OPERATIONS & MAINTENANCE PLAN
1.0 INTRODUCTION
An Operation and Maintenance Program is designed to manage asbestos in place to safeguard the health of building occupants. This is accomplished by training, cleaning, work practices, and inspections to maintain ACM in good condition. Removal is often not the best course of action to reduce asbestos exposure. The O&M program is designed to prevent asbestos fiber release and control fiber releases if they occur. A well-run O&M program may be all that is necessary to control the release of fibers. Emphasizing the importance and effectiveness of a good O&M program is critical to putting the potential hazards of asbestos exposure in proper perspective. Basic O&M procedures to minimize and/or contain asbestos fibers may include wet methods, HEPA vacuuming, area isolation, PPE, and avoidance of certain activities, such as sawing, sanding, and drilling ACM.
2.0 MANAGEMENT
The Safety Office maintains the Asbestos Management Plan for the university and coordinates the asbestos abatement program. The objective of the plan is to identify and maintain, in safe condition, asbestos-containing material (ACM) in university buildings. The Plan also addresses emergency response procedures, recordkeeping, training, and housekeeping procedures. The management of the ACM is an involved and ongoing process with observations, assessments, and possible response actions occurring daily. The plan is arranged for quick reference by maintenance and housekeeping personnel, campus contractors and vendors, and other university employees. The Plan is kept in the Safety Office, Facilities Management, Housekeeping, and the Police Department.
3.0 INSPECTIONS
All buildings on campus have been surveyed for ACM. Campus areas containing ACM are identified on floor plans. Asbestos containing materials on campus are inspected semi-annually by Safety Office personnel to assess its condition. The material condition is compared to the condition of the last inspection and changes are recorded on an inspection form. Conditions that require a response will be reported to supervision. The Safety Office maintains maps showing the location of asbestos containing materials on campus. If you have a concern about ACM in your area please call the Safety Office.
4.0 SIGNS & LABELS
Warning signs have been placed at all entrances to mechanical rooms containing ACM. Pipes containing asbestos insulation have been labeled.
5.0 PUBLIC NOTIFICATIONS
Public notices have been placed in all buildings on campus that contain ACM. Notification is given by the Safety Office to appropriate departments when an abatement activity is scheduled. The information given to building occupants contains the following points:
1. The location and condition of the ACM in their area.
2. Asbestos only presents a health hazard when fibers become airborne and are inhaled. The mere presence of ACM does not present a health hazard.
3. Do not disturb the ACM.
4. Report any evidence of disturbance or damage of ACM to supervision.
5. Report any dust or debris that might come from the ACM or any changes in the condition of ACM to supervision.
6. Cleaning and maintenance personnel are taking special precautions to guard against disturbing ACM.
7. All ACM is inspected periodically and additional measures will be taken if needed to protect the health of building occupants.
6.0 TRAINING
1. All Facilities Management & Housekeeping personnel are given a two hour asbestos awareness training session ever year by the Safety Office. The training class addresses the following subjects:
2. Safety Office personnel and other workers trained in asbestos removal operations attend annual refresher training courses.
7.0 ABATEMENT ACTIVITIES
1. A small crew of workers in Facilities Management have taken a 16-hour Asbestos Operations & Maintenance course. This crew is restricted to removing only non-friable asbestos floor tiles at the university. Removal operations are limited to 160 sq. ft. per eight hour job. Only hand tools and wet methods will be used. Respirators, tyvek suits, and medical evaluations are not required. Air monitoring of workers is required if the work may exceed the PEL.
2. Asbestos removal operations involving friable asbestos floor tiles, sprayed or trowled on ACM, thermal system ACM, ceiling tile, pipe insulation, glove bagging or large spill cleanups will be contracted to an asbestos abatement firm by the Safety Office.
3. Safety Office personnel have received the 40 hour asbestos/worker supervisors course and may clean up small spills (single 5 ft x 5 ft glove bag).
4. EPA will be notified if the annual total of asbestos abated by university personnel exceeds 160 sq. ft.
8.0 MEDICAL SURVEILLANCE PROGRAM
1. The university does not include its asbestos workers in a medical surveillance program because workers are not exposed to asbestos fibers above the OSHA action level for more than 30 days per year.
2. If respiratory protection is required, workers will be medically evaluated per OSHA regulations. Safety Office personnel have been medically evaluated and are permitted to wear respirators.
9.0 MAINTENANCE WORK PRACTICES
1. All maintenance workers are advised of the proper procedures to follow when their work involves possible contact with ACM. The "Asbestos Maintenance Policy" is posted on the employees bulletin board and addresses procedures and precautionary considerations for daily maintenance activities.
2. When building renovation activities are planned, the supervisor in charge conducts a detailed assessment of the project area to see if any ACM will be encountered. The supervisor will review the Asbestos Management Plan and contact the Safety Office if necessary to determine what material has been identified and reviews building plans to see if ACM may be revealed by the renovation being conducted. The supervisor in charge will verify the project area as asbestos free or ACM will not be disturbed during renovation activities.
10.0 SAFE WORK PRACTICES
General Safety Procedures
The following general precautions should be followed to reduce exposure and lower the risk of asbestos related health problems:
1. Drilling, sawing, or using nails on asbestos materials can release asbestos fibers and should be avoided.
2. Floor tiles, ceiling tiles or adhesives that contain asbestos should never be sanded.
3. Use care not to damage asbestos when moving furniture, ladders, or any other object.
4. Know where asbestos is located in your work area. Use common sense when working around products that contain asbestos. Avoid touching or disturbing asbestos materials on walls, ceilings, pipes, ducts, or boilers.
5. All asbestos containing materials should be checked periodically for damage or deterioration. Report any damage, change in condition, or loose asbestos containing material to a supervisor.
6. All sampling, removal, or repair work involving asbestos must be done by specially trained personnel. OSHA and EPA regulations are very specific about work practices and equipment required to work safely with asbestos. These requirements may include proper respirators, special enclosures, training, exposure monitoring, long term record keeping, and medical surveillance.
7. Asbestos should always be handled wet to help prevent fibers from being released. If asbestos is soaked with water or a mixture of water and liquid detergent before it is handled, the fibers are too heavy to remain suspended in the air.
8. In the presence of asbestos dust above the PEL, the use of a respirator approved for asbestos work is required. A dust mask is not acceptable because asbestos fibers will pass through it. The use of respirators must be approved by the Safety Office.
9. Dusting, sweeping, or vacuuming dry asbestos with a standard vacuum cleaner will put the fibers back into the air. A vacuum cleaner with a special high efficiency filter (HEPA) must be used to vacuum asbestos dust.
10. If a HEPA vacuum is not used cleanups must be done with a wet cloth or mop. The only exception to this would be if the moisture presents an additional hazard such as around electricity.
11. Asbestos waste, including all clean up materials, must be sealed in a double 6-mil plastic asbestos bag and properly labeled before being disposed in an EPA approved landfill.
12. Remember, the mere presence of asbestos itself does not create a health hazard unless the material is disturbed and releases fibers to the atmosphere. Protect yourself and others by being aware of where asbestos is located, the dangers involved, and using common sense when working around ACM.
Stripping Asbestos Floor Tiles
The following procedures should be used when caring for asbestos containing floor tiles.
1. Sanding of asbestos containing floor tiles is prohibited.
2. Stripping of finishes shall be conducted using wet methods and low abrasion pads at speeds lower than 300 rpm. Do not perform dry stripping or overstrip the floor.
3. When high speed buffing is done, ensure that there is adequate sealer and finish on the floor. Always keep the machine moving.
4. Do not remove or attempt to repair loose floor tiles. Improperly removed asbestos containing floor tiles could result in the release of high levels of asbestos.
5. Report loose floor tiles to supervision immediately. Avoid running the machine over loose tiles.
Asbestos Floor Tile Removal
1. Do not remove 9 in. x 9 in. or 1 ft. x 1ft. floor tiles unless you have have received proper training or the tiles and mastic have been tested and found to be free of asbestos.
2. Removal of tiles and mastic containing asbestos must be performed by individuals who have taken a 16-hour Asbestos Operations & Maintenance course.
3. Notify the Safety Office before beginning the work. Only non-friable asbestos floor tiles may be removed by university personnel.
4. Removal operations by university personnel are limited to 160 sq. ft. per eight hour job and only hand tools can be used.
5. Respirators, tyvek suits, and medical evaluations are not required. Air monitoring of workers is not required if historical data is available for the procedure.
6. Restrict access to the area.
7. Mist the floor with amended water until completely wet.
8. Using a wide blade, attempt to pry the floor tile loose without breaking.
9. Mist the removed area with amended water prior to scraping the underlying mastic. If mastic solvent is used, extinguish all flames in the immediate area and ensure that there is adequate ventilation.
10. Wet wipe or HEPA vacuum the removal area.
11. Place the tiles, mastic, and any contaminated materials into double 6-mil plastic disposal bags that are properly labeled for asbestos disposal.
11. Keep the asbestos waste at the site and notify the Safety Office for proper disposal.
12. Clearance samples are not required if less than 160 sq. ft. have been removed using procedures in which historical data exists.
11.0 EMERGENCY PROCEDURES
Clean up of asbestos spills must be performed by specially trained personnel. OSHA and EPA regulations are very specific about work practices and equipment required to work safely with asbestos. These requirements may include respiratory protection, special enclosures, training, exposure monitoring, record keeping, and medical surveillance. Proper procedures must be followed to reduce the spread of asbestos fibers after a release has occurred, such as the partial collapse of a ceiling containing spray-on asbestos. Depending on the severity of the release, an asbestos contractor may be called to conduct the cleanup operation.
Initial Response and Notification
1. If a release or suspected release of asbestos fibers occurs, take the following general steps to reduce exposure to occupants until trained asbestos personnel arrive:
2. The Police Department will:
3. Safety Office personnel will assess the spill and determine if in-house personnel can clean up the spill or an asbestos contractor should be called.
Specific Emergency Procedures
Major Release
1. If the spill is greater than the amount that would fill a single 5 ft x 5 ft glove bag, the Safety Office will call a licensed asbestos contractor to clean up the spill.
2. The Safety Office and Police Department will ensure that the site is secured until the arrival of the asbestos contractor.
3. The Ventilation System will be shut off.
4. The Safety Office, Facilities Management, and the Police Department will consult and determine if an evacuation of the area or building is necessary. If necessary, the Police Director or Safety Manager will order an evacuation and notify the Vice President for Business Affairs, Director of Facility Planning & Construction, Director of Facilities, Assistant Vice President for Communications, and other appropriate university officials. The Vice President for Business Affairs will notify the President, if appropriate.
Minor Release
1. A minor release is the quantity of ACM that would fill a single 5 ft x 5 ft glove bag. The Safety Office will assess the spill and clean up minor releases. Spills greater than this amount will be cleaned up by a licensed contractor.
2. Workers involved in cleaning up small quantities of asbestos must receive at least 16 hours of training in asbestos management.
3. The following procedures should be used to clean up small releases:
Containment
1. Asbestos workers can breach containment for life threatening emergencies. Non-asbestos workers can enter containment without proper PPE for
2. Non-life threatening emergencies that occur in containment (e.g., cut water line) shall be reported immediately to the Safety Office. The Safety Office will assess the situation and determine what PPE is needed by non-asbestos workers. Non-asbestos workers are not to enter the containment until permission has been obtained from the Safety Office.
Equipment
The following equipment is available to clean up asbestos spills:
12.0 CONTRACTORS
Vendor Notification- Materiel Management & Contracts
A building asbestos survey has been conducted and an inventory of known asbestos containing material is on file in the Safety Office. Before you begin work you are advised to consult the inventory listing and determine if the activities of your work will disturb identified materials. If so, advise the Director of Materiel Management & Contracts before work commences. Further, if during the execution of your work, should you encounter materials which you believe may contain asbestos, you shall notify the Director of Materiel Management & Contracts before proceeding.
Contractor Notification- Capital Outlay & Construction
Reference Section 48 of Capital Outlay General Conditions reproduced below:
48. Asbestos
(a) This subsection applies to projects involving existing buildings where asbestos abatement is not a part of the work, when the scope of the project has been reviewed and a comprehensive survey conducted by an individual licensed by the Virginia Department of Professional and Occupational Regulation to conduct building inspections for asbestos containing materials in buildings, and where the Owner has attempted to remove or encapsulate all asbestos containing material that may become friable or damaged during this project.
Prior to commencement of work, the results of the comprehensive survey or any other asbestos survey shall be made available to the Contractor, who shall be responsible for performing his work so as not to disturb any remaining asbestos, encapsulated or otherwise, identified in such survey or surveys.
If the Contractor discovers or inadvertently disturbs any material that he knows, should have known or has reason to believe, may contain asbestos that has not been previously identified, was overlooked during the removal, was deemed not to be friable or was encapsulated, the Contractor shall stop work in the area containing or suspected to contain the asbestos, secure the area, and notify the Owner and the Architect/Engineer immediately by telephone or in person with written notice as soon as possible. The Owner will have the suspect material sampled.
If the sample is positive and must be disturbed in the course of the work, the Owner shall have the material repaired or removed and shall pay for the bulk sample analysis.
Except as provided in §11-4.1 of the Code of Virginia, if the material disturbed is not within the Contractor's authorized work and/or work area or under this Contract, the Contractor shall pay for all associated sampling and abatement costs.
(b) If asbestos abatement is included as a part of the work, the contractor shall assure that the asbestos abatement work is accomplished by those duly licensed as described in Section 3 of these General Conditions and in accordance with the specific requirements of the Contract and all applicable laws and regulations.
(c) If asbestos abatement is included as part of the work, the licensed asbestos Subcontractor shall obtain the insurance required under Section 11 (e) of these General Conditions.