Asbestos management activities include the following (as described in the Asbestos Management Plan):
- Program Coordination
- Exposure Monitoring
- Construction Review
- Work Order Review
- Environmental Sampling
- Building Inspections
- Hazard Assessment
- Asbestos Materials Inventory
- Asbestos Awareness Training
Asbestos Management Plan
Asbestos-containing materials (ACM) have been used widely in the construction industry. While the use of ACM in new building systems has ceased for most major applications, the presence of ACM in older building systems is still widespread. On this campus, ACM is still present in numerous buildings in the form of pipe insulation, sprayed-on fireproofing, sprayed-on acoustic insulation, and flooring materials. In most cases, this ACM does not pose a health hazard if left undisturbed. Nevertheless, activities that have the potential to disturb ACM must be carefully managed to prevent fibers from becoming airborne and creating an inhalation hazard.
The purpose of this plan is to describe a program for controlling exposure to asbestos in campus buildings. The principal elements of this program involve requirements and responsibilities for surveys, training and certification of workers, employee notifications, proper work procedures for activities that have the potential to disturb ACM, and proper disposal of asbestos wastes.
Asbestos-Containing Material (ACM) - any material containing more than one percent asbestos.
Asbestos-Containing Construction Material (ACCM) - any manufactured construction material that contains more than one tenth of one percent asbestos by weight.
Presumed Asbestos-Containing Material (PACM) — thermal system insulation and surfacing material found in buildings constructed no later than 1980. These materials are assumed to contain asbestos unless data rebuts the classification.
Friable Asbestos Material — any material containing more than one percent asbestos that, when dry, can be crumbled, pulverized or reduced to a powder by hand pressure.
Non-Friable Asbestos-Containing Material — any material containing more than one percent asbestos, that, when dry, cannot be crumbled, pulverized or reduced to a powder by hand pressure.
Category I Non-Friable Asbestos-Containing Material — asbestos-containing packings, gaskets, resilient floor covering and asphalt roofing products containing more than one percent asbestos, that, when dry, cannot be crumbled, pulverized or reduced to a powder by hand pressure.
Category II Non-Friable Asbestos-Containing Material — any material, excluding Category I Non-Friable Asbestos-Containing Material, containing more than one percent asbestos that, when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure.
Regulated Asbestos-Containing Material (RACM) — friable asbestos material; Category I Non-Friable Asbestos-Containing Material that has become friable or will be subjected to sanding, grinding, cutting or abrading; and Category II Non-Friable Asbestos-Containing Material that has a high probability of becoming crumbled, pulverized or reduced to a powder by the forces expected to act on the material in the course of demolition or renovation operations.
These definitions describe the types of asbestos-containing materials that are regulated under California Code of Regulations, Title 8, Sections 341.6 and 1529, and the National Emission Standard for Asbestos as implemented by the Air Pollution Control District, County of San Diego.
A. Facilities Services is Responsible For
- Coordinating with the Chancellor’s Office the encumbrance of funds and the administration of contracts for asbestos abatement projects.
- Developing removal and re-insulation specifications for asbestos abatement contracts.
- Acting as project manager for asbestos abatement contracts.
- Soliciting technical assistance from Environmental Health and Safety in regards to specification development, the planning phase of asbestos projects, and evaluating the credentials of prospective contractors.
- Maintaining a cadre of trained personnel who are capable of performing Class III asbestos work in support of the campus operations and maintenance program.
- Transmitting records of laboratory results related to airborne asbestos surveys, including those performed during abatement projects, to Environmental Health and Safety for evaluation and retention.
- Coordinating with Environmental Health and Safety and maintaining a comprehensive operations and maintenance program that provides for locating, identifying, maintaining and/or abating friable and non-friable asbestos-containing material.
B. Environmental Health and Safety (EH&S) is Responsible For
- Coordinating asbestos-related matters not directly associated with abatement projects. This includes employee notification efforts (Center for Human Resources), and handling inquiries from employees on potential exposure in the workplace or classroom.
- Developing and maintaining the SDSU Asbestos Management Plan, including a Standard Operating Procedure for Cal/OSHA Class III asbestos work and an Employee Notification Procedure.
- Maintaining an Up-to-Date inventory of all known locations of friable and non-friable ACM in SDSU buildings.
- Providing technical assistance to Facilities Services in specification development, the planning phase of asbestos projects, evaluating credentials of contractors, and developing and implementing site monitoring activities before, during, and after abatement operations.
- Performing bulk asbestos sampling, and evaluating, recording, and maintaining laboratory results for all surveys that are not associated with a specific abatement project.
- Receiving, recording and evaluating laboratory results related to airborne asbestos surveys, including those performed during abatement projects.
- In conjunction with the project manager, providing initial inspection of asbestos abatement project set-up, including the containment barrier, airlock assembly, decontamination facilities, and worker protection program.
- Providing technical assistance to the project manager as requested prior to and during asbestos abatement projects.
- Providing hazard awareness training to workers who may encounter asbestos hazards in the workplace.
- Providing training and consultation on the use of personal protective clothing and equipment by asbestos workers.
- Coordinating the medical surveillance of asbestos workers.
- Ensuring that asbestos contractors notify the appropriate regulatory agencies, e.g., APCD, EPA.
C. General Project Managers are Responsible For
Ensuring that contractors whose work may involve disturbing or coming into contact with asbestos-containing materials in SDSU buildings are notified of the conditions that may be encountered before any such work is started. This may be done by referring the contractor to Environmental Health and Safety for consultation.
D. General Managers or Executive Directors of Auxiliaries are Responsible For
- Ensuring that all asbestos-related work performed on state-owned buildings is performed in accordance with this procedure.
- 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.
- Ensuring that operations and maintenance programs are implemented that meet or exceed procedures outlined in this document for their buildings.
A. Monitoring and Inventory
- 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.
- EH&S shall maintain an inventory of all known locations of ACM in SDSU buildings. This information will be disseminated to Facilities Services and Facilities Planning and Management, and should be consulted prior to scheduling work in buildings.
B. Personnel Notifications
- 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.
- 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.
- 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
- Cal/OSHA Class III asbestos work may be performed by Facilities Services personnel who meet the qualifications specified in Section IV.E.
- A detailed procedure for Class III asbestos work is presented as Attachment B.
D. Operations and Maintenance
- Ensuring that all asbestos-related work performed on state-owned buildings is performed in accordance with this procedure.
- 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.
- Ensuring that operations and maintenance programs are implemented that meet or exceed procedures outlined in this document for their buildings.
E. Training and Qualifications
- 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:
- Asbestos Coordinator, 619-594-6778
- 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.
- Asbestos Awareness Training. All Facilities Services 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.
- Hazard Communication. All Facilities Services 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
- 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
(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
- 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 analysis to monitor employee exposure or define the hazard
(d) Steps taken to prevent recurrence or avoid future overexposure
(e) Type of structure repaired, constructed, or demolished, or product being manufactured
- 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:
- 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.
- 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 the Asbestos Coordinator, 619-594-6778 during normal business hours (Monday - Friday, 8 a.m. - 4:30 p.m.).
J. Record Keeping
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:
|Record||Required Retention Time|
|Medical examinations||Duration of employment plus thirty (30) years|
|Training Records||Duration of Employment plus one (1) year|
|Respirator fit test records||Three (3) years|
|Exposure measurement results||At least thirty (30) years|
|Required notification records(Bulk and air samples)||Duration of ownership|
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).
Asbestos Containing Materials (ACM) are prevalent in buildings throughout the San Diego State University Campus. Typically, ACM is found in fireproofing, acoustical and decorative ceiling and wall plasters, and thermal pipe and tank insulation. ACM may also be found in such materials as plaster walls, ceiling and floor tiles, roof felts, chemical hoods, oven gaskets, automobile brakes and clutches, and many other items. Because of the significant amount of asbestos (both friable and non-friable) within SDSU buildings, it is imperative that a coordinated program be in place for identifying ACM, notifying building occupants of its presence and location, and developing procedures to minimize disturbance of asbestos and possible exposure. This section describes the San Diego State University program for identifying and characterizing the condition of asbestos in buildings.
II. System-wide Survey (Historical)
Two system wide asbestos surveys were performed for the CSU System. Baker Consultants performed the initial survey in 1985, and a follow-up survey was performed in 1987-88 by the Dynamac Corporation. The scope of each survey was as follows:
- Locate all suspected friable asbestos containing building materials (ACBM).
- Sample all suspected materials and analyze them using Polarized Light Microscopy (PLM).
- Characterize the condition of the asbestos based upon a modified EPA algorithm developed by the consultants.
- Assign a hazard ranking category and number to each sample location that tested positive for asbestos.
- Develop abatement cost estimates for all asbestos locations that were categorized as C, D, and F by Dynamac or 4, 5, 6, and 7 by Baker Consultants.
- Cost estimates included asbestos abatement, development of abatement specifications, project monitoring, and, in the Dynamac report, restoration. However, restoration costs were not included for all locations that were needed, and Baker consultants did not include any restoration costs in their reports.
- Develop guidelines for an asbestos operation and maintenance program.
III. Campus Inspection and Surveillance Programs
A. Periodic Surveillance of Known Locations of ACM
In order to prevent exposure of building occupants to asbestos fibers, periodic surveillance of known locations of friable and non-friable ACM will be performed to determine if damage or deterioration has occurred. Facilities Services personnel will conduct the periodic surveillance and maintain the associated records. If there is a need to perform additional sampling and analysis of suspect building materials, the Asbestos Coordinator in EH&S should be contacted (extension 46778).
B. Inspection of Previously Unidentified ACM
Neither one of the system-wide asbestos surveys sampled for and confirmed the presence of non-friable ACM such as plaster walls, vinyl asbestos floor tiles, ceiling tiles, and roofing felts. Because of the potential for employee exposure to asbestos fibers when these materials are disturbed (e.g., penetrating walls, removing floor & ceiling tiles), a procedure shall be used to ensure that building materials are sampled and analyzed prior to the start of construction or maintenance activities. Cal/ OSHA requires that certain building materials be sampled for the presence of asbestos, or assumed to be ACM. Additionally, the NESHAP requires that RACM (regulated asbestos containing material) must be removed prior to demolition or renovation.
1. Work Order Review
Facilities Services must route work orders through EH&S. EH&S will assess the potential for asbestos hazards. This may involve the sampling and analysis of suspected asbestos containing building materials. The proposed work shall not commence until EH&S has completed the assessment and approved the work order. The work order is then sent forward with comments relating to asbestos control.
2. Bulk Materials Sampling & Analysis
AHERA sampling techniques shall be utilized throughout the sampling survey (reference EPA “Pink Book”). Asbestos sampling shall be performed only by EH&S or Facilities Services staff who are trained in this process. The samples are analyzed by an EPA accredited laboratory. A copy of the laboratory sample results shall be sent by EH&S to the Project Manager. The results are also entered into the Campus Asbestos Material Location File.
(a) Asbestos bulk samples shall be collected by, or under the direction of, a person who has completed an asbestos building inspector course and who is currently certified.
(b) The immediate area shall be secured so that building occupants are not present. Preferably, sampling should be performed outside of normal business hours.
(c) An appropriate respirator equipped with HEPA filters shall be donned prior to collecting samples.
(d) Asbestos containing material should not be sampled dry. Wet the surface of the sample area with a surfactant (typically 50% polyethylene-glycol) or water. For core sampling, a wet sponge can be placed over the sampled area and the core will be run through the sponge into the suspected ACM. Penetrate the suspected material completely with a sharp object such as a coring tool, blade or knife and remove a small section of the suspect material. Minimum sampling numbers:
- Area of the homogeneous suspect ACM <1000 linear or square feet (3) three bulk samples shall be collected.
- Area of homogeneous suspect ACM is at least 1000 linear or square feet, but <5000 linear or square feet, at least (5) bulk samples shall be collected.
- Area of homogeneous suspect ACM is >5000 linear or square feet (7) seven bulk samples shall be collected from each area.
(e) Place the sample in a sealed container.
(f) Patch or repair the material where the sample was removed.
(g) Label the sealed container and record the following information:
- Location of sample (a graphic depiction of sample location should be included for demolition records)
- Type of material (e.g., plaster wall, thermal system insulation)
- Name or initials of individual taking sample
- Laboratory that will be analyzing sample and phone number
- Sample result (to be filled in after analysis)
- Sample number - unique to the location and/or sample
(h) Submit the sample to an EPA approved laboratory for analysis.
(i) Depending upon the quantifying limit needed, the sample should be analyzed by either of two methods:
- Polarized Light Microscopy (PLM) for quantifying limits equal to or exceeding 0.1% asbestos by weight.
- Transmission Election Microscopy (TEM) if a detection limit below 0.1% asbestos by weight is needed.
Note: Fine dust samples from operations like brake rebuilding should be analyzed using TEM.
3. Quality Assurance (QA)
Appropriate analytical Quality Assurance (QA) procedures must be established and followed by the analytical laboratory. It is the responsibility of EH&S to ensure that appropriate QA requirements are provided to Purchasing and Contracts for inclusion in bid specifications.
All sample results are incorporated into the Master Data Base “Asbestos Locations Within SDSU Buildings.” This list is communicated to building occupants in accordance with the notification requirements of Section IV.B of the Asbestos Management Plan.
The master ACM Sample list is maintained by the Asbestos Coordinator and is available in the EH&S Office during normal work hours (8 a.m. to 4:30 p.m.).
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
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.
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.
EH&S will maintain a record of all bulk material and air sampling results performed in support of friable or non-friable asbestos work. Facilities Services personnel are responsible for providing EH&S with a copy of the “Competent Person Designation and Duties Checklist” for its records.
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 record keeping.
II. Program Components
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.
Facilities Services personnel that are AHERA Management Planner certified 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 periodically. 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 Facilities Services 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. Facilities Services 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 glove bag 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.
Training requirements related to O&M are described in Section IV.E and Attachment D of the Asbestos Management Plan.
V. Recording Keeping
Record keeping requirements related to O&M are described in Section IV.J of the Asbestos Management Plan.
I. Training Requirements
Cal/OSHA Title 8 CCR 5208 and 8 CCR 1529 requires that asbestos awareness training is provided annually to employees who perform housekeeping, maintenance, and custodial during which employees may contact but do not disturb ACM or PACM and activities to clean up dust, waste and debris resulting from Class I, II, and III activities. This awareness training must include information about:
- Methods of Recognizing Asbestos (including signs/labels)
- Methods of Recognizing Damaged Asbestos
- Health Effects Associated with Asbestos Exposure
- Relationship between Smoking & Asbestos Diseases
- Minimizing Exposure to Asbestos
- Appropriate Work Practices (including engineering controls, decontamination, and waste disposal)
- Emergency Procedures
- Respiratory Protection/Personal Protective Equipment (PPE)
- Medical Surveillance Program
II. SDSU Asbestos Awareness Training
Asbestos Awareness Training is provided at SDSU either in-person by SDSU EHS (Asbestos Program Manager) or online (e.g.- CSU Learn). A SDSU email account is required to enroll in the online training.
To schedule in-person training or to enroll in the online training, contact EHS (Asbestos Program Manager) at x4-6778.
The following checklist is designed to aid Facilities Services in completing the procedures pertinent to asbestos abatement utilizing a glove bag or small negative air enclosure. This should not be construed as a complete list of requirements for all abatement jobs. If you have questions, contact your supervisor or the Asbestos Program Manager at EHS. Additional information is located in the Asbestos Management Plan in the SDSU Hazard Control Program Manual.
- Area/s and ACM have been assessed for their potential to release fibers
- EHS has been notified (extension 4-6778)
- Entry is controlled to “regulated areas”
- Ventilation has been secured, diffusers are sealed
- AHERA “competent person” is on-site
- Respirators and other PPE is available and ready for use, including but not limited to disposable coveralls, gloves, safety glasses
- Visquene (2 layers) have been placed under and around the ACM being disturbed
- TSI around removal location has been taped
- Tools, wipes and misc. equipment have been placed in glove bag
- Glove bag has been securely affixed. Seams have been sealed and are airtight
- Glove bag has been tested with smoke tube and does not leak
- Personal sampling pumps are calibrated with proper cartridges
- Area sampling pumps are calibrated and have proper cartridges
- Blank cartridges are available
- Access ways are posted and secured
- Amended water or wetting agents are available and are used
- Waste bags are properly labeled
- HEPA vacuum and/or other dust controlling methods are present and are being used
- Electrical circuits, etc. have been locked out-tagged-out
- Electrical cords are grounded and are not frayed
- Area is left clean, no (visible) signs of asbestos contamination
- Waste is double bagged and disposed properly