Asbestos O & M Program

Disturbance of Suspect Friable ACM

OSHA defines a "disturbance" as an activity involving ACM or presumed ACM (PACM) that disrupts the matrix, crumbles or pulverizes, or generates visible debris. Suspect asbestos-containing materials (ACM) may be unintentionally disturbed by building occupants, custodial staff, or contractor personnel. A change in material condition (i.e. water damage, deterioration, and air erosion) may cause ACM to physically breakdown and separate from its substrate (ceiling, walls, piping, flooring, etc.). Asbestos fibers may also be accidentally released when a breach occurs in a regulated containment area where abatement activities are taking place.

As a result of conditions where there is a potential for airborne asbestos fiber release, the is a risk of inhalation of fibers by building occupants in the immediate area. Fiber release episodes are categorized as "minor" or "major". Whether the disturbance is intentional, unintentional, minor or major, the debris must be promptly cleaned up by asbestos-trained personnel ONLY to minimize further distribution of the debris into the environment.

• Minor fiber release episodes occur when a disturbance of ACM causes debris less than 3 square feet or 3 linear feet.
  • This debris can be cleaned up by departmental personnel who have Operations & Maintenance (O&M) training.
• Major fiber release episodes occur when a disturbance of ACM causes debris greater than 3 square feet or 3 linear feet.
  • This debris may require cleanup by personnel certified as Asbestos Workers.

Response

In accordance with 29 CFR 1926.1101(d)(2), asbestos hazards on a multi-employer work site shall be abated by the contractor who created or controls the source of the asbestos contamination. For example, if there is a significant breach of an enclosure containing Class I work, the employer responsible for erecting the enclosure shall repair the breach immediately. All employers of employees exposed to asbestos hazards shall comply with applicable protective measures to protect their employees. This may include either removing their employees from the area until the enclosure breach is repaired, or perform an Initial Exposure Assessment in accordance with 29 CFR 1926.1101(f)(2).

If you believe that a minor or major fiber release episode has occurred in your work area, the following procedures should be taken to minimize the spread of asbestos fibers:

• Direct all occupants in adjacent areas to leave the affected area. Notify your immediate supervisor.
• Secure the area by locking all access points to the space. It would be prudent to post a sign indicating "Access to space has been temporarily restricted". If the debris is in a public space and the area cannot be secured, use alternate means to isolate the immediate area, such as rope, caution tape, wet-floor A-frame signs, etc. to prevent pedestrian traffic in the area. Provide a building contact on the warning sign, if possible.
• For cleanup and response actions, notify the Departmental Safety Representative (DSR) at one of the customer service lines listed below:
  • Facilities Services at 231-4300 for academic and administration buildings, or renovation projects.
  • Division of Student Affairs at 231-1111 for residential and dining buildings, or renovation projects.
  • After hours incidents should be reported to VT Police at 231-6411.
• Notify EHS at 231-3600 for all other locations, or when there is a potential employee or general public exposure.
  • Any personnel expressing concerns about potential exposure to friable ACM should complete and Employer’s Accident Report. 
  • EHS will determine what area air monitoring will need to be performed.
  • EHS will assist in determining what response actions need to be taken, if necessary.

Disturbance of Suspect Non-Friable ACM

If the debris is considered non-friable, such as floor tile in good condition, there is little chance of fibers being released; however, the coordination of prompt cleanup should still be conducted immediately by the appropriate Departmental Safety Coordinator.

Documentation

The responsible Departmental Safety Coordinator responding to the disturbance shall maintain documentation regarding the event, and shall notify EHS immediately (if not already notified). Depending on the severity of the fiber release, asbestos abatement contractors may be needed to develop a strategy for conducting cleanup operations. The following information must be included:

• Date of the event
• Location of the event (building and room number)
• Type of ACM that was disturbed (friable, non-friable, floor tile, pipe insulation, etc.)
• Potential cause of the disturbance (water damage, accidental contact, deterioration, etc.)
• Actions taken to prevent spread of fibers (cover/seal air ducts, shut off HVAC in area, etc.)
• Names and contact information of persons concerned about possible exposure to asbestos fibers
  • Note: OSHA defines employee exposure as the exposure to airborne asbestos that would occur if the employee were not using respiratory protection.
• Names of departmental workers or contractor personnel who will be performing cleanup activities
• Date the cleanup was completed
• Quantity of properly labeled bags used to collect the debris
• Means of disposal of accumulated waste and appropriate waste manifest, if applicable

The Departmental Safety Coordinator is also responsible for notifying appropriate departmental management to ensure properly asbestos-trained personnel conduct the cleanup of ACM debris. Any area having a fiber release episode involving the disturbance of friable ACM shall be cleared by an accredited Project Monitor using either Phase Contrast Microscopy (PCM) or Transmission Electron Microscopy (TEM) air sampling.