UNIVERSITY
OF DELAWARE'S ASBESTOS MANAGEMENT PLAN
1.0
Purpose
The
University of Delaware is committed to provide its employees, sub contractors,
students and visitors with a safe environment, and to ensure that safe work practices
are followed. This commitment includes reducing occupational as well as general
population exposure to asbestos. The asbestos management plan (AMP) will be reviewed
and updated as needed by the University's Asbestos Specialist.
2.0
Definitions
2.1
Asbestos- includes chrysotile, amosite, crocodilite, tremolite asbestos, anthophyllite
asbestos, actinolite asbestos and any of these minerals that have been chemically
treated and/or altered.
2.2
Asbestos Containing Material- means any material containing more than one-percent
asbestos.
2.3
Building/Facility Owner- means the University of Delaware.
2.4
Employee Exposure- means that exposure to airborne asbestos that would occur if
the employee were not using respiratory protection.
2.5
Fiber- means a particulate form of asbestos 5 micrometers or longer, with a length
to diameter ratio of at least 3 to 1.
2.6
High-Efficiency Particulate Air (HEPA) Filter- means a filter capable of trapping
and retaining at least 99.97 percent of 0.3-micrometer diameter mono-dispersed
particulates.
2.7
Permissible Exposure Limit (PEL) -
(1)
Time Weighted Average (TWA)- The employer shall ensure that no employee is exposed
to an airborne concentration of asbestos in excess of 0.1 fibers per cubic centimeter
of air as an eight hour TWA.
(2)
Excursion Limit (EL)- The employer shall ensure that no employee is exposed to
an airborne concentration of asbestos in excess of 1.0 fibers per cubic centimeter
as averaged over a sampling period of thirty minutes.
2.8
Presumed Asbestos Containing Material (PACM)- means thermal system insulation,
sprayed or troweled on surfacing material, and debris in buildings constructed
before 1980 that are assumed to contain greater than one percent asbestos but
has not been sampled or analyzed to verify or negate the presence of asbestos
as defined by the OSHA standard.
2.9
Regulated Area- means areas established by the employer to demarcate areas where
airborne concentrations of asbestos exceed or there is a reasonable possibility
they may exceed, the permissible exposure limit.
2.10
Small Operations and Maintenance Activities- means any activity conducted by the
University's in-house asbestos team that requires the abatement of less than 25
linear feet or 10 square feet of known or assumed ACM.
2.11
Surfacing Material- means material that is sprayed, troweled-on, or otherwise
applied to surfaces (such as acoustical plaster on ceilings, fireproofing materials
on structural members, or other materials for acoustical or fireproofing purposes).
2.12
Suspect Asbestos Containing Materials- means any material that may contain more
than one- percent asbestos but has not been sampled and tested to determine its
asbestos content.
2.13
Thermal System Insulation- means material applied to boilers, pipes fittings,
tanks, breaching, ducts or other structural components to prevent heat loss or
gain.
3.0
Personnel Covered Under the Asbestos Management Plan
3.1
Personnel to be covered under this plan will be identified by the Department of
Environmental Health & Safety (DEHS). This information will be provided for their
consideration. This will include but not be limited to custodians, skilled craftsmen,
project and construction managers, outside contractors, or any other person that
may come in contact with ACM on a routine basis.
4.0
Identification of ACM or ACM Hazards Prior To Renovation or Demolition Projects
4.1
Prior to the start of any scheduled or emergency renovation or demolition project,
the project manager, construction manager or other person responsible for the
project must determine if any suspects ACM may be disturbed during the
operation.
4.2
If the University's project manager, construction manager or other responsible
person cannot determine if suspect ACM will be disturbed during the operation,
then the Asbestos Specialist must be contacted to make the final determination.
4.3
If a determination has been made by the University's project manager, construction
manager, or other responsible persons that suspect ACM will be disturbed,
the University's
Asbestos Specialist must be notified to determine if bulk sampling of the suspect
ACM or any other applicable action will be necessary.
4.4
To initiate an asbestos survey the project manager, construction manager or other
responsible person will utilize the "University of Delaware Hazard Communication
Form" and submit the form to the Asbestos Specialist for review.
4.5
Under no circumstances will any suspect ACM be disturbed without following the
prescribed procedures as outlined above.
5.0
Identification of ACM or ACM Hazards for Small Scale Operation and Maintenance
Activities
5.1
Prior to the start of any small scale operation and maintenance activity or emergency
response activity, such as but not limited to, valve or pipe repair, computer
cable installation above suspended ceiling, etc., a determination must be made
if any suspect ACM will be disturbed.
5.2
This determination must be made by the person responsible for the operation. If
the person responsible for the project cannot make the appropriate determination,
the Asbestos Specialist or in-house asbestos team must be contacted.
5.3
If the amount of ACM removed during the small-scale operation and maintenance
activity exceeds the quantity limit, then the Asbestos Specialist must be contacted.
5.4
Under no circumstances, will any suspect ACM be disturbed without following the
prescribed procedures as outlined above.
6.0
Permissible Exposure Limit and Excursion Limit
6.1
The University's asbestos management plan is committed in trying to maintain asbestos
exposures below the permissible exposure limit (PEL) of 0.1 fibers per cubic centimeter
of air as averaged over an eight hour time weighted average and the
excursion limit
(EL) of 1.0 fibers per cubic centimeter of air as averaged over a 30 minute sampling
period. Work practices, engineering controls, and personal protective equipment
will be utilized to maintain asbestos airborne concentrations below the PEL and
EL.
7.0
Exposure Monitoring
7.1
Exposure monitoring shall be performed on target groups of personnel who are potentially
exposed to airborne asbestos fibers at or above the PEL or EL. This includes but
is not limited to custodians, in-house asbestos abatement team, and any other
target groups the Department of Environmental Health & Safety deemed appropriate.
Air monitoring will be performed periodically to ensure airborne concentrations
do not exceed the PEL or EL. If the air monitoring indicates statistically that
the affected target group of personnel are below the PEL or EL, the Department
of Environmental Health & Safety may advise to discontinue air monitoring for those
groups. The Department of Environmental Health & Safety will reinstate air monitoring
activities whenever there has been a change in work processes, engineering control
equipment, personnel, work practices, that may result in new or additional
exposures
to asbestos at or above the PEL or EL. If the PEL or EL is exceeded, then work
practices, engineering controls will be re-evaluated by the Asbestos Specialist.
All exposure monitoring will be conducted by the Asbestos Specialist, the University’s
asbestos consultant or any other party the Asbestos Specialist deems
qualified.
7.2
Affected groups or their representatives may observe at any time the air monitoring
activities. Affected personnel will receive the results of the test within 15
days. Any results above the PEL or EL will also include a written statement on
corrective action incorporated to reduce airborne asbestos fibers below the PEL
or EL.
7.3
Exposure monitoring will help identify personnel who need to be covered by the
medical surveillance program as outlined in section 8. of the AMP.
8.0
Medical Surveillance
8.1
The University will supply a medical surveillance program for the University's
in-house abatement team. All medical exams will be provided free of charge to
the employee and be performed by or under a licensed physician. The medical surveillance
program will comply with the OSHA standards 29 CFR 1910.1001
and 1926.1101.
8.2
At a minimum, the exam will include medical and work history, a complete physical
exam, with the emphasis on the respiratory system, the cardiovascular system,
and the digestive tract; pulmonary function test; and respiratory disease standardized
questionnaire as set forth in the OSHA standards 29 CFR 1910.1001 and 1926.1101.
8.3
Physical exams will be made available on a yearly basis, and chest roentgenogram
will be performed as outlined in 29 CFR 1910.1001 and 1926.1101.
8.4
Upon termination of employment the employee will be required to complete a medical
exam within thirty days before or after termination. This exam will be provided
free of charge to the employee.
8.5
The University will provide a copy of the physician's written statement to the
employee within 30 days of receipt.
8.6
All personal information received by the University will be held in strict confidence.
9.0
Record Keeping of Employee Information
9.1
The University will keep accurate records of all exposure measurements taken to
monitor employee exposure to asbestos. Records will be kept for 30 years.
9.2
The University will also maintain an accurate record for each employee subject
to medical surveillance. These records will be maintained for the duration of
employment plus 30 years.
9.3
The University will maintain all employee training records for one year beyond
the last date of employment by the University.
9.4
The University will comply with the OSHA standards 29 CFR 1910.1001
and 1926.1101 concerning
recordkeeping for employee information.
10.0
Recordkeeping of Asbestos Containing Materials Location
10.1
The Department of Environmental Health & Safety will maintain records about the
presence, location, and quantity of ACM identified to date in each building.
10.2
The University community may access all records concerning ACM at any time. Coordination
of such activities will be made through the Asbestos Specialist.
11.0
Regulated Areas
11.1
The University will establish and set apart regulated areas wherever airborne
concentrations of asbestos potentially exceed the PEL or EL. Only authorized personnel
will be permitted to enter regulated areas. All personnel entering regulated areas
will be required to wear appropriate respiratory protection. These types of areas
include but are not limited to asbestos abatement projects, above suspended ceilings
where asbestos fireproofing or plaster exists, crawlspaces where damaged ACM exists,
or other areas that the Department of Environmental Health & Safety has deemed
a regulated area.
11.2
No smoking, eating, drinking, chewing tobacco or gum, or applying cosmetics is
permitted in regulated areas.
11.3
Warning signs must be posted at all areas where asbestos removal, encapsulation,
enclosure activities are in progress. The signage will conform to 29 CFR
1910.1001 and 1926.1101.
12.0
Communication of Hazards
12.1
Personnel engaged in housekeeping activities, operation and maintenance activities,
or other activities that could potentially disturb ACM might be exposed to asbestos
fibers. The University is committed to minimize personnel asbestos exposure through
the following mandates:
(1)
In buildings constructed before 1980, personnel will treat thermal system insulation,
sprayed or troweled on surfacing materials, and floor tile and linoleum as asbestos
containing material, unless properly sampled and analyzed for asbestos content.
(2)Inform
and provide training for employees performing housekeeping activities or other
activities that may contaminate the work area.
(3)
The University shall keep records of the presence, location, and quantity of ACM
identified to date in each building.
(4)
Persons responsible for the oversight of demolition and renovation projects must
communicate the location, presence, and quantity of ACM at each work site to all
contractors prior to the start of work.
(5)
All building occupants will be notified concerning abatement activities prior
to the start of any asbestos project. This activity can be accomplished through
meetings or written correspondence.
13.0
Training
13.1
The Department of Environmental Health & Safety will provide training for all employees
who are potentially exposed to asbestos fibers above the PEL or EL. Training will
be provided on an annual basis or at the time of being hired. The training program
will inform employees about ways in which they can safeguard their health.
13.2
The elements of the training course will include the health affects of asbestos;
common types of ACM that are present at the University, locations of known ACM,
signs of damage and deterioration of ACM; the proper response to fiber release
episodes; and where the housekeeping requirements are located in 29 CFR 1910.1001.
13.
All training will be provided free of charge to the individuals covered under
this plan.
14.0
Control Methods
14.1
To the extent feasible, engineering and work practice controls must be in place
to reduce and maintain employee exposure at or below the PEL or EL. The following
are a list of requirements established by the Department of Environmental Health & Safety.
(1)
Design, construct, install, and maintain local exhaust ventilation and dust collection
systems according to the American National Standard Fundamentals Governing the
Design and Operation of Local Exhaust Systems, ANSI
Z9.2-2006.
(2)
Provide local exhaust ventilation system for all hand operated and power operated
tools such as saws, scorers, abrasive wheels, and drills those produce or release
asbestos fibers.
(3)
Handle, mix, apply, remove, cut, score, or work asbestos in a wet state to prevent
employee exposure.
(4)
Sanding of floors containing asbestos is prohibited.
(5)
Using compressed air to remove asbestos or materials that contain asbestos is
prohibited.
15.0
Respiratory Protection
15.1
Respiratory protection is required in all areas that the PEL or EL may be exceeded.
This includes but is not limited to; above suspended ceiling where ACM plaster
or other damaged ACM exists, removal of ACM, drilling or cutting into ACM plaster
walls, accessing crawlspaces with damaged ACM, etc.
15.2
Respirators will be equipped with High Efficiency Air Particle (HEPA) filters
for all asbestos related activities.
16.0
Protective Clothing
16.1
Any employee or contractors exposed to airborne concentrations of asbestos that
may exceed the PEL or EL are required to wear protective clothing, such as full
body clothing, head coverings, gloves, and foot coverings. Eye protection is also
required.
16.2
Asbestos contaminated work clothing will not be permitted to leave the work site.
All contaminated work clothing will be disposed of as ACM waste.
17.0Hygiene
Facilities and Practices
17.1
All personnel that work in regulated areas are required to set up or have access
to clean change rooms and shower facilities. All personnel will comply with CFR
1910.1001 and 1926.1101.
18.0
Housekeeping
18.1
All surfaces must be maintained as free as possible of accumulations of waste
containing asbestos and/or asbestos dust. HEPA filtered vacuums or wet methods
are the preferred choices for these activities. Compressed air will not be permitted
for any housekeeping activities.
18.2
Only qualified and trained personnel, determined by the Department of Environmental Health & Safety will be permitted to clean asbestos waste or debris.
18.3
All ACM or PACM floor tile shall not be sanded for any reason and that low abrasion
pads at speeds lower than 300 rpm and wet methods must be employed. If floors
have a sufficient layer of wax, brushing or dry buffing is permitted.
19.0
Asbestos Waste and Storage
19.1
All asbestos waste generated at the University of Delaware will be disposed of
at an EPA approved landfill designated by the Department of Environmental Health & Safety. All asbestos waste generated will be bagged and transported in accordance
with all applicable State and Federal regulations.
19.2
All waste generated by the University's asbestos abatement team will be stored
only at the University's storage facility designated for asbestos waste. There
will be no exceptions.
20.0
Asbestos Abatement Activities
20.1
State of Delaware licensed asbestos workers or supervisors as defined by the Department
of Natural Resources and Environmental Control shall only conduct all removal,
patch and repair, enclosure, encapsulation, or disturbance of ACM.
20.2
All asbestos abatement related activity will be completed in strict accordance
with OSHA CFR 1926.1101, 1910.1001 and the
State of Delaware asbestos regulations.
20.3
Any asbestos abatement contractor performing asbestos related task at the University
must first be pre-approved by the Department of Environmental Health & Safety.
