Environmental Health and Safety

Asbestos O & M Program

Roles and Responsibilities

The Asbestos Operations and Maintenance Program is administered by Environmental Health and Safety, along with Designated Safety Representatives from those departments involved in asbestos-related activities.


Departments involved in work-related activities where asbestos-containing materials (ACM) may be disturbed during maintenance, custodial, renovation, or demolition activities shall:

  • Designate a safety representative specifically to address asbestos activities.
  • Manage projects involving asbestos abatement.
  • Retain project documentation in such a manner that it is available upon request to EHS, VOSH, or others as necessary.
  • Update electronic information regarding location of materials in campus facilities.
  • Serve as administrator for university contracts for analytical, inspection, project monitoring and abatement activities (with input from EHS).
  • Ensure Asbestos Worker, Operations and Maintenance, Asbestos Supervisor, Asbestos Inspector, and Project Monitor training is provided (by a third party) to employees involved in asbestos activities.
  • Maintain a labeling program to identify known ACM in buidings under their purview.

Designated Safety Representative (DSR)

Renovation, demolition, alteration of a building material (i.e. wall, ceiling, floor, insulation, etc.), or maintenance activities which may disturb ACM shall not occur unless it has been reviewed and approved by the DSR. Designated departmental asbestos safety representatives are responsible for the following:

  • Serving as Asbestos Inspector for their department.
  • Inspecting work sites and sampling suspect bulk materials for asbestos (if historical information isn't available).
  • Maintaining records and communicate results to relative parties for upcoming projects (i.e. supervisors, project managers, contractors, etc.) on the "Asbestos and Lead Inspection Report".
  • Providing or coordinating project monitoring services with the Project Manager during renovation and maintenance activities to protect the interests of the building occupants and the university.
  • Monitoring employee exposure during small scale abatement or maintenance activities.
  • Performing periodic reassessments of known ACM in campus buildings and documenting conditions and findings.
  • Maintaining current at least one person licensed/certified to conduct Project Monitoring and Asbestos Inspector duties.
  • Participating in quarterly meetings scheduled by EHS.
  • Any other duties and responsibilities as defined by Memorandums of Understanding as agreed upon between departments.

Departmental Safety Representatives who coordinate or perform asbestos-related activities include:

  • Gabe Lineberry (540-231-5776) for NI&S employees performing work tasks in various buildings on campus.
  • Dave Rettig (540-231-9397) for Division of Student Affairs (540-231-1111) buildings on campus.
  • Vacant (540-315-2396) for buildings covered by Facilities Services (540-231-4300) on campus.
  • Robin Miller (540-231-2341) for all other buildings on campus that do not fall under one of the above, or potential employee exposure.

Asbestos Supervisors

Departmental personnel performing asbestos-related activities shall be under the supervision of a currently trained Asbestos Supervisor. The Asbestos Supervisor shall meet the defintion of a Competent Person per OSHA, and shall ensure:

  • Employees performing custodial, maintenance, or small-scale, short-duration repair activities have been adequately trained to the appropriate level.
  • Work activities are conducted in a safe and healthy manner consistent with training and applicable regulations.
  • Personal protective equipment (PPE) is appropriate, available, and worn by employees engaged in asbestos activities.


Preventative maintenance and custodial staff should coordinate with their Departmental Safety Representative to assure they are aware of the location of all suspect and known ACM in the buildings for which they work in.

  • Employees involved in work activities which may accidentally disturb ACM shall recieve awareness level training from EHS annually.
  • Employees involved in asbestos repair or abatement activities shall maintain current the appropriate level of training/certification - Operations and Maintenance or Asbestos Worker/Supervisor.

Additional training or services may include, but is not limited to:


Environmental Health and Safety will provide technical support, employee exposure investigations, and oversight for this program; however, involvement by EHS does not relieve the departments, supervisors, or contractors of their individual responsibilities.  EHS responsibilities for this program include:

  • Developing, implementing, and administering the Asbestos Operations and Maintenance (O&M) Program, including delineation of responsibilities and standardized work procedures (SWP).
  • Providing awareness level training to custodial and maintenance personnel annually, and maintaining centralized training records.
  • Providing respiratory protection training and fit-testing to employees.
  • Serving as a technical resource for program application on campus.
    • Robin Miller, 231-2341
    • Zachary Adams, 231-5985
  • Conducting periodic audits and inspections of those departments performing asbestos-related activities to program requirements.
  • Responding to potential personnel exposure incidents and campus complaints as reported by the responsible DSR and/or Project Manager.
  • Retaining asbestos historical data/records and providing access to information to departments and building occupants.
  • Maintain an active list of abatement priorities based upon information gathered during the periodic reassessments of ACM.
  • Providing medical surveillance services for all employees involved in asbestos-related work, including chest x-rays. Issue notification letters when exposures occur.
  • Assisting Real Estate Management with preparation of disclosures and other legal documents for leased properties.
  • Scheduling quarterly meetings with DSRs to coordinate requirements of this program.


In accordance with 18VAC15-20-10, an Asbestos Contractor's License is required for firms that contract with another person, for compensation, to carry out an asbestos abatement project that exceeds 10 linear or 10 square feet. Contractors must comply with all local, state, and federal safety requirements, and must assure that all employees performing work on Virginia Tech property have been trained as an Asbestos Worker, and are provided appropriate personal protective equipment.

Multi-employer worksite rules also apply to asbestos projects. In accordance with 29 CFR 1926.1101(d):

  • Employers performing work requiring the establishment of a regulated area (Class I, II or III work), shall inform other employees on the site of:
    • The nature of the work with ACM or PACM,
    • The existance of and requirements pertaining to regulated areas, and
    • Measures taken to ensure that employees of other employers are not exposed to asbestos.
  • Asbestos hazards 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 safety measures to protect their employees.
    • For example, if employees working immediately adjacent to a Class I asbestos job are exposed to asbestos due to the inadequate containment of the job, their employer shall remove the employees from the area until the enclosure breach is repaired.
  • All employers of employees working adjacent to regulated areas (Class I, II or III work) established by another employer on a multi-employer worksite shall take steps on a daily basis to ascertain the integrity of the enclosure and/or the effectiveness of the control method relied on by the asbestos contractor to assure that asbestos fibers do not migrate to such adjacent areas.
  • All general contractors on a construction project which includes asbestos work covered by 29 CFR 1926.1101 shall be deemed to exercise general supervisory authority over the work even though the general contractor is not qualified to serve as the asbestos "competent person". As supervisor of the entire project, the general contractor shall ascertain whether the asbestos contractor is in compliance with OSHA requirements, and shall require the contractor to come into compliance, when necessary.

Contractor responsibilities for conducting asbestos work in Virginia are detailed 18VAC15-20-451.

The “Safety Requirements for Contractors and Subcontractors” program provides additional information for contractors on campus.