Environmental Health and Safety

Asbestos Management Plan

Requirements

A. Monitoring and Inventory
B. Personnel Notifications
C. Cal/OSHA
D. Operations and Maintenance
E. Training and Qualifications
F. Medical Monitoring
G. Reporting of Incidents
H. Waste Management
I. Emergency Response Assistance
J. Recordkeeping
K. Demolition and Renovation

A. Monitoring and Inventory:

1. EH&S shall coordinate an asbestos sampling and analysis program for the purpose of characterizing the nature and extent of asbestos occurrence in SDSU buildings. Periodic surveillance will be conducted with emphasis placed on those areas into which personnel are either scheduled or likely to enter for the purpose of performing work. The protocol that shall be followed for asbestos sampling and analysis is presented in Attachment A.
   
   
2. EH&S shall maintain an inventory of all known locations of ACM in SDSU buildings.  This information will be disseminated to Physical Plant and Facilities Planning and Management, and should be consulted prior to scheduling work in buildings.

B. Personnel Notifications:

1. Employees in buildings known to contain ACM shall be notified in compliance with Assembly Bill 3713 and modifying legislation (i.e., AB 1564). The “Asbestos Notification to Employees” will be performed by EH&S and the Center for Human Resources. The notification will be sent to all employees, including part-time student workers. A current notification letter  and ACM inventory  is available on the EH&S Web site.
   
   
2. Contractors shall be notified in writing by the SDSU Project Manager as to the known existence of ACM in buildings or areas where construction or demolition is scheduled to occur.
   
   
3. EH&S shall transmit copies of the “Asbestos Notification to Employees” to the management of auxiliary organizations and Associated Students who shall ensure that the information contained therein is distributed to personnel within their organizations.

C. Cal/OSHA Class III Asbestos Work:

1. Cal/OSHA Class III asbestos work may be performed by Physical Plant personnel who meet the qualifications specified in Section IV.E.
   
   
2. A detailed procedure for Class III asbestos work is presented as Attachment B.

D. Operations and Maintenance:

1. Ensuring that all asbestos-related work performed on state-owned buildings is performed in accordance with this procedure.
   
   
2. Ensuring that personnel under their supervision are notified, in accordance with Section IV.B.3 of this Procedure, regarding the known existence of asbestos in buildings.
   
   
3. Ensuring that operations and maintenance programs are implemented that meet or exceed procedures outlined in this document for their buildings.

E. Training and Qualifications:

1. Inspector Training. Any person engaged in the inspection of a facility for ACM shall have successfully completed an EPA-approved three-day inspector course of study. Certified inspectors for SDSU are:
   
   
   • Veronica Hoban, 619-594-1858 <vhoban@mail.sdsu.edu>
   
   
   
2. Asbestos Worker Training and Qualifications. Any person who performs Class III asbestos work shall be properly trained and protected. At a minimum, this protection entails:
   
   (a) Successful completion of a 4-day EPA-approved training course for asbestos abatement workers.
   (b) Enrollment in a program of medical surveillance.
   (c) Being properly fitted and instructed in the use and care of a respirator.
   (d) Refitting for the respirator annually or when a significant change in the face-to-mask fit is detected.
   
   
3. Asbestos Awareness Training. All Physical Plant personnel who contact but do not disturb ACM in the course of their work shall be given two-hour asbestos awareness training. The content of this training is presented in Attachment D.
   
   
4. Hazard Communication. All Physical Plant personnel are informed of the locations of asbestos and the presence of asbestos hazards on campus.

F. Medical Monitoring:

All personnel who perform Class III asbestos work will receive medical surveillance in accordance with the SDSU MEDICAL SURVEILLANCE PROGRAM, which is Chapter 11 of the SDSU Hazard Control Program Manual.

G. Reporting of Incidents:

1. Any incident, accident, or emergency resulting in a known exposure of one or more employees must be immediately report to EH&S, who will assess the case and determine whether notification of Cal/OSHA is required. In making its assessment, EH&S will use the reporting criteria specified by Title 8, CCR, Section 5208(3), which are summarized as follows:
   
   
   (a) The employee(s) is unprotected by an appropriate respirator
   (b) The employee(s) is exposed to asbestos fibers at the following time-weighted concentrations:
   
   
   (1) Eight-hour time-weighted average concentration of greater than 0.1 fibers/cc, or
   (2) Thirty-minute time-weighted average concentration of greater than 1 fiber/cc
   
   
   
2. If required, EH&S will report the incident to Cal/OSHA within fifteen days of the event. The items which shall be addressed in the report include:
   
   
   (a) Number of employees overexposed
   (b) Circumstances surrounding the overexposure
   (c) Results of any environmental analyses to monitor employee exposure or define the hazard
   (d) Steps taken to prevent recurrence or avoid future overexposures
   (e) Type of structure repaired, constructed, or demolished, or product being manufactured
   
   
3. A copy of each report submitted to Cal/OSHA shall be posted by EH&S in the locations(s) where the incident occurred and in other locations where it will be conspicuous to other potentially affected employees.

H. Waste Management:

All asbestos-containing waste materials are considered hazardous wastes and must be handled and disposed in accordance with hazardous waste management procedures. This involves one of the following:

1. For asbestos abatement contracts, the SDSU Project Manager shall ensure that provisions for proper asbestos waste handling, storage and disposal are included in the contract specifications.
   
   
2. For asbestos waste generated by SDSU activities (“in-house” work), the job supervisor shall ensure that asbestos-containing wastes are delivered to EH&S, who will coordinate the proper disposal.

I. Emergency Response Assistance:

When emergency assistance is needed to recover from an asbestos-related event outside of normal business hours, contact Public Safety at extension 4-1991 and request that they in turn contact Veronica Hoban, Asbestos Coordinator during normal business hours (Monday - Friday, 8 a.m. - 4:30 p.m.) at extension 4-6778.

J. Recordkeeping:

Departments with specific asbestos-related responsibilities shall prepare and maintain appropriate records to document that prescribed activities are conducted in accordance with this procedure. These records include, but are not limited to, those presented in Table 1:

K. Demolition and Renovation:

Demolition and renovation operations that involve the presence of RACM in excess of specified amounts must be conducted in accordance with the notification requirements and procedures for asbestos emission control of the National Emission Standard for Asbestos (as implemented by APCD Rule 361.145).