Asbestos Operations and Maintenance Plan Policy #8

SUNY Cortland

Asbestos Operations and Maintenance Plan Policy #8

ASBESTOS OPERATIONS AND MAINTENANCE PLAN

Contents:

1.Introduction

2.Warnings and Notifications

3.Employee Training

4.Inspections

5.Routine Work Practices

6.Record-keeping

7.Medical Surveillance

8.Emergency Response

9.AppendixA-GeneralBuilding Survey

10.Appendix B-Controlled Area

1. Introduction

This program has been prepared and implemented to eliminate or minimize the possibility of exposure to asbestos for students, employees and visitors to SUNY Cortland. Asbestos has been used as pipe insulation and coverings, boiler and tank insulation, patching compounds, fire proofing, roof felts, acoustical plasters, etc. The buildings on the SUNY Cortland campus contain asbestos in a variety of forms. This policy is designed to create a system whereby these materials are inspected, maintained, and repaired to prevent their deterioration to the point of releasing fibers.

In 1986, the State University of New York authorized Hall-Kimbrell Environmental Services, Inc. to conduct an asbestos inspection of the campuses in the SUNY system. Samples of suspect materials were collected and analyzed. The resultant report shall be referred to as the “Hall Kimbrell Report” and is available for inspection at the library. (The report is also on file at the following offices: Environmental Health & Safety, Facilities, Physical Plant, and Heating Plant.) The Hall Kimbrell Report identified asbestos containing materials and prioritized these materials at SUNY Cortland based on the potential for exposure to workers and other building occupants. Those having a high degree of exposure potential will be addressed first (usually through abatement (removal), encapsulation, or enclosure), and those having a lesser degree can be controlled for a longer period of time via this Operations and Maintenance Plan.

An Operations and Maintenance Plan is designed to minimize the possibility of accidental disturbance of the asbestos-containing materials and to protect workers and other building occupants who must work around these materials. The parts of this O&M Plan are:

•a written plan or statement of intent;

•a warnings and notification system (Part II);

•a provision for the training of employees who will come in contact with the materials (Part III);

•a periodic, routine in-house monitoring or inspection system (Part IV);

•a thorough recordkeeping system (Part IV);

•a medical screening program for high risk workers;

•Emergency Response Procedures (Part VII).

2. Warnings & Notifications

Information

General information concerning the presence of asbestos will be given to the building occupants in various educational sessions as described further in Part III. Building occupants who wish to learn more about asbestos in the buildings may feel free to contact the Asbestos Coordinator (Environmental Health & Safety Officer, X2508, or Facilities Program Coordinator, X2214) or review the Hall Kimbrell Report, a copy of which is located in the library. Appendix A lists those buildings which contain any asbestos materials. Maintenance staff is required to check with their Supervisor to determine if their work will disturb any asbestos prior to commencing such work (although this review is frequently completed prior to the assignment of the task).

Controlled Area Stickers

Controlled area stickers are for those areas generally accessed by custodians, maintenance workers, or contractors but not by the general public. (Identification of these areas is located in Appendix B.) The sticker is usually placed on the door, in plain sight and easy to view. The sticker informs people that they are entering an area containing asbestos materials and that their activities may disturb these materials. If the work includes removal, repair, or other disturbances of asbestos containing materials, the worker must obtain approval from the campus Asbestos Coordinator and fill out an Asbestos Work Order form (Appendix C). [In some buildings, rather than posting each entrance, a notice will be posted in the Custodian’s Office that all activity in a certain area of the building is prohibited unless authorized by the Asbestos Coordinator (e.g. “No entering above drop ceilings.”).]

Caution Stickers

In conjunction with the controlled area stickers, caution stickers will be used in the controlled areas to designate which materials contain asbestos. In a typical boiler room, stickers were placed on all equipment and mechanical systems which are insulated with asbestos covering, such as boilers, tanks, ducts, breaching and pipes. If the ceiling is fireproofed with asbestos containing materials, the stickers were placed on the walls about six inches beneath the material. Before any work is done on materials labeled with a caution sticker, approval must be obtained via the Asbestos Work Order Form from the campus Asbestos coordinator. [Again in some areas, general instructions about asbestos containing materials will be placed in a notice on the Custodian’s Office or on a plaque near the equipment of concern.]

3. Employee Training

General Occupants

The Asbestos Coordinator will make available periodic seminars for the occupants of the buildings on the topic of asbestos. If any occupant has a question they should feel free to contact the Asbestos Coordinator for the answers to their specific questions.

Custodial & Maintenance Personnel

Key elements in initiating and carrying out a functional Operations and Maintenance Plan are the Maintenance and Custodial staffs. These groups may be responsible for the routine cleanup of dust (which may contain very small quantities of asbestos fibers) from walls, floors, furniture, etc., using specialized mopping, vacuuming, and wiping techniques. It is these groups that also have the greatest risk of encountering or disturbing asbestos materials in the course of their work. (It is intended that only New YorkState certified asbestos handlers will work with or disturb asbestos).

The training of this group of employees basically covers the following topics: •General background on asbestos, explanation of Operations and Maintenance Plan, abatement efforts to date

•Medical review of asbestos related illness and mechanisms of exposure

•Use of HEPA Vacuums

•Use of special cleaning methods, disposal of cleaning materials, and techniques to replace dusting

4. Inspections

Regular

It is expected that all personnel will report any deterioration involving any asbestos containing materials to their Supervisor. This responsibility is particularly emphasized for Maintenance and Custodial personnel as they have received additional training and their jobs take them to various locations where asbestos may be damaged.

Semi-annual

The campus Asbestos Coordinator will coordinate an in-depth semi-annual inspection of each building reported to contain friable asbestos-containing materials.

Air Sampling

Air sampling for asbestos will be conducted on a periodic basis usually associated with the semi-annual inspections. Areas to be sampled will be chosen by the Asbestos Coordinator on the basis of potential hazard and/or specific concerns. The results from air sampling will be available to interested parties through a written request to the Asbestos Coordinator.

5. Routine Work Practices

All individuals who work with asbestos in any capacity will be required to follow the work procedures as stated by the most current version of Code Rule 56. (Only members of the Special Response Team will do any asbestos work.) If there is any ambiguity in the application of the rules, the Asbestos Coordinator should be contacted for any interpretation and/or advice. The Hall Kimbrell Report lists recommendations for various types of asbestos repairs and the section of the report may act as a supplement to Code Rule 56. (See pages II. 18-26 in Volume V of the Hall Kimbrell Report.)

6. Record Keeping

The originals of all documents pertaining to this Operations and Maintenance Plan are kept on file in the office of the campus Asbestos Coordinator. The standard documents kept on file in the Asbestos Coordinator’s office will be the Operations and Maintenance Plan, report of survey and laboratory analyses, amendments to report of surveys and analyses, semiannual inspection documents, and lists of authorized asbestos workers.

7. Medical Surveillance

All individuals who are members of the Special Response Team will receive annual physicals during the time that they are active on the team. They will also receive a final physical examination when they cease to be members of the team and/or when they terminate their employment with the College. The physical exam will be based on the recommendations made by OSHA for the medical surveillance of asbestos workers. Records associated with these exams will be maintained in the Environmental Health & Safety Office.

Should any other personnel have a significant exposure to asbestos; the Environmental Health & Safety Officer will make recommendations for medical surveillance.

8. Emergency Response

During the time from implementation of the Operations and Maintenance Plan until the removal of the asbestos-containing materials, it may become necessary to remove or encapsulate material that has or may soon become friable.

Minor/Significant/Major Episodes

In general it is useful to separate incidents into three classes: minor episodes, significant episodes, and major episodes. (It is important to note that the following definitions are listed to assist in decision making for the Asbestos Coordinator. They do not direct his/her actions past the requirements of Code Rule 56 and other regulations. The criteria need to only be taken into account along with other factors. For example, a four square foot asbestos ceiling delamination in a frequently used hallway may be treated quite differently from the same size episode in an infrequently used mechanical room.

A minor episode is defined as one where the total amount of asbestos is less than three square feet or less than three linear feet. The area will be isolated and the Special Response Team will clean up the area. Usually, no air monitoring is required.

A significant episode for this plan is one that includes asbestos of more than three square or linear feet, but less than 10 square feet or 25 linear feet. The area will be isolated and the Special Response Team will clean up the area. Air monitoring is required when the glove bag or tent fails or is not used.

When the total amount of asbestos involved in an incident is greater than that defined by Code Rule 56 as a minor project, i.e. More than 10 square feet or 25 linear feet, it is a major episode, the area will be isolated upon the discovery, and usually an outside contractor will be brought on site to review the plans and proceed with the repair. Notifications to the Department of Labor and/or the Environmental Protection Agency are generally required. Air monitoring is generally required.

There are three primary situations where an emergency measure could become necessary: water damage, delamination, and glove bag removal situations. Following are instructions for dealing with those situations on the minor or significant episodes magnitudes.

(A)Water Damage

If asbestos ceiling material becomes heavily water damaged from roof leaks, the material will become swollen and lose its bonding capability. During this stage, the white “snowflake” material releases many more fibers into the air than undamaged material. To retard fiber release the material should be encapsulated with a very light bridging encapsulant or the material should be removed. This procedure should only be used for lightly damaged areas. Although each situation could call for modification of the encapsulation procedure, the basic procedure to encapsulate a small water damaged area is:

•Isolate the area. Unauthorized personnel should be prevented access by appropriate signage, locks, and/or barricades. Only those individuals using appropriate respirators and protective overalls will be allowed to enter the area.

•The HVAC system outlets should be sealed and the system shut down.

•Move all movable fixtures away from the area with water damage after wet wiping and/or HEPA vacuuming.

•Place 6 mil polyethylene on the floor and wall (if damage is within a few feet of the wall).

•Patch the area of the roof where the leakage is occurring. Allow at least 24 hours before proceeding with encapsulation.

•Wearing disposable coveralls and respirators, HEPA vacuum the damaged area holding the nozzle ½” to 1” from the material and make several passes over the material.

•With an airless sprayer or compressed air sprayer set to a fine mist, lightly coat the damaged area with encapsulant. Apply the encapsulant with the sprayer held 8”-12” from the material and apply in several passes over the material.

•Allow 4-8 hours for fibers to settle. Dispose of plastic and asbestos debris and clean the surrounding area by wet wiping and/or HEPA vacuuming.

(B)Delamination

In some cases the asbestos-containing ceiling material, through water damage or building vibration, has become dislodged and physically separated from the substrate. The material is then ready to break off and fall to the floor, thereby releasing many fibers into the air. The dislodged material should be removed in the following method:

•Isolate the area. Unauthorized personnel should be prevented access by appropriate signage, locks, and/or barricades. Only those individuals using appropriate respirators and protective overalls will be allowed to enter the area.

•The HVAC system outlets should be sealed and the system shut down.

•Wet wipe and/or HEPA vacuum and remove furniture and place plastic in the area of the fiber fallout.

•Wearing disposable coveralls and respirators, HEPA vacuum the damaged area holding the nozzle ½” to 1” from the material and make several passes over the material.

•Must the area to be removed with amended water.

•With a utility knife or other cutter, slice through the material to the substrate around the area which is dislodged.

•With one worker holding the HEPA nozzle equipped with a spread cone close to the material, gently remove the dislodged material using a putty knife and place in the cone and/or disposal bag.

•Re-vacuum the area.

•Spray a light coating of colored encapsulant on and around the area to retard further fiber release.

•Dispose of plastic in disposal bags and wet wipe and HEPA vacuum the area.

(C)Glove Bag Removal

In the event that mudded joint packing or pipe covering becomes deteriorated, damaged, or if the material requires removal to work on pipes, valves, elbows, etc., the material must be removed by “glove bag” operations:

•After sealing off the work area and HVAC system and donning respirator and coveralls, cut the sides of the glove bag to fit the size pipe to be worked on and insert the tools needed into the attached tool pocket.

•Attach the glove bag to the working area by folding the open edges together and sealing with staples and tape. (Remember, this sealed area will be supporting the weight of the debris; additional support may be necessary.)

•Seal the edges of the glove bag around the working area with tape or “Velcro” ties to form a tight seal. Slice open the side port to allow entry of the wetting nozzle and HEPA vacuum hose. Insert the nozzle from the portable sprayer and thoroughly wet the area to be removed. The HEPA vacuum hose may then be inserted into the side port and sealed with duct tape.

•Insert arms into the armholes and gloves and proceed to remove the asbestos from the valve fitting and pipe. Insert a spray nozzle and spray the pipe and any remaining insulation with encapsulant. When the job has been completed, turn on the HEPA vacuum to remove air from the bag.

•With the air being removed from the glove bag, squeeze the bag tightly (as close to the top as possible) and twist seal and tape closed to keep the asbestos material safely at the bottom of the bag. Turn off the HEPA vacuum and remove the hose from the side port, taking care to seal the side port with staples and duct tape.

•The glove bag may now be cut and removed from the working area, placed into another plastic bag, and disposed of properly.

•Precede to HEPA vacuum the work area for any residual materials.

•Once all pipe insulation has been removed, decontaminated and disposed of according to these specifications, the entire work area shall be wet cleaned and/or HEPA vacuumed.

Any time an area of asbestos-containing material has to be encapsulated or removed, it must be recorded and the controlled copies of the Hall Kimbrell Report will be modified.

Whenever, any asbestos containing material is removed and then replaced with a substitute material, the new material must be clearly labeled as being asbestos free.

Appendix A

Buildings with No Suspect Material

Davis Field Press Box

McDonald Garage

Buildings with All Suspect Material Analyzed as Negative

None

Building with Asbestos Containing Materials

Old Main

President’s Residence—Graham Avenue

MillerAdministrationBuilding

MoffettCenter

Memorial Library