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

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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

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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
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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
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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.
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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
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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.
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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
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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
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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;
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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
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• 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
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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;
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•	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:
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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.
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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
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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
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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
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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.
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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
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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
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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
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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
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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.
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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
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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
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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.
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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.
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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
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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.
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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;
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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
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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
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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
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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
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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
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•	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.
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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.
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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.
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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.
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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.
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