Asbestos Management

Background

Asbestos is a naturally occurring fibrous mineral that is found in many products. Initially, it was thought to be a remarkable product because it is fireproof, very strong, and could be used in many applications ranging from plaster and other building materials to being woven into fabrics. Asbestos is known to cause serious adverse health effects, including asbestosis, mesothelioma, and lung cancer.

Purpose

The purpose of this program is to ensure that Hampshire College employees understand the hazards of asbestos exposure and are aware of the proper procedures that must be followed when cleaning, maintenance, repair, or any type of work that may potentially disturb asbestos must be performed. The main responsibility of employees is to recognize asbestos or the potential that a material may contain asbestos, and to know whom to contact regarding concerns and to provide immediate notification upon discovering damaged or deteriorated asbestos. Additionally, facilities and grounds personnel must be certain that renovation and new construction materials installed either by Hampshire College personnel or outside contractors do not contain asbestos. The ultimate goal of this plan is to protect the environment and the health of the entire College community.

Important Definitions

Asbestos: Includes chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos, actinolite asbestos, and any of these minerals that have been chemically treated and/or altered.

Asbestos-containing material (ACM): Any material containing more than one percent asbestos.

Friable ACM: Any material containing more than one percent asbestos, which when dry, may be crumbled, pulverized or reduced to powder by hand pressure.

Presumed Asbestos Containing Material: Thermal system insulation (TSI) and surfacing material found in buildings constructed no later than 1980.

Regulatory Compliance

Asbestos is regulated in Massachusetts by the Department of Environmental Protection (DEP) and the Division of Labor and Workforce Development (DLWD). Federally, asbestos is regulated by the Occupational Safety and Health Administration (OSHA), as well as the Environmental Protection Agency (EPA) under the Clean Air Act and the Toxic Substances Control Act.

Asbestos is still mined and asbestos-containing products continue to be manufactured. EPA does not monitor distribution and processing of asbestos containing products; therefore, it is of the utmost importance that facilities and grounds personnel read all product literature, including material safety data sheets, before purchasing and installing any building materials. If there is any doubt, the supplier or manufacturer should be asked to certify that the material does not contain asbestos.

Training

Asbestos Hazard Awareness Training:

Hampshire College employees who may come into contact with asbestos will receive asbestos hazard awareness training. Awareness level-trained personnel are not expected or authorized to perform any work that will disturb ACMs or suspected ACMs. Materials that are confirmed by lab analysis to contain trace (<1%) asbestos (see procedure below) can be disturbed by awareness level-trained personnel. This training will be conducted by environmental health and safety and will consist of:

Health effects of asbestos exposure
Locations of asbestos-containing materials (ACM) and presumed asbestos-containing materials (PACM)
Recognition of ACM and PACM damage and deterioration
Housekeeping requirements
Proper response to fiber release episodes

Training will be conducted initially for new employees and reviewed annually for all affected employees during safety training refreshers.

Operations and Maintenance (O&M) 16-Hour Training:

Hampshire College employees who will have a need to disturb ACMs or trace ACMs, such as when drilling a hole or repairing a pipe leak, will attend a 16-hour training course. O&M level-trained personnel are authorized to perform projects where ACMs are disturbed in amounts that are no greater than 3 SF or 3 LF and the amount of asbestos to be removed must be confined to one standard-size asbestos waste bag.

This training will be conducted by ATC Associates or other certified environmental training firm. A 4-hour annual refresher is required.

Asbestos Coordinator and Assessment Procedure

The carpenter foreman will serve as the Hampshire College asbestos coordinator. Prior to any renovation work or clean-up of degraded building materials, the asbestos coordinator must be notified. If there are suspected ACMs (see definition below) in the area, the asbestos coordinator will contact environmental health and safety to see if records are available for the specific location. If there are no records, the asbestos coordinator or environmental health and safety will arrange for ATC Associates or other qualified asbestos consulting firm to sample the material.

No work can proceed in the area until it has been confirmed that asbestos is not present. If the results are positive for asbestos, the course of action taken will depend on the scale of the project. If the project is a very small scale disturbance, such as drilling a hole, Hampshire College employees with 16-hour asbestos operations and maintenance (O&M) training can perform the work. If the project is larger than 3 SF or 3 LF and the asbestos to be removed will not be confined to one standard asbestos waste bag, the asbestos coordinator will arrange for abatement to be performed by a qualified asbestos contractor.

The asbestos coordinator must inform building occupants and campus safety and security when asbestos abatement will be conducted in areas of occupied buildings. The asbestos coordinator must assess the condition of asbestos, investigate reported concerns, and coordinate with environmental health and safety to take appropriate action if asbestos is found to be in a damaged or deteriorating condition.

Records

All records pertaining to asbestos abatements, training, sampling and testing will be kept by the office of environmental health and safety.

Suspect Asbestos-Containing Materials

All building materials, with the exception of mastic, will be assumed to contain asbestos if they were purchased or installed prior to 1980. Mastic materials purchased or installed prior to 1990 will be assumed to contain asbestos. These materials will be assumed to contain asbestos unless environmental health and safety has records indicating the materials in that specific location were sampled and results indicate that they are negative for asbestos. Suspect materials can only be removed or disturbed by an O&M-trained employee, depending upon the scope of work, or a licensed asbestos contractor, unless the asbestos coordinator arranges to have samples taken by a qualified consultant and results prove the material does not contain asbestos.

Procedure for Trace Asbestos Materials

Trace asbestos refers to a material that contains less than one percent (< 1 %) asbestos. Employees must have a minimum of asbestos awareness training to perform work that will disturb materials containing trace asbestos. In addition, these employees must also be in the respirator program. The work requirements are as follows:

Training (awareness level or O&M level)
Employees must be in respirator program
Initial exposure monitoring (get personal air pump and forms from EH&S)
Worker protection (suits, respirators, etc.)
Seal off area to prevent transmission of dust beyond the immediate work area
Post construction area warning signs
Use wet methods (amended water: water mixed with surfactant (soap))
Use HEPA-vacuums
Prompt clean-up and disposal of waste and debris contaminated with trace asbestos in leak tight plastic bags or containers. (Materials containing <1% asbestos are not considered asbestos waste. These waste bags and containers can be disposed of as construction debris)
Record-keeping requirements associated with personal air monitoring and negative exposure assessment

Procedure for Asbestos Containing Materials

Hampshire College employees that have completed the 16-Hour O&M training and are in the respirator program can perform very small projects that will disturb asbestos. Specifically, O&M-trained employees can do work that involves no more than 3 LF or 3 SF, and the asbestos removed must be confined to one standard asbestos waste bag. The work requirements are as follows:

Training (16-Hour O&M level).
Employees must be in respirator program.
Submit a blanket notification using asbestos notification form ANF-001 to DEP within 24 hours of completing the project. (Communicate with EH&S in advance).
Initial exposure monitoring (get personal air pump and forms from EH&S).
Worker protection (suits, respirators, etc.).
Seal off area to prevent transmission of dust beyond the immediate work area.
Post asbestos warning signs.
Use wet methods (amended water).
Use HEPA-vacuums.
Prompt clean-up and disposal of waste and debris contaminated with asbestos in leak tight, labeled asbestos waste bag or containers. Waste must be double-bagged.
Store waste in a locked, secure area for pickup and disposal by an asbestos contractor.
Record-keeping requirements associated with personal air monitoring and negative exposure assessment.

Any asbestos project that involves more than 3 LF or 3 SF and for which the amount of asbestos to be removed will exceed more than one bag cannot be done by Hampshire College personnel. The asbestos coordinator will hire a licensed asbestos contractor to perform the work.

Repair and Renovation Work

All scheduled clean-up, repair, and renovation work must first be cleared by the asbestos coordinator to ensure that asbestos-containing materials will not be disturbed. Examples of activities that qualify as a "disturbance" are listed below. If renovation and repair work cannot be accomplished without disturbing asbestos-containing materials, the asbestos coordinator will determine whether or not the project is within the scope of what O&M-trained employees can perform. If it is not, the asbestos coordinator will arrange for an asbestos contractor to perform the work, or otherwise abate the asbestos so that Hampshire College personnel can safely perform the repair or renovation work.

Disturbances include, but are not limited to:

Removing, sanding, cutting, hammering, or drilling through flooring, wall, fire door, and ceiling materials.
Work that will disturb pipe and other mechanical or thermal systems insulation.
Dry-sweeping mechanical rooms or areas that may contain asbestos materials.
Dry-buffing or dry-stripping asbestos-containing flooring materials; (only wet stripping methods can be done using low abrasion pads at speeds below 300 rpm) .

Emergency Asbestos Work

Any incident that causes the release of asbestos fibers when proper containment measures are not in place is considered an emergency. Examples of emergencies are the discovery of asbestos debris on the floor; ceiling collapse, flooding, or water damage that causes asbestos floor tile to pop up and break; or a leak in a pipe insulated with asbestos. The asbestos coordinator will determine if the emergency can be resolved by O&M-trained employees. If it cannot, an asbestos contractor will be immediately called in. Facilities and grounds must shut down the HVAC system to prevent asbestos fibers from contaminating other areas and, if possible, shut off the steam or water lines, if the emergency involves a leak. If there is reason to suspect that the HVAC system has been contaminated, an asbestos contractor will perform the work. While preparing to address the emergency, and/or while waiting for the asbestos contractor, facilities and grounds personnel must ensure their and others' safety by keeping untrained and unauthorized people from entering the asbestos emergency area.

Classes of Asbestos Work

Class I asbestos work: Activities involving the removal of TSI and surfacing (sprayed-on, troweled-on, or otherwise applied) ACM and PACM.

Class II asbestos work: Activities involving the removal of ACM which is not thermal system insulation (TSI) or surfacing material. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics.

Class III asbestos work: Repair and maintenance operations, where ACM, including TSI and surfacing ACM and PACM, is likely to be disturbed.

Class IV asbestos work: Maintenance and custodial activities during which employees contact, but do not disturb, ACM or PACM and activities to clean up dust, waste, and debris resulting from Class I, II, and III activities.

Hampshire College employees with 16-Hour O&M training will perform work involving asbestos-containing materials to the extent that is allowed by their training. A licensed asbestos contractor will perform all Class I, II, III and IV work involving more than 3 LF or 3 SF and for which the amount of asbestos removed will exceed one standard waste bag. Asbestos awareness-trained employees can perform activities in which asbestos is contacted, but not disturbed, such as cleaning floors. Asbestos awareness-trained employees can also perform work involving disturbance and cleanup of materials containing trace (<1%) asbestos, provided they meet the criteria specified in this plan.

Asbestos Contractor

Hampshire College generally contracts the services of Abide, Inc. for asbestos removal and emergency abatement work. Abide, Inc. is licensed as an asbestos contractor by the Commonwealth of Massachusetts Department of Labor and Workforce Development (DLWD).

Abide, Inc.
483 Shaker Road
PO Box 886
East Longmeadow, MA 01028
413.525.0644

Hampshire College can, at any time, seek competitive bids or contract the services of other licensed asbestos contractors. Responsibilities of the asbestos contractor include, but are not limited to: Maintaining the required written OSHA programs; submitting the Massachusetts asbestos notification form (ANF-001) a minimum of 10-business days prior to abatement projects, or within 24-hours of small-scale incidental maintenance blanket projects, and/or within the timeframes required by each agency; advising the College on how to get waivers from DEP and DLWD, if required, when emergency abatements are performed or when requesting to deviate from required practices specified in the regulations or from work practices specified in the original notification; maintaining applicable license, training, and other records; regulating the work area by posting properly worded warning signs, installing physical barriers when necessary and taking any security measures needed to ensure that unauthorized personnel do not unintentionally or deliberately enter the work area; and packaging and labeling all waste correctly and in accordance with Department of Transportation (DOT) and EPA requirements.

The asbestos contractor must provide the Hampshire College director of environmental health and safety with a complete documentation report that includes the original waste disposal and documentation form, notification, air clearance results, if applicable, and a copy of the invoice. The asbestos contractor is responsible for all aspects of regulatory compliance when working for Hampshire College.

Asbestos Consultants

A licensed asbestos inspector will take samples, when required, to determine whether materials contain asbestos, and provide the director of environmental health and safety with the original report of results from the certified laboratory. A certified asbestos management planner may be contracted to develop asbestos removal specifications or project designs for large-scale or other projects. A certified asbestos monitor/industrial hygienist will be on site to conduct final air clearance sampling when required after an abatement project and will provide the director of environmental health and safety with the original, complete report, including project log and results from the certified laboratory. The asbestos consultant is responsible for maintaining current licenses, training certificates, and any other credentials required by applicable regulations. The asbestos consultant is responsible for all aspects of regulatory compliance pertaining to their services and, when contracted as a full time, on-site monitor, must ensure that the asbestos contractor is in compliance with all applicable regulations.

Medical Examination

All employees performing asbestos removal must be medically cleared prior to wearing a respirator. Additionally, a medical exam will be given to any employee that is exposed at or above the PEL for 30 or more days per year or who engages in Class I, II, or III work for 30 or more days per year. The exam will consist of a medical and work history, questionnaire, physical examination, pulmonary function test, and a chest x-ray. The medical exam will be performed on an annual basis and the chest x-ray will be performed every 5 years thereafter.

Personal Air Monitoring

Personal air monitoring will be conducted for all asbestos and trace asbestos work for which we don't have a negative exposure assessment. Prior to beginning the work, make sure the personal sampling pump, cassettes, cassette labels, and air sampling worksheet are in place so the necessary documentation will be completed.

A representative employee will wear a personal air pump to collect an air sample from the breathing zone. (OSHA's permissible exposure limit is 0.1 f/cc based upon an 8-hour time-weighted average (TWA)).
If the asbestos work will take longer than 30 minutes, a separate sample must be taken for a 30-minute period during the phase of the work that is most likely to produce the highest exposure. This is called the short term exposure limit (STEL). OSHA has an established an excursion limit (EL) of 1.0 f/cc for 30 minutes. No employee can be exposed to an airborne concentration of asbestos in excess of 1.0 f/cc for longer than 30 minutes.
A certified lab will analyze the cassette(s) to determine the exposure level.
Employees will be notified of the results within 5 days of receiving them from the lab.

Negative Exposure Assessment

Personal air monitoring will be conducted for each specific asbestos removal task. If results reveal that exposure levels are below the PEL and EL, respirators and other PPE will not be required when performing that task when using the same work methods. A negative exposure assessment will only allow us to perform certain tasks without PPE. All other work practice requirements, such as wet methods, containment, waste disposal, etc. must still be strictly adhered to. Data for the negative determination must have been collected no more than 12 months prior to the job, otherwise personal monitoring must be conducted. We cannot make a negative determination for the removal or disturbance of friable materials, such as pipe insulation. When working with friable materials, respirators and PPE must always be worn.

Program Review

This program will be reviewed periodically by the director of facilities and grounds, the asbestos coordinator, and the director of environmental health and safety to ensure compliance with OSHA, EPA, DEP, DLWD, and DOT regulations. Additionally, any asbestos emergencies that may arise, or scheduled abatement projects can create the opportunity to evaluate our response to determine if procedures outlined in this policy were adhered to and if there is new information or guidelines that can be implemented to improve this policy and our overall environmental and safety efforts.

Resources:

OSHA 29 CFR 1910.1001: Occupational Safety and Health Standards - Asbestos

OSHA 29 CFR 1910.1200: Hazard Communication

OSHA 29 CFR 1926.1101: Safety and Health Regulations for Construction - Asbestos

OSHA 29 CFR 1910.134: Respiratory Protection

MA DLWD 453 CMR 6.00: Removal, Containment, or Encapsulation of Asbestos

MA DEP 310 CMR 7.09 & 7.15: U Dust, Odor, Construction and Demolition and U Asbestos

MA DEP 310 CMR 19.061: Special Waste

MA DEP Policy BWP-96-012: Policy Concerning Non-Friable Asbestos-Containing Materials

MA DEP: Asbestos Cement Shingles Guidance Document

Town of Amherst, MA Board of Health

Town of Hadley, MA Board of Health

EH&S 3/2010