UVa Seal

Policy: Asbestos-Containing Materials Management 


Date: 06/30/05 Policy ID: SEC-007 Status: Final

Policy Type: University
   
Contact Office: Environmental Health and Safety
   
Oversight Executive: Vice President for Research
   
Applies To: Academic Division and the Medical Center.
   
Table of Contents: 

Policy Statement
Procedures

   
Reason for Policy: 

In order to prevent harmful exposures to asbestos, and to ensure compliance with all local, state and federal regulations, including OSHA 29 CFR 1926.1101, OSHA 29 CFR 1910.1001, EPA 40 CFR 61, EPA 40 CFR 762, EPA 40 CFR 762 & 763, the Virginia Administrative Code and the Virginia Department of Professional and Occupational Regulation.

   
Policy Summary:  Asbestos-Containing Materials within University of Virginia buildings must be properly managed.
   
Definition of Terms in Statement: 

Asbestos-Containing Materials (ACM): Materials that contain greater than 1% asbestos by laboratory polarized light microscopy (PLM) analysis.

ACM Inspection: Inspection of a building or portion of a building by a State Licensed Asbestos Inspector for ACM, which includes taking samples of suspected ACM, the analysis of these samples by a State Licensed Asbestos Analytical Laboratory using PLM, and a report summarizing the types and locations of identified ACM.

ACM Management Plan: Plan developed by a State Licensed Asbestos Management Planner which describes how ACM will be properly managed in-place, while einsuring the safety of building occupants, visitors and maintenance/custodial personnel, until such materials can be properly removed.

ACM Abatement Project: The removal of ACM by a State Licensed Asbestos Abatement Contractor with Licensed Abatement Workers and Supervisors using methods specified by a State Licensed Asbestos Abatement Project Designer.

ACM Abatement Project Monitoring: Daily inspections of asbestos abatement activities conducted by a State Licensed Abatement Project Monitor, that include confirming integrity of work site enclosures, abatement equipment, worker credentials, regulatory and specifications compliance, and taking air samples during and after abatement to ensure a healthy environment for University of Virginia faculty, staff and students and/or future occupants of the area(s) involved.

Friable ACM: ACM that can be crumbled, pulverized or reduced to a powder by hand pressure, and when disturbed, readily releases asbestos fibers into the air.

Project Manager: University of Virginia representative who may be the Facilities Management Project Manager, Maintenance Superintendent, Cost Center Manager, or other person who either oversees, plans, supervises or arranges for a maintenance, construction, renovations or demolition project within University of Virginia facilities.

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Policy Statement: 

ACM within University of Virginia buildings must be properly managed. Any UVA building constructed prior to 1988 may have ACM in it. Many building materials must be presumed to contain asbestos until properly tested and proven asbestos-free.

Environmental Health & Safety (EHS) maintains records of all past ACM inspections within UVA buildings and all past abatement/repair activities. EHS provides asbestos awareness training classes to maintenance and custodial employees to inform them of the dangers of ACM, help them to recognize suspected ACM, and instruct them on how to report damaged ACM. Where necessary, EHS provides Asbestos Operations and Maintenance training to UVA employees, as determined by their department, who are responsible for working in asbestos-contaminated work sites, who must repair ACM or remove small quantities of non-friable ACM.

To prevent accidental disturbance of ACM, which could lead to airborne asbestos hazards, EHS performs inspections prior to maintenance, renovations or demolition projects to determine what materials contain asbestos. Disturbance of these identified ACM must either be avoided during the projects or the ACM properly removed or repaired prior to these projects. If ACM abatement or repairs are necessary, EHS designs and monitors theses activities as well.

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Procedures: 

All UVA faculty, staff and students must follow these procedures in buildings constructed prior to 1988:

  1. Prior to any maintenance or construction project that could disturb building materials, or involve work in areas where ACM may be present, the Project Manager (PM) shall first contact EHS to request a hazardous materials inspection. A representative from EHS shall discuss the project scope with the PM and review past inspection records. If the area(s) in question has already been inspected, a copy of the report shall be sent to the PM. If an inspection is needed, the PM shall meet an EHS representative on site and provide a floor plan which specifies the area(s) and scope of work involved with the project. The EHS representative will perform the inspection, take samples where necessary and submit them to a laboratory for PLM analysis. Once the results of this testing are received, EHS will send a report to the PM detailing types and locations of the identified ACM.
  2. Unless EHS determines the identified ACM are in stable condition and will not be disturbed by the planned project, the ACM must either be properly repaired or removed prior to the project. All ACM repair or removal activities must be designed by EHS, performed only by State Licensed and/or OSHA trained asbestos professionals, and the activity monitored by EHS. The PM must contact EHS well in advance of a planned asbestos abatement/repair activity, to schedule the design and monitoring work.
  3. EHS will provide OSHA-required Asbestos Awareness training to all maintenance and custodial staff who work in UVA buildings constructed before 1988. Such training shall consist of a 2-hour initial course presented during the employee’s first year of employment, and an update course each year thereafter. This training is also offered to Contract Services employees who work in UVA buildings and who are not given such training by their employer. Attendees of these courses are trained in ACM recognition, regulations, health effects, personal protection and this policy.
  4. In addition to Asbestos Awareness training, UVA employees who are required to work in areas containing damaged or deteriorated friable ACM, must attend annual training by EHS in respiratory protection, personal protective equipment, the use of asbestos engineering controls and safe work practices. Those employees who are further responsible for repairs and maintenance to ACM, must also attend an initial 14-hour Asbestos Operations and Maintenance (O&M) course taught by EHS, with an annual update course. UVA employees who are required to perform asbestos abatement, must attend a State-approved Asbestos Worker or Asbestos Supervisor course, an annual update course and must be qualified to obtain a State Department of Professional And Occupational Regulation Asbestos Worker or Supervisor License.
  5. Damaged or deteriorated ACM needing repairs or ACM debris requiring clean up must be reported immediately to EHS. Arrangements will be made by EHS to have this work performed properly.
  6. All ACM repairs, debris clean up, and abatement activities performed by University employees must be monitored by EHS. In addition to daily inspections and environmental air testing, EHS will also conduct personal air testing as required by the OSHA Asbestos Standard to determine airborne asbestos fiber exposures for the affected employee(s). EHS will send results of such monitoring to the PM, and will maintain records of the activities for an indefinite period.
  7. All UVA employees who are required to wear respirators for asbestos work must follow all applicable sections of Respiratory Protection contained in the Controlling Hazardous Air Contaminants and Respiratory Protection policy.

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Related Information: 

Controlling Hazardous Air Contaminants and Respiratory Protection

   
Policy Background: 
   
Major Category: Safety, Security and Environmental Quality
   
Category Cross Reference: 
   
   
Process: 
   
Next Scheduled Review: 06/30/14
   
Approved By, Date: Policy Review Committee, 06/30/05
   
Revision History: Updated 7/18/11.
   
Supersedes (previous policy):  Asbestos-Containing Materials Management XIV.B.1