airborne fiber concentrations inside and outside the building is termed
prevalent level sampling. These results can be used as control data for comparing
sample concentrations detected during and after the abatement project.
Background level sampling provides good data for documentation purposes. It is
particularly useful when an abatement project is conducted in a portion of the
building, with other areas of the building remaining occupied. Airborne fiber levels
monitored in these occupied areas during the abatement project shall never
exceed the indicated background level in these areas before the project began.
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Also, the airborne fiber concentrations inside the abatement area after cleanup is
completed cannot be expected to be lower than the airborne fiber levels outside
the building before abatement began. PCM analysis is most often used, but shall
be supported by selected TEM analysis to more accurately confirm the presence
of asbestos fibers.
Because low airborne fiber concentrations are typically found prior to abatement
activities, a large volume of air shall be sampled to obtain a low detection limit.
Simply stated, detection limit is the lowest value that can be reliably reported for
the sampling and analytical methods used. The volume of air measured to obtain
0.01 fiber per cubic centimeter of air (fiber/cc) detection limit shall range between
1,000 to 2,500 liters, depending on the filter size and counting method used.
Samples can be collected at a flow rate of 2-15 liters per minute.
Background samples shall be collected throughout the building as well as in the
areas where abatement will take place. As a rule of thumb, one sample shall be
taken for every 50,000 cubic feet (5,000 sq. ft. with 10 ft. ceilings) of building space
(minimum of 3 samples). At least two samples shall be collected from outside the
building.
Because results of background level sampling are used as baseline data, the same
sampling and analytical techniques shall be used for background samples as will
be used for samples taken outside the work area during and after the removal
project.
2. Personal Sampling
Personal sampling is conducted during a renovation or abatement project to
determine employees’ exposure ( outside any respirator ) to airborne fibers. Data
from personal monitoring serves many purposes. Personal monitoring during an
abatement project is required by the OSHA Asbestos Standard unless Type C
supplied air respirators are used. Under OSHA and hazard communication laws,
employees have the right to know the asbestos concentrations to which they are
exposed and what measures are being taken to protect them. Also, results of
personal sampling can be used to select proper respiratory protection for an
employee if conditions warrant something other than Type C respirators. Data
from personal monitoring can be used as an indication of effective removal or
control techniques which result in the lowest employee exposure. This, in turn,
reduces the potential of asbestos-related diseases and the risk to the worker.
Personal samples shall be taken during the first full day of removal activity.
Additional personal samples shall be taken when the type of material being
removed or the location (i.e., building) changes. Personal samples shall be
collected throughout the duration of the project for compliance with current OSHA
regulations, unless Type C respirators are being used. Even with Type C
respirators it is prudent practice to conduct personal air monitoring every two
weeks, and when work practices or conditions change significantly.
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Personal samples shall be collected at flow rate of 1-2 liters per minute from at
least 25% of the workers doing a particular job. Samples for asbestos exposure
shall be taken to determine the 8-hour, time-weighted average (TWA)
concentration. Over an eight-hour period, filters may have to be changed several
times to prevent overloading. Results of each sample are put into this equation to
obtain a time-weighted average for the total sampling period.
C,1 1 + C T + C 3 T 3
= Time Weighted Average (TWA)
T 1 +T 2 +T 3 ...
C 1 , C 2 ... = Concentration of each sample
T 1 , T 2 ... = Duration of each sample
Typically, PCM is used to analyze personal samples collected during the removal
project.
3. Area Air Sampling Inside the Work Area
In addition to personal samples, area air samples are collected inside the work
area daily to determine the concentrations of airborne asbestos fibers. Usually,
two to three PCM air samples are usually adequate to index the airborne fiber
concentrations inside the work area. The data from these samples can be used
on a relative basis to monitor work conditions from one day to the next. A radical
increase in area concentrations would signal that work practices need to be
adjusted.
4. Area Air Sampling Outside the Work Area/Inside the Building
During an abatement project, samples are collected from locations outside the
work area, but inside the building to determine how well asbestos fibers are being
contained to the worksite. These samples are especially important in situations
where unprotected people are occupying other areas of the building. Potential
leakage points where sampling shall be conducted include the clean side of the
containment barriers separating the work area from occupied parts of the building
and inside the shower and clean rooms of the decontamination unit. If the
abatement project is being conducted in a multistory building, area air samples
shall be collected from floors above and below the abatement activity.
A large air volume is necessary to obtain the desired detection limit of 0.01 fibers
per cubic centimeter (0.01 f/cc) for these samples. High volume pumps can be
used to shorten the sampling time so that problems which develop can be
detected relatively quickly. Phase contrast microscopy is generally the analytical
method used for these air samples.
AHERA’s air clearance collection and TEM analysis method can also be used to
determine background levels inside and outside the building.
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5. Area Air Sampling Outside the Building
Area air samples are placed in locations outside of the work area during an
abatement project to detect leakage for fibers from the worksite. Typically, pumps
are placed at the entrance of the decontamination unit, at doors or windows, near
the exhaust of negative air filtration units,. and at the waste load-out area.
Generally, samples are collected using high volume pumps, and analyzed by PCM.
6. Air Sampling After Final Cleanup of the Work Area
Area air sampling is conducted upon conclusion of an asbestos abatement project
to estimate the airborne fiber concentrations of residual fibers. The area must
pass a thorough visual inspection for remaining material before final clearance
sampling is initiated. Samples are placed inside the work area, and inside the
building/outside the work area. AHERA’s protocol and minimum number of
samples (13) have been generally accepted by the asbestos abatement industry.
Ideally, phase contrast microscopy and electron microscopy are used in
combination as a two-stage process for final clearance sampling. Phase contrast
analyses can be used to determine if any gross contamination remains in the work
and side-by-side samples can be taken for analyses by electron microscopy. If the
PCM samples indicate airborne fiber levels are below 0.01 f/cc using aggressive
sampling techniques, then the next set of samples are collected per the AHERA
protocol and submitted of analyses by TEM. As discussed earlier, TEM is the
analytical method recOgnized as having the best resolution and positive fiber
identification capabilities, and is required by AHERA for schools.
The airborne fiber concentration for clearance by TEM is 70 structures per square
millimeter (s/mm 2 ), based on the average of the results for all inside workers’
samples. If the results by TEM analysis indicate the airborne fiber concentrations
are higher than this clearance standard, then the area must be recleaned and
retested until the criterion is met.
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8
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Section 8 Personal Protective Equipment and
Decontamination Procedures
Selection of 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.
8.1 Respirators
Respirators used for O&M activities must be selected based on the requirements of
regulations and a Respiratory Protection Program developed 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.
1. Appendix ‘E’ of the EPA Green Book includes EPA’s recommendations on the
types of respirators to be used for custodial and maintenance tasks.
2. 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.
3. NIOSH recommends minimizing occupational exposure to cancer producing
substances, such as asbestos to the lowest feasible level.
4. A calculated maximum exposure level for workers of 0.01 f/cc of air inside the
respirator is to be used by .EPA workers when selecting respiratory protection in
accordance with EPA guidance.
5. OSHA has stated that the OSHA permissible exposure limit (PEL) 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. EPA workers’ selection of
personal protective equipment, including respiratory protection, is detailed in EPA’s
41 Health & Safety Guidelines,” revised March, 1991.
6. Full face PAPRs shall be desirable to provide additional eye and face protection for
workers and are the minimum level of respiratory protection used by EPA asbestos
inspectors.
(a) PAPR’s are preferred by many workers instead of negative pressure
respirators.
(b) OSHA regulations 29 CFR 1910.1001 and 29 CFR 1926.58 require that an
employer provide a PAPA in lieu of a negative pressure respirator if an
employee chooses to use this type of respirator.
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7. Depending upon the type of work and work practices to be used, combination
respirator filter cartridges or a different type of respirator might be necessary to
protect workers from other contaminants or hazardous substances.
8. Respiratory protection for asbestos work requires the use of high efficiency
particulate air (H EPA) fitter cartridges.
8.2 Protective clothing
Protective clothing for O&M work typically consists of disposable coveralls, gloves and/or
boots.
1. Protective clothing for O&M work can be selected by the APM or the worker,
depending upon the O&M procedures.
2. The protective clothing option selected might depend in part upon the
decontamination procedures to be used and the type of work area preparation or
enclosure.
3. The APM shall also determine whether boots, gloves, hardhats and other
protective equipment are needed for O&M tasks.
4. Protective clothing selections made by the APM shalt be recorded on the
Maintenance Work Authorization Form.
8.3 Decontamination procedures
Decontamination procedures typically used for O&M work include HEPA vacuuming on
a drop cloth, changing in a change room, or showering.
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9
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Section 9 O&M Plan Purpose and Scope
9.1 O&M Plan Purpose
1. The purpose of an O&M Plan is to minimize exposure of all building occupants to
asbestos fibers. An O&M plan includes work practices to:
(a) maintain ACBM in good condition and minimize the release of asbestos
fibers by controlling activities which may disturb ACBM;
(b) minimize airborne asbestos exposure for building occupants,
maintenance/custodial workers and the public;
(c) establish procedures for controlling and containing ACBM which has been
disturbed or has released fibers and dust or debris;
(d) establish administrative procedures and work practices to achieve the
objectives for the program;
(e) monitor ACBM through periodic visual surveillance.
9.2 Levels of O&M Projects
O&M work is divided into three levels. These levels are based on the NIBS O&M Work
Practices Manual, which contains the work practices to be used in conjunction with this
program. The NIBS document forms the basis of the SMs document included within this
Program.
The three levels are:
1. 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.
2. 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.
3. 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.
9.3 Work Scheduling
1. Level 2 and 3 work shall 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.
2. If an area is always occupied, plans shall be made to isolate the work area from
building occupants using visual and/or physical barriers.
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3. If a special work area arrangement is required, it might be beneficial to provide a
sketch to the workers showing how the area is to be set up.
4. If respirators are used for Level I 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.
5. Scheduling of work might be affected by notification requirements. All notification
requirements shall be met before work is scheduled.
6. Under certain circumstances, some emergency work can be performed prior to the
filing of a notification.
7. Review regulations and contact federal, state and local regulatory agencies
concerning notification requirements for emergency work.
9.4 Appointing the APM and APC
The appointment of the APM and APC (if required) is the first step to be completed in
implementing the Program for the management of ACBM at EPA occupied or controlled
facilities. The APM shall have overall responsibility for ensuring that the SOPs and SMs
of the Program are properly executed. An APC shall work with the APM to see that EPA’s
workers are protected in accordance with the Policy and Program when work on ACBM
is performed.
An important aspect of this program is that it is designed to work for the different
ownership and lease arrangements commonly used for EPA occupied or controlled
facilities:
I. EPA owned and managed facility (EPAO).
2. EPA leased facility (EPAL).
3. EPA facility owned and managed by GSA (GSAO).
4. EPA facility leased by GSA (GSAL); including EPA Occupied/EPA Delegated.
5. EPA facility accessed through an Inter-Agency Agreement (lAG).
The lease arrangement for [ ‘Jame of Factrity] is [
A successful asbestos O&M Management program requires the cooperation and
participation of all occupants of the facility. Workers performing asbestos O&M work
must follow the SOPs and SMs included in this Program to achieve the objectives listed
above.
The Policy, SOPs and SMs apply to any facility(ies) to be occupied by the EPA and shall
be made a part of any space solicitations or lease agreements.
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The Documentation Package for Asbestos Operations and Maintenance Programs in the
U.S. General Services Administration (GSA) Facilities (dated September 24, 1990), is
referenced in this Program and utilized to provide consistency in documentation.
Applicable forms are included in the appendices.
The Program utilizes as its SMs, the asbestos-related work practices developed by the
National Institute of Building Sciences (NIBS) in the NIBS document entitled “Guidance
Manual, Asbestos Operations and Maintenance Work Practices”.
9.5 Assigning Workers
Workers assigned to perform O&M work shall have:
1. Training and experience in the skills and techniques required for the tyçe of work
to be performed.
2. Training in applicable asbestos O&M procedures.
3. The O&M plan for the facility.
4. Site-specific building conditions.
The EPA Green Book, NIBS document and SMs document of this Program provide
guidance concerning the level of training recommended for conducting different types of
O&M activities.
State and local regulations may impose training requirements for O&M activities.
1. Verify that state and local requirements are met before scheduling work.
2. 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 shall verify that their training,
respirator fit tests and medical surveillance are current and in compliance with applicable
regulations and the requirements of work practices to be used.
Once workers are selected for a task, the APM (and/or APC) shall review the work
practice with the workers.
9.6 Elements of an O&M Plan
9.6.1. Building Inspection and Assessment : To determine if an asbestos control and
management program shall be implemented, the building owner shall conduct (or
shall have already conducted) an initial building inspection and survey to locate
and assess the condition of all ACBM in the building.
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Any building to be occupied or controlled by EPA shall be inspected as described
under this Program prior to use or occupancy. Each inspection shall be performed
by an accredited or certified asbestos inspector.
For each inspection, the certified inspector shall provide a written assessment of
all friable known or assumed to be present in the building. The inspector shall
classify and give reasons for classifying the ACBM and suspected ACBM into one
of the seven categories defined below:
1) Damaged or significantly damaged thermal system insulation ACBM.
2) Damaged friable surfacing ACBM.
3) Significantly damaged friable surfacing ACBM.
4) Damaged or significantly damaged friable miscellaneous ACBM.
5) ACBM with potential for damage.
6) ACBM with potential for significant damage.
7) Any remaining friable ACBM or friable suspected ACBM.
An effective O&M plan shall address all types of ACBM present in a building.
ACBM that may be managed as part of an O&M plan in buildings can be classified
in one of the following categories, which have been used in recent EPA guidance
documents on ACBM. The SMs are divided into the same three categories.
• Surfacing Material: Examples include ACBM sprayed or troweled onto
surfaces, such as decorative plaster on ceilings or acoustical ACBM on the
underside of concrete slabs or decking, or fireproofing materials on
structural members.
• Thermal System Insulation ( Sl) Material: Examples include ACBM applied
to pipes, boilers, tanks and ducts to prevent heat loss or gain, or
condensation.
• Miscellaneous Material: Examples include asbestos-containing ceiling or
floor tiles, textiles, and other components such as asbestos-cement panels,
asbestos siding and roofing materials.
9.6.2 Asbestos Safety Training . Adequate asbestos safety training of personnel who
may be required to enter work areas where there is the potential for exposure to
asbestos fiber concentrations above normal background levels is a Program
principle. Individuals occupationally exposed to asbestos and managers of
activities involving asbestos are to be instructed on the basic risks to health from
asbestos and on basic asbestos protection principles. The development of all
training materials shall take into consideration employees’ duties, nature of work
assignments, and responsibilities. The primary goal of asbestos safety training is
to provide the worker(s) with the knowledge necessary to safely work with, or
around, asbestos-containing building materials and sources of asbestos fibers in
a manner consistent with Program principles.
Training shall be provided for:
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• TheAPM
• The APC
• Asbestos Workers
• Asbestos Inspectors
9.6.3 Asbestos Exposure Monitoring . The primary goal of EPA’s exposure monitoring
program is to optimize the level of protection for workers and the building
environment, and to demonstrate and document such protection. This is
accomplished by collecting information derived from occupational and
environmental exposure data, which can be used by managers and workers in
order to maintain exposures to program levels. A specific objective of the EPA
Program is to reduce the risk to workers’ health associated with exposure.
Supplementary objectives include developing information regarding the trends of
fiber exposures received by workers, environmental conditions in workplaces, and
exposure risks associated with particular operating practices and/or work sites.
Other analyses of monitoring data may be performed to identify opportunities for
improving operating practices and methods, and enhancing overall Program
quality.
Exposure and air monitoring work to be performed as a part of this SOP shall
include:
1. Initial Air Monitoring for workers
Initial monitoring is discussed in paragraph (f)(2) of OSHA standard 29 CFR
1926.58:
Initial monItoring. (i) Each employer who has a workplace or work
operation covered by this standard, except as provided for in paragraphs
(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
exemptions.. The OSHA requirements for exposure monitoring data under
the Construction Industry Asbestos Standard (29 CFR 1926.58) are
specified in paragraph (f)(2)(iii).
“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 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 requirement.)
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2. Area Air Monitoring
OSHA requires periodic monitoring unless supplied air respirators are used.
Periodic monitoring is discussed in paragraph (f)(3) of OSHA standard
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 workers
are equipped with supplied-air respirators operated in the positive pressure
mode, the employer may dispense with the daily monitoring required by this
paragraph.”
3. Clearance Air Monitoring
Termination of monitoring is discussed in (0(4) of OSHA standard 1926.58:
‘Termination 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 workers whose exposures are
represented by such monitoring.”
Initial air monitoring is required by OSHA regulations to document levels of
airborne ACBM in the breathing zone of workers. Initial monitoring shall be
performed during all asbestos O&M projects unless statistically reliable historical
exposure monitoring data in strict accordance with the OSHA requirements has
been previously obtained for the level and type of work being done. At the APM’s
discretion, personal air monitoring may be conducted for all asbestos O&M work.
All initial monitoring samples shall be analyzed by PCM in accordance with the
OSHA reference method.
Area air monitoring shall be performed during asbestos O&M work to document
levels of airborne asbestos in or near a work area. Area air monitoring is most
commonly used outside of the immediate work area to provide documentation that
contamination has not spread to other areas of a facility. Area monitoring is not
required by OSHA, but may be used for all asbestos O&M work if desired by the
APM. Area monitoring is also used for background monitoring prior to the start
of a project.
Clearance air monitoring is used to verify the airborne fiber levels are reduced
below the required clearance level or background levels existing prior to the start
of work. Clearance monitoring shall be used on all asbestos O&M projects unless
historical data has indicated that airborne fiber levels for the work shall not exceed
the required clearance level.
All projects needing clearance sampling shall be cleared by PCM using at least 3
samples obtained in the work area. All samples must be below a clearance level
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of 0.01 f/cc or equivalent to the pre-work background fiber level for the work to be
considered complete. If the samples are not below these clearance levels, the
area must be re-cleaned and re-tested until the established clearance level is
obtained.
Exposure monitoring will be needed to validate that each work practice level meets
the intended exposure goals. To fit within the level definitions, the following must
hold true:
• Level I (No Worker or Area Protection) work practices shall 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.
• 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.
The only way that a work practice can be validated is to monitor airborne levels
during the work. Personal monitoring is required to determine if work area
isolation is needed. If no disturbance of ACBM will occur (such as with many Level
I work practices), monitoring might not be required.
The Air Monitoring Program developed for a specific facility needs to address how
exposure monitoring will be conducted to provide data for use in the design and
validation of work practices. The program shall define exposure limits for both
workers and the building environment.
The PCM air monitoring required by OSHA for exposure monitoring does not
distinguish between asbestos and non-asbestos fibers. TEM analysis of clearance
samples is required by the federal government under AHERA for applicable school
projects. EPA’s Program follows this protocol, although it is not required for non-
school buildings.
Under EPA’s Asbestos Program, to obtain O&M clearance after Level 2 and 3
work, the following procedure is established:
• Personal monitoring shall consist of samples to obtain an 8 hour time-
weighted average (TWA), if possible, and excursion limit (EL) monitoring
samples.
Analysis by PCM.
• Analysis by TEM of 20% of air tests taken as a validation check.
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This procedure shall be used before and after dust sampling, as a quality control
method. It may also be used in special circumstances (for example, if the APM is
unsure of what level work practice to use for a particular project).
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 shall be used only when the test area is
contained; Aggressive disturbance of open areas shall not be undertaken.
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. 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.
Some asbestos consultants recommend examining settled dust for accumulations
of asbestos fibers as another surveillance tool in an O&M program. While no
universally accepted standardized protocols currently exist for sampling and
analysis of settled dust, positive results (i.e., ACBM are present in the dust) may
indicate the need for special cleaning of the affected area, or other action.
Because the results of this testing are difficult to interpret and evaluate at this time,
building owners shall carefully consider the appropriateness of this testing to their
situation.
Workplace Control Level (WCL). The WCL is 70 s/mm 2 , as determined by the
TEM analysis methodology established by AHERA.
The establishment of a WCL is consistent with the AHERA regulations established
for public and private schools.
Personnel Monitoring. Personnel monitoring means determining individual workers’
exposure(s) to asbestos fibers. Information derived from personnel monitoring is
used for minimizing the exposure to certain tissues and organs of workers; and for
minimizing the collective exposure of workers. This approach limits risks to the
health of both individuals and groups of workers. Exposures can be determined
through a variety of methods, including measurements derived from air pumps and
sampling devices placed in the work area and/or placed on the worker’s person
in their breathing zone. Routine individual monitoring constitutes regularly repeated
or continuous measurements made for individuals. Collected data is Used for
calculating estimated exposures.
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OSHA and EPA regulations require workers to wear respirators and protective
clothing whenever they are exposed, or likely to be exposed, to fiber levels above
OSHA’s permissible levels. It is important that workers be properly trained in the
use of respirators and protective clothing. All asbestos O&M activities may not
require the use of respirators and protective clothing. Worker and respiratory
protection required for asbestos O&M activities are desciibed by the SMs. The
APM shall be trained in the selection of respiratory protection and personal
protective equipment.
Respirators used shall be approved by MSHA and NIOSH. A respiratory protection
program is required by OSHA for workers that use respirators. Workers must be
properly fit-tested to wear assigr ed respirators.
9.6.4 Medical Surveillance . Federal regulations require those workers who remove,
enclose or encapsulate asbestos-containing materials to participate in a medical
surveillance program provided by their employer, at no cost to the worker(s).
Workers involved in building maintenance, repair, renovation and demolition
activities shall also participate.
Each asbestos worker participating in a medical surveillance program shall
complete a standardized medical questionnaire of medical and work histories, and
undergo a physical examination with emphasis on lungs, heart and digestive
systems.
All medical exams and procedures must be performed by or under supervision of
licensed physician without charge to employee at a reasonable time and place.
If needed, an appendix may be added to this document to include medical monitoring
reports or information. Remember to include a reference here as well as at the Table of
Contents.
9.6.5 Notification Program
Initial Notifications
All building occupants and maintenance workers shall be informed about the
location and physical condition of any ACBM in their building that they might
disturb. The need to avoid disturbing the ACBM shall be stressed. Occupants
shall be notified for two reasons:
1. Building occupants shall be informed of any potential asbestos hazard in
their vicinity.
2. Informed persons are less likely to unknowingly disturb the material and
cause fibers to be released into the air.
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It is important to undertake an open approach to the ACBM notification procedure.
Clear lines of communication shall be established with building occupants
regarding asbestos issues. People who are informed of the presence, location and
condition of ACBM in a building where they work or live, who understand that the
mere presence of ACBM is not necessarily hazardous to them, and who accept
that ACBM can often be managed effectively in place can be very helpful in
eliminating or reducing hysteria on the part of other less informed building
occupants.
In service and maintenance areas (such as boiler rooms), labels or signs such as
“Caution - Asbestos - Do Not Disturb” placed directly on or adjacent to thermal
system insulation ACBM will alert and remind maintenance workers not to
inadvertently disturb the ACBM. In most cases, all boilers, pipes, and other
equipment with ACBM in service areas where damage may occur shall have
prominent warning labels or signs placed on or next to the ACBM. Based upon
the most recent visual inspection of an area, areas with damaged ACBM may
require respiratory protection and protective clothing for entry into these areas.
The EPA occupant notification program consists of sending Occupant Notification
letters to all occupants once an inspection for ACBM has been completed. This
notification includes the following general information:
1. That a survey has been performed and has identified areas where ACBM
are located, in the facility.
2. The condition of the ACBM and actions to be taken.
3. ACBM must be maintained in good condition and shall not be disturbed.
4. Report any damage of ACBM to APM or APC.
5. ACBM will be periodically reinspected and actions will be taken to maintain
or remove (if necessary) the ACBM.
Asbestos Work Notifications
All facility occupants shall be notified by the APM or APC before work on ACBM
will be performed in any area of their facility. Such notification shall describe the
work location, work to be performed, the work schedule, and precautions to be
used to protect building occupants.
The APM shall file all notices required by federal, state and local regulations prior
to the start of any O&M activities that are governed by these regulations.
Federal requirements for notification are set forth in• the National Emission
Standards for Hazardous Air Pollutants (NESHAP) rules and the EPA Worker
Protection Rule.
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I
I
9.6.6 Surveillance and Reinspection . A visual reinspection of all ACBM shall be
conducted at regular intervals by the building owner as part of the O&M program.
Combined with ongoing reports of changes in the condition of the ACBM made by
service workers, the reinspections shall help ensure that any ACBM damage or
deterioration will be detected and corrective action taken.
Periodic Surveillance. At least once every 6 months the building owner shall
conduct period surveillance of all ACBM located within the building occupied or
controlled by EPA.
Each person performing periodic surveillance shall be:
• Accredited or certified as an Inspector
Reinspection. At least once every 3 years the building owner shall conduct a
reinspection of all friable and non-friable known or suspected ACBM.
Each person performing a reinspection shall be:
• Accredited or certified as an inspector.
Periodic review of the Program, and its ongoing SOPs and SMs, is essential to
ensure that the objectives are being met. A key feature of the review is a
reinspection of all ACBM in the building. Combined with ongoing reports of
changes in the condition of the ACBM made by service workers, the reinspection
will ensure that any damage or deterioration of the ACBM will be detected and
corrective action taken. Additional control measures may be necessary if the
ACBM deteriorates.
9.6.7 Control System . The building owner shall include in the O&M program a system
to monitor and control all work that may occur in the building that could disturb
ACBM. The building APM shall be the person designated to manage and
administer the required control system.
Under these SOPs and the SMs documents included under this Program, a work
practice system is provided for administration and operation of work practices to
control any disturbance of ACBM.
Engineering controls to be used on asbestos O&M projects vary based on the type
of project being performed. Regulations require certain engineering controls for
projects depending upon the amount of work to be performed and anticipated
airborne fiber levels during the work. Personal protective equipment shall be used
in addition to, and not instead of, engineering controls for asbestos O&M work.
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These SOPs adopt the NIBS O&M Work Practices as the Program’s SMs. The
SMs are divided into three categories based on the type of ACBM encountered:
‘S’ Procedures - for surfacing materials
‘T’ Procedures - for ISI materials
‘M’ Procedures - for Miscellaneous materials
The introductory material of the SM5 document must be reviewed by all asbestos
O&M personnel at this facility.
Work permits for work involving ACBM will be integrated into current work
processing procedures. The review of work involving ACBM will consist of the
following:
1. An initial review to determine whether the facility has been surveyed, and if
so, whether it contains ACBM.
2. For facilities with ACBM, survey data and asbestos location drawings, if
available, will be reviewed to determine whether the work may disturb
ACBM. If insufficient data exists, bulk samples shall be obtained and
analyzed, or the material(s) shall be assumed to contain ACBM and treated
accordingly.
3. For work that may disturb ACBM, the ACBM project type and work
practices will be selected.
4. Where the task is not covered by previously approved standard work
practices, the SMs shall make sure that the appropriate work practices and
protective measures are used for the job.
5. For all jobs where contact with ACBM is likely, the APM or a designated
supervisor qualified by training or experience shall visit the work site when
the work begins to see that the job is being performed properly. For
lengthy jobs where disturbance of ACBM is intended or likely, periodic
inspections shall be made for the duration of the project.
6. Any deviation from standard and approved work practices shall be recorded
immediately on this form and the practices shall be immediately corrected
and reported to the APM.
7. Upon completion of the work, a copy of the evaluation form shall be placed
in the permanent asbestos file for the building.
Building owners shall consider using asbestos O&M work control forms similar to
those which already may be in use for non-ACBM work in their facilities.
The O&M management system shall also address work conducted by outside
contractors. Many building owners contract for a least some custodial and
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maintenance services. A building’s asbestos work control/permit system shall also
cover contract work. -
At a minimum, contracts with service trades or abatement companies shall include
the following provisions to ensure that the service or abatement workers can and
will follow appropriate work practices:
• Proof that the contractor’s workers have been properly trained and notified
about ACBM in the owner’s building and that they are properly trained and
accredited to work with ACBM.
• Copies of respiratory protection, medical surveillance, and worker training
documentation as required by OSHA, EPA and/or state regulatory
agencies.
• Notification to building tenants and visitors tI?at abatement activity is
underway.
The NIBS Guidance Manual is used as the model in developing EPA’s Asbestos
Program and its SMs. The following is a brief outline of topics included in SMs:
I. Manual Organization
II. Asbestos Program Manager General Procedures
Ill. Worker General Procedures
IV. Surfacing Materials Work Practices
V. Thermal Systems Insulation Work Practices
VI. Miscellaneous Materials Work Practices
VII. Appendices
• The APM .or APC shall review work practices with the workers who will
perform the work.
• Workers shall be notified to consult with the APM or designated person:
• If they have any questions during the work.
• If any problems occur.
• If it appears to the workers that additional precautions might be
necessary to safely perform the work.
• Detailed procedures are given 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.
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• The general procedures shall 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 shall be reviewed periodically by
the APM to verify that the proper procedures are being followed.
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Section 10 Recordkeeping
Records of all asbestos O&M activities and programs must be retained to comply with
Federal requirements. Records to be maintained as a requirement of these SOPs shall
include the following:
1. Personal air sampling records, for at least 30 years. A copy of personal air
sampling records shall be kept in the worker’s medical records. The APM shall
also keep a copy for review when selecting work practices. Personal air samples
are those collected in the worker’s breathing zone during performance of work
involving asbestos exposures.
2. Objective air monitoring data used to qualify for exemptions from OSHA’s initial
monitoring requirements for the duration of the exemption.
3. Medical records for each employee subject to the medical surveillance program for
the duration of their employment plus 30 years. Administrative records related to
the medical surveillance program shall be retained in the Safety and Health
Manager’s office.
4. All asbestos O&M personnel training records for one year beyond the last date of
each worker’s employment.
5. Survey and assessment reports.
6. A copy of this manual.
7. Respiratory Protection Program.
8. Work Permit forms.
9. Surveillance and Reinspection Data.
10. Notifications sent to employees/building occupants/contractors.
11. Records request forms.
12. Fiber release reports.
13. Waste disposal records.
14. Initial/Periodic cleaning forms.
15. O&M Plan acknowledgement forms.
16. Regulations maintained for O&M work.
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Section 11 Quality Assurance and Quality Control
(QA/QC)
A QA/QC program for O&M work includes the following primary components:
1. A regular review of the records by the APM and APC. These records shall be
reviewed every three months for completeness, unless the APM and APC mutually
agree that a longer interval is satisfactory. Action shall be taken immediately to
correct any discrepancies in file documentation or work practices.
2. The APM and APC shall review O&M activities in progress as often as necessary
(a minimum of once a month is suggested). Reviews shall be conducted as
necessary for the APM and APC to remain familiar with the ability of the workers
to perform work in accordance with the work practices. State or local
requirements may dictate the amount of oversight required.
3. A review of a summary of work performed since the last review. A review of
several work requests shall be performed by a trained person that does not
routinely process work requests to verify that survey data is being properly used,
and that additional data is being obtained when needed.
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Section 12 References
United States Environmental Protection Agency, Pesticides and Toxic Substances
(TS-799), Document 20T-2003, July, 1990, Managing Asbestos In Place. A Building
Owner’s Guide to operations and Maintenance Programs for Asbestos-Containing
Materials . Also known as the “EPA Green Book”.
United States Environmental Protection Agency, Office of Pesticides and Toxic
Substances, Document EPA 560/5-85-024, June, 1985, Guidance for Controlling
Asbestos-Containing Materials in Buildings . Also known as the “EPA Purple Book”.
United States Environmental Protection Agency, Document EPA 560 5 85 030a,
October, 1985. Asbestos in Buildings: Simplified Sampling Scheme for Friable
Surfacing Materials . Also known as the “EPA Pink Book”.
Asbestos Hazard Emergency Response Act (AHERA), Federal Register (40 CFR
Part 763), October 30, 1987.
National Institute of Building Sciences, Guidance Manual Asbestos Operations and
Maintenance Work Practices, September, 1992.
EPA Health and Safety Guidelines for EPA Inspectors, (Revised), March, 1991.
EPA Policy and Program for the Management of Asbestos-Containing Building
Materials at EPA Facilities (Draft), July, 1994.
EPA Standard Methods for Conducting Asbestos O&M Work Practices (Draft),
July, 1994.
American National Standards Institute/American Society for Quality Control -
ANSI/ASQC E4.
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Section 13 Definitions
Abatement - The general term used to define any of the following response actions:
operations and maintenance, repair, encapsulation, enclosure/encasement, or removal.
Accessible - When referring to ACM means that the material is subject to disturbance by
school building occupants or custodial or maintenance personnel in the course of their
normal activities.
Accredited or Accreditation - When referring to a person or laboratory means that such
person or laboratory is accredited in accordance with section 206 of Title Il of the Act.
Adequately Wet - Adequately Wet means sufficiently mixed or penetrated with liquid to
prevent the release of particulate. 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.
Agency Facility - Property owned or substantially controlled by EPA. Property that is
rented or leased by the Agency, or that is loaned to the Agency, is considered to be
substantially controlled by the EPA.
Agency Safety, Health, and Environmental Management Program Managers (hereafter
referred to as SHEMP managers TM ) - Managers who, have the technical and managerial
skills have the authority and responsibility to represent the authority of the AAs and
RAs in the effective implementation, management and administration of safety, health and
environmental management programs, including development of O&M Plans.
Air Erosion - The passage of air over friable ACBM which may result in the release of
asbestos fibers.
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 ACBM
to control asbestos fibers.
Asbestos - The asbestiform varieties of: Chrysotile (serpentine), crocidolite (riebeckite);
amosite (cummingtonitegrunerite); anthophyllite; tremolite; and actinolite.
Asbestos-Containing Materials (ACM) - Any material or product which contains more than
1 percent asbestos.
Asbestos-Containing Building Materials (ACBM) - Surfacing ACM, thermal system
insulation ACM, or miscellaneous ACM that is 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 regulated source. This term includes filters from control
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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.
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 ACBM.
Asbestos Hazard Emergency Response Act (AHERA) - An EPA regulation published in
the October 30, 1987 Federal Register (40 CFR Part 763) covering asbestos-containing
materials in schools. AHERA requires local education agencies to identify ACBM 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.
NESHAP requires 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 Coordinator (APC) - An EPA employee (worker) or designated
representative who supervises aspects or the building asbestos management and control
program. (For leases through GSA, GSA may also have a representative who
coordinates EPA and other federal government tenants.)
Asbestos Program Manager (APM) - A building owner or designated representative who
supervises all aspects of the facility asbestos management and control program. (For
EPA owned facilities, will most likely be an EPA worker.)
Breathing Zone - A hemisphere forward of the shoulders with a radius of approximately
6 to 9 inches.
Bridging Encapsulant - An encapsulant that forms a discrete layer on the surface of an
in situ asbestos matrix.
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.
Critical Work - Activities deemed essential by an EPA Division Director, or higher-level EPA
manager, that (1) must be conducted in order to protect workers from hazards likely to
cause serious injury or illness; or (2) must be undertaken to prevent damage to property
or facilities, which would otherwise result in a sustained impairment of Agency strategic
mission or essential capability for which no comparable and acceptable alternate exists.
Damaged Friable Miscellaneous ACM - Friable miscellaneous ACM which has deteriorated
or sustained physical injury such that the internal structure (cohesion) of the material is
inadequate or, if applicable, which has delaminated such that its bond to the substrate
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(adhesion) is inadequate or which for any other reason lacks fiber cohesion or adhesion
qualities. Such damage or deterioration may be illustrated by the separation of ACM into
layers; separation of ACM from the substrate; flaking, blistering, or crumbling of the ACM
surface; water damage; significant or repeated water stains, scrapes, gouges, mars, or
other signs of physical injury on the ACM. Asbestos debris originating from the ACBM
in question may also indicate damage.
Damaged Friable Surfacing ACM - Friable surfacing ACM which has deteriorated or
sustained physical injury such that the internal structure (cohesion) of the material is
inadequate or which has delaminated such that its bond to the substrate (adhesion) Is
inadequate, or which, for any other reason, lacks fiber cohesion or adhesion qualities.
Such damage or deterioration may be illustrated by the separation of ACM into layers;.
separation of ACM from the substrate; flaking, blistering, or crumbling of the ACM
surface; water damage; significant or repeated water stains, scrapes, gouges, mars, or
other signs of physical injury on the ACM. Asbestos debris originating from the ACBM
in question may also indicate damage.
Damaged or Significantly Damaged Thermal System Insulation ACM - Thermal system
insulation ACM on pipes, boilers, tanks, ducts, and other thermal system insulation
equipment where the insulation has lost its structural integrity, or its covering, in whole or
in part, is crushed, water-stained, gouged, punctured, missing, or not intact such that it
is not able to contain fibers. Damage may be further illustrated by occasional punctures,
gouges, or other signs of physical injury to ACM; occasional water damage on the
protective coverings/jackets; or exposed ACM ends or joints. Asbestos debris originating
from the ACBM in question may also indicate damage.
Delamination - Separation of one layer from another.
Disposal Bag - Properly labeled 6 mil (0.15 mm) thick (or thicker) leak-tight plastic bags
used for transporting asbestos waste from work and to disposal site.
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.
Employee Work Activities - Official work performed by EPA employees in EPA controlled
facilities, in facilities of private or other public employers, or at temporary work sites, e.g.,
hazardous waste sites, spill sites, and other environmental investigation sites.
Encapsulant - A material that surrounds or embeds asbestos fibers in an adhesive matrix,
to prevent release of fibers.
Encapsulation - The treatment of ACBM with a material that surrounds or embeds
asbestos fibers in an adhesive matrix to prevent the release of fibers, as the encapsulant
creates a membrane over the surface (bridging encapsulant) or penetrates the material
and binds its components together (penetrating
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Enclosure - The construction of an air-tight, impermeable, permanent barrier around
ACBM to prevent the release of asbestos fibers into the air.
EPA - U.S. Environmental Protection Agency.
Establishment - A single location where Agency activities are conducted, but which
receives administrative assistance and support from a higher level or another location.
Excursion Umit (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 Episode - Any uncontrolled or unintentional disturbance of ACBM resulting
in visible emission.
Friable - Material, that when dry, may be crumbled, pulverized, or reduced to powder by
hand pressure, and includes previously nonfriable material after such previously nonfriable
material becomes damaged to the extent that when dry it may be crumbled, pulverized,
or reduced to powder by hand pressure.
Friable Asbestos - See °Regutated ACBM”.
Functional Space - A room, group of rooms, or homogeneous area (including crawl
spaces or the space between a dropped ceiling and the floor or roof deck above),
designated by a person accredited to prepare management plans, design abatement
projects, or conduct response actions.
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 in diameter or larger.
Homogeneous Area - An area of surfacing material, thermal system insulation material,
• or miscellaneous material that is uniform in color and texture.
Major Fiber Release Episode - The falling or dislodging or more than 3 square or linear
feet of friable ACBM.
• 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
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regulation 29 CFR 1926.58 discusses mini-enclosures and recommends that a change
room be constructed contiguous to the mini-enclosure.
Minor Fiber Release Episode - The falling or dislodging of 3 square or linear feet or less
of friable ACBM.
Minor Work - Work disturbing ACBM that does not affect quantities of ACBM in excess
of the regulated small scale, short duration project limit.
Miscellaneous ACBM - 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.
Negative Pressure System - A local exhaust system, utilizing HEPA filtration capable of
maintaining a pressure differential with the inside of the Work Area at a lower pressure
than any adjacent area, and which cleans recirculated air or generates a constant air flow
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 Standard for 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.
Non-friable - Material in a facility which when dry may not be crumbled, pulverized, or
reduced to powder by hand pressure.
Officer-in-Charge of Reporting Unit an Establishment or a Workplace - The senior
management official responsible for implementing safety, health, and environmental
programs, including O&M Plans, at that designated location. In the Regions, it is the RA.
In the research laboratories, it is the laboratory director.
Operations & Maintenance (O&M) Program - A program of work practices to maintain
friable ACBM in good condition, ensure clean up of asbestos fibers previously released,
and prevent further release by minimizing and controlling friable ACBM disturbance or.
damage. .
Operations and Maintenance Plan - A formulated plan of training, cleaning, work practices
and surveillance to maintain ACBM in good condition.
“Worker(s)” includes full-time, part-time, temporary, and permanent EPA employee (s);
federal, state or local government employee(s) assigned or detailed to the EPA;
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enrollee(s) in the EPA’s Senior Environmental in-school program participant(s); intern(s)
and fellow(s) assigned to the EPA; and others who are designated on a case-by case
basis by the Director, SHEMD.
Occupied Area - An area where workers 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.
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.
Potential Damage - Circumstances in which: (1) friable ACBM is in an area regularly used
by building occupants, including maintenance personnel, in the course of their normal
activities; and (2) there are indications that there is a reasonable likelihood that the
material or its covering will become damaged, deteriorated, or delaminated due to factors
such as changes in building use, changes in operations and maintenance practices,
changes in occupancy, or recurrent damage.
Potential Significant Damage - Circumstances in which: (1) friable ACBM is in an area
regularly used by building occupants, including maintenance personnel, in the course of
their normal activities; (2) there are indications that there is a reasonable likelihood that
the material or its covering will become significantly damaged, deteriorated, or
delaminated due to factors such as changes in building use, changes in operations and
maintenance practices, changes in occupancy, or recurrent damage; and the material is
subject to major or continuing disturbance, due to factors including, but not limited to,
accessibility or, under certain circumstances, vibration, or air erosion.
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.
Preventive Measures - Actions taken to reduce disturbance of ACBM or otherwise
eliminate the reasonable likelihood of the material’s becoming damaged or significantly
damaged.
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Regulated ACBM (RACBM) - As defined by NESHAP in the November 20, 1990 Federal
Register, regulated asbestos-containing material (RACBM) means (a) Friable asbestos
material; (b) Category I nonfriable ACBM that have become friable; (c) Category I
nonfriabte ACBM that will be or have been sublected to sanding, grinding, cutting, or
abrading; or (d) Category II nonfriable ACBM that have a high probability of becoming or
have 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.
Friable asbestos material means any material containing more than 1 percent
asbestos as determined using the method specified under AHERA (40. CFR Part
763, Subpart F, Appendix A, section 1, Polarized Light 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 nonfriable asbestos-containing material (ACBM) 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 nonfriable ACBM means any material, excluding Category I nonfriable
ACBM 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 ACBM, “remove” refers to the
removal of ACBM as needed to perform a maintenance or repair O&M activity.
Removal - The taking out or the stripping of substantially all ACBM from a damaged area,
a functional space, or a homogenous area.
Removal Encapsulant - A penetrating encapsulant specifically designed to minimize fiber
release during removal of asbestos-containing materials rather that for in situ
encapsulation.
Repair - Returning damaged ACBM to an undamaged condition or to an intact state so
as to prevent fiber release.
Reporting Unit - A location or group of locations where Agency business is conducted
and which has the same line management authority for laboratories and field units at
other locations. This would include a complete region, an ORD or program laboratory,
RTP, etc.
Respirator - A device designed to protect the wearer from the inhalation of harmful
atmospheres.
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Response Action - A method, including removal, encapsulation, enclosure, repair,
operations and maintenance, that protects human health and the environment from friable
ACBM.
Routine Maintenance Area - An area, such as a boiler room or mechanical room, that is
not normally frequented and in which maintenance employees or contract workers
regularly conduct maintenance activities.
Significantly Damaged Friable Miscellaneous ACM - Damaged friable miscellaneous ACM
where the damage is extensive and severe.
Significantly Damaged Friable Surfacing ACM - Damaged friable surfacing ACM in a
functional space where the damage is extensive and severe.
Surfacing ACBM - 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.
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 Bafflers - One or more layers of 6 mil polyethylene installed to isolate a work
area from other portions of a facility.
Thermal System Insulation (TSI) - 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 (1WA) - In air sampling, this refers to the average air
concentration of contaminants during a particular sampling period.
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.
Workplace - A physical location where the Agency’s work or operations are performed.
A workplace means a distinctly separate activity housed within an establishment or which
is geographically close to shares O&M Plan responsibility of an establishment.
Workplace Control Level - An exposure level which is intended to limit the risk to an
individual from asbestos fibers. This indoor level at EPA occupied or controlled facilities
is 70 structures per millimeter squared (70 s/mm 2 ).
Work Practices - Procedures designed to be followed to avoid or minimize fiber release
during activities affecting ACBM.
65
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14
-------
Section 14 Appendices
14.1 Appendix A: Standard Forms
1. Inspection Summary Sheet: Use to summarize ACM inspection results for
each homogenous area.
2. Bulk Sample Data Form: Use to summarize sample data for all
homogenous areas from a bulk sampling inspection and to record
laboratory results following analysis of samples.
3. Surfacing Assessment Form (2 pgs.): Use during an inspection for
recording data on surfacing ACM.
4. TSI Assessment Form: Use during an inspection for recording data on
thermal system insulation ACM.
5. Miscellaneous Assessment Form: Use during an .inspection for recording
data on miscellaneous ACM.
6. Master Ust of Training Information: Summarizes training information for all
employees.
7. Verification of Employee Training: Form to be used for each employee to
record training courses attended, respirator program participation, and
medical surveillance program participation.
8. Sample Information Letter to Tenants/Occupants: Sample letter to be used
to notify tenants and occupants of planned renovation work, inspections for
ACM, and the establishment of the O&M Plan.
9. Occupant Notification Form: Use to record information and dates related
to notifications sent to building occupants, tenants, and employees.
10. Basic and Initial Medical Questionnaire (OSHA) (11 pgs.): Standard OSHA
questionnaire for an initial medical surveillance examination.
11. Periodic Medical Questionnaire (3 pgs.): Standard OSHA questionnaire for
annual physical examinations for employees enrolled in a medical
surveillance program.
12. Reinspection Form: Use to record information for each homogenous area
during an ACM reinspection.
13. Work Control Application Form: Use to request approval to perform O&M
work that may involve asbestos.
66
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14. O&M Activity Form (2 pgs.): Use to record information on work practices
used for work on ACM.
15. Records Request Form: Use to request information in O&M records from
Asbestos Program Manager.
16. Air Sample Form: Use to record data and results of air samples obtained
during O&M activities.
17. Fiber Release Episode Report: Form for recording response activities
related to a fiber release episode.
18. Waste Tracking Form and Waste Disposal Record: Use to record
information related to waste disposal, including type of containers,
notifications, disposal site, and chain of custody.
19. Initial/Periodic Cleaning Form: Use to record special cleaning work
information and work practices.
20. Contractor’s Acknowledgment Form: Form to be completed by contractors
certifying that they will comply with the Policy and Standard Operating
Practices.
21. Clearance Inspection Checklist: Form for recording information on
inspections and clearance sampling conducted at the completion of work
on ACM.
22. NESHAP Notification of Demolition and Renovation Form (2 pgs.): NESHAP
required form to be submitted 10 working days in advance of any work
involving regulated ACM that will be stripped, dislodged, curt, drilled, or
similarly disturbed.
23. NESHAP Waste Shipment Record (3 pgs.): Form required to document
asbestos-containing waste that is transported off a facility site.
67
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BUILDING INSPECTION SUMMARY SHEET
Building: _____________________________________________________ GSA Bldg.No.:__________________________________
________________________________________________________ Date of Inspection:
Are
Homogeneous Area No.:______________ Functional Space No.________________
Category of ACM: ______ Surfacing ______ Thermal System Insulation ______ Miscellaneous
Type of Asbestos: _______ Chrysotile _______ Ainosite _______ Other________
Percent Asbestos: ____________________
Amount of ACM: _______________
Friable: _______ Yes _______ No
Material Assessment: _____ No Damage Damaged _____ Other________________
Reason for Damage:
Homogeneous Area No.:______________ Functional Space No._________________
Category of ACM: _______ Surfacing _______ Thermal System Insulation _______ Miscellaneous
Type of Asbestos: _______ Chrysotile _______ Amosite _______ Other_________
Percent Asbestos: _______________________
Amount of ACM: ___________________
Friable: ________ Yes ________ No
Material Assessment: _______ No Damage Damaged Other_____________________
Reason for Damage:
Area:
Homogeneous Area No.:_____________ Functional Space No.________________
Catcgory of ACM: _______ Surfacing _______ Thermal System Insulation _______ Miscellaneous
Type of Asbestos: _______ Chrysotile _______ Amosite _______ Other_________
Percent Asbestos: ______________________
Amount of ACM: ___________________
Friable: _______ Yes _______ No
Material Assessment: _______ No Damage Damaged• Other
Reason for Dam age:_
-------
Building:
Address:
Bldg. No.:
DATA FORM
BULK SAl iPLE
lnspector —
Signature: —
Date:
Sample Location
Sample
No.
Type of
Material
Description
of Sample
.
Asbestos
Functional
Space No.
Homogeneous
Area No.
Floor
Room
Location
in Room
Type
%
-------
Surfacing Asbestos-Containing Material
Assessment Form
_____ GSA Bldg. No.:_____
ddress:____________________________________________________________________________________
Area:__________________________________________ Date of Assessment:
Location of Surfacing ACM: ____ Ceiling ____ Wall ____ Other (specify)_
Homogeneous Area No.:_____________ Functional Space No.:______
(Note: A separate assessment form will be completed for each type of surfacing ACM.)
Type of Surfacing ACM: Fire roof&ng __________ Thermal Insulation
Acoustical Plaster ____________ Decoration
Other (specify)
Type of Ceiling: Concrete 3-coat Plaster Ceiling
(if applicable)
Suspended Metal Lath Concrete Joists/Beams
Tile Suspended Lay-in Panels
Metal Deck Corrugated Steel
Steel Beam or Bar Joists Other (specify)
Ceiling Shape: _______ Flat Dome _______ Folded Plate
(if applicable)
Barrel Other (specify)
Type of Coated Wall: Smooth Concrete Thermal Insulation
(if applicable)
Masonry Wall or Ceiling Board
Other (specify)
Total Amount of Material:_________________________ Ceiling Height:
Estimated Thickness:_________________________ Is Thickness Uniform: — Yes — No
If no, give range of thickness:_______________________
Asbestos Known?______ Type:_____________________ Percentage:____ Asbestos Assumed?____
mount of Damaged Material:_________________________________________________________________________________
-------
Surfacing Assessment Form
Page Two
escription of Coating: ______ Fibrous ______ Granular/Cementitious
_____ Concrete-Like
Coating Debris on Floor/Furniture/Work Surfaces: _______ Yes _______ No
Is coating subject to disturbance by curtains, expandable partitions, etc. _______ Yes _______ No
Type of lighting: _____ Surface Mounted _____ Suspended _____ Recessed
Type of Heating/Cooling System:
What is above the room being evaluated:____________________________________________
Current Condition of ACM:
Physical Damage/Deterioration: Major _______ Minor None
Water Damage/Deterioration: Major _______ Minor None
Potential for Future Damage, Disturbance, or Erosion:
Accessibility High _______ Moderate Low
Activity & Movement: _______ High _______ Moderate Low
Change in Building Usc: _______ Scheduled____ Possible _______ None
Vibration: _______ High _______ Moderate _______ Low
Air Plenum: _______ Yes _______ No
Friability: High _____ Low
Amount of ACM Exposed: _____________________ Greater Than 10%
_______________ 10% or Less
_____________________ Not Exposed
Comments:____________________________________________________
Assessor:______________________________ Date Report Completed:.
Signed:_______________________________ Date:__________________
(Facility Asbestos Control Manager)
-------
Thermal System Insulation (TSI)
Assessment Form
Building:________________________________ GSA Bldg. No.:____________________
drcss:
Area: Date of Assessment:
Homogeneous Area No.:________________________ Functional Space No.:_________________
(Note: A separate assessment form will be completed for each type of TSI ACM.).
Type of Pipe and Boiler Insulation (ACM):
Duct Insulation ________ Duct Wrapping ________ Transite Board _____
Boiler Lagging _________ Tank insulation ________ Elbow Joints (No.): ______
Pipe Insulation: ________ Water Pipe ________ Steam Pipe
Area Around: ________ Valves ________ Flanges ________ Other _________________________
Total Amount ACM: _____________ Linear Feet ____________ Square Feet ____________
Area of Damaged ACM: ____________ Linear Feet ______________ Square Feet ______________
Asbestos Known? _________ Type:___________________________ Percentage:_______ Asbestos Assumed?_________
Location Specifics: ________ Air Handler Room ________ Boiler Room
______ Mechanical Room ______ Air Plenum
________ Enclosed Space ________ Stairwell
_______ Garage _______ Peripheral HVAC
_________ Other (specify)
Condition of ACM:
Physical Damage/Deterioration: Major Minor _________ None
Water Damage/Deterioration: Ma 1 or Minor _________ None
Friability of Damaged Area: _______ High Low
Potential for Future Damage, Disturbance, or Erosion:
Arce s sibility- High Moderate ________ Low
Activity & Movement: ______ High Moderate ______ Low
Change in Building Use: ________ Scheduled Possible _________ None
Vibration: ________ High Moderate ________ Low
Air Plenum: ________ Yes No
Comments:______________________________________________________________
Asscsson____________________________ Date Report Completed:.
— _________________________________________ Date:
(Facility Asbestos Control Manager)
-------
rca:_________________________________________________ Date of Assessment:_
Homogeneous Area No.:_____________________________ Functional Space No.:_
(Note: A separate assessment form will be completed for each type of miscellaneous ACM)
Type of Miscellaneous ACM: ______ Floor Tile ______ Ceiling Tile
(Attached separate sheets
if more than one type.) ________ Mastic ________ Roofing Felt
________ Extrusion Panels ________ Shingles
aapboard _________ Millboard
Asbestos/Cement Piping Walicovering
________ Sheet Goods ________ Other_____
_______ Paints & Coatings __________________
_________________ Linear Feet _________________
_____________ Linear Feet _______________
Square Feet ____________
Square Feet ____________
Type: Percentage:
________ Mechanical Area ________ Lobby
Hallway ________ Cafeteria
_______ Roof
Date Report Completed:
Condition of ACM:
Physical Damage/Deterioration: _________ Major
Water Damage/Deterioration: Major
Friability of Damaged Area: ________ High
Potential for Future Damage, Disturbance, or Erosion:
Accessibility: ________
Activity & Movement: _________
Change in Building Use: _________
Vibration: ________
Air Plenum: _________
!ned:
(Facihty Asbestos Control Manager)
Date:
Building
Address:
Miscellaneous Asbestos.Containing Material Assessment Form
______________ GSA Bldg. No.:_________________
Total Amount ACM:
Area of Damaged ACM:
Asbestos Knovrn?
Location:
_________ Office
__________ Conference Room
Garage
__________ Other (spccify)_
Asbestos Assumed?__________
Minor ________ None
Minor ________ None
Low
Moderate
Moderate
Possible
Moderate
No
_____ High
______ High
__________ Scheduled
____ High
______ Yes
__Low
__Low
________ None
__Low
-------
MASTER LIST OF T . ING INFORMATION
:
SOCIAL
COMPLETION
TRAINING
EMPLOYEE NAME
SECURITY
DEPARTMENT
TRAINING RECEIVED
DATE
ORGANIZATION
NUMBER
-------
Verification Of Employee Training
Employee Name ___________________________________________
)cial Security # _______________________________________________
Position ___________________________________________________
Employee: ___________ GSA ___________ Non-GSA
Training Provider _________________________________________
Address ___________________________________________________
Training Course Title __________________________________
Date of Course S
Length of Course (Hours)
Was This Course: ______ Initial Training Update Training
Does Course Have Full Approval of U.S. Environmental Protection Agency?
oes Employee Participate in Respirator Program? ______ Yes ______ No
Does Employee Participate in Medical Surveillance Program? ____ Yes ____ No
Attach Copy of Certificate Indicating Successful Completion of Training (including appropriate
examination).
-------
Sample Information Letter to Tenants/Occupants
MEMORANDUM FOR: Building Tenant Agencies/Occupants
FROM: _______________________
Facility Asbestos Program Manager
SUBJECT: Notification of the Presence of Asbestos-Containing Material
in ( Facility Name) .
As communicated to building tenant agencies and occupants in a memorandum dated
__________________, scheduled renovation of_______________________ within
the ______________________ building, asbestos-containing material was identified in
_________________________ The entire facility was inspected for the presence of
asbestos-containing materials by _____________________________________
Upon receipt of the survey results, consultation was entered into with experts in the field
of asbestos detection and control to develop a course of action specifically designed to
protect the health and safety of building occupants. An asbestos-related Operations and
Maintenance (O&M) program was established to provide an effective means for dealing
with the asbestos situation. The objectives of the O&M plan are to:
• establish a program of work practices to maintain asbestos-containing
materials in good condition
• ensure the safe clean-up of asbestos fibers previously released
• prevent release of asbestos fibers by minimizing disturbance and damage
• develop an in-house asbestos response team to effectively handle
emergency situation.
Through the establishment of a trained, in-house asbestos response team and use of
experienced outside asbestos abatement contractors, the asbestos situation within this
facility can be controlled in a manner which will be safe to the health of the building
occupants. Of course, the help and cooperation of all tenant agencies and occupants
will be needed.
This office will implement a policy of providing informational updates on any activity which
will involve the intentional disturbance of asbestos-containing material during building
operations, emergency response to asbestos fiber releases, and precautions and
procedures designed to ensure the health and safety of the building occupants. In
addition, information can be gained directly by contacting this office at ______________
-------
TENANT/EMPLOYEE/BUILDING OCCUPANT NOTIFICATION FORM
_____________________________ GSA Building No.:_______
idress:
TENANI AGENCIES
_________ No tenant agencies in this facility
Tenant agencies notified of:
______________ presence of asbestos-containing materials Date_
implementation of O&M program Date_
__________________ ACM abatement plans Date_
__________________ air monitoring results Date_
Attach list of tenant agencies notified.
Attach documentation that tenant agency received notification (optional).
EMPWYEES/OCCUPAJ’u’TS
Notification of all facility employees of _________ presence of ACM
________ implementation of O&M program
________ ACM abatement plans
_________ air monitoring results
Type of notification (check all that apply and list dates)
Letter Daie:_
Postcd notice Date:_
Newsletter Date:_
Public meeting Date:_
Awareness seminar Date:_
GSA NOTIFICATIONS
Notification to GSA Regional office; Mail Code:_
Notification to GSA Field Office; Mail Code:_
Sent by.
Office: __________
Phone: _______________
Date: _________________
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BASIC EXAMINATION FOR ASBESTOS WORKERS
COMPANY: ____________________
DATE: _________________________
APPLICANT NAME: _______________ SS#: ____________________
ADDRESS: _______________________ TELEPHONE: _______________
DATE OF BIRTH: ___________________
MEDICATIONS:
KNOWN DRUG ALLERGIES:
BROKEN BONES:
SURGERY:
DOES PATIENT WEAR GLASSES OR CONTACTS:
DOES PATIENT HAVE KNOWN PROBLEMS REGARDING HEIGHTS OR
CONFINED SPACES:
HAS PATIENT EVER HAD PROBLEM WiTH EARS:
DOES PATIENT SMOKE: ___________ HOW MUCH __________
CARDIO-PULMONARY EXAMINATION
1. BLOOD PRESSURE: SYSTOLIC DIASTOLIC PULSE ____
2. HEART: MURMURS
RATE
RHYTHM
ENLARGEMENT HEIGHT WEIGHT_______
3. LUNGS:
4. PULMONARY FUNCTION: Within Normal Limit ___________
Outside Normal Limits _____ (copy attached)
5. PA CHEST X-RAY: Within Normal Limits ___ Outside Normal Limits
6. RECOMMENDATIONS:
It is my opinion that the above named patient is is not medically qualified to
wear a respirator in the performance of his/her joth
-------
Prom Federal Register/VoL 51, No. 119/Friday, June 20, 1986/Rules and Regulations
Part 1
INITIAL MEDICAL QUESTIONNAIRE
1. Name
2. Social Security # ____ ____ ____ ____ ____ ____ ____ _____
1 2 3 4 5 6 7 8 9
3. CLOCK NUMBER ___ ___ ___ ___ ____
10 11 12 13 14 15
4. PRESENT OCCUPATION ___________________________________
5. PLANT
6. ADDRESS
7.
(Zip Code)
8. TELEPHONE NUMBER ___________________________________
9. INTERVIEWER _________________________________________
10. Date ______________________ ____ ____ ____ ____ _____
16 17 18 19 20 21
11. Date of Birth
22 23 24 25 26 27
12. Place of Birth _______________________________________________
13. Sex 1. Male
2. Female
14. What is your marital status? 1. Single 4. Separated/
2. Married Divorced
3. Widowed
15. Race 1. White 4. Hispanic
2. Black 5. Indian
3. Asian 6. Other
16. What Is the highest grade completed in school? ___
(For example, 12 years is completion of high school)
-------
OCCUPATIONAL HISTORY
17 A. Have you ever worked full time 1. Yes _____ 2. No _____
(30 hours per week or more) for
6 months or more?
IF YES TO 1 A:
B. Have you ever worked for a year 1. Yes _____ 2. No _____
or more in any dusty job? 3. Does Not Apply ____
Specify job/industry __________ Total Years Worked ____________________
Was dust exposure: 1. Mild_______ 2. Moderate _________ 3. Severe ______
C. Have you ever been exposed to gas or I. Yes ______ 2. No ______________
chemical fumes in your work?
Specify job/industry __________________ Total Years Worked _________________
Was exposure: 1. Mild _______ 2. Moderate _________ 3. Severe__________
D. What has been your usual occupation or job — the one you have worked at the
longest?
1. Job occupation __________________________________________________
2. Number of years employed in this occupation _________________________
3. Position/job title_______________________________________________________
.4. Business, field or industry ____________________________________________
(Record on lines the years in which you have worked in any of these Industries, e.g.,
1960-1969)
Have you ever worked:
YES NO
E. Inamine! . . . . . . . . . . . . . . . . .
F. Inaquarry?. . . . . . . . . . . . . . . . . .
C. Inafoundry? . . . . . . . . . . . . . . . . .
H. Inpottery? . . . . . . . . . . . . . . . . . .
L In a cotton, flax, or hemp mill? . . . . . . . . . . _______
SI. Wlthasbestos?. . . . . . . . . . . . . . . . .
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18. PAST MEDICAL HISTORY
YES NO
A. Do you consider yourself to be in good health? _______ _______
If “NO” state reason ________________________________________________
B. Haveyouanydefectofvision? . . . . . . . _____ _____
IF “YES” state nature of defect ____________________________________
C. Haveyouanyhearingdefeet?. . . . . . . . . ______ ______
If “YES” state nature of defect ______________________________________
D. Are you suffering from or have you ever suffered from:
a. Epilepsy (or fits, seizures, convulsions?) _______ _______
b. Rheumatic fever? _______ _______
c. Kidney disease? _______ _______
d. Bladder disease? _______ _______
e. Diabetes? _______ _______
f. Jaundice? _______ _______
19. CHEST COLDS AND CHEST ILLNESSES
19 A. If you get a cold, does It usually 1. Yes _____ 2. No _____
go to your chest? (Usually means 3. Don’t get colds _______________
more than 1/2 the time)
20 A. During the past 3 years, have you 1. Yes 2. No _____
had any chest illnesses that have
kept you off work, Indoors at home,
or in bed?
IF YES TO 20A:
B. Did you produce phlegm with any of
these chest illnesses? 1. Yes _____ 2. No _____
3. Does Not Apply __________
C. In the last 3 years, how many such Number of Illnesses
Illnesses with (increased) phlegm did No. such illnesses
you have which lasted a week or more?
-------
21. Did you have any lung trouble before 1.
the age of 16?
22. Have you ever had any of the following?
1A. Attacks of bronchitis? 1.
IF yES. O 1A:
B. Was It confirmed by a doctor? 1.
3.
C. At what age was your first attack?
2A. Pneumonia (include bronchopneumonia)?
IF YES TO 2A:
B. Was it confirmed by a doctor?
C. At what age did you first have it?
3A. Hay Fever?
B. Was it confirmed by a doctor?
C. At what age did it start?
23. A. Have you ever had chrcrnic bronchitis?
IF YES TO 23A:
B. Do you still have It?
C. Was it confirmed by a doctor?
D. At what age did It start?
24. A. Have you ever had emphysema?
IF YES TO 24A:
B. Do you still have It?
C. Was it confirmed by a doctor?
Yes 2. No
Yes ____ 2. No ____
Yes _____ 2. No _____
Does Not Apply _____
Age in Years _____
Does Not Apply _____
1. Yes ____ 2. No ____
1. Yes ____ 2. No _____
3. Does Not Apply __________
Age in Years _____
Does Not Apply __________
1. Yes ____ 2. No _____
3. Does Not Apply __________
Age in Years _____
Does Not Apply __________
1. Yes ____ 2. No _____
1. Yes ____ 2. No _____
3. Does Not Apply__________
1. Yes __ 2.No ___
3. Does Not Apply_________
Age In Years ____
Does Not Apply _____
1. Yes __ 2.Nó ___
1. Yes __ 2.No ___
3. Does Not Apply_________
1. Yes ____ 2. No _____
3. Does Not Apply________
-------
D. At what age did It start? Age In Years _____
Does Not Apply_________
25. A. Have you ever had asthma? I. Yes ____ 2. No _____
IF YES TO 25a
B. Do you still have it? 1. Yes ____ 2. No _____
3. Does Not Apply__________
C. Was It confirmed by a doctor? 1. Yes ____ 2. No _____
3. Does Not Apply__________
D. At what age did it start? Age In Years _____
Does Not Apply_________
E. If you no longer have it, at what Age Stopped _____
age did It stop? Does Not Apply __________
26. Have you ever had:
A. Any other chest illness? 1. Yes ____ 2. No _____
If yes, Please specif.y ________________________________________________
B. Any chest operations? 1. Yes ____ 2. No _____
If yes, Please specify ________________________________________________
C. Any chest injurIes? 1. Yes ____ 2. No ______
If yes, Please specify ________________________________________________
27. Has a doctor ever told you that you 1. Yes ____ 2. No _____
had heart trouble?
[ F YES TO 27A:
B. Have you ever had treatment for heart 1. Yes ____ 2. No _____
trouble in the past 10 years? 3. Does Not Apply__________
28. A. Has a doctor every told you that 1. yes ____ 2. No _____
you had high blood pressure?
IF YES TO 28A:
B. Have you had any treatment for high 1. Yes ____ 2. No _____
blood pressure (hypertension) in the 3. Does Not Apply__________
past ten years?
29. When did you last have your chest
z-rayed? (Year) ____ ____ ____
25 26 27 28
30. Where did you last have your chest x-rayed (if known)? _____________________
What was the outcome?
-------
FAMILY HISTORY
31. Were either of your natural parents ever told by a doctor that they had a chronic
lung condition such as:
FATHER MOTHER
1. Yes 2. No 3. Don’t 1. Yes 2. No 3. Don’t
Know Know
A. Chronic
Bronchitis?
B. emphysema?
C. Asthma?
D. Lung cancer?
FATHER MOTHER
1. Yes 2. No 3. Don’t 1. Yes 2. No 3. Don’t
Know Know
E. Other chest
conditions?
F. Is parent currently
alive?
C. Please Specify Age if Living Age if Living
Age at Death Age at Death
Don’t Know Don’t Know
H. Please specify
cause of death ____________________ ____________________
COUGH
32. A. Do you usually have a cough? (Count a 1. Yes ____ 2. No. _____
cough with first smoke or on first going
out of doors. Exclude clearing of throat.)
(If no, skip to question 32C.)
B. Doyouusuallycoughasmucha4to6 1. Yes 2. No
times a day 4 or more days out of the week?
C. Do you usually cough at all on gettIng 1. Yes 2. No
up or first thing In the morning?
D. Do you usually cough at all during the 1. Yes 2. No
rest of the day or at night?
-------
IF YES TO ANY OF ABOVE (32A, B, C, or D), ANSWER THE FOLLOWING. IF NO TO
ALL, CHECK DOES NOT APPLY AND SKIP TO NEXT PAGE.
E. Do you usually cough like this on most 1. Yes ____ 2. No _____
days for 3 consecutive months or more 3. Does Not Apply__________
during the year?
F. For how many years have you had the cough? Number of Years _____
Does Not Apply__________
33. A. Do you usually bring up phlegm from your 1. Yes•____ 2. No
chest? (Count phlegm with the first smoke or on
first going out doors. Exclude phlegm
from the nose. Count swallowed phlegm.)
(If no, skip to 33C.)
B. Do you usually bring up phlegm like this 1. Yes ____ 2. No
as much as twice a day 4 or more days
out of the week?
C. Do you usually bring up phlegm at all on 1. Yes 2. No
getting up or first thing in the morning?
D. Do you usually bring up phlegm at all 1. Yes 2. No
during the rest of the day or at night?
IF YES TO ANY OF THE ABOVE (33A, B, C, OR D), ANSWER THE FOLLOWING:
IF NO TO ALL, CHECK DOES NOT APPLY AND SKIP TO 34A.
E. Do you bring up phlegm like this on most 1. Yes ____ 2. No _____
days for 3 consecutive months or more 3. Does Not Apply__________
during the year?
P. For how many years have you had trouble Number of Years _____
with phlegm? Does Not Apply__________
EPISODES OF COUGH AND PHLEGM
34. A. Have you had periods or episodes of 1. Yes 2. No
(increased ) cough and phlegm lasting
for 3 weeks or more each year?
(Por persons who usually have cough
and/or phlegm)
B. IFYESTO34A:
For how long have you had at least 1 such Number of Years
episode per year? Does Not Apply
-------
WHEEZING
35. A. Does your chest ever sound wheezy or
whistling
1. When you have a cold? 1. Yes ____ 2. No
2. Oceasi.-nally apart from colds? 1. Yes ____ 2. No
3. Most thiyc or nights? 1. Yes ____ 2. No
B. IFYESTO1,2,or31n35A:
For how many years has this been present? Number of Years _____
Does Not Apply_________
36. A. Have you ever had an attack of wheezing 1. Yes 2. No
that has made you feel short of breath?
LFYESTO 36A:
B. How old were you when you had your first Age In Years _____
such attack? Does Not Apply —
C. Have you had 2 or more such episodes? 1. Yes ____ 2. No _____
3. Does Not Apply __________
D. Have you ever required medicine or 1. Yes ____ 2. No _____
treatment for the(se) attack(s)? 3. Does Not Apply __________
BREATHLESSNESS
37. If disabled from walking by any condition -
other than heart or lung disease, please
describe and proceed to question 39A.
Nature of condition(s) _____________________________________________________
38. A. Are you troubled by shortness of breath 1. Yes 2. No
when hurrying on the level or walking
up a slight bill?
IFYESTO38A:
B. Do you have to walk slower than people 1. Yes ____ 2. No _____
of your age on the level because of 3. Does Not Apply_________
breathlessness?.
C. Do you ever have to stop for breath when 1. Yes — 2. No _____
walking at your own pace on the level! 3. Does Not Apply_________
D. Do you ever have to stop for breath after 1. Yes ____ 2. No _____
walking about 100 yards (or after a few 3. Does Not Apply_________
minutes) on the level?
E. Are you too breathless to leave the house 1. Yes ____ 2. No
or breathless on dressing or climbing one 3. Does Not Apply
flight of stairs?
-------
TOBACCO SMOKiNG
39. A. Have you ever smoked cigarettes? 1. Yes ____ 2 No. _____
(No means less than 20 packs of cigarettes
or 12 oz. of tobacco In a lifetime or
less than I. cigarette a day for 1 year.)
IF YES TO 39A:
B. Do you now smoke cigarettes (as of 1. Yes 2. No
one month ago)?
C. How old were you when you first started Age in Years
regular cigarette smoking? Does Not Apply__________
D. If you have stopped smoking cigarettes Age Stopped
completely, how old were you when you Check if still smoking
stopped? Does Not Apply __________
E. How many cigarettes do you smoke per Cigarettes per day
day now? Does Not Apply
F. On the average of the entire time Cigarettes per day•
you smoked, how many cigarettes Does Not Apply
did you smoke per day?
C. Do or did you inhale the cigarette 1.. Does Not Apply ___________
smoke? 2. Not At All _____
3. SlightLy _____
4. Moderately _____
5. Deeply _____
40. A. Have you ever smoked a pipe regularly? 1. Yes 2. No
(Yes means more than 12 oz. of tobacco
in a lifetime.)
IF YES TO 40A:
FOR PERSONS WHO HAVE EVER SMOKED A PIPE
B. 1. How old were you when you started
to smoke a pipe regularly? Age ____
2. If you have stopped smoking a pipe Age Stopped _____
completely, how old were you when Check if still
stopped? smoking pipe
Does Not Apply __________
C. On the average over the entire time you oz. per week _____
smoked a pipe, how much pipe’ tobacco did (a standard pouch
you smoke per week? of tobacco contains
14/2 oz.)
Does Not Apply__________
-------
D. How much pipe tobacco are you smoking now? Oz. per week
Not currently
smoking a pipe
E. Do you or did you inhale the pipe smoke? 1. Never smoked
2. Notatall
3. Slightly
4. Moderately
5. Deeply
41. A. Have you ever smoked cigars regularly? 1. Yes ____ 2. No
(Yes means more than 1 cigar a week for
a year)
IF YES TO 41A:
FOR PERSONS WHO HAVE EVER SMOKED CIGARS
B. 1. How old were you when you started Age
smoking cigars regularly?
2. If you have stopped smoking cigars Age Stopped
completely, how old were you when Check If still
stopped? smoking cigars
Does Not Apply
C. On the average over the entire time you Cigars per week
smoked cigars, how many cigars did you Does Not Apply
smoke per week?
D. How many cigars are you smoking per week Cigars week
now? Check If not
smoking cigars
currently
E. Do you or did you inhale the cigar smoke? 1. Never smoked
2. Notatall
3. Slightly
4. Moderately
5. Deeply
Date ____________________ Signature’ ________________________
-------
From FederaL RegjsterfVoL 51, No. 119/Friday, June 20, 1986/Rules and Regulations
Part 2
PERIODIC MEDICAL QUESTIONNAIRE
1. Name
2. Social Security #____ ____ ____ ____ ____ ____ — ____ _____
1 2 3 6 7 8 9
3. CLOCK NUMBER ___ ___ ___ ___ ____
10 11 12 13 14 15
4. PRESENT OCCUPATION ___________________________________
5. PLANT
6. ADDRESS
7.
(Zip Code)
8. TELEPHONE NUMBER ____________________________________
9. INTERVIEWER ____________________________________________
10. Date ___________________ ____ ____ ____ ____ _____
16 17 18 19 20 21
11. What is your marital status? 1. Single 4. Separated/
2. Married Divorced
3. Widowed
OCCUPATIONAL HISTORY
12 A. In the pa.st year, did you 1. Yes ____ 2. No
worked full time (30 hours
per week or more) for 6 months or
• more?
IFYESTO 12A:
12. B. In the past year, did you work 1. Yes ____ 2. No _____
in any dusty job? 3. Does Not Apply
12. C. Was dust exposure: 1. Mild ____ 2. Moderate _____ 3. Severe —
12. D. In the past year, were you 1. Yes — 2. No
exposed to gas or chemical
fumes in your work?
-------
12. F.. Was exposure: 1. Mild _______ 2. Moderate 3. Severe
12. F. In the past year,
what was your. 1. Job/occupation __________________________
2. Position/job title? ________________________
13. RECENT M 1 T)ICAL HISTORY
13. A. Do you consider yourself to be
in good health? Yes No
If NO, state reason ______________________________________
13. B. In the pa3t year, have you
developed: Yes No
Emphysema?
Rheumatic fever?
Kidney disease?
13 ladder disease?
Diabetes?
Jaundice?
Cancer?
14. CHEST COLDS AND CHEST ILLNESSES
14. A. If you get a cold, does it usually 1. Yes _____ 2. No
go to your chest? (Usually means 3. Don’t get colds _______
more than 1/2 the time)
15. A. During the past 3 years, have you 1. Yes _____ 2. No
had any chest illnesses that have 3. Does not Apply
kept you off work 1 indoors at home,
or in bed?
15. B. IFYESTO15A:
Did you produce phlegm with any of
these chest illnesses? 1. Yes _____ 2. No
3. Doà Not Apply
15. C. In the past years, how many such Number of Illnesses
Illnesses with (increased) phlegm did No. such illnesses
you have which lasted a week or more!
-------
IS. RESPIRATORY SYSTEM
In the past year, have you had:
Further Comment on Positive
Yes or No Answers
Asthma ________
Bronchitis _________
flay Fever __________
Other Allergies _______
Pneumot Ia -
Tuberculosis _______
Chest Surgery __________
Other Lung Problems _________
Heart Disease ________
Do you have:
Further Comment on Positive
Yes or No Answers
Frequent colds __________
Chronic cough __________
Shortness of breath
when walking or
climbing one flight
of stairs
Do you:
Wheeze __________
Cough up phlegm _________
Smoke cigarettes _________ Packs per day How many years —
Date ____________________ Signature
-------
ASBESTOS-CONTAINING MATERIAL REINSPECTION FORM
____________________________ GSA Bldg. No.:_______
ddress:
_______________________________________________________________ Date of Reinspection:
Homogeneous Area No.:_____________________________________ Functional Space No.:_____
Date of Original Assessment:_________________________________________ Date of Last Reinspcction:_
Categoiy of Asbestos-Containing Material: ________ Surfacing ________ Thermal System Insulation
Miscellaneous
Description of ACM:
Amount of Material:__________________________________
Any Change in Material Condition?: Yes
No
Describe:_________________________________
Asbestos Known?______ T}pc:
Any ACM Debris on Floors/ Surfaces/Etc.?: Yes
Percentage:_________
No
Asbestos
Assumed?____________
Since the Last Assessment/Reassessment, Has There Been Any Change In:
Physical Damage: Yes
Water Damage: Yes
Exposed Surface Area: Yes
No
Describe:_____________________________
No Describe:
.
No Describe:
.
Accessibility to ACM: Yes
Activity in Area: Yes
Building/Area Use: Yes
F r iability Yes
Vibration in Area: Yes
Approximate Amount of ACM Showing A Change In Condition (i.e., area or pa
No
Describe:_____________________________
No
Describe:_____________________________
No
Describe:_____________________________
No
Describe:______________________________
No
Describe:_____________________________
rcentage):
Reinspection Conducted By Date:_
Inspector’s Company/Organization___________________________________ Phone:
Next Scheduled Reinspection:______________________________________________
Signed: Date:_
(Facility Asbestos Control Manager)
-------
Work Control Application for.Performing Maintenance/Renovation Work
Notes to applicant: (1) Submit this application as soon as work which may involve asbestos is initiated,
and attach supporting documents, such as drawings and reimbursable work authorization. Include
information known at the time of application, and discuss revisions with the Facility Asbestos Control
[ anager as the project develops.
(2) Review of the application is based on the asbestos known to GSA; the applicant retains the
responsibility for controlling asbestos the applicant encounters and immediately reporting to GSA any
unexpected materials suspected of containing asbestos, or unexpected conditions of known asbestos.
Building: ___________________________ GSA Building No.: —
Address:
Area of Work:
Dates of Work: Start ________________________________ Completion
Description of Work Involved: __________________________________________________________
Asbestos Control Method(s): Proposed by Applicant Accepted by Facil. Asb. Control Mgr.
Removal _____________________ _____________________
Encapsulation ____________________ ____________________
Enclosure ____________________ ____________________
Repair __________________ _________________
O&M ______________ ______________
Other ___________________ ___________________
Type (Category) And Approximate
Amount of Asbestos-Containing Materials:
Type (fireproofing,
pipe lagging, etc.) _____________________ _____________________
Protective equipment (describe):
Personal: _____________________ _____________________
Work area: _____________________ _____________________
Contractor/Agency Name: ________________________ Contact:_______________
Address: ________________________________ Phone: _______________
Review by Facility Asbestos Control Manager:
Accepted by ______________________ Date: _________________ Project Number: -
Denied by ____________________ Date: _______________ Reason for Denial:
-------
OPERATIONS & MAINTENANCE PROGRAM ACTIVITY
Building __________________________ GSA Bldg. No. ______
Ad fre s s
_________________________________ Dates of Project:
________________________ GSA Project/Contract No.:
Purpose of O&M Activity _________ Minor Repair
__________ Small Scale Removal
_________ Small Scale Encapsulation
_________ Abate Pre-E dsting ACM Debris
__________ Fiber Release Episode
___________ Periodic Cleaning
Type of Material: ______ Surfacing ______ Thermal System Insulation
_______ Miscellaneous
Approximate Amount of Material Involved: _____________ SF _____________ LF
Cause of O&M Activity: ______________ Deterioration ______________ Vandalism
__________ Delamination _________ Maintenance Activity
______________ Water Damage ______________ Other (Specify)
Physical Damage _________________________
Precautions Taken: _____________ Warning Signs Posted
_________ Air Handling System Shut Down; ________ Modified
_____________ Access to Area Restricted
Work Practices Used: _____________ Wet Wiping Glovebags
__________ HEPA-Vacuum __________ Other (Specify)
_______________ Endosures
_____________ Steam Cleaning
Protective Equipment Used: _____________ Respirators; Type
Protective Clothing
Other (Specify) —
-------
O&M PROGRAM ACTIVI1Y
PAGE 2 of 2
as Air Monitoring Conducted? _____ Yes _____ No
ttach air sampling log form)
Were Affected Tenant Agencies Notified? _____ Yes _____ No
(Attach Occupant Notification Form)
Brief Description of Action: ______________________________________________________
Start Date _______________________________ Completion Date _______________
Work Conducted: _____________ In-House _____________ Outside Contractor
Name of Contractor: __________________________________
Address: _______________________________________
Contact/Phone: _______________________________________
Contractor Personnel Involved: __________________________________
GSA Project Supervisor:
Phone: _______
GSA Personnel Involved: _______________________________
Work Completed According to GSA Requirements/Standards:
Signed: Date:
GSA Project Supervisor
Facilities Asbestos Control Manager
-------
RECORDS REQUEST FORM
_____________ GSA Building No.:
Address:
Requesting Agency:
Contact Person:_______________________ Date Requested:
Room/Building________________________ Phone:_______
Records Requested:
Area or Subject:
Contract Number:_____________________________________________
Description of Records: ____________________________________
Reason for Request:
Request Received By:________________________ Date:___________________
Request Granted By:______________________ Date:________________
Request Denied By:_______________________ Date:_________________
Reason: _____________________________________________________
Facility Asbestos Control Manager Approval:_________________________________
(Signature)
Date:____________
Date Records Sent:
-------
DATA FORM IRSAMPLtS
flulIding GSA Building No -
Addrecs
Sample
Number
Date
Location
Type of Sample
Activity
Being
Sampled
.
•
Name, Social
Security
Number and
Organization
of Individual
Monitored
Sampling Information
Perconal
Area
I(nside)
O(utside)
Start
Time
Stop
Time
Mins.
flow
Rate
1/mm.
Vol.
Method
of
Analysis
Fiber
Concent.
•
8-Hr.
Excur.
.
T’sNA
q learencc)
Additional Comments:
Sampling Technician: Date:
Signature:
Technician’s Firm:
-------
Fiber Release Episode Report
Building: _____________________________________________________ GSA Building No.:
dress:
rca: ________________________________________________________ Date: ________
Episode Reported By- _________________________________ Date: _____
(Name, Title) Phone:___________
Type of Material: ______ Suifacing ______ Miscellaneous
_________ Thennal System Insulation
Approximate Amount of Material Releastd _______________________________________________
Asbestos Type and Content (If Known) _______________________________________________________
Cause of Release: ___________ Deterioration ___________ Physical Damage
___________ Delamination ___________ Vandalism
_________________ Water Damage _________________ Maintenance Activity
Was area sealed off from nonessential personnel? ________ Yes ________ No How:___________________
Was air handling system shut down/modified? ________ Shut Down ________ Modified ________ No
Description Of Clean-Up Procedures: ____________________________________________________________
Clean-Up Conducted: ____________________________ Outside Contractor ________________________ In-House
Name of Contractor _____________________________________ Response Team Leadcr ___________
Address: ___________________________________________________
Equipment Used: HEPA-Vacuums Respirators
Wet-Wiping Pmtectn e Clothing
________ Steam Cleaning Other (Specify)
Was Regsonal Office contacted regarding release? ______ Yes ______ No
Person Contacted: _____________________________________ Dept.: _____
Title: ______________________________________________________________________ Phone: ______
Was follow-up letter/information sent? _________ Yes _________ No Date:
Signed: ________________________________________________________________ Date: ________
(Facility Asbestos Control Manager)
-------
Waste Tracking Form
Part I- To be completed by woekers :
Maintenance World Anthorization No. ____
Work Location: Building:
Room# o rArea,
Type of ACM id
Quantity of Waste generated:
Othor—- ----
,uLmL ;
Waste transported to: __________________
Transported b .
Tracking Poem given to:________________
Part 2- To be completed by Asbestos Program Manager
Waste Properly Packaged & Labeled: Yes — No —
EXCEPmUONS:_____________________
Waste Storage Locatioc: ________
Waste Disposal Location: _______
Waste Skipenent R rds Reoeived:
fli
SIGNED:
ASBESTOS PROGRAM MANAGER
DATh
flV4UU C
Bags
-------
WASTE DISPOSAL RECORD FORM
Building: ____________________________________ GSA Bldg. No.:
ddress: ______________________________________ GSA Project No.:
Area of Work:
WASTE INFORMATION
ACM Removal
______ Wet Removal
Dry Removal (EPA Approval Forms Attached)
Containerization (check all that apply )
______ Labelled 6 mu bags
______ Metal drums (labeled) ______ Fiberboard drums (labeled)
______ Other (specify)
DISPOSAL NOTIFICATION (Check All That Apply and Provide Copies)
Local NESHAP notification Date: ____________
State NESHAP notification Date: _____________
Federal EPA notification Date: _____________
Landfill Operator Date: ____________
CHAIN OF CUSTODY (Attach Landfill Receipts/Forms)
______ Contractor Date ____________ Manifest No.:
______ Waste hauler Date ____________ Manifest No.:
______ Landfill operator Date ____________ Manifest No.:
DISPOSAL SITE
Landfill name: __________________________________________
Mailing address: __________________________________________
Phone number: _________________________________________
Amount of material: ____________________________________
Form Completed By ________________________________ Date:
GSA Contract # __________________________________
gned: ___________________________________________ Date:
(Facility Asbestos Control Manager)
-------
Record of Initial/Periodic Special CIe ’ning
Building ________________________________________ GSA Building No.: _______
Address ______________________________________ Date:_________________
Area acaned ____________________________________ Initial acaning
_______________________________________ Periodic Recleaning
hems acaned: Drapes/Curtains
Furniture Fixtures
flooring Other
Equipment Used: HEPA-Vacuums
Wet-Wiping
Steam acaning
Any Visible Debris in Area ______ Yes ______ No
Any Change in ACM Condition Since Previous acaning Yes — No N/A_____
Extent of Change
GSA Activity.Supcrvisor ___________________________________
GSA Personnel Involved _______________________________
Name of Contractor _________________________________
Address: __________________
Contact/Phone: ___________
Contractor Personnel Involved: _________________________________________
Comments
Signed _________________________________________ Date:
GSA Activity Supervisor
Next Scheduled aeaning ________________________________________________
Signed: _______________________________________________________ Date:
Facility Asbestos Control Manager
-------
CONTRACTOR’S ASBESTOS OPERA11ONS AND MAINTENANCE POUCY AND
STANDARD OPERA11NG PRAC11CES ACKNOWLEDGEMENT
FaclTfty:
Contractor:
Address: Phone:______________________
Type(s) of Work Peiiormed: ____________________________________________
The above named Contractor hereby certifies that they:
1. Have been informed of the presence, type, and locations of asbestos-containing
materials at this facility.
2. Have a copy of the Policy and Standard Operating Practices for this facility.
3. Have reviewed and understand the Policy and Standard Operating Practices.
4. Will comply with the Policy and Standard Operating Practices and the procedures
in the Program when working around and working with asbestos-containing
materials present at this facility.
5. Will train the Contractor’s employees in accordance to comply with the Policy and
Standard Operating Practices training requirements.
Signed: ___
Print Name:
Title: ______
Date:
-------
CLEARANCE INSPECTION CHECKLIST
Building: Project No.:
Address: _________________________________________
)cation: _________________________________________ GSA Bldg. No.:
Date and Time Inspection Started: ________________________ Completed
Asbestos-Contpining Material Being Abated: _____________ Surfacing
_________ Thermal System Insulation
________ Miscellaneous
Approximate Amount of Material Abated: _____________ Sq. Ft. _____________ LF
Inspection for Residual Dust: _____________ None Found
____________ Residual dust found on:
____________ floor ____________ horizontal surfaces
pipes __________ HVAC equipment
lights _______________ other (specify)
;pection for Gross Contamination: _____________ None Found
_____________ Gross contamination found on:
_____________ deck _____________ structural members
pipes _______________ other (specify)
_____________ floors _______________________________
Results of Clearance Inspection: __________ Pass __________ Fail
Comments:
Clearance of Air Sampling Conducted: ____________ Yes _____________ No _______________
Results of Clearance Air Sampling: ______________ Area Passes: _____ Yes _____ No
Copies of data sheets attached.
Area Inspected By:_____________________________ Date:____________ Time:_______
Inspector’s Company/Organization:_______________________________ Phone:____________________________
ned:___________________________________________________ Date:_______________________________________
(Facility Asbestos Control Manager)
-------
NOTIFICATION OF DEMOLITION AND RENOVATION
O rdered Demo
j Tel:
R-Rcnovation
E Emer. Rcnovauon)
‘ Operator Project # Postmark Date Received Notification it
I. TYPE OF NOTIFICATION (O=Oziginal R=Received C=Cancclled):
U FACILITY INFORMATION (Identify owner, removal contractor, and other operator)
OWNER NAME:
Address:
City: I Stale:
Contact:
REMOVAL CONTRACrOR:
Address
City: I Stale:
Contact:
OTHER OPERATOR:
Address:
City:________________ I Stare: rzip;_____________________________________
Contacc
Ill. TYPE OF OPERATOR (D=Demo
IV. IS ASBESTOS PRESENT? (Ye ’No)
V. FAcILrry DESCRIPTION (Include building name, number and floor or room number)
Ifld 1 e:
Address:
City: I State: I County:
Sac Location:
Building Size: it of Floors: I Age in Years:
Present Use: Prior Use:
VI. PROCEDURE, INCLUDING ANALYTICAL METHOD IF APPROPRIATE. USED TO DETECT THE PRESENCE OF
ASBESTOS MATERIAL:
VII. APPROXIMATE AMOUNT OF ASBESTOS,
INCLUDING:
1. Regulated ACM to be removed
2. Catego y I ACM Not Removed
3. Category H ACM Not Removed
RACM
To Be
Removed
Nonfriab le
Asbestos
Material Not
To Be Removed
Indicate Unit of
Measurement Below
Cat I
Cat II
UNIT
Thp eS
LnF t : Lnm:
Surface Area__________________
V [ l A KiOff Facility Component
:
•
SgFt: Sgm:
Cu Ft: Cu m:
VIII. SCHUDULED DATES ASBESTOS REMOVAL (MM/DD/YY) Start Complete:
IX. SCHUDULED DATES DEMO/RENOVATION (MM/DD/YY) Start: Complete:
Continued on page two
Tel:
Zip:
Zip:
Tel:
——f————.—— —
Notification of Demolition and Renovation
-------
NOTIFICATION OF DEMOLITION AND RENOVATION (continued)
X. DESCRIPTION OF PLANNED DEM0LmON OR RENOVATION WORK, AND METHOD(S) TO BE USED:
XI. DESCRIPTION OF WORK PRACTICES AND ENGINEERING CONTROLS TO BE USED TO PREVENT EMISSIONS OF
ASBESTOS AT THE DEMOLITION AND RENOVATION SITE:
X l i WASTETRANSFORTERKI
Name:
Address:
Cia: Istaxe:
Zip:
Contact Person: — Telephone:
TRANSPORTER #2
Name:
..
Address:
City: Siaze: Zip:
Contact Per ion: Te lephone
XIII. WASTE DISPOSAL SITE:
Name:
Location:
City: State: T Zip:
Telephone:
XIV. IF DEMOL ON ORDERED BY A GOVERNMENT AGENCY, PLEASE IDENTIFY THE AGENCY BELOW:
Name: TT
Authority:
Date of order (MMJDD/YY) Daze ordered to begin (MMIDD/YY)
XV. FOR EMERGENCY RENOVATIONS
Daze and hour of emergency (MM/DD/YY):
Description of the Sudden, Unexpected Event:
.
Explanation of how the event caused unsafe conditions or would cause equipment damage
(or an unreasonable financial burden:)
XVI. DESCRIPTION OF PROCEDURES TO BE FOLLOWED IN THE EVENT THAT UNEXPECTED ASBESTOS IS FOUND
OR PREVIOUSLY NONFRIABLE ASBESTOS MATERIAL BECOMES CRUMBLED, PULVERIZED, OR REDUCED TO
POWDER.
XVI. I CERTIFY THAT AN INDIVIDUAL TRAINED IN THE PROVISIONS OF THE THIS REGULATION (40 CFR PART 61.
SUBPART M) WILL BE ON-SITE DURING THE DEMOLiTION OR RENOVATION AND EVIDENCE THAT THE RE
QUIRED TRAINING HAS BEEN ACCOMPLISHED BY THIS PERSON WILL BE AVAILABLE FOR INSPECTION
DURING NORMAL BUSINESS HOURS. (Required I year after promulgation)
XVII. I CERTIFY THAT THE ABOVE INFORMATION IS CORRECT.
(Signature of Owner Operator)
(date)
(Signature of wnaA)perator)
Notification of Demolition and Renovation
(date)
BILUNG CODE 6S60-3O.C
-------
5..
0
5...
C
1. Work site name and mailing address
Owner’s name
2. Operator’s name and address
Operator’s telephone no.
Owner’s telephone no.
4. Name, and address of responsible agency
3. Waste disposal site (WDS) name, mailing address, and physical site location
WDS phone no.
S. Dcsoription of materials
6. Containers
No.
Type
8. Special handling instructions and additional information
7. Total quantity
m 5 (yd )
Printed/typed name & title
9. OPERATOR’S CERTIFICATION: I hereby declare that the contents of this consignment arc fully and accurately described above
by proper shipping name and are classified, packed, marked, and labeled, and arc i t t all respects in proper condition for transport by
highway according to applicable international and government regulations .
Signature
Month Day Year
10. Transporter I (Acknowledgment of receipt of materials)
Printed/typed name & tide
Address and telephone no.
11. Transporter 2 (Acknowledgment of receipt of materials)
Printed/typed name & title
Address and telephone no.
Signature
Month Day Year
Signature
Month Day Year
12. Discrepancy indication space
a .
13. Waste disposal site owner or operator:
a Certification of receipt of asbestos materials covered by this manifest except as noted in item 12.
Printed/typed name & tide Signature Month Day Year
Continued on next page (page 1 of 3)
Waste Shipment Record
-------
INSTRUCTIONS
Waste Generator Section (items 1-9)
I. Enter the name of the facility at which asbestos waste is generated and the address where the
facility is located. In the appropriate spaces, also enter the name of the owner of the facility and the
owners phone number.
2. II a demolition or renovation, enter the name and address of the company and authorized agent
responsible for performing the asbestos removal. In the appropriate spaces, also enter the phone
number of the operator.
3. Enter the name, address, and physical site location of the waste disposal site (WDS) that will be
receiving the asbestos materials. In the appropriate spaces, also enter the phone number of the
WDS. Enter “on-site” if the waste will be disposed of on the generator ’s property.
4. Provide the name and address of the local, State, or EPA Regional office responsible for
administering the asbestos NES HAP program.
5. Indicate the types of asbestos waste materials generated. If from a demolition or renovation, indicate
the amount of asbestos that is
— Friable asbestos material
— Nonfriable asbestos material
6. Enter the number of containers used to transport the asbestos materials listed in item 5. Also enter
one of the following container codes used in transporting each type of asbestos material (specify any
other type of container used if not listed below):
• DM — Metal drums, barrels
DP — Plastic drums, ban ls
BA —6 mu plastic bags or wrapping
7. Enter the quantities of each type of asbestos material removed in units of cubic meters
(cubic yards).
8. Use this space to indicate special transportation, Lreaunent, storage or disposal or Bill of Lading
information. If an alternate waste disposal site is designated, note it here. Emergency response
telephone numbers or similar information may be included here.
9. The authorized agent of the waste generator must read and then sign and date this certification. The
daze is the date of receipt by transporter.
NOTE: The waste generator must retain a copy of this form.
Continued on next page (2 of 3)
Waste Shipment Record
B L1JNQ COOE 5 O-6oC
-------
Transi)orler Section (Items 10 & 11)
10. & 11. Enter name, address, and telephone number of each transporter used, if appLicable. Print or
type the full name and title of person accepting responsibility and acknowledge receipt of
materials as listed on this waste shipment record for u .nspcrt. Enter date of receipt and
sigT ature.
NOTE: The transporter must retain a copy of this form.
Dist,osal Site Section (Items 12 & 13)
12. The authorized repr senta1ive of the WDS must note in this space any discrepancy between waste
described on this manifest and waste actually received as well as any improperly enclosed or
contained waste. Any rejected materials should be listed and destination of those materials
provided. A site that converts asbestos-containing waste material to nonasbestos material is
considered a WDS.
13. The siEnature (by hand) of the authorized WDS agent indicates acceptance and agreement with
statements on this manifest except as noted in item 12. The date is the date of signature and receipt of
shipment.
NOTE: The WDS must retain a completed copy of this form. The WDS thust also send a completed copy to the
operator listed in item 2.
(Page3 of 3)
Waste Shipment Record
Bai G COOE e3co- .C
-------
15
-------
Section 15 Abbreviations and Acronyms
AA - Assistant Administrator
ACBM - Asbestos-Containing Building Materials
AHERA - Asbestos Hazard Emergency Response Act
APC - Asbestos Program Coordinator
APM - Asbestos Program Manager
ASHARA - Asbestos School Hazard Abatement Reauthorization Act
CEU - Continuing Education Unit
EPA - Environmental Protection Agency
EPAL - EPA Leased Facility
EPAO - EPA Owned and Managed Facility
GSA - General Services Administration
GSAL - EPA Facility Leased by GSA
GSAO - EPA Facility Owned and Managed by GSA
JAG - Inter-Agency Agreement
NIBS - National Institute of Building Sciences
O&M - Operations and Maintenance
OARM - Office of Administration and Resources Management
OSHA - Occupational Safety and Health Administration
PDSHEMO - Program Designated Safety, Health, and Environmental
Management Official
RA - Regional Administrator’•
RDSHEMO - Regional Designated Safety, Health, and Environmental
Management Official
SEE Program - Senior Environmental Employment Program
SHEMD - Safety, Health, and Environmental Management Division
SHEMP - Safety, Health, and Environmental Management Program
SM - Standard Method
SOP Standard Operating Practice
SS/SD - Small-Scale, Short Duration
TQM - Total Quality Management
TSI - Thermal System insulation
WCL - Workplace Control Level
kdm a:\epa sop\sop.518
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DISCLNMER
This document was developed by Gobbell Hays Partners, Inc. (GHP), under a subconsultant agreement with Booz, Men & Hamilton,
Inc. (BAH) with funding provided by the U.S. Environmental Protection Agency (EPA).
The U.S. EPA disclaims any and all responsibility for the contents of this document and assumes no liability associated therewith.
EPA makes no warranty, guarantee, or representation, expressed or Implied, with respect to the accuracy, effectiveness, or usefulness
of any information, methods, or materials contained herein or for damages arising from such use; nor assumes any responsibility
for any injury to IndMduals or property, or for any financial loss, sustained as a result of the use or application of the contents of
this document.
This document contains Information and advice based on expert opinion and review. However, the information is not a substitute
for professional advice regarding the use of this information in the in-place management of asbestos.containing building materials
In facilities; and the adherence to applicable law, guidance, regulations, practices, and procedures..
fri consideration of the permission given by GHP and BAH to use this document and In consideration for the value received through
the use of this document, the purchaser and/or user of this document and its heirs, representatives, and assignees, covenants not
to sue, waives and releases GHP and BAH from any and all claims, demands, and causes of action for any injury to individuals or
or property, and for any and all financial loss or economic damages sustained by or arising from the user’s and/or purchaser’s use
of or reliance on this document. Use of this document does not relieve the purchaser and/or user from complying with all applicable
laws and regulations.
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