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Asbestos Management Plan |
PART I: GENERAL PROVISIONS OF THE MANAGEMENT PLAN
1.0 INTRODUCTION
This Asbestos Management Plan was developed in accordance with the United States Department of Labor, Occupational Safety and Health Administration’s (OSHA’s) Asbestos Standards [29 CFR 1910.1001, 29 CFR 1926.1101].
These regulations place a burden of asbestos management on the owners and operators of facilities that may contain asbestos-containing materials (ACMs), as well as employers whose employees may be expected to work near or with ACMs. As the University is both a facility owner and an employer, it has responsibilities in both aspects of the Standards. These responsibilities include identification of potential asbestos exposure hazard, notification of employees and occupants of the presence of ACM, employee awareness and operational training, recordkeeping, and management of renovations and maintenance operations.
In general, the management plan development process consisted of:
This plan is based on inspections conducted on the dates indicated. Condition assessments
and subsequent assigned response actions of ACM identified are based on the conditions at
the time of the inspection.
This plan is divided into two parts. Part I provides general provisions of the plan; Part II is the Operations and Maintenance Program.
2.0 PURPOSE AND POLICY
The objective of this Management Plan is to allow the continuation of normal building maintenance and service activities while limiting the potential exposure of building occupants, maintenance workers, and outside service personnel to airborne asbestos fibers. The program’s policies and work procedures have been specifically designed to meet the needs of both the University and the community at-large.
This Management Plan is guided by four (4) specific policy statements:
1) Asbestos-containing materials identified at the University’s facilities are to be maintained under an Operations and Maintenance program to be instituted by the Manager. Members of the University community are expected to comply with this Management Plan relative to operations that they may undertake.
2) Under this Management Plan, to the extent that the objective of the Management Plan is not compromised, intact ACM will not be removed until a condition arises pursuant to Policy Statement three (3) below.3) Instances and conditions which would motivate removal of some portion of the ACM in the facility include:
- When it is determined that ACM will be disturbed by repair, renovation or demolition activity; or
- Where a response to damaged ACM is necessary, and it is determined that removal is either the only acceptable response or the most cost effective response relative to all factors considered.
4) Repair is the minimally necessary response action to damaged ACM that is not removed.
Locations and approximate amounts of all identified ACM are detailed in the Asbestos Identification Survey Reports issued by PMK.
3.0 DEFINITIONS
“Accredited Inspector” means a person who has completed a course at a USEPA approved training facility in the inspection of buildings for Asbestos-Containing Materials, pursuant to the current regulations promulgated in response to the Asbestos Hazard Emergency Response Act (AHERA).
“Accredited Management Planner” means a person who has completed a course at a USEPA approved training facility in the management of Asbestos-Containing Materials in buildings, pursuant to the current regulations promulgated in response to the Asbestos Hazard Emergency Response Act (AHERA).
“Accredited Asbestos Abatement Project Designer” means a person who has completed a course at USEPA approved training facility n the design of asbestos abatement projects, pursuant to the current regulations promulgated in response to the Asbestos Hazard Emergency Response Act (AHERA).
“ACM” means Asbestos-Containing Material.
“CMU” means concrete masonry unit.
“EPA” means the United States Environmental Protection Agency.
“HEPA filter” means High Efficiency Particulate Absolute filter.
“NIOSH” means the National Institute of Occupational Safety and Health.
“N.J.A.C.” means the New Jersey Administrative Code.
“NJDOL” means the New Jersey Department of Labor.
“NJDCA” means the New Jersey Department of Community Affairs.
“N.J.S.A.” means New Jersey Statutes Annotated.
“O & M” means Operations and Maintenance.
“OSHA” means the United States Department of Labor Occupational Safety and Health Administration.
“Subcode” refers to the New Jersey Asbestos Hazard Abatement Subcode, a part of the New Jersey Uniform Construction Code.
“USEPA” means the United States Environmental Protection Agency.
FEDERAL AND STATE REGULATIONS REFERENCED IN THIS MANAGEMENT PLAN
OSHA Standards for Asbestos - 29 CFR 1910.1001 and 29 CFR 1910.1101.
OSHA Respiratory Protection Standard - 29 CFR 1910.134.
USEPA National Emission Standards for Hazardous Air Pollutants - 40 CFR Part 61.
USEPA Asbestos-Containing Materials in Schools Rule - 40 CFR 763, Subpart E.
New Jersey Asbestos Hazard Abatement Subcode - N.J.A.C. 5:23-8.
New Jersey Solid Waste Management Regulations - N.J.A.C. 7:26 et seq.
New Jersey Asbestos Control and Licensing Act - N.J.S.A. 34:5A-32, et seq.
4.0 GENERAL SCOPE
4.1 MANAGEMENT STRUCTURE
4.1.1 PROGRAM MANAGEMENT
Program Management shall originate from the Manager, which shall be the Director of the Office of Affirmative Action, Human Relations, and Compliance. The Manager shall delegate, as necessary, oversight and review of the Plan to appropriate personnel and consultants.
The Manager may delineate specific buildings with no identified ACM and conditions which preclude the potential presence of concealed suspect material to be exempt from the requirements of this Management Plan. A copy of this exemption must be included in the Management Plan.
4.1.2 INITIAL NOTIFICATION OF UNIVERSITY COMMUNITY
Notification of the development of this Plan shall be made in writing to management representatives in different departments of the University community. The departments of Campus Planning and Construction, Facilities Management, Information Systems, and University Police shall be required to designate a Plan contact person (or persons) whom the Manager may approach regarding Plan implementation issues.
The Manager shall meet with these contact persons to discuss the elements of this Plan, especially relative to the “Notification of Employee or Contracted Labor” requirement following.
4.1.3 NOTIFICATION OF EMPLOYEE OR CONTRACTED LABOR
Anytime anyone other than the University’s employees are required to conduct custodial or maintenance type activities in this building (such as outside contractors, telephone workers, etc.):
Notification to the workers may be in the form of reading of this Management Plan, or by other written information that as a minimum includes the type and/or location of ACM in the building, and any special precautions required.
Notification to the designated person of the presence and intended activities of the outside workers shall be made by appropriate building personnel prior to the workers beginning their activities so that a determination of whether the activities will disturb ACM can be made. The designated person shall then release the workers to proceed and document the release, any specific instructions, and evidence of the worker’s notification. The Manager shall maintain such documentation.
University employees who may contact ACM as part of their regular assigned duties shall participate in an in-house awareness training program.
4.1.4 EMERGENCY SITUATIONS
In the event that emergency responses are required, a person designated by the Manager (usually the Fire and Safety Supervisor) shall be contacted by telephone and may direct responses by telephone. Written documentation of the emergency and response must be completed within 24 hours of the initial telephone contact and forwarded to the Manager.
4.2 OCCUPANT AWARENESS
The Plan will be available from the Manager’s on-site office in Wilson Hall during normal business hours. University employees, as appropriate, shall receive awareness training pursuant to the OSHA Standard. Reinspection and assessment of the subject building shall be performed periodically (5 years) to review the condition of ACM being maintained in-place.
4.3 LABELING OF ACM
The location of any ACM in routine maintenance areas (such as boiler rooms) shall be marked with warning labels affixed immediately adjacent to, or directly upon, the ACM, as appropriate Labeling shall be in accordance with the OSHA Standard for General Industry, 29 CFR 1910.1001.
PART II: OPERATIONS AND MAINTENANCE PROGRAM
1.0 GENERAL SCOPE
The following procedures will be utilized if an O & M program is established for maintenance personnel or work performed by any contractors.
1.1 PROGRAM MANAGEMENT
Program Management shall originate from the Manager, with oversight and review of work locations and procedures being performed by the person(s) designated by the Manager.
1.2 SCOPE
This Plan shall apply to all spaces and building elements at the subject Campus containing ACM and shall not apply to areas where ACM is not present.
1.3 DEFINITIONS
Words, terms and abbreviations used in this Plan shall have the meanings described in the Definitions section of this Management Plan.
1.4 ENGINEERING CONTROLS
Engineering controls such as, but not limited to, isolation, enclosure, local exhaust ventilation, and dust collection shall be used during response action activities. Local exhaust and dust collection systems shall utilize High Efficiency Particulate Absolute (HEPA) filters manufactured for use with asbestos particles. All hand-operated and power-operated tools which may produce or release fibers shall be equipped with local HEPA-filtered exhaust systems.
2.0 CLEANING AND MAINTENANCE PROCEDURES
2.1 GENERAL WORK PRACTICES
General work practices, including but not limited to, handling of asbestos; cleaning of adjacent surfaces and materials; personal protection and hygiene; and isolation of work areas shall be in accordance with the OSHA Standards. Specific instructions and work practices shall be in accordance with the Specific Instructions and Work Practices section of this Program.
2.2 EQUIPMENT AND SUPPLIES
Specialized equipment and supplies, such as but not limited to, HEPA filter equipment, and respiratory and personal protection equipment shall be commercially available equipment and supplies manufactured for their intended use.
2.3 SPECIFIC INSTRUCTIONS AND WORK PRACTICES - NON-FRIABLE ACM
ROUTINE WORK PRACTICES - NON-FRIABLE ACM
The non-friable ACM (resilient asbestos floor tiles, floor tile mastic) is to be cleaned by non-abrasive cleaning agents and methods only. Mild detergents applied by soft mops and/or rags is an acceptable practice. No special personal protective equipment is required for this work. ACM is never to be sanded, chipped, gouged, broken, or otherwise made to break down and become friable.
REMOVAL OF LOOSE OR BROKEN ACM - NON-FRIABLE ACM
Non-friable ACM that has loosened and is to be removed shall be removed in intact sections whenever possible. Removed sections shall be stored and disposed of in accordance with Section 8.0 of this O & M program. No special personal protection equipment is required for this work.
Non-friable ACM that has been broken shall be removed by wetting the broken pieces and the surrounding area with an amended water solution and placing the broken pieces in approved disposal bags. The area from which the pieces were removed, and the surrounding areas, are then to be cleaned using a HEPA filtered vacuum. Personal protective equipment shall be as required by Section 5.0 of this O & M Program.
REMOVAL OF INTACT ACM -NON-FRIABLE ACM
Should the need arise to remove intact non-friable ACM for renovation or other purposes, it shall be removed by methods that will not cause the ACM to break down and become friable.
Removal of more than three square feet or three linear feet of ACM shall be accomplished by a licensed asbestos abatement contractor in a manner specified by an asbestos abatement project designer.
2.4 SPECIFIC INSTRUCTIONS AND WORK PRACTICES - FRIABLE ACM
SCHEDULED REMOVAL - FRIABLE ACM
Scheduled removal of the ACM in any amount shall be accomplished by an asbestos abatement contractor licensed pursuant to N.J.S.A. 34:5A-32 et seq., in a manner specified by an accredited abatement project designer, and in accordance with Section 10.0 of this O & M Program and the requirements of N.J.A.C. 5:23-8.
REPAIR OR EMERGENCY REMOVAL - FRIABLE ACM
Repair or emergency removal shall consist of small-scale, short duration renovation and maintenance activities including:
All such work shall be in strict accordance with the OSHA Standards.
RENOVATION PROJECTS
Renovation and/or demolition projects may motivate reinspection of certain building spaces and/or invasive inspection of such spaces as enclosed bathroom cores and columns at the Manager’s discretion. The owner will utilize the services of an accredited inspector to perform these invasive inspections.
3.0 FIBER RELEASE EPISODE
Major (disturbance of greater than three linear or three square feet) or minor fiber release episodes shall be handled in accordance with the Emergency Procedures detailed in the Management Plan (Part I, Section 4.0). In addition, the following information shall be recorded by the person(s) designated by the Manager and maintained by the Manager:
4.0 RESPIRATORY AND PERSONAL PROTECTION
4.1 PERSONAL PROTECTIVE CONTROLS
No special protective equipment is required for employees of the Manager or other authorized party who may perform work involving non-damaged, non-friable ACM.
Personnel involved in work with friable or damaged non-friable ACM shall use, as a minimum, the following personal protective equipment and procedure:
4.2 MEDICAL EXAMS AND RESPIRATORY PROTECTION PROGRAM
Should any of the Manager’s employees be trained to complete short duration response actions, the Manager shall establish a Respirator Program pursuant to the OSHA Respiratory Protection Standard 29 CFR 1019.134 and N.J.A.C. 12:100.
4.3 OTHER HEALTH AND SAFETY HAZARDS
The owner shall comply with all standards involving other health and safety hazards which may require consideration including but not limited to ladders, scaffolding, electrical equipment, and chemical solvents.
5.0 TRAINING PROGRAMS
All employees whose work requires them to come into contact with or handle ACM shall be furnished with a minimum of fourteen hours of Operations and Maintenance Training, including specific work practices and safety procedures. The Fire and Safety Supervisor is required to attend this training. Training shall be provided prior to or at the time of initial assignment and at least annually thereafter. Operations and Maintenance Training shall be provided by a qualified training agency.
All employees who perform housekeeping operations in an area which contains ACM shall be provided an asbestos awareness training course, which shall at a minimum contain the following elements: health effects of asbestos, locations of ACM in the building, recognition of ACM damage and deterioration, and proper response to fiber release episodes. Each employee shall be trained at least once a year.
The following employees are required to attend the awareness-training course:
- Custodians
- Plumbers
- HVAC employees
- Information System Technicians
All outside contractors working in an area of a building where ACM is located will be notified of the presence of the ACM and will be required and responsible for the appropriate level of training for their employees. Contractors must be able to provide verification that their workers have been trained regarding the proper handling of ACM.
At the date of plan implementation, the Manager is utilizing the services of a New Jersey-licensed asbestos abatement contractor to perform all O & M procedures with its in-house staff members following completion of their training. Of course, the Manager may choose to supplement its O & M capabilities at any time with qualified contracted parties.
6.0 RULES, NOTIFICATIONS, AND PERMITS
6.1 EPA AND OSHA COMPLIANCE
All O & M work shall be performed in compliance with all applicable Federal and State regulations. Compliance with these standards shall be overseen by the Manager.
7.0 WASTE DISPOSAL
7.1 BAGGING AND HANDLING
Any asbestos-containing materials which are not in use, or in place on ceilings, walls, floors, or mechanical system components shall be stored in such a way so as to prevent the release of fibers.
A lockable metal drum shall be maintained in a designated area for temporary storage of O & M generated waste. This designated area shall be in a secured area.
Disposal of asbestos-containing
waste shall be in strict accordance with N.J.A.C. 7:26 Solid Waste Regulations. The
owner shall utilize contractor/haulers as necessary to effect this disposal.
7.2 LABELING
The bags shall be labeled in accordance with applicable regulations.
8.0 PERIODIC INSPECTIONS
At least every five years beginning with the implementation of this Management Plan, all areas where ACM has been identified shall be reinspected for changes in its condition. The reinspection shall be conducted by a person with adequate training. Results of the periodic surveillance shall be forwarded to the Manager for inclusion into this Management Plan.
8.1 INSPECTION CONTROL
The Manager is responsible for maintaining records sufficient to indicate when reinspections are required and for making the necessary arrangements for the reinspections to be conducted by accredited inspectors.
8.2 MANAGEMENT PLAN UPDATES
Should reinspections result in changes of any kind to be made to this Management Plan, those changes may be made by an in-house inspector or an accredited management planner, or the reinspection results may be reviewed by an accredited management planner, and evidence of that review maintained by the Manager.
8.3 SPECIAL INSPECTIONS
Renovation and/or demolition projects shall motivate reinspection of certain building spaces and/or invasive inspection of such spaces as enclosed bathroom cores and columns. The Manager shall utilize the services of an accredited inspector for all inspections.
9.0 ABATEMENT ACTIVITIES
9.1 ABATEMENT DEFINED
The word abatement as used in this O & M Program is a generic term that means any of several procedures to control fiber release from ACM. This includes removal, encapsulation, enclosure, and repair.
9.2 CHAIN OF COMMAND
The Manager shall implement the abatement projects through the use of a professional asbestos consultant. This consultant shall be licensed as an Asbestos Safety Control Monitor (ACSM) and shall consider all aspects and policies of this Management Plan when developing and executing an abatement project.
9.3 USE OF LICENSED CONTRACTORS
Except as noted directly following, only contractors licensed by the New Jersey Department of Labor (NJDOL) to perform asbestos abatement activities shall be used. The asbestos abatement contractors shall use workers licensed with the NJDOL.
As allowed by the applicable New Jersey Asbestos Licenses and Permits Code (N.J.A.C. 8:60/12:120), a contractor that is not a New Jersey-licensed asbestos abatement contractor may undertake removal of asbestos-containing floor tile and/or floor tile mastic utilizing an “excursion method” process approved by the New Jersey State Department of Health. The University may opt to arrange floor tile/mastic removals in this manner.
9.4 REGULATION AND SPECIFICATION COMPLIANCE
All work involving the ACM shall be performed in compliance with all pertinent federal, state, and local codes and regulations. The work shall be performed in accordance with site specific specifications prepared by an accredited asbestos abatement project designer.
All asbestos abatement projects shall comply with the requirements of the USEPA regulation 40 CFR Part 61, Subpart M, and the United States Department of Labor Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.1101.
In addition, the specific work procedures and on-site monitoring requirements of abatement projects conducted in the building shall be conducted in general accordance with the New Jersey Asbestos Hazard Abatement Subcode, N.J.A.C. 5:23-8, as adopted and edited for use by the consultant.
9.5 PERSONAL PROTECTIVE EQUIPMENT
All visitors to active abatement job sites in the building shall be required to wear the necessary personal protective equipment.
9.6 OCCUPANCY CONSIDERATIONS
All abatement work shall take place
in compliance with applicable standards.
9.7 QUALITY ASSURANCE
The contractor’s performance of the work and final release criteria shall be monitored by an ASCM pursuant to criteria adopted by specification from N.J.A.C. 5:23-8. The quality of the abatement contractor’s work shall be primarily determined by visual inspection and air sampling in accordance with the project specifications and N.J.A.C. 5:23-8.
9.8 POLICY DEVIATION
Deviation by any worker or contractor from these established policies shall be investigated and acted on accordingly. The Manager shall not tolerate any mindful deviation from these requirements.
9.9 NOTIFICATIONS
Written notice of the intent to perform asbestos abatement activities in the building shall be transmitted by the contractor to the appropriate Federal, State and local agencies. The notices shall include:
9.10 FIRE AND EMERGENCY NOTIFICATION
Local fire and emergency personnel must be notified of the abatement project and of any special precautions to be used in case of emergency. Telephone numbers of the local authorities must be prominently displayed at the job site.
9.11 WASTE AND WATER DISPOSAL
All required ACM and ACM-contaminated wastes shall be properly enclosed and manifested for hauling and disposal.
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