U.S. ENVIRONMENTAL PROTECTION AGENCY POLICY AND PROGRAM FOR THE MANAGEMENT OF ASBESTOS-CONTAINING BUILDING MATERIALS AT EPA FACILITIES Office of Administration and Resources Management Safety, Health, and Environmental Management Division Washington, D.C. July, 1994 ------- U.S. ENVIRONMENTAL PROTECTION AGENCY SAFETY, HEALTH, AND ENVIRONMENTAL MANAGEMENT MANUAL CHAPTER 16 PROGRAM FOR THE MANAGEMENT OF ASBESTOS-CONTAINING BUILDING MATERIALS AT EPA FACILITIES Office of Administration and Resources Management Safety, Health, and Environmental Management Division Washington, D.C. July, 1994 ------- CONTENTS L Purpose 1 2. Background 2 3. Policy 3 3.£l Scope 5 3.b. Operational Flexibility 6 4. Program Components 6 4.a. Program Administration 6 4.a.l. Central Administration 8 4.a.2. Program Offices, Regional Offices, Laboratories, and Other Operating Units 8 4.a.3. Pollution Prevention Subcommittee of the Safety, Health, and Environmental Management Steering Committee 8 4.a.4. Budget and Resources 8 4.b. Program Elements 10 4.b.l. Building Inspection and Assessment 10 4.b.l.a. Material Types 10 4.b.l.b. Inspection 11 4.b.l.c. Assessment 11 4.b.2 Asbestos Safety Training 11 4.b.2.a. Asbestos Safety and Management Training Requirements 12 4.b.2.b. Asbestos Worker Safety Training Requirements .. 14 4.b.2.c. Asbestos Inspector Training Requirements 15 4.b.2.d. Course Attendance/Examination 16 4.b.2.e. Continuing Educational and Safety Training 16 4.b.2.f. Training Waivers 17 4.b.2.g. Training Records 17 4.b3. Asbestos Monitoring 17 4.b.3.a. Asbestos Exposure Control System and Rationale . 18 4.b.3.b. Workplace Control Level (WCL) 18 4.b.3.c. Environmental Monitoring 19 4.b.3.d. Personnel Monitoring 19 4.b.3.e. Medical Surveillance Program Participation for EPA Workers 19 4.b.3.f. Personal Monitoring for Other Workers 20 i ------- CONTENTS (Continued) 4.b.3.f. Personal Monitoring for Other Workers 20 4.b.3.g. Monitoring for Visitors/Guests 21 4.b3.h. Concurrent Occupational Exposure 21 4.b3.i. Respiratory Protection, Personal Protective Equipment, and Decontamination 21 4.b.3.j. Monitoring Records and Worker Notification .... 21 4.b.4. Medical Surveillance 22 4.b.4.a. Content of Medical Examination 22 4.b.4.b. Implementation of Medical Surveillance 22 4.b.4.c. Recordkeeping 24 4.b.5. Notification to Building Workers, Tenants and Other Occupants 24 4.b.6. Surveillance and Reinspection 26 4.b.6.a. Periodic Surveillance 26 4.b.6.b. Reinspection 26 4.b.7. Control System 27 4.b.8. Work Practices 27 4.b.8.a. Minor Fiber Release Episode 28 4.b.8.b. Major Fiber Release Episode 28 4.b.9 Communications, Outreach and Program Visibility 29 4.c. Specific Responsibilities 29 4.d. Program Evaluation and Quality Systems 33 5. Authority 33 6. References 35 7. Definitions 36 8. Abbreviations and Acronyms 45 ii ------- PROGRAM FOR THE MANAGEMENT OF ASBESTOS-CONTAINING BUILDING MATERIALS AT EPA FACILITIES 1. PURPOSE This directive sets forth the Environmental Protection Agency's policy for managing asbestos-containing building materials (ACBM) in Agency occupied or controlled buildings. This policy establishes an Agency-wide asbestos operations and maintenance management program, elaborates an organizational structure under which the program is operated, and characterizes the management functions associated with each element of the organization. The national safety, health, and environmental management program has as its focus the development, implementation and on-going management of consistent ACBM Operations and Maintenance (O&M) Plans for each EPA facility where ACBM are known or assumed to be present. The polity and program (hereinafter the "Program") have been developed with the goal of minimizing ambient asbestos fiber levels, economic, social, technical, and environmental factors being taken into account. The Program's objectives include compliance with applicable Executive Orders, federal, state, and local environmental governmental laws, standards, and guidelines; incorporation of appropriate elements of nationally recognized consensus standards; and effective use of the wide range of both internal and external resources and expertise available to EPA. Standard Operating Practices (SOPs), maintained under this Program in other documents, establish guidance for the general approaches and work practices which are implemented at the operations level to effectuate the various requirements of the Program in EPA occupied or controlled buildings. 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 exposure to asbestos. An operating principle of the Program is to demonstrate continuous and measurable improvement in its management and operations, using Total Quality Management (TQM) processes. 1 ------- 2. BACKGROUND The President, by Executive Order, has directed that all Federal agencies establish safety, health and environmental management programs. The EPA's omnibus Safety, Health, and Environmental Management Program (SHEMP) Order, mandates the establishment of internal Agency policies, programs and standards which address both general and specific occupational safety and health and environmental matters. This Program, and its associated SOPs and SMs, addresses various aspects of EPA workers' protection from the job-related hazards of asbestos in accordance with the omnibus SHEMP Order. Emphasizing the importance and effectiveness of an internal Agency-wide management program for ACBM is a critical element of the Agency's broader efforts to mitigate the hazards and risks of asbestos exposure in the workplace. 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. In general, as with cigarette smoking and the inhalation of tobacco smoke, the more asbestos fibers a person inhales, the greater the risk of developing an asbestos-related disease. Most of the cases of severe health problems resulting from asbestos exposure have been experienced by workers who held jobs in industries such as shipbuilding, mining, milling, and fabricating, where they were exposed to very high levels of asbestos in the air, without the benefit of worker protection now afforded by law. Many of these same workers were/are also smokers. These persons worked directly with asbestos materials on a regular basis and, generally, for long periods of time as part of their jobs. Additionally, there is an increasing concern for the health and safety of construction, renovation, and building maintenance workers, because of possible periodic exposure to elevated levels of asbestos fibers while performing their jobs. Whenever the risk posed by asbestos is discussed, it must be 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 intentionally disturb the ACBM in the performance of maintenance activities. For these workers in particular, a complete and effective management program (commonly referred to 2 ------- as an "O&M Plan") can greatly reduce asbestos exposure. This kind of management program can also minimize asbestos exposures for other building occupants as well. 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. Asbestos became a popular commercial product because it is strong, will not burn, resists corrosion, and insulates well. In the United States, its commercial use began in the early 1900's and peaked in the period from World War II into the 1970's. Under the Clean Air Act of 1970 the EPA has been regulating many asbestos-containing materials which, by EPA definition, are materials with more than one percent (>1%) asbestos. The Occupational Safety and Health Administration's (OSHA) asbestos construction standard (29 CFR 1926.58) in section K, "Communication of hazards to employees," specifies labeling many materials containing 0.1% or more asbestos. In the mid-1970's several major kinds of asbestos materials, such as spray-applied insulation, fireproofing, and acoustical surfacing material, were banned by the EPA because of growing concern about health effects, particularly cancer, associated with exposures to such materials. Intact and undisturbed asbestos-containing building materials do not pose a health risk. The mere presence of asbestos in a building does not mean that the health of building occupants is endangered. 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. 3 ------- 3. POLICY It is the policy of EPA to provide a safe and healthful workplace free from recognized, significant risks of serious injury or death associated with exposure to asbestos fibers. It is also Agency policy to limit its workers' indoor exposure to airborne asbestos fibers to levels at or below the Workplace Control Level of 70 s/mm2 as stipulated herein. This applies to EPA workers - as building occupants - in Agency occupied or controlled facilities. This policy shall be effectuated through an Agency-wide asbestos management program administered by the Safety, Health, and Environmental Management Division, Office of Administration. Building owners and/or designated Agency personnel [Asbestos Program Managers or Coordinators, (APM or APC)], shall oversee the implementation and on-going management of consistent SOPs and SMs. Together these comprise the local ACBM Operations and Maintenance (O&M) Plan required for each EPA occupied or controlled facility where ACBM are known or assumed to be present. This polity requires the Agency and Agency workers to be in compliance with applicable Executive Orders; federal, state, and local health, safety, and environmental laws, standards, rules, and regulations. The Agency shall maintain a Program which establishes the organizational structure, managerial functions, technical framework, monitoring system, training requirements, and other elements through which this policy is effected. Standard Operating Practices promulgated under this directive establish general guidance for approaches and work practices and Standard Methods provide guidance for specific procedures and techniques. Facility-specific O&M Plans shall detail the training and work practices which are intended to ensure that: (1) asbestos-containing building materials are maintained in good condition, (2) accidental or uncontrolled releases of asbestos fibers are prevented, or, (3) in the event of accidents, asbestos fibers are properly cleaned up, and (4) the condition of asbestos-containing building materials in Agency workplaces is periodically monitored. New building materials, furnishings, fixtures, and equipment for construction, renovation, and restoration of EPA occupied or controlled facilities shall be free of asbestos-containing materials. Existing surfacing, Thermal System Insulation (TSI), and miscellaneous ACBM which is significantly damaged shall be removed. Any remaining or damaged ACBM shall be placed under a properly implemented and managed O&M Plan. EPA shall acquire no space with ACBM through purchase, exchange, or transfer. When evaluating space(s) offered for lease, rank ACM as follows: first choice if space has no asbestos or asbestos only bound in a solid matrix; second choice if space has asbestos in thermal system insulation. For either choice, asbestos must not be damaged or subject to disturbance by routine operations, and the lessor must implement an asbestos operations and maintenance program conforming to 4 ------- EPA's Policy and Program requirements, and consistent with associated EPA guidance documents. 3.a. SCOPE. The provisions of this policy apply to all EPA activities and EPA worker(s) at EPA occupied or controlled facilities, both foreign and domestic. The term "worker(s)" includes full-time, part-time, temporary, and permanent EPA employee(s); a federal, state, or local government employee(s) assigned or detailed to the EPA; an enrollee(s) in the EPA's Senior Environmental Employment (SEE) Program; a student(s) assigned to the EPA; an EPA stay-in-school program participant(s); an intern(s) or fellow(s) assigned to the EPA; and others who are designated on a case-by- case basis by the Director, SHEMD. Although this policy does not apply directly to EPA contractors, the APM's and/or APCs (through Contracting Officers) shall assure that the specifics of this policy for O&M Plans are included in contract requirements for new construction, renovation, demolition, maintenance/repairs, and rental or leasing of Agency workplaces. However, the employees or agents of such agencies, when performing work at EPA occupied or controlled facilities, are required to comply with this policy, and other applicable sections of the Program. If a non-EPA worker's employer or agency has an occupational exposure control system in conflict with EPA's, then the most protective values shall apply, insofar as these workers or agents are concerned. Contractors, grantees, and organizations with which EPA has agreements, must comply with applicable federal, state, and local environmental laws and standards pertaining to exposure to asbestos fiber concentrations. Among other requirements are those mandated by the U.S. Environmental Protection Agency, the Occupational Safety and Health Administration, and the Department of Transportation. EPA contractors, grantees, and signatories to agreements with the EPA may be affected by the requirements of this Program. Specifically, requirements for personnel exposure monitoring, and emergency plans and procedures as described in this Program may impact upon EPA contractors, grantees, and signatories to agreements with the EPA when performing work at EPA occupied or controlled facilities, or at other locations on behalf of the EPA The employees of contractors, grantees, and other organizations having agreements with EPA are specifically excluded from enrollment in this Program, except as provided in the previous paragraphs of this section. 3.b. OPERATIONAL FLEXIBILITY. The provisions for worker safety and health established by this policy may be augmented or supplemented by local EPA managers, but they cannot be deleted, replaced, or superseded, except as stipulated in this Directive. This clause is intended to provide for 5 ------- a degree of flexibility at the operational level in unique or special non- routine situations, without compromising or diminishing the level of worker protection afforded by this policy. 4. PROGRAM COMPONENTS 4.a. PROGRAM ADMINISTRATION The Program 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. This Program 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". The standard operating practices (SOPs) are premised upon the users having a copy of the Green Book and being familiar with its content. Users are also expected to have copies of applicable federal, and specific state, and local health, safety, and environmental standards, and are expected to be familiar with their requirements. The administrative objectives set forth by this Program are to: limit EPA workers' exposure to asbestos fiber levels to below the workplace control level with economic, technical, and environmental factors being taken into account; • work within the EPA organizational framework and in accordance with other EPA administrative directives and guidance; define and delegate clear lines of authority and assign responsibility; ensure compliance with applicable federal, state, and local environmental laws and standards, and Executive Orders; • incorporate appropriate elements of nationally recognized consensus standards and guidance documents; • maximize the contribution and participation of administrative, management, and technical personnel at all operating levels within the Agency, and to effectively use the national expertise and resources available to EPA; demonstrate continuous and measurable improvement in the management and operations of the Program, using Total Quality Management (TQM) methods; 6 ------- collaborate with other federal, state, and local environmental governmental agencies, through EPA's Outreach program to share information and resources, and to promote the transfer of relevant innovative technologies; and export appropriate information and technologies to the private sector and to the international community, where warranted. 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. The arrangements addressed by this Program 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 (IAG). Where applicable, reference is made to the Program designation noted above for each lease/own arrangement. The Program outlines how SOPs are organized and how they are to be applied under each type of lease/ownership arrangement A successful asbestos management program requires the cooperation and participation of all occupants of the facility. Employees performing asbestos O&M work must follow the SOPs included in this Program to achieve the objectives listed below. The objectives of the SOPs set forth in this Program are to: • protect human health and the environment; maintain ACBM in good condition and minimize the release of asbestos fibers by controlling activities which may disturb ACBM; • minimize airborne asbestos exposure for building occupants, maintenance/custodial workers and the public; establish procedures for controlling and containing ACBM which have been disturbed or have released fibers and dust or debris; establish administrative procedures and work practices to achieve the objectives of the program; and 7 ------- • monitor ACBM through periodic visual surveillance. The Program and SOPs are to be applied to new facilities to be occupied by the EPA and shall be made a part of any 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 Program and utilized to provide consistency in documentation. Applicable forms are included in the appendices. This Program utilizes asbestos-related standard methods developed by the National Institute of Building Sciences (NIBS) in the NIBS document entitled "Guidance Manual, Asbestos Operations and Maintenance Work Practices". 4.a.l. Central Administration. The overall national Program is administered and managed by the Safety, Health, and Environmental Management Division (SHEMD), Office of Administration (OA), Office of Administration and Resources Management (OARM), in collaboration with the Chemical Management Division - Office of Pollution Prevention and Toxics, Office of Prevention, Pesticides and Toxic Substances. 4.a.2. Program Offices. Regional Offices. Laboratories, and Other Operating Units. Senior Safety, Health, and Environmental Management officials [such as the Regional Designated Safety, Health, and Environmental Management Official (RDSHEMO) and Program Designated Safety, Health, and Environmental Management Official (PDSHEMO)] are responsible for the implementation and on-going management of the Program within their operating units. At the local level (at each EPA occupied or controlled facility), the provisions of this directive are to be met by delegating the authority and assigning responsibility for the management of Program operations to an Asbestos Program Manager (APM) and/or Asbestos Program Coordinator (APC). 4.a3. Pollution Prevention Subcommittee of the Safety. Health, and Environmental Management Steering Committee. The Subcommittee is responsible for making policy, Program, and resource-related recommendations to the Chair of the Steering Committee, and for presenting an Annual Report on the effectiveness and status of the Program. Subcommittee members, in addition to representation from SHEMD, are drawn from the ranks of senior and mid-level managers Agency-wide, and are appointed by, and report to, the Chair of the Agency's Safety, Health, and Environmental Management Steering Committee. Ex-officio 8 ------- appointments to the Subcommittee may be made by the Steering Committee Chair, at his/her discretion. 4.a.4. Budget and Resources. (Note: Further information relating to funding responsibilities is provided under Section 4.c. "SPECIFIC RESPONSIBILITIES"). OARM shall allocate sufficient resources required for the central administration and management of the Program. OARM shall manage the resources which are used to conduct central Program operations in direct support of program office, regional, or laboratory needs. Central Program operations administered and offered out of Headquarters may include, but are not limited to: providing routine and emergency medical and health consultative services and related training services; developing, updating, and distributing core components of basic and advanced asbestos safety training; maintaining a computer based Operations and Maintenance (O&M) Guidance Manual for Work Practices accessible to designated users (produced and maintained in collaboration with the National Institute of Building Sciences, through a Memorandum of Understanding); enabling access to specialized professional and technical support, not locally available, via contracts accessible through OA/SHEMD; and overseeing quality assurance functions. Assistant Administrators (AAs), Regional Administrators (RAs), Laboratory Directors, and directors and managers of other operating units are responsible for ensuring that adequate funds are allocated, and appropriate human and other resources are provided within their organizations to implement and maintain the Asbestos Management Program for their workers. Local resource requirements for program offices, regions, laboratories, and other operating units may include, but are not limited to, those needed for: management, supervision, and technical support; local operations required for specialized external and internal monitoring services; 9 ------- • acquisition and maintenance of computer hardware and software, and other equipment, products and services required to support or to interface with Headquarters; development of local additions or enhancements to asbestos safety training programs; implementation of TQM initiatives, as well as performance of local quality assurance/quality control (QA/QC) activities; and • ensuring availability of qualified asbestos protection workers responsible for overseeing that the provisions of this Program, and associated SOPs and SMs, are carried out at every work site where enrolled workers are assigned. When special technical assistance is required at the local operating level, and the necessary expertise is not locally available, support may be provided through the National Technical Assistance Contract (NTAC), or other vehicles, operated by SHEMD. PROGRAM ELEMENTS 4.b.l. Building Inspection and Assessment: To determine if an asbestos management program shall be implemented, the building owner shall conduct (or shall have conducted) an initial building inspection and survey to locate and assess the condition of all ACBM in the building. Only a trained, experienced and qualified inspector, certified under the Asbestos Hazard Emergency Response Act (AHERA), as required by the Asbestos School Hazard Abatement Reauthorization Act (ASHARA), shall perform the sampling of suspect ACBM for laboratory analysis. If an inspection and assessment of the building is not performed in accordance with SOPs and SMs maintained under separate documents of this Program, then certain suspect materials must be assumed to contain asbestos, and treated accordingly under the control and management program of the O&M Plan. The building inspection serves as the basis for establishing an effective overall plan for controlling and managing the asbestos in the building. 4.b.l.a. Material Types. An effective O&M program shall address all types of ACBM present in a building. ACBM that may be managed as part of an O&M program are classified as follows: 10 ------- 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 (TSI): Examples include ACBM applied to pipes, boilers, tanks, and ducts to prevent heat loss or gain, or condensation. Miscellaneous ACM* Examples include asbestos-containing ceiling or floor tiles, textiles, and other components such as asbestos- cement panels, asbestos siding and roofing materials. 4.b.l.b. Inspection. 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 inspector. Each person performing an inspection shall: visually inspect the area to identify the locations of all suspected ACBM; • touch all suspected ACBM to determine whether they are friable; • identify all homogeneous areas of friable suspected ACBM and all homogeneous areas of nonfriable suspected ACBM; and assume that some or all of the homogeneous areas are ACBM, and, for each homogeneous area that is not assumed to be ACBM, collect and submit for analysis bulk samples. 4.b.l.c. Assessment For each inspection, the accredited or certified inspector shall provide a written assessment of all friable known or assumed ACBM present in the building. The inspector shall classify and give reasons for classifying the ACBM and suspected ACBM into one of seven defined categories, as described by the SOP document provided under this Program. 11 ------- 4.b.2. Asbestos Safety Training. Adequate asbestos safety training of workers who may be required to enter work areas where there is the potential for exposure to asbestos fiber concentrations above normal background levels is principle to the Program. Workers 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 workers' 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. All core training material created for the asbestos management Program will be developed and provided by SHEMD in consultation with representative operating units. Regions, laboratories, and other operating units are encouraged to supplement the core training material with information designed to fulfill locally identified special training needs. 4.b.2.a. Asbestos Safety and Management Training Requirements. Asbestos safety and management training shall be provided to each facility's designated Asbestos Program Manager (APM) and Asbestos Program Coordinator (APC). Asbestos safety training shall be designed to provide EPA Headquarters, regional, laboratory and field workers with a knowledge base which includes, at a minimum: an overview of the EPA Program for the Management of Asbestos-Containing Building Materials at EPA Facilities; • a fundamental understanding of asbestos; a fundamental understanding of the health effects of asbestos exposure; basic concepts of asbestos protection, including management and design of response actions; an understanding of the contents of the National Institute of Building Sciences' (NIBS) Guidance Manual for Asbestos Operations and Maintenance Work Practices, dated September, 1992; and 12 ------- familiarity with the program elements and operation of EPA's National Asbestos Management Program. The asbestos safety training program shall be designed for workers with little or no prior knowledge of asbestos effects and asbestos safety principles. The APM shall attend the following two courses to fulfill the asbestos safety and management training described above: 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. Regardless of formal title or job descriptions, any EPA worker or persons employed by an outside contractor or agency who supervises any of the following activities must have taken and successfully completed the contractor/ supervisor training course: a small scale short duration (SSSD) response action activity; a maintenance activity that disturbs, or has the potential to disturb, known, assumed or suspected ACBM; and/or a response action for a minor or major fiber release. Asbestos abatement supervisors include those persons (APM's and APC's) who provide supervision and direction to workers performing response actions, and may include those individuals with the position title of foreman, working foreman, or leadman. At lease one supervisor (who is employed by and a representative of the contractor performing the abatement work) is required to be at the worksite at all times while response actions are being conducted. Asbestos workers must have 13 ------- access to accredited supervisors throughout the duration of the project. Completion of AHERA 5-day Contractor/ Supervisor Course fulfills the above training requirements. Project Designer: a 3-day training course that includes lectures, demonstrations, a field trip, course review and a written examination. Any EPA worker 01 persons employed by an outside contractor, or consultant, or agency who designs any of the following activities must have taken and successfully completed the project designer course: a small scale short duration (SSSD) response action activity; a maintenance activity that disturbs, or has the potential to disturb, known, assumed or suspected ACBM; and/or a response action for a minor or major fiber release. Completion of the AHERA 3-day project designer course fulfills the above training requirements. Annual refresher courses are required for all APM's. The APC shall attend the contractor/supervisor course as described above for the position of APM to fulfill the asbestos safety and management training. 4.b.2.b. Asbestos Worker Safety Training Requirements. Asbestos worker safety training is required for the following categories of workers: • EPA workers who routinely engage in, or expect to routinely engage in, assigned work where the potential for disturbing ACBM at EPA occupied or controlled facilities is likely; and 14 ------- EPA workers who are assigned to engage in emergency response activities where the potential for disturbing asbestos-containing materials at EPA occupied or controlled facilities is likely. The training objectives of asbestos worker safety training are to: (1) familiarize workers with EPA- accepted procedures and techniques for controlling and managing disturbances of asbestos; (2) educate workers regarding the criteria for securing expert asbestos safety or health consultation; and (3) teach workers to adopt work practices and supervisory techniques for ensuring that worker exposure is as low as reasonably technically and economically achievable. "Hands-on" familiarization with equipment and materials is included. Emphasis is to be placed on encouraging workers to request expert assistance in response to situations or facility conditions where asbestos exposure risks are uncertain, or where asbestos fiber concentrations exceed thresholds specified in the Standard Operating Practices. This course may be offered at EPA Headquarters, regional offices, laboratories, or at select work sites. Asbestos workers shall attend the following course to fulfill the asbestos worker safety training described above: 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. (NOTE: A person who has attended courses and become accredited or certified as a contractor/supervisor may perform in the role of an asbestos worker without possessing a separate accreditation or certification as a worker.) Completion of the AHERA 4-day worker training course fulfills the above training requirements. 15 ------- 4.b.2.c. Asbestos Inspector Training Requirements. Asbestos inspector training is required for the following categories of workers: • those who routinely engage in, or expect to routinely engage in, work assignments to visually inspect or collect bulk samples from a building to determine the presence of asbestos; those who engage in emergency response activities to visually inspect or collect bulk samples from a building to determine the presence of asbestos; and • immediate supervisors of workers who engage in routine and/or emergency inspection work assignments. The training program shall be designed for persons with little or no prior knowledge of asbestos effects and asbestos safety principles, and to familiarize workers with EPA-accepted procedures for conducting asbestos inspection and surveys. Asbestos inspectors shall attend the following course to fulfill the asbestos inspector training described above: • 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. Completion of the AHERA 3-day inspector training course fulfills the above training requirements. 4.b.2.d. Course Attendance/Examination. Each Program participant attending a required EPA asbestos training course will receive a certificate of attendance. A passing grade of 70% on the examination is required. The purpose of these courses is to objectively gauge the participants' comprehension and knowledge of the subject matter, including an understanding of EPA's asbestos safety, health, and environmental protection 16 ------- policy and Program administrative, managerial, and operational requirements. The courses are also intended to help ensure that workers are equipped with sufficient information which, when coupled with the exercise of good judgement, skills, and work practices, can enable the safe accomplishment of certain general types of asbestos-related work assignments. 4.b.2.e. Continuing Education and Safety Training. In addition to successfully completing the specified training and refresher training, continuing professional development courses shall be completed periodically. In general, the completion of one continuing education course per year related to asbestos, for which a nationally recognized accrediting body awards Continuing Education Units (CEUs), is sufficient to meet this requirement. 4.b.2.f. Training Waivers. Workers who are required to have asbestos safety training shall nol be granted a waiver and must successfully complete the required training course(s). 4.b.2.g. Training Records. The satisfactory completion of initial and annual refresher training courses must be documented. A written record of the specific training course completed, date of completion, and the names of workers who have fulfilled the training requirements shall be maintained. Passage of an examination is required. The responsibility for ensuring that safety training requirements are fulfilled by EPA workers within the proper time frame lies with their supervisors. Supervisors are expected to work in cooperation with the facility APM or APC. Responsibility for ensuring that safety learning materials and training resources are available rests with the local SHEMP Manager. 4.b.3. Asbestos Monitoring. The primary goal of EPA's asbestos 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 assimilating information derived from personnel and environmental exposure data, which can be used by managers and workers in order to maintain exposures within Program levels. Information regarding the trends of asbestos exposures received by workers, environmental conditions in workplaces, and exposure risks associated with 17 ------- particular operating practices and/or work sites shall be used to ensure that Program objectives are met. Other analyses of monitoring data may be performed to identify opportunities for improving operating practices and methods, and enhancing overall Program quality. Although conducting certain tests and measurements is an integral part of any safety program, a state-of-the-art monitoring system involves more than just measurement: it must also involve competent data interpretation, a uniform system of record-keeping and notification, and a mechanism that will enable continuous improvement in the management and operation of the program. In the case of a suspected significant exposure to a worker due to an asbestos fiber release occurrence, additional and/or special monitoring may be needed. The results may provide information which can be used to minimize workers' health risks, and to prevent similar worker and/or environmental exposure occurrences in the future. 4.b.3.a. Asbestos Exposure Control Systems and Control System Rationale. The Program's exposure control system is based on two principles: (1) justification - there shall not be any significant risk of exposure to airborne concentrations of asbestos fibers above the Workplace Control Level for occupants of buildings under the jurisdiction of this Program without the expectation of an overall benefit from the activity causing the exposure; and (2) limitation - exposure to asbestos fibers as a result of routine and/or emergency occupational activities shall not exceed the lowest of: (a) levels established under this Program; (b) levels which apply to the control of an exposure that are established by other federal, state, or local regulatory agencies, or (c) any applicable current or future protection guides for workers established by the President, or approved as federal guidance. Any asbestos exposure levels applicable to EPA workplaces under Executive Order, or under federal, state, or local safety and health or environmental law(s) or standard(s) are incorporated herein and made a part of this Program. In the event that a conflict exists, the most protective level shall apply. The principles cited above are to be incorporated into all aspects of Program management and operations by EPA managers and workers. Special attention shall be given to incorporating them into administrative 18 ------- controls, work practices, education and training programs, engineering controls, the criteria for selection of asbestos safety-related personal protective equipment, and the criteria for selection of technologies to be applied for environmental management 4.b.3.b. Workplace Control Level (WCL). The Workplace Control Level for asbestos fibers is seventy structures per square millimeter (70 s/mm2), as determined by transmission electron microscopy (TEM). The analytical methodology shall be that established under the Asbestos Hazard Emergency Response Act. EPA occupied or controlled facilities under the jurisdiction of this Program are required to limit indoor levels of airborne asbestos fibers to at, or below, the Workplace Control Level, unless ambient outdoor levels are normally higher. In the unlikely event that normal outdoor levels are higher than 70 s/mm2, the indoor level is expected to be maintained below the normal outdoor level. 4.b.3.c. Environmental Monitoring. Environmental monitoring is required to establish workplace conditions during various types of activities and conditions. The requirements for environmental monitoring are detailed in the SOPs and SMs associated with this Program. Among other purposes, such monitoring is used to ensure that indoor air levels of asbestos fibers are monitored at or below the Workplace Control Level. Environmental monitoring is typically conducted using air pumps and sampling devices placed at various locations within a building, and analyzed in accordance with established methods by nationally accredited laboratories. 4.b.3.d. Personnel Monitoring. Personnel monitoring means determining individual workers' exposure(s) to asbestos fibers. Information derived from STET monitoring is used for minimizing the exposure of asbestos within the breathing zone of workers; and for minimizing the collective exposure of workers. This approach limits the 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 19 ------- worker's person in their breathing zone. Collected data is used for calculating estimated exposures. Management's decision to include a worker in breathing zone or other monitoring is to be principally based upon its judgement that the worker may be occupationally exposed, either routinely or during emergency responses, to asbestos fiber levels above normal background. The decision to include a worker shall be guided by the individual worker's specific working conditions, job duties, and other factors. 4.b3.e. Medical Surveillance Program Participation for EPA Workers. The Program requires that a written respiratory protection program be developed and implemented prior to workers performing: a small-scale, short duration (SS/SD) response action activity; a maintenance activity that disturbs, or has the potential to disturb, known, assumed, or suspected ACBM; and/or a response action for a minor or major fiber release. An element of the respiratory protection program is medical surveillance for workers required to wear respirators. Medical records for each worker subject to the medical surveillance program must be retained by the APM and/or SHEMP Manager for the duration of the worker's employment plus thirty (30) years. 4.b.3.f. Personal Monitoring for Other Workers. Workers, including contractors, who are not participating in this Program and who work at EPA occupied or controlled facilities, or who perform work on behalf of EPA at other locations where there is potential for significant exposure to asbestos fiber levels above normal background, are required to be appropriately monitored for asbestos exposure by their employer and participate in a medical surveillance program. 20 ------- Contract workers whose performance is not in accordance with EPA's requirements or nationally recognized and accepted consumer standards, and/or who are not appropriately monitored for asbestos exposure by their employer to EPA's satisfaction, may be ordered to stop performing work on EPA's behalf, at EPA occupied or controlled facilities. EPA reserves the right to make these determinations, and to take appropriate actions based upon determinations made during its monitoring of contractor performance, under the terms and conditions of the contract. EPA procurement officials shall ensure that appropriate language is included in contracts, grants, and agreements which mandates that organizations which are signatories to agreements with EPA provide asbestos safety and health protection programs for their workers. Such programs must fully comply with all applicable federal, state, and local environmental laws and standards pertaining to safety and health protection; conform to nationally recognized consensus standards; and meet accepted standards of care. 4.b.3.g. Monitoring for Visitors/Guests. In instances when visitors or guests may be at risk of significant exposure to asbestos fiber levels above normal background, EPA may elect to require the visitor or guest to wear respiratory protection and/or otherwise be monitored for potential exposure, while they visit specified work areas. Visitors and guests who are candidates for monitoring must be informed of the hazards prior to entering the work area, and be provided with an appropriate orientation. Visitors and guests the EPA elects to monitor for potential exposure are also required to read and sign an informed consent form, which reflects their comprehension of the risks and their consent to assume the associated risks, before entering the work area. This consent to assume the associated risks does not constitute a waiver of an individual's statutory rights or entitlement, such as those conferred under workers' compensation laws. The completed visitor or guest consent form must bear original signatures, and indicate the visitor/guest current full name, address, telephone number, age, birthdate, and social security number (or other unique identifier, such as a passport number in the case of foreign visitors). For adults, the signed form will be kept on file by the local APM and/or SHEMP Manager for a period of not less than three years, or 21 ------- in the case of minors, maintained for a period which extends through the third year following the eighteenth birthday of the minor. If appropriate, they will be counselled by the local SHEMP Manager, in collaboration with the local APM. Visitors/guests can include EPA employees. Such employees may occasionally have need to visit areas to perform work activities not related to the operations routinely conducted in the area. 4.b.3.h. Concurrent Occupational Exposure. In the event that a worker participating in EPA's monitoring program concurrently incurs occupational exposure arising from work for another employer or activity outside the EPA, it is incumbent upon that worker to report his/her non-EPA exposure(s) to the local EPA SHEMP Manager and/or APM. 4.b.3.i. Respiratory Protection, Personal Protective Equipment, and Decontamination. Guidance regarding respiratory protection, personal protective equipment, and decontamination procedures are provided in separate Standard Operating Practices and Standard Methods documents maintained under this Program. 4.b.3.j. Monitoring Records and Worker Notification. Asbestos monitoring data, both environmental and personnel, shall be permanently archived on the Asbestos Safety Information Management System (ABSIMS) at EPA Headquarters. Data maintained on this system will be directly accessible by respective authorized SHEMP managers, APMs, APCs, and/or their designees. Workers shall be notified in writing of their exposure data periodically, even in cases where there is no detectable exposure above normal background levels. However, in the event that a worker's exposure exceeds the OSHA action level of 0.1 fibers per cc, or in the event environmental levels of asbestos in indoor air exceed 70 s/mm2, workers and/or occupants shall be notified by the SHEMP manager on an immediate basis. Monitoring and dosimetry records for personnel shall be maintained in a manner consistent with that of other confidential records, and in accordance with Privacy Act restrictions. Monitoring and dosimetry records for personnel shall be maintained by the Agency for a period of not less than 30 years following a worker's 22 ------- separation from the Agency. Environmental monitoring data, not considered personnel monitoring data, shall be maintained for not less than 70 years. Information and data maintained in ABSIMS is considered to be administrative, and not medical, in nature. 4.b.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. 4.b.4.a. Content of Medical Examination. 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. 4.b.4.b. Implementation of Medical Surveillance. A medical surveillance program shall be implemented for: EPA workers required to wear a negative pressure respirator; • EPA workers falling under OSHA construction industry standards exposed at or above the action level of 0.1 fibers per cubic centimeter on an 8-hour time-weighted average (TWA) for 30 days per year; and • other EPA workers where workers are likely to be exposed to airborne asbestos at concentrations at or above 0.1 fibers per cubic centimeter for one or more days per year. All medical exams and procedures must be performed by or under supervision of a licensed physician without charge to the employee, and at a reasonable time and place. If someone other than a physician performs a pulmonary function test, that person must have training in spirometry from an appropriate academic or professional institution. If X-rays are taken they must be interpreted by a radiologist or a physician proficient in X-ray interpretation, preferably a "B" reader. 23 ------- If available from a worker, or from worker's previous employer(s), collect and maintain in worker's file, information from previous occupational medical records. The physician shall not reveal in its written opinion to the worker any other specific findings or diagnoses unrelated to occupational exposure to asbestos. Written opinions shall include the following: results of medical examination as they relate to fitness for duty; physician's opinion if worker has a medical condition that would increase risk of health impairment due to exposure; • recommended limitations on worker or worker's use of protective equipment; and statement that worker has been informed by physician of the results of the medical exam and any conditions that might result from exposure. Medical examination shall be provided to each worker by the employer, at no cost to the worker, as follows: Pre-placement Before negative-pressure respirators are assigned. Within 10 days of the 30th day of exposure at or above the OSHA action level of 0.1 fibers/cc. No initial exam required if a worker has had an equivalent exam within the past year. • Annually Periodic examinations are required at least annually, and as the examining physician deems appropriate. 24 ------- 4.b.4.c. Recordkeeping • Medical records shall be maintained by EPA for the duration of the worker's employment plus thirty (30) years. Records shall be kept confidential, (separate from workers files) by the APM and/or SHEMP Manager. Medical records must be available upon request of the worker, the worker's representative or Secretary of OSHA. Workers must be notified of their rights under the OSHA Access to Records provision at least annually. 4.b.5. Notification to Building Workers. Tenants and Other Occupants. Workers, occupants, and tenants shall be informed about the location and physical condition of the ACBM that they might disturb, and the need to avoid disturbing the material shall be stressed. When EPA owns the building, the notification shall be distributed through its APM. When EPA is a tenant, notifications may come through GSA, and its designated APC, or in certain instances, EPA may be notified directly through its APC. All building occupants shall be notified for two reasons: Building occupants shall be informed of any potential hazard in their vicinity; and Informed persons are less likely to unknowingly disturb the material and cause fibers to be released into the air. Building owners shall inform occupants about the presence of ACBM by distributing written notices, and/or by posting signs or labels in central locations where affected occupants can see them. Holding awareness or information sessions can be especially beneficial. The methods used may depend on the type and location of the ACBM, and on the number of people affected. Some states and localities have "right-to- know" laws which may require that all workers and visitors in buildings with ACBM be informed that asbestos is present. In service and maintenance areas (such as boiler rooms, telephone/electrical closets, tunnels/crawlspaces, etc.), signs 25 ------- such as "Caution - Asbestos - Do Not Disturb" shall be placed directly adjacent to thermal system insulation ACBM to alert and remind maintenance workers not to inadvertently disturb the ACBM. The specific information given to building workers, tenants and other occupants can vary. For example, since service workers carry out certain tasks that office workers or tenants do not perform, they shall receive additional information. Most important, O&M workers shall receive the training necessary for them to perform their tasks safely. Information given to building occupants and workers shall contain the following points to the extent they reflect building conditions: ACBM have been found in the building and are located in areas where the material could be disturbed. The condition of the ACBM, and the response which is appropriate for that condition. Asbestos only presents a health hazard when fibers become airborne and are inhaled. The mere presence of ACBM does not represent a health hazard. The location(s) of the ACBM (e.g., ceilings in Rooms 101 and G-323, walls in the lobby, above suspended ceilings in the first floor corridor, on columns in the main entry, on pipes in the boiler room). Do not disturb the ACBM (e.g., do not push furniture against the ACBM, do not damage TSI). Report any evidence of disturbance or damage of ACBM to the Building Asbestos Program Manager, or Asbestos Program Coordinator. Report any dust or debris that might come from the ACBM or suspect ACBM, any change in the condition of the ACBM, or any improper action (relative to ACBM) of building workers to the building Asbestos Program Manager, or Asbestos Program Coordinator. Cleaning and maintenance workers are taking special precautions during their work to properly clean up any asbestos debris and to guard against disturbing ACBM. 26 ------- All ACBM are inspected periodically and additional measures will be taken if needed to protect the health of building occupants. 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. 4.b.6.a. 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; visually inspect all areas of known or suspected ACBM; record the date(s) of the surveillance and changes in the condition of the ACBM, if any changes have occurred since the last surveillance inspection; and submit the surveillance report to the APM for recordkeeping and review by the APC, if requested by the APC. 4.b.6.b. 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; visually reinspect, and reassess, the condition of all friable known or assumed ACBM; visually inspect material that was previously considered nonfriable ACBM and touch the material to determine whether it has become friable since the last inspection or reinspection; 27 ------- identify any homogeneous areas with material that has become friable since the last inspection or reinspection; collect and submit for analysis bulk samples for each homogeneous area of newly friable material that is already assumed to be ACBM; assess the condition of the newly friable material in areas where samples are collected, and newly friable materials in areas that are assumed to be ACBM; and record the following and submit to the building APM a copy of such record within 30 days of the reinspection: the date of the reinspection, and any changes in the condition of the ACBM; the exact locations where samples were collected during the reinspection, and a description of the manner used to determine sampling locations; and any assessments or reassessments made of friable material. 4.b.7. Control System. The building owner shall include in its 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. 4.b.8. Work Practices. Under the SOP and SM documents included under this Program, a work practice system is provided for administration and operation of work practices to control any disturbance of ACBM. The APM responsible for a facility, work site, activity or operation, in which the potential for a serious occurrence or exposure exists, must evaluate the likelihood of such incidents and must establish written strategies, plans and procedures necessary for managing them. In the event of an accident, contamination/exposure event or other serious occurrence, or fiber release, EPA workers shall follow the established site-specific emergency response plans and procedures. Written emergency plans and procedures must be developed, implemented and executed to provide for immediate 28 ------- safety and health protection. If no written emergency response plans and procedures exist, then work shall noj be undertaken by EPA workers until adequate procedures have been formulated by the responsible party. 4.b.8.a. Minor Fiber Release Episode. The Agency shall ensure that the procedures described below are followed in the event of a minor fiber release episode (i.e. the falling or dislodging of 3 square or linear feet or less of friable ACBM): • Thoroughly saturate the debris using wet methods. Clean the area in accordance with procedures outlined in the Standard Methods (SM). Place the asbestos debris in a sealed, leak-tight container. Repair the area of damaged ACBM with materials such as asbestos-free spackling, plaster, cement, or insulation, or seal with latex paint or an encapsulant, or immediately have the appropriate response action implemented. 4.b.8.b. Major Fiber Release Episode. The Agency shall ensure that the procedures described below are followed in the event of a major fiber release episode (i.e., the falling or dislodging of more than 3 square or linear feet of friable ACBM): Restrict entry into the area and post signs to prevent entry into the area by persons other than those necessary to perform the response action. • Shut off or temporarily modify the air-handling system to prevent the distribution of fibers to other areas in the building. The response action for any major fiber release episode must be designed by persons accredited to design response actions and conducted by workers accredited to conduct response actions. 4.b.9 Communications. Outreach, and Program Visibility. SHEMD shall maintain Program-related communications Agency-wide as part of 29 ------- their management activities to instill Program awareness, stimulate interest and support, and encourage creative participation at all levels within the Agency. Among other matters, communications may be directed to: the distribution of appropriate information regarding Program costs and resource requirements, overall operating information and statistics, reports and recommendations of the Asbestos Subcommittee of the Safety, Health, and Environmental Management Steering Committee; the dissemination of pertinent information about asbestos occurrences, asbestos exposure trends analysis, changes in the Program, Policy, Standard Operating Practices or Standard Methods. SHEMD will also sponsor and participate in forums for gathering and exchanging current information related to asbestos safety and worker health protection. Professional societies, federal, state and local environmental agencies, and others may be invited to participate in these forums. These initiatives may include: • seminars and workshops; • collaborative efforts for developing and advancing asbestos safety within, as well as outside, the Agency; and fostering the development of computer-based networks for the exchange of information both inside and outside the Agency. Local operating units shall also maintain a communications initiative directed toward: • disseminating information regarding asbestos occurrences, improvements to management processes and work practices, and changes to available services and support among others. SPECIFIC RESPONSIBILITIES Assistant Administrator. Office of Administration and Resources Management is responsible for overseeing the Agency-wide management of the Program. The Assistant Administrator shall ensure that adequate human, financial and other resources are allocated for the central administration and management of the Program and for centrally supported operations within the program offices, Regions, Laboratories, and other operating units. As Chairman of the Safety, Health, and Environmental Management Steering Committee, the Assistant 30 ------- Administrator shall appoint members to the Pollution Prevention Subcommittee of the Safety, Health, and Environmental Management Steering Committee, and shall receive and act on all reports and recommendations made by the subcommittee. Pollution Prevention Subcommittee of the Safety. Health, and Environmental Management Steering Committee makes polity, program, and resource-related recommendations to the AA for OARM, based upon (1) periodic review of operational data, including select Occurrence Reports and waivers, (2) Program information obtained via sub-committee activities, (3) QA/QC and TQM reports, and (4) the collective expertise of the group. The Subcommittee presents an Annual Report of the effectiveness and state of the Program to the AA for OARM. Director of the Safety. Health, and Environmental Management Division shall: • formulate the Agency's safety, health, and environmental management policies, programs, plans, standards, protocols, priorities, budget and staffing requirements in accordance with applicable statutes, regulations and guidelines, including those identified in Section 5, "AUTHORITY": develop the Program and provide the documentation and guidance to implement and maintain the Program within regions, laboratories, program offices, and other operating units; • provide or identify sources for the core components of the asbestos safety training program(s), and review and approve asbestos safety training courses to satisfy the requirements of the directive; • establish the requirements for medical surveillance and exposure monitoring program(s) and health consultative services; provide managerial and technical support, for establishing and maintaining the national Program requirements at regions, laboratories, program offices, and other operating units; • conduct quality assurance activities in order to ensure operations compliance with the Program, evaluate Program effectiveness, and foster continuous Program improvement; and • provide resources and staffing support, such as the taking of minutes, for the Pollution Prevention Subcommittee of the Safety, Health, and Environmental Management Steering Committee. Director of the Office of Pollution Prevention and Toxic Substances shall allocate sufficient resources to provide technical assistance and support to 31 ------- the SHEMD, regions, laboratories, and other operating units to ensure implementation, management and maintenance of Program policies, standards, protocols, priorities, and evaluation activities in accordance with applicable statutes, regulations and guidelines, including those identified below in Section 5, "AUTHORITY". Assistant Administrators. Regional Administrators. Laboratory Directors and directors and managers of other operating units shall allocate funding, human and other resources required to implement, manage and operate the Program in all operating units, Agency-wide, for which they have responsibility. They shall delegate authorities and assign responsibilities for implementing, operating, and maintaining the local asbestos management program activities. Safety. Health, and Environmental Management Program Managers shall: provide direct assistance to the AA, RA, and other senior management officials in the development, management, implementation and evaluation of the Program; • assist in assuring that the requirements of the directive are met; implement delegated components of the Program, such as the asbestos training courses, coordinating workers medical surveillance and monitoring functions, and participating in, and maintaining certain records for, quality assurance activities; • consult with managers and supervisors, and facilitate the provision of technical and other assistance. Asbestos Program Manager fAPM1 is the building owner's representative for all asbestos related O&M activities. For most EPA occupied facilities, this person will not be an EPA employee. However, in those instances where EPA owns and operates the building, the APM will most likely be an EPA employee. The APM shall: maintain current generic safety policies, plans and procedures; provide technical support locally in the development of site safety plans; • provide managerial and technical resources to the Regional SHEMP Manager and other managers and supervisors; conduct investigations of occurrences, accidents, and employee exposure excursions above established levels, in concert with the SHEMP Manager; and 32 ------- • manage and administer the facility's O&M Program. Asbestos Program Coordinator (APC) is an EPA employee and represents EPA in coordinating asbestos related O&M activities with the APM. In lease arrangements with GSA, where the building is owned by parties other than the federal government, the GSA building representative may also have the title and selected duties of the APC in the coordination with EPA and other federal agency tenants. In all lease arrangements (when EPA does not own the building), EPA shall have a person designated as the APC to represent and coordinate the activities of EPA and its workers. Officers-in-Charge. Site Managers. APM and APC are ultimately responsible for the health and safety of workers on-site. As such they shall assure implementation of the Program, and all related guidance and Directives, at reporting units, establishments or workplaces. Supervisors are responsible for: • supervising workers in a manner so as to ensure that their health is protected through the application of this Program, and related guidance and directives; identifying workers who are required to participate in, or be discharged from the Program; and • being aware of any significant worker exposure or environmental release of asbestos, and taking the appropriate response action. Participating Workers are responsible for: complying with the requirements established by this Program, and following other directives, Standard Operating Practices, Standard Methods, and related guidance in the performance of their work; adhering to Program principles in all asbestos related work activities; completing all required training on a timely basis; participating in reviews of exposure occurrences; familiarizing himself/herself with the emergency response plans and procedures at work sites; and reporting concurrent asbestos related work from other employers. 33 ------- 4.d. PROGRAM EVALUATION AND QUALITY SYSTEMS Quality Systems, involving planning, implementation, inspection/survey, assessment, reporting, and quality improvement ensure that Program management and operations functions are established, monitored, and continuously improved to limit EPA workers' occupational exposure. Quality Assurance (QA) includes specific activities for collecting and analyzing information to indicate levels of success and effectiveness of individual Program functions. These QA activities focus on processes and outcomes, and include: • program audits and self-assessments; • occurrence reporting; quality control activities; operating data and reports; and performance standards and indicators. A system has been established, including Standard Methods, to measure and ensure the quality control (QC) of the Program's products and services to ensure optimal achievement of objectives. Quality Improvement (QI) tools and activities are applied to evaluate and enhance processes, procedures, and practices of the Program. The QI component of the Program includes a self-assessment system that utilizes QA/QC data and EPA Total Quality Management (TQM) techniques. Quality Assurance activities will be conducted in accordance with the Agency's Quality Manual, based on American National Standards Institute (ANSI)/American Society for Quality Control (ASQC) national consensus standards, and the principles of TQM. Program quality requirements are detailed in a Quality Systems Standard Operating Practices document. 5. AUTHORITY This Directive and "Program for the Management of Asbestos-Containing Building Materials at EPA Facilities" is part of the Safety, Health and Environmental Management Program established under EPA Order 1440.1. Executive Order 12088, Federal Compliance with Pollution Control Standards. October 13, 1978. Executive Order 12196, Occupational Safety and Health Programs for Federal Employees. February 28, 1980, effective October 1, 1980. 34 ------- Federal Register. Tuesday, November 20,1990, 40 CFR Part 61, Environmental Protection Agency, National Emission Standards for Hazardous Air pollutants; Asbestos NESHAP Revision; Final Rule. 35 ------- 6. 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 Standard Operating Practices for Asbestos Safety and Health Protection Practices (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 As revisions and updates occur to the above noted references, additional information may be included as reference material for this policy statement, including new guidance documents or regulations. 36 ------- 7. 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 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 II 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") - Managers who have the technical and managerial skills and 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: Chiysotile (serpentine), crocidolite (riebeckite); amosite (cummingtonitegrunerite); anthophyllite; tremolite; and actinolite. Asbestos-Containing Materials (ACM) - Any material or product which contains more than 1 percent asbestos. 37 ------- |