Environmental Health and Safety
Asbestos Management Plan
STANDARD OPERATING PROCEDURE
FOR CLASS III & CLASS IV ASBESTOS WORK
I. PURPOSE
This Standard Operating Procedure (SOP) describes control measures for performing Class III and Class IV asbestos work pursuant to 8 CCR 1529. ACM is present in campus structures in a wide variety of forms. This SOP addresses several types of removal operations as separate items. The control measures of this SOP are “good work practices” in addition to the applicable requirements described in the parent procedure, the Asbestos Management Plan.
The four EPA classifications for asbestos work are:
- Class I Asbestos Work: Removal of TSI or Surfacing ACM or PACM.
- Class II Asbestos Work: Removal of any other ACM/ PACM that is not TSI or surfacing material.
- Class III Asbestos Work: Repair and maintenance operations where ACM/ PACM is likely to be disturbed.
- Class IV Asbestos Work: Maintenance and custodial activities where employees contact ACM/ PACM and activities to clean up debris. Custodial personnel do not perform asbestos clean up.
II. FRIABLE ACM
A. DEFINITION
Many of the control measures for ACM removal depend on whether or not the material is considered “friable.” The determination of friability is, therefore, a critical step in developing the strategy of ACM removal. If a suspect material is, when dry, capable of being crumbled, pulverized or reduced to a powder by hand pressure, and if the material contains asbestos fibers in excess of 1‰, it is considered friable ACM and must be treated as a hazardous material.
B. GENERAL PROTECTION REQUIREMENTS
1. Primary consideration will be given to the protection of building occupants and asbestos workers. The following steps shall be taken for any work that may involve disturbing friable ACM:
(a) Restrict entry to the area for all personnel other than those needed to perform the work.
(b) Post signs to communicate the hazard and to prevent entry by unauthorized personnel.
(c) Shut off or temporarily modify the air handling system, and restrict other sources of air movement.
(d) Use work practices (e.g., negative pressure enclosure or glove bag operations as described below) which are designed to prevent the spread of any fibers released by the work being performed.
2. All personnel who are likely to disturb ACM or who may be exposed above the permissible exposure limits (PELs) must be properly trained and protected. As a minimum, this protection entails:
(a) 4-day EPA approved course for asbestos abatement workers and annual 8-hour refresher training.
(b) Medical surveillance.
(c) Initial fitting for a respirator.
(d) Refitting for a respirator annually or whenever a significant change in the face to mask fit is detected.
(e) Asbestos exposure monitoring.
3. All personnel who contact ACM must receive 2-hour asbestos awareness training.
C. NOTIFICATIONS
EH&S must be notified of projects that are likely to cause the disturbance of ACM. Contact the Asbestos Program Manager at 619-594-6778. The Asbestos Program Manager will determine the monitoring, notification, and other protection measures for the project in question. Because most asbestos work will require exposure monitoring, and the Ni-Cad batteries on the samplers take approximately 24 hours to recharge, it is desirable for EH&S to receive at least 24-hour notice of asbestos work.
D. EXPOSURE MONITORING
EH&S may conduct exposure monitoring during asbestos work and clearance monitoring at the completion of asbestos work. Additionally, EH&S may collect baseline air samples from the work site prior to asbestos work. If the potential exists for the release of fibers to the extent that the PELs may be reached, EH&S will establish a full personnel protection and monitoring program for the project in question. At present the PELs for asbestos are 0.1 fibers per cubic centimeter of air as an 8-hour time weighted average and 1.0 fibers per cubic centimeter of air as averaged over a 30-minute period. Personnel monitoring will be performed during the asbestos work to demonstrate that breathing zone concentrations were maintained below the PELs.
E. GLOVE BAG OPERATIONS
The “Glove Bag” method provides a safe means for removal of small amounts of ACM on pipes and in small surface areas. The following procedures should be followed when the glove bag method is used to remove ACM.
1. Utilize personal protective clothing, such as the “Tyvek” suits, gloves and a respirator that has been provided and fitted by EH&S.
2. Isolate the area where the ACM is located. Place barrier tape across the doorways and at least 20 feet around the area where the ACM is located.
3. Place 6-mil plastic sheeting under the glove bag set-up.
4. Ensure that all ventilation units that service the area where the ACM is located are shut off and tagged out.
5. Don the respirator and perform a “negative” and “positive” pressure test. If you are unable to obtain a successful pressure test on the respirator, see your supervisor. DO NOT PROCEED WITH ACM WORK WITHOUT A PROPER RESPIRATOR FIT.
6. Determine the area where the ACM is to be removed. Place the glove bag next to the pipe and measure how much area will need to be removed. Tape the area on the pipe to delineate the area from which ACM will be removed. Tape the bottom seam of the glove bag. Slit the side seams of the glove bag to fit the pipe diameter. Seal the sides and top seam with tape after placing the necessary tools into the bag. Cut a small hole in the bag in the same area where the wetting wand will be placed during the actual ACM removal stage. Fill the bag with smoke from the smoke tube and seal the hole. Gently squeeze the bag and observe any leaking areas. Tape the leaking areas to achieve an airtight seal. If the pipe lagging is badly damaged or deteriorated the ACM may require wetting or taping to prevent a further release of fibers.
7. Most glove bags will melt or deteriorate at temperatures of 130o F or more. For steam or hot water lines, therefore, it may be necessary to shut off the pipe valve to ensure that the bag does not deteriorate or that the worker does not receive burns.
8. Wet the ACM completely prior to removal and keep the ACM wet during the removal process. Use amended water in an airless spray pump. A hand spray bottle may also be used. The hole created for the spray wand can also be used for the HEPA vacuum nozzle.
9. All visible ACM must be removed from the pipe using a hard brush and amended water while the glove bag is still in place. Wet wipe and spray the pipe with encapsulant prior to removing the glove bag. Special attention must be given to exposed ends of pipe lagging.
10. Place all tools into one of the armholes and pull inside out. Tape and cut the arm from the glove bag and remove the tools while they are still sealed in the arm or glove.
11. Wet the inside of the bag with amended water and place the vacuum nozzle into the bag to cause the bag to collapse. Unseal the bag and remove from the pipe. Place the bag into another 6-mil asbestos waste bag and seal tightly. This bag must be marked as an ASBESTOS DISPOSAL BAG with the proper Danger and warning labels:
Contains Asbestos Fibers
Avoid Creating Dust
Cancer and Lung Disease Hazard
12. The exposed section of pipe will now be closed and sealed with a non-asbestos material.
13. If the remaining pipe contains ACM, the pipe must be labeled “DANGER ASBESTOS MATERIAL.”
III. NON-FRIABLE ACM
Many applications of ACM are not friable, but nevertheless can pose a health hazard if not managed properly. The application of non-friable ACM most commonly encountered at SDSU is a flooring material known as vinyl asbestos tile (VAT). Other non-friable forms may include roofing felt, underground water lines, laboratory benchtops, etc. Although the following requirements relate specifically to VAT, the principles are generally applicable to other asbestos work involving non-friable ACM.
- VINYL ASBESTOS TILE (VAT)
Most vinyl asbestos floor tiles on campus are of the 9” x 9” tile size. The floor tiles are held in place by an adhesive (mastic) that may also contain asbestos. If there is any doubt whether a specific area of floor tile or mastic contains asbestos, call EH&S at 619-594-6778 to arrange for positive identification. (Note: Most flooring material in buildings constructed prior to the mid-1970s should be considered as suspect ACM.)
1. Because there is a possibility that during a VAT procedure employees may become exposed to asbestos fibers in excess of the PELs, the notification procedure for VAT jobs is the same as that prescribed for the glove bag operations.
2. All removal of VAT should be performed under wet conditions.
3. The tiles should be removed with the least amount of breakage of the tiles.
4. All vacuuming MUST be performed with a HEPA-filtered vacuum only.
5. Mopping or wet wiping may be used to wet-clean debris (which must be assumed to contain asbestos) from the floor. The mop or wipe is to be moved in one direction for no more than six feet, turned over, and the action is repeated for six more feet in the same direction. At the end of the two passes the mop or wipe is to be rinsed in a water bucket. These actions may be repeated, utilizing the same bucket of water until the water becomes visible soiled.
6. Mop heads and wipes are to be used for one project only. They are to be disposed of by placing them into an asbestos disposal bag at the end of the project. Asbestos-containing rinse water may also require controlled disposal. Contact EH&S for guidance on disposal of all asbestos-contaminated wastes.
IV. DOCUMENTATION
EH&S will maintain a record of all bulk material and air sampling results performed in support of friable or non-friable asbestos work. Physical Plant personnel are responsible for providing EH&S with a copy of the “Competent Person Designation and Duties Checklist” for its records.
This page last updated January 28, 2008
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