Asbestos Management Plan: Attachment C

This section describes SDSU’s Operations and Maintenance (O&M) Program. The program applies to asbestos-containing materials (ACM) that are managed “in place,” as opposed to management by removal. The purpose of the O&M Program is to define a course of action aimed at safeguarding the health of SDSU employees, students, and visitors by maintaining ACM in a stable condition, thereby preventing deterioration or damage that can result in the release of asbestos fibers.

Specifically, the four directives that have been established to accomplish this objective are:

A. Monitor the condition of ACM on campus

B. Maintain ACM in good condition

C. Ensure proper cleanup of releases of asbestos fibers

D. Prevent further release of fibers

The O&M Program is a major component of the overall SDSU Asbestos Management Program. It provides a system of surveillance, control, and work practices that applies specifically to O&M activities. These procedures are used in conjunction with other elements of the Asbestos Management Program, such as notification, training, and recordkeeping.

SDSU is responsible for notifying employees, contractors and other building occupants of the location of ACM. Notification to some regulatory agencies is also required. The notification program is detailed in Section IV.B and Attachment D of the Asbestos Management Plan.

Physical Plant personnel will perform regular surveillance to note, assess, and document any changes in the condition of ACM. This includes a visual and tactile surveillance of known ACM at least annually. EH&S will sample dust found in areas around ACM, and will also perform supplemental periodic air monitoring based on O&M reports, assessed priorities, and in the event of fiber release episodes. Any debris noted during the surveillance will be cleaned up immediately.

Activities that may disturb ACM must be coordinated with EH&S. The Physical Plant Work Control Center will compare incoming work orders with the asbestos locations list published by EH&S. Work orders that have the potential for disturbing ACM due to proximity to the material or the nature of work performed will be sent to EH&S for evaluation. Physical Plant personnel involved in completing work orders will receive 2-hour asbestos training as described in Attachment D of the Asbestos Management Plan. EH&S will perform necessary sampling of suspect ACM as described in Attachment A.

Work Practices for custodial, maintenance, and trades workers will be tailored to prevent the release of fibers based on the nature of the work to be performed. Four levels of O&M work practices are involved:

1. Worker protection programs. These include SDSU’s Respiratory Protection Program, the use of appropriate personal protective equipment, personal and area air sampling administered by EH&S, and most importantly, administrative and engineering controls where feasible. Administrative and engineering controls are discussed in Section II of the Asbestos Management Plan. (A copy of the EPA pamphlet - Asbestos in Buildings, Guidance for Service and Maintenance Personnel is available.)

2. Basic O&M procedures. General glovebag procedures are described in Attachment B. Additional work practices such as wet wiping, area isolation, HEPA vacuuming, and use of personal protective equipment are to be employed whenever feasible. Specific O&M procedures as they relate to other applications of ACM are described in Attachment B of the Asbestos Management Plan.

3. Special O&M cleaning techniques. Special cleaning practices are required to decontaminate areas that contain surfacing or insulation, especially if the material is damaged or deteriorated. Proper O&M cleaning involves the use of wet cleaning or wet-wiping practices to pick up asbestos fibers. The use of a vacuum cleaner equipped with a high efficiency particulate air (HEPA) filter is preferable to wet cleaning in some instances, especially where significant amounts of asbestos debris exist. Ordinary vacuum cleaners shall not be used for O&M cleaning. Dry sweeping or dusting can result in suspension of fibers and should not be used.

4. Response to asbestos fiber release episodes. Accidental fiber releases involving greater than 3 square or linear feet of ACM are to be managed by isolating the site, erecting barriers, shutting off ventilation systems, notifying EH&S and other affected personnel, and clean-up under the guidance of EH&S and the procedures in this document. EH&S will coordinate clearance air sampling and notifying government agencies, if required. Minor releases (less than 3 square or linear feet of ACM) may be handled using wet methods, HEPA vacuums, and notifications and other guidance coordinated by EH&S.

O&M activities often result in the generation of asbestos-containing waste materials. All waste materials that are known or suspected to contain asbestos shall be handled in accordance with Section IV.H of the Asbestos Management Plan.

Training requirements related to O&M are described in Section IV.E and Attachment D of the Asbestos Management Plan.

Recordkeeping requirements related to O&M are described in Section IV.J of the Asbestos Management Plan.


	Business and Financial Affairs > Environmental Health and Safety > Asbestos Management > Plan >
	Environmental Health and Safety Asbestos Management Plan OPERATIONS AND MAINTENANCE PROGRAM I. SUMMARY AND PURPOSE This section describes SDSU’s Operations and Maintenance (O&M) Program. The program applies to asbestos-containing materials (ACM) that are managed “in place,” as opposed to management by removal. The purpose of the O&M Program is to define a course of action aimed at safeguarding the health of SDSU employees, students, and visitors by maintaining ACM in a stable condition, thereby preventing deterioration or damage that can result in the release of asbestos fibers. Specifically, the four directives that have been established to accomplish this objective are: A. Monitor the condition of ACM on campus B. Maintain ACM in good condition C. Ensure proper cleanup of releases of asbestos fibers D. Prevent further release of fibers The O&M Program is a major component of the overall SDSU Asbestos Management Program. It provides a system of surveillance, control, and work practices that applies specifically to O&M activities. These procedures are used in conjunction with other elements of the Asbestos Management Program, such as notification, training, and recordkeeping. II. PROGRAM COMPONENTS A. NOTIFICATION SDSU is responsible for notifying employees, contractors and other building occupants of the location of ACM. Notification to some regulatory agencies is also required. The notification program is detailed in Section IV.B and Attachment D of the Asbestos Management Plan. B. SURVEILLANCE Physical Plant personnel will perform regular surveillance to note, assess, and document any changes in the condition of ACM. This includes a visual and tactile surveillance of known ACM at least annually. EH&S will sample dust found in areas around ACM, and will also perform supplemental periodic air monitoring based on O&M reports, assessed priorities, and in the event of fiber release episodes. Any debris noted during the surveillance will be cleaned up immediately. C. WORK CONTROL Activities that may disturb ACM must be coordinated with EH&S. The Physical Plant Work Control Center will compare incoming work orders with the asbestos locations list published by EH&S. Work orders that have the potential for disturbing ACM due to proximity to the material or the nature of work performed will be sent to EH&S for evaluation. Physical Plant personnel involved in completing work orders will receive 2-hour asbestos training as described in Attachment D of the Asbestos Management Plan. EH&S will perform necessary sampling of suspect ACM as described in Attachment A. D. WORK PRACTICES Work Practices for custodial, maintenance, and trades workers will be tailored to prevent the release of fibers based on the nature of the work to be performed. Four levels of O&M work practices are involved: 1. Worker protection programs. These include SDSU’s Respiratory Protection Program, the use of appropriate personal protective equipment, personal and area air sampling administered by EH&S, and most importantly, administrative and engineering controls where feasible. Administrative and engineering controls are discussed in Section II of the Asbestos Management Plan. (A copy of the EPA pamphlet - Asbestos in Buildings, Guidance for Service and Maintenance Personnel is available.) 2. Basic O&M procedures. General glovebag procedures are described in Attachment B. Additional work practices such as wet wiping, area isolation, HEPA vacuuming, and use of personal protective equipment are to be employed whenever feasible. Specific O&M procedures as they relate to other applications of ACM are described in Attachment B of the Asbestos Management Plan. 3. Special O&M cleaning techniques. Special cleaning practices are required to decontaminate areas that contain surfacing or insulation, especially if the material is damaged or deteriorated. Proper O&M cleaning involves the use of wet cleaning or wet-wiping practices to pick up asbestos fibers. The use of a vacuum cleaner equipped with a high efficiency particulate air (HEPA) filter is preferable to wet cleaning in some instances, especially where significant amounts of asbestos debris exist. Ordinary vacuum cleaners shall not be used for O&M cleaning. Dry sweeping or dusting can result in suspension of fibers and should not be used. 4. Response to asbestos fiber release episodes. Accidental fiber releases involving greater than 3 square or linear feet of ACM are to be managed by isolating the site, erecting barriers, shutting off ventilation systems, notifying EH&S and other affected personnel, and clean-up under the guidance of EH&S and the procedures in this document. EH&S will coordinate clearance air sampling and notifying government agencies, if required. Minor releases (less than 3 square or linear feet of ACM) may be handled using wet methods, HEPA vacuums, and notifications and other guidance coordinated by EH&S. III. WASTE MANAGEMENT O&M activities often result in the generation of asbestos-containing waste materials. All waste materials that are known or suspected to contain asbestos shall be handled in accordance with Section IV.H of the Asbestos Management Plan. IV. TRAINING Training requirements related to O&M are described in Section IV.E and Attachment D of the Asbestos Management Plan. V. RECORDKEEPING Recordkeeping requirements related to O&M are described in Section IV.J of the Asbestos Management Plan.
	[top of page]	This page last updated January 28, 2008 Site contact: UCO Web Support

Environmental Health and Safety

Asbestos Management Plan

OPERATIONS AND MAINTENANCE PROGRAM