Asbestos and ACM Management Plan

Purpose

The purpose of this plan is to provide guidance for the proper management of asbestos-containing materials (ACM) on campus.

Scope and Applicability

This plan applies to worker health protection (TOSHA) and compliance with EPA regulations. This shall apply to anyone on campus who is potentially exposed to asbestos and to all buildings that contain asbestos and ACBM on campus. Specific roles are outlined for EHS, Facilities Services, Facilities Planning, Department Heads, and Employees.

Abbreviations and Definitions

Abbreviations

ACM– Asbestos Containing Materials

ACBM– Asbestos Containing Building Materials

EHS – Environmental Health and Safety

EPA – Environmental Protection Agency

NESHAP – National Emission Standard for Hazardous Air Pollutants

TOSHA – Tennessee Occupational Safety and Health Administration (or Act depending on context)

PACM –Presumed Asbestos Containing Material

TSCA – Toxic Substances Control Act

Definitions

Friable asbestos – materials that contain asbestos fibers and can be crushed by hand pressure.

Roles and Responsibilities

Employees who are likely to come in contact with ACM or PACM shall:

• Follow prescribed guidelines.
• Report any problems to their supervisor.

Department Heads who have employees who may come in contact with ACM or ACBM shall:

• Ensure these individuals receive the necessary training.
• Consult EHS at 974-5084 or Facilities Services at 974-5107 when questions arise.
• Ensure employees follow prescribed procedures.
• Report problems to EHS or Facilities Services.

Environmental Health and Safety shall:

• Conduct visual inspections of PACM during routine building inspections. Example – 9”x9” floor tiles, old pipe lagging).
• Notify the Facilities Services asbestos coordinator when problems are encountered.
• Support ancillary standards related to asbestos such as respiratory protection, personal protective equipment, heat stress, confined space entry, etc.

Facilities Services shall:

• Maintain records as necessary, including the database of sampling and results.
• Identify departments who have personnel who are likely to be exposed to PACM or ACBM and communicate to these departments the asbestos program Provide training upon request for asbestos awareness, or further courses as needed.
• Serve as the asbestos coordinator for buildings.
• Develop operation and maintenance plans related to asbestos as necessary
• Collect and have samples analyzed for ACBM or PACM.
• Have at least two individuals on staffs who are certified asbestos inspectors.
• Have at least one individual on staff who is certified as an asbestos project supervisor.
• Have at least one individual on staff who is certified as an asbestos monitor
• Notify building occupants of impending asbestos abatement work. Notification will be modified in the event of an emergency (e.g. water leak disturbing ACM or PACM).
• Serve as the contract manager and abatement supervisor for the University’s asbestos contractor for projects that fall under Facilities Services.
• Have buildings and structures scheduled for renovation or demolition checked for ACM and abated by a certified asbestos contractor before it can be disturbed.

Facilities Planning shall ensure that:

• Buildings and structures scheduled for capital renovation or are checked for ACM and abated by a certified asbestos contractor before it can be disturbed.
• Only certified asbestos contractors manage ACM.
• Complaints during capital projects are adequately addressed.
• Records are maintained as necessary related to asbestos in capital projects.

Plans/Programs

Routine Inspections:

• EHS will inspect buildings on campus annually and look for friable asbestos.
• When suspect material is encountered, it shall be treated as PACM.
• Sampling by certified asbestos inspectors may be necessary to confirm the presence of ACM.
• If the PACM is damaged and exposure is likely, the area shall be secured, signs posted and other efforts made to prevent accidental exposure.

Complaints:

• EHS or Facilities Services shall investigate complaints involving asbestos.
• Steps “a-d” for routine inspections shall be followed
• EHS or Facilities Services shall communicate the findings to the complainant
• Any asbestos complaint to EHS involving Facilities Services personnel or contractor shall include the Facilities Services asbestos inspection immediately.

Planned Abatement:

• Facilities Services or Facilities Planning shall notify the building representative of the building where abatement will occur as early as possible. At least 24 hours before the start of work signs shall be posted on all the outside doors.
• Notification will be made by posting signs at the entrances to the area where work will occur, contacting the building representative and requesting the information be conveyed to occupants, as well as posting signs at all of the outside entrances.
• The contractor shall follow all State OSHA and EPA standards regarding asbestos abatement.

Disposal:

Asbestos is considered a special waste in Tennessee and as such a permit is required by the Tennessee Department of Environment and Conservation, Division of Solid Waste.

• Contractors licensed to manage asbestos shall be responsible for obtaining, maintaining and following the requirements related to their permit.
• Incidental waste asbestos that is generated by processes other than construction may be managed through the University’s hazardous waste program administered by EHS.

Recordkeeping

The following records shall be kept indefinitely, except as otherwise noted.

• Sampling (bulk)
• Sampling air (personal and area)
• Sampling clearance
• Complaints
• General building inspections – minimum 10 years
• Asbestos building inspections
• Training records – minimum three years

Training and Information

Awareness

General awareness training shall be provided to all employees who are likely to disturb ACM. Training may be obtained from EHS or other means.

Inspectors, Supervisors, Monitors and Management Planner

Facilities Services and EHS shall have employees who are trained as asbestos inspectors, monitors, supervisors and asbestos management planner.

Building Occupants

Building occupants shall be notified of asbestos abatement activities in advance by signs, e-mail, and contacting the building representatives.

Contractors

Contractors performing renovation, maintenance, repair, and similar activities shall be notified before work commences.

General Posting

Warning signs shall be conspicuously posted in areas where asbestos is known to be present and likely to be disturbed.

References

OSHA General Industry Standard 29 CFR 1910.1000

OSHA Construction Standard 29 CFR 1926.11.01

EPA 40 CFR 763 (TSCA)

EPA 40 CFR 61 part M (NESHAP)

Disclaimer

The information provided in these guidelines is designed for educational use only and is not a substitute for specific training or experience.

The University of Tennessee Knoxville and the authors of these guidelines assume no liability for any individual’s use of or reliance upon any material contained or referenced herein. The material contained in these guidelines may not be the most current.

This material may be freely distributed for nonprofit educational use. However, if included in publications, written or electronic, attributions must be made to the author. Commercial use of this material is prohibited without express written permission from the author.