O&M Program Elements
- 2.1 Education and Training
- 2.2 Occupant Awareness
- 2.3 Building Surveys, Inspections, and Hazard Assessments
- 2.4 Exposure Monitoring
- 2.5 Management
2.1 Education and Training
2.1.1 Custodial and Maintenance Training
All maintenance and custodial staff who perform duties that contact but do not disturb ACM (OSHA Class IV work) shall receive Asbestos Awareness training on an annual basis. Training will include:
- Background on asbestos, its characteristics and typical use
- Health effects of asbestos exposure
- Purpose of the Asbestos O&M Program
- Recognition and response actions when identifying ACM or suspect ACM damage and deterioration
- Location of ACM in buildings where work is to be conducted
- Proper response to accidental fiber release episodes
2.1.2 Worker Training: Small-scale, Short-duration Asbestos Projects
Maintenance personnel who perform duties that involve small-scale, short-duration removal or repair of ACM, or that are required to work in environments contaminated with ACM, shall receive 14-hours of training in addition to the 2-hour awareness training.
Employees who perform asbestos repair or removal operations other than small-scale, short-duration shall meet the training requirements established by the Virginia Department of Professional and Occupational Regulation (DPOR) for an Asbestos Worker. Training for an Asbestos Worker must be conducted by an EPA/AHERA or DPOR board approved asbestos training program.
All personnel required to wear respiratory protection or that perform minor repair or maintenance work involving asbestos materials shall receive training on respiratory protection. The requirements of the Respiratory Protection and Medical Surveillance Programs may be obtained by contacting EHS at 231-2509.
2.1.3 Inspector, Management Planner, Supervisor, Designer, and Project Monitor Training Qualifications
Personnel who sample suspect ACM, conduct building inspections, perform condition assessments, make recommendations for removal procedures or who monitor asbestos projects shall meet the minimum qualifications for Asbestos Inspector, Project Monitor, Project Designer and/or Asbestos Supervisor as established by the DPOR as applicable, and shall meet the definition of "competent person" as defined by the EPA.
2.1.4 Designated Departmental Safety Coordinators
Facilities, CNS and Student Affairs have designated safety coordinators who serve as the liaison to coordinate the specific efforts of the asbestos program for their department.
2.2 Occupant Awareness
2.2.1 Building Occupant Awareness
- Occupants of buildings will be made aware of the existence of the Asbestos O&M Program, and will be provided access to this document upon request. Occupants should presume that most building materials (e.g., ceiling tile, floor tile, wall materials, pipe insulation) may contain asbestos and should exercise caution to assure suspect ACM is not to be damaged or disturbed except under controlled conditions by trained personnel. Occupants may review asbestos-related building survey records specific to their building or work area either by contacting their designated departmental safety representative or EHS at 231-2509.
- Prior to the start of an asbestos abatement project, additional information will be provided to building occupants that will explain the work that is to be performed, and the measures that are being employed to protect them. This information will be made available either at group meetings, or by letter, the use of media resources, or a combination of the above.
2.2.2 Building Preventative Maintenance and Custodial Supervisors
Preventative maintenance personnel and custodial supervisors should coordinate with their departmental safety representative to assure they know the location of all suspect and known ACM in the buildings for which they are responsible.
2.2.3 Request for Suspect ACM to be Sampled
It is the mandate of the Virginia Department of Labor and Industry and the administration of Virginia Tech, that no renovation, alteration of a building material, or maintenance activity will occur that has not been reviewed either by EHS, the designated departmental safety representative or a licensed asbestos consultant for the possibility of contact with, or disruption of, ACM, or the presence of damaged or deteriorated ACM in the work area.
Each department performing the following types of activities must implement a system to assure all suspect asbestos materials that may be disturbed are identified and removed using approved procedures or that proper precautions are taken to avoid the material:
- Conduct maintenance, renovation or repair activities
- Conduct work in asbestos contaminated work environments (e.g. pipe chases, crawlspaces or other building areas where deteriorated or damaged ACM may be present)
- Work with ACM during machinery repair (for example, during the replacement of asbestos brake shoes or clutch pads)
- Conduct any work or operation that potentially impacts ACM.
Departmental Safety Representatives who have suspect asbestos materials analyzed, coordinate asbestos abatement or repair activities, or perform air sampling will coordinate with EHS to assure this information is maintained in a centralized repository.
2.2.4 Building Signage
- Signs and Labeling of ACM
Facilities Services and Student Affairs will maintain a labeling program to identify known ACM in university buildings under their purview. The number and location of these signs or labels shall be sufficient to clearly identify ACM in routine maintenance areas. Labels shall conform to current OSHA Asbestos standards.
Non-asbestos thermal system insulation (TSI) installed in areas with existing ACM TSI shall be labeled as either "Asbestos Free" or "Non-asbestos" by the installer. If the non-asbestos product is installed in-line with existing ACM (for example, on the same run of pipe), then the boundary between ACM and non-ACM shall be clearly delineated.
Signs or labels will be substituted by employee training and the distribution of records in accordance with this program for some types of ACM. These types include: asbestos-containing floor tile and linoleum, asbestos-cement ceiling tile and ductwork, and other types of non-friable ACM maintained in good condition and repair.
Reasonable precautions shall be taken to ensure that labels remain visible. During painting or other operations where labels will be hidden or covered, existing labels shall either be removed and new labels affixed after painting, or existing labels shall be otherwise protected.
- Contaminated Building Areas
Signs conforming to the current OSHA standards shall be posted restricting access to building areas that are contaminated with ACM debris where it has been demonstrated, or can reasonably be expected, that airborne asbestos fiber concentrations exceed the permissible exposure limit (PEL) (e.g. regulated area). Signs shall read:
DANGER
ASBESTOS
CANCER AND LUNG DISEASE HAZARD
AUTHORIZED PERSONNEL ONLY
RESPIRATORS AND PROTECTIVE CLOTHING
ARE REQUIRED IN THIS AREA
A secondary sign shall be posted that will direct the worker to contact EHS @ 231-2509 for assistance.
Signs shall be posted restricting access to building areas that are contaminated with ACM debris where airborne asbestos fiber concentrations do not exceed the PEL. Signs shall read:
WARNING
AREA CONTAMINATED WITH ASBESTOS DEBRIS
AVOID CREATING DUST
AUTHORIZED PERSONNEL ONLY
CONTACT EHS @ 231-2509 FOR ACCESS
Access to contaminated building areas may be restricted by limiting the availability of keys to these areas to personnel with appropriate asbestos-related training, who will enter only under the supervision and/or direction of EHS personnel.
2.2.5 Contractor Awareness Program
Contractors employed by the university shall be informed by the project supervisor or designated Departmental Safety Representative of the location of suspect and known ACM in the work area to which they are assigned. Contractors shall, under no circumstances, damage or disturb suspect or known ACM unless they are a licensed Asbestos Abatement Contractor and have been specifically employed to perform asbestos removal.
The project supervisor shall provide contractors with a copy of the asbestos inspection report specific to their work and the materials that are to be disturbed.
The university project manager shall caution contractors that they shall not proceed with any change in work that requires that a material be disturbed that the inspection report shows has not been previously tested (e.g. "suspect" ACM). If a change in the scope of work becomes necessary, a new request shall be submitted using the departments designated procedure.
It will be the responsibility of the contractor to provide their own asbestos awareness program that complies with OSHA requirements.
2.3 Building Surveys, Inspections, and Condition Assessments
2.3.1 General
Building inspections for the presence and condition of ACM shall be performed in accordance with the asbestos survey standard for buildings to be renovated or demolished as promulgated by the Environmental Protection Agency's National Emission Standards for Hazardous Air Pollutants, and enforced by the DOLI. Buildings built after January 1, 1978 shall not be exempted unless suitable documentation can be obtained that certifies that installed materials are asbestos free. A copy of the current survey standard may be obtained by contacting EHS at 231-2509.
2.3.2 Reassessment of ACM and Suspect ACM
Facilities Services and Student Affairs shall assure that the condition of all known or suspect ACM is periodically assessed as required. Any change in material condition shall be noted during this inspection and, if necessary, the relative hazard posed to building occupants by this material shall be assessed. A complete record of these assessments shall be maintained by the Departmental Safety Representative. Any building inspection, abatement or air monitoring reports generated by a consultant shall also be maintained by the Departmental Safety Representative and shall be made available to EHS.
2.3.3 Capitol Projects
Facilities University Design and Construction shall secure the services of a licensed Asbestos Inspector to collect samples of suspect ACM that will be damaged or disturbed by the proposed work. The inspecting agency shall prepare an inspection report in accordance with the survey standards detailed herein. The report shall include an assessment of damaged or deteriorated ACM in the work area as well as ACM in other building areas that may be damaged or disturbed by the proposed work (e.g. through traffic, construction induced vibration, and so forth). The inspecting agency shall be provided access to EHS records and sampling data for the building(s) in question.
2.3.4 Leased Properties
- Existing and New Leases
In accordance with the directive of the Virginia DOLI, the university shall take necessary precautions to ensure that no additional leases are entered or existing leases extended in buildings which contain friable asbestos which could subject employees or clients to health risks.
- Assessment of Existing Leased Spaces
In accordance with the directive of the Virginia DOLI, the agency is responsible for the assessment of existing leased spaces for friable asbestos. This assessment shall, if possible, be performed through the landlord, and shall conform to current state asbestos inspection standards.
ACM not posing a hazard, as indicated in the asbestos inspection report for the facility, need not be removed as a condition for lease with the Commonwealth. An effective management plan, however, must be developed and implemented by the building owner if the ACM is to remain safely in-place.
A copy of the management plan and inspection report for the facility shall be provided to EHS and shall be made accessible to building occupants.
- Renovation of Leased Property by University Personnel
Requests for sampling of suspect ACM associated with renovation or demolition work conducted or supervised by in-house personnel shall be coordinated through the Office of University Planning and shall be conducted by a licensed Asbestos Inspector.
The removal, repair, encapsulation, enclosure or alteration of asbestos materials in leased spaces shall be the responsibility of the building owner even if the renovation or demolition project is being conducted at the request of, or is being supervised by, university personnel. These asbestos activities must also be conducted by a licensed Asbestos Worker.
2.4 Exposure Monitoring
2.4.1 Personal Air Samples for University Personnel
The Departmental Safety Representatives for Student Affairs, Facilities Service and Communications Network Services shall conduct personal air monitoring and project clearance sampling as needed or required, or shall coordinate such monitoring with EHS as necessary. The results of all air samples taken shall be provided to EHS. Historic sampling data may only be used if previous samples were taken during an asbestos project involving similar material types under similar material and environmental conditions.
A copy of personal air sampling results shall be submitted to the employee for which the samples were secured within 15 days of receipt from the laboratory.
2.4.2 Personal Air Sampling for Non-university Personnel
Asbestos abatement contractors shall be responsible for securing air samples for their own personnel to meet the requirements of 29 CFR 1926.1101.
2.4.3 Air Sampling during Asbestos Projects
A licensed Project Monitor is required for all asbestos abatement projects performed in buildings that are occupied or intended to be occupied upon completion of the asbestos project, and the removal exceeds 260 linear feet, 160 square feet, or 35 cubic feet of ACM. The project monitor shall secure baseline (e.g. background) air samples before the start of the project, if necessary, and shall secure air samples outside of the work area during the project. The project monitor will, in addition, perform a final visual inspection and will secure final clearance air samples using aggressive air sampling techniques (if required) as outlined in 2.1-526.14:1 of the Code of Virginia.
The work area will be considered safe for re-occupancy if all final clearance air samples are less than 0.01 fibers per cubic centimeter (f/cc) of air sampled as determined by Phase Contrast Microscopy (PCM).
Aggressive air sampling will not be performed if the work area is not contained and is not under negative pressure.
In the event that baseline air samples indicate that the background particulate load will not allow the use of PCM for analysis of final clearance air samples, and if it is not possible to establish a clean source of make-up air to the work area, then final clearance samples shall be analyzed using Transmission Electron Microscopy (TEM) in accordance with 40 CFR, Part 763.
The cost for analysis of air samples associated with asbestos projects shall be borne by the department initiating the work.