Asbestos
600a. Asbestos-Containing Materials (ACM) Management
Practices to ensure the safe handling of asbestos are predicated by knowing where the asbestos is located throughout your campus. These practices are primarily aimed at facility management rather than specific work practices, which are clearly specified in the regulations.
BMP
- A specific individual must be designated to be responsible for the developing and implementation of a campus-wide comprehensive asbestos management program. This individual must be trained and provided top-down management support.
- The first step in identifying suspect ACM is to conduct a visual inspection of the building or buildings in question. This inspection should also be used to quantify the amount of ACM in the building if the suspect material is found to contain asbestos. Visual inspection information from confirmed ACM should then be used to demarcate areas to be resurveyed on a periodic basis.
- Changes in the condition of the ACM should be tracked over time. If the material is seen to be deteriorating, then removal or repair, whichever best suits the situation, should be followed.
- EPA Asbestos Hazardous Emergency Response Act (AHERA) requirements for surveying buildings and managing asbestos should be followed as much as possible.
- Whenever possible, sample areas when not occupied to avoid possible non-survey personnel exposure and concern.
- Samples must be collected only by the UT Arlington Asbestos Program personnel or other certified Asbestos Inspectors.
- Certain materials are commonly found to contain asbestos, and therefore, can sometimes be assumed to be ACM. These may include:
- Thermal system insulations (TSI) that are not obviously fiberglass or foam rubber. TSIs are those found on plumbing, boilers, furnaces, steam heat exchanges, etc.
- Sometimes asbestos containing thermal insulations still have the manufacturer's label. These are immediately considered asbestos containing.
- Floor tiles, sheet flooring, backing and the adhesives holding them in place can also be assumed to be ACM. This includes both 9"x 9" and 12"x 12" tiles. If large-scale removal is required, they may then be sampled to confirm their content. These materials are sometimes managed as separate entities, because they are considered non-friable.
- Another non-friable material that is often assumed to be ACM is Transite. This is the brand name for a preformed material used for roofing, oven liners, chemical fume hood liners, piping and sheeting (both flat and corrugated), etc. The material was made by compressing a mixture of asbestos and Portland Cement.
- Asphaltic roofing materials such as shingles and tarpaper can also be assumed to be ACM. However, as long as they are not cut, drilled, ground, sanded or otherwise reduced to a powder, they can be handled and disposed as standard construction waste (except in certain counties). As with flooring, if large-scale removal is required, they may be sampled before removal. OSHA "competent person" regulations may also apply.
- Before being used for bulk or air sample analysis, the laboratory should hold certain nationally recognized credentials. These may be accreditations by the U.S. Department of Commerce, National Institute of Standards and Technology, National Voluntary Laboratory Accreditation Program (NVLAP) and the American Industrial Hygiene Association (AIHA).
- For ease and speed of access to information, computerized databases should be developed for asbestos abatement projects, air and bulk sample data, etc.
- Floor plans (hard copy or electronic) of buildings that are known to contain troweled or spray applied ceiling, wall or superstructure coatings, transite ceilings or walls and ceiling tiles should be kept on file at the unit responsible for asbestos management, as well as the facilities and/or operations office. This allows quick reference to the locations of these materials for personnel and designers that may be involved with building renovations or demolitions. Emergency notification of occupants is also expedited in the event of a ceiling/roof leak or other structural failure.
- Contractors who may discover suspect materials during the course of their work shall be instructed to notify UT Arlington Asbestos Program personnel representatives as soon as possible, before continuing work.
- All asbestos abatement projects should be documented from design to completion. This information should be kept on file forever, as should the associated computer generated information for each project. The information contained in these files should include information such as regulatory authority notification, asbestos waste shipment and disposal manifests, daily project logs, inspection reports and air monitoring and inspection data from the independent project monitoring consultant used for each project.
- The Office of Facilities Management should instruct its personnel on topics such as the location of ACM, the use of the aforementioned asbestos building floor plans, and work stoppage procedures when ACM is unexpectedly encountered. OSHA and EPA asbestos awareness training requirements should be followed.
- Prequalification of asbestos contractors should be conducted. This consists of sending a prospective contractor a letter of request for information used to verify their competence in asbestos abatement. The documentation should include information on proper licensing, insurance, past projects completed with references, and the names of any industrial hygienists that have inspected or monitored their projects.
- A contractor should be in business under the same management structure for at least three continuous years.
- Regulatory authorities in the jurisdictional area of past projects or corporate offices should also be contacted for their records.
- The Office of Facilities Management Asbestos Program personnel should also be involved in contractor qualifications to ensure insurance and bonding capacities.
- After prequalification, contractors who are found to be in noncompliance with either your requirements or regulations should be immediately removed from the qualified bidders list. Documentation should be kept on the reasons behind the decision, and it should be kept on file for future reference should the contractor change names, etc. and try to be re-qualified at a later date.
- In-house asbestos abatement performance specifications should be developed for consistent expectations for work conducted by contractors and consultants. This should include requirements for items such as pre-project submittals (required by both in-house policies and applicable regulations), contractor work plans, work practices, air sampling requirements, waste handling, final report requirements, etc.
- In-house project initiation and completion checklists should be developed for auditing purposes. Checklists should include items to "check" such as: submittals received and approved, waste shipments records received/verified/approved, final reports received and approved, air monitoring reports received and approved, invoice received and approved, etc.
- In-house project design checklists should be developed as per UT Arlington requirements.
- Coordination between facility personnel, Environmental Health and Safety, facility occupants, etc. is ESSENTIAL for asbestos projects to run as smoothly as possible.
- DO NOT withhold information from concerned employees or occupants. Meet with them up front and keep them informed throughout all projects, no matter how small or trivial.
- DO NOT allow the asbestos contractor to hire an air-monitoring consultant. The property owner should hire the consultant independently from the contractor.
- DO NOT allow untrained individuals to:
- Access areas above ceiling tiles where ACM is present;
- Remove intact ACM ceiling tiles;
- Remove vinyl asbestos tile (VAT);
- Drill ACM materials, such as transite panels inside chemical fume hoods; or
- Otherwise handle ACM materials as specified in state and federal regulations.
Training
- All individuals involved in building inspections, developing management plans, designing projects, conducting asbestos removal, and collecting bulk building materials shall attend initial and annual training programs approved by the Pa. L&I.
- DO NOT allow untrained individuals to:
- Access above ceiling tiles where ACM is present;
- Remove intact ACM ceiling tiles;
- Remove VAT;
- Drill ACM materials, such as transite panels inside chemical fume hoods; or
- Otherwise handle ACM materials as specified in state and federal regulations.
- Facilities Management should instruct its personnel on topics such as the location of ACM, the use of the aforementioned asbestos building floor plans, and work stoppage procedures when ACM is unexpectedly encountered. OSHA and EPA Asbestos Awareness training requirements should be followed.
- Samples must be collected only by certified asbestos inspectors.
- Training programs conducted in-house should be coordinated with the individual designated by the institution as responsible for the asbestos program.
600b. Asbestos Containing Equipment
Asbestos may be found in laboratories, support areas and the equipment used therein. Such uses include, but are not limited to, equipment door gaskets, equipment insulating materials (interior and exterior), lab tong insulation sleeves, high temperature gloves, wire gauze supports, transite panels inside fume hoods, soapstone lab bench tops, wire insulation and in electrical panels.
BMP
- Maintenance activities (i.e., drilling, sanding, cutting) of suspected asbestos-containing material (ACM) must be done using special precautions and following the guidelines listed in the UTA Asbestos Program (UTA AP).
- Repair/replacement of suspected ACM found in laboratory equipment must be done by individuals or companies approved by the UTA AP.
- Evaluate the asbestos-containing materials periodically to assess damage and to repair/replace and dispose of properly.
P2-E2
- If you have ACM equipment, consider implementing a disposal and replacement program.
- For specific requirements related to storage, inspection, training, record keeping, disposal or removal, consult with the UTA AP.