Environment, Health and Safety Manual - Chapter 05.04: Occupational Safety Policies - Asbestos Control Program

Title

Environment, Health and Safety Manual - Chapter 05.04: Occupational Safety Policies - Asbestos Control Program

Introduction

The Asbestos Control Program is a set of practices and procedures applied to building cleaning, maintenance, construction, renovation and general operation in order to maintain buildings at the University of North Carolina at Chapel Hill ("UNC-Chapel Hill" or "University").

The Asbestos Control Program applies to all UNC-Chapel Hill construction and maintenance personnel including, but not limited to:

• Building Services,
• Engineering and Construction,
• Planning and Design, and
• Energy Services.

The goals at UNC-Chapel Hill are to:

• Manage the asbestos containing materials (ACM) in UNC-Chapel Hill buildings to ensure that exposures to personnel and the environment are minimized and are below the permissible exposure limit (PEL) as established by the US Occupational Safety and Health Administration (OSHA);
• Ensure that all removal and disposal of ACM complies with all local, state, and federal regulations; and,
• Maintain records of surveys, monitoring activities, maintenance activities involving ACM, and personnel exposure.

This program is administered by the UNC-Chapel Hill Department of Environment, Health and Safety. The following individuals oversee the program:

• Asbestos Industrial Hygienist: Environment, Health and Safety;
• Asbestos Supervisor for Campus Maintenance and Housing Support: Supervisor of the Insulation Shop for Campus and Service Shops.

Regulatory Agencies

There are several federal and state regulatory agencies that guard the public from exposure to asbestos. These include:

• Occupational Safety & Health Administration: OSHA is responsible for enforcement of the Occupational Safety & Health Act. Under this act, OSHA establishes requirements that employers must follow in order to provide a safe and healthful working environmental for their employees. OSHA has two asbestos standards that may apply to University employees, depending on the work being completed:
  • 29 CFR 1910.1001: Asbestos Standard for General Industry.
    • The asbestos standard for general industry typically only applies at companies that manufacture asbestos containing products.
  • 29 CFR 1926.1101: Asbestos Standard for Construction Industry.
    • This asbestos standard applies to employees renovating, repairing, demolishing, or testing asbestos containing materials. This standard is the most appliable to the University.
  In North Carolina, OSHA standards are enforced by the North Carolina Department of Labor, Occupational Safety & Health Division.
• Environmental Protection Agency: The EPA is responsible for enforcement of environmental laws designed to protect the general public from exposure to hazardous substances. Laws pertaining to the university include:
  • 40 CFR 61.145: Asbestos Standard for Demolition & Renovation
  • 40 CFR 61.148: Asbestos Standard for Insulating Materials
  • 40 CFR 61.150: Asbestos Standard for Demolition & Renovation Operations
  • 40 CFR 763 Appendix C: Asbestos Model Accreditation Program for States
• North Carolina Department of Health & Human Services: NC DHHS operates the Health Hazards Control Unit (HHCU) who is responsible for enforcing the Asbestos Hazard Management Program outlined in NCAC Title 10A, Chapter 41, Subchapter C .0601-.0611.
• North Carolina Construction Office: The NC State Construction Office has written guideline criteria for asbestos abatement for state owned buildings.

Definitions and Acronyms

• Asbestos Containing Material (ACM): Any material or product that contains more than 1% asbestos.
• Campus Community: Individuals who are not specifically included in the asbestos control program such as students, faculty, non-custodial and non-maintenance staff, and the public.
• Excursion Limit: The acceptable level to which an employee may be exposed to asbestos over a 30-minute time-weighted average. This limit is set to 1.0 fiber per cubic centimeter (f/cc).
• Friable: Material that, when dry, can be crumbled, crushed, pulverized, or reduced to powder by hand pressure.
• HEPA: High efficiency particulate air filter that is capable of filtering 99.97% of the particulates of 0.3 µm in diameter from the air.
• Permissible Exposure Limit (PEL): The acceptable level to which an employee may be exposed to asbestos over an 8-hour time-weighted average. This limit is set to 0.1 f/cc.
• Potentially Asbestos Containing Material (PACM): Material that is suspected to contain asbestos but has not yet been tested. Any suspected material must be treated as containing asbestos until proven otherwise.
• Thermal System Insulation (TSI): Materials placed around boilers and associated piping intended to maintain the temperature of the contents.

Personnel Associated With the Program

• EHS Asbestos Industrial Hygienist
• Facilities Services Training Coordinator
• Insulation Shop Manager

Communicating Hazards to the Campus Community

• Information about asbestos in campus buildings and the asbestos control program is available on the EHS Website. Additional information about asbestos in campus housing is located on the Carolina Housing website. This information is reviewed periodically to ensure it is up to date with current information, policies, and procedures.
• Signs must be placed on mechanical room doors behind which asbestos insulation exists. The signs must state:
  • WARNING!: Some of the pipe insulation and other thermal system insulation in this room contain asbestos. Avoid creating dust from any insulation. If disturbance of this material is anticipated during any work task then contact the Environment, Health and Safety (919-962-5507) prior to beginning work.
• General information about asbestos and who to contact in for questions and concerns must be included in the new employee orientation training.
• Optional training must be available to all University employees and students regarding the hazards of asbestos. The training must be in an online format and equivalent to the Level 1 Awareness Training (see "Training" section below).
• Notification must be sent to building occupants before starting work on asbestos. Signs advising employees and students regarding ongoing asbestos removal must be posted outside of the abatement area. The signs must state:
  • DANGER
    ASBESTOS
    MAY CAUSE CANCER
    CAUSES DAMAGE TO LUNGS
    AUTHORIZED PERSONNEL ONLY

Training

All University employees must have access to asbestos training to ensure they are aware of the following:

• the hazards of asbestos,
• how to protect themselves from exposure to these hazards, and
• the contents of the asbestos control program.

Training is outlined based on work tasks below:

1. Level 1 Awareness Training: All University employees must have access to an online training presentation that must include the following information:
   1. Health hazards associated with asbestos,
   2. Regulations pertaining to asbestos,
   3. Presence of asbestos in university buildings, and
   4. Dos and don’ts.
2. Level 2 Housekeeping/General Maintenance Training: All University housekeeping and general maintenance employees must be provided with a two-hour advanced asbestos awareness course. The course must be provided online (with an option to schedule an in-person class) and must include the following information:
   1. History of asbestos use,
   2. Routes of exposure to asbestos,
   3. Health hazards associated with asbestos,
   4. Buildings that may have ACM,
   5. Typical building components that may contain asbestos,
   6. How to protect yourself from exposure,
   7. How to identify damaged asbestos containing materials, and
   8. Who to contact with questions pertaining to asbestos.
   The course may be taught in person at the request of a department supervisor. All University employees eligible for Level 2 Training must complete the training upon initial hire/assignment and at least annually thereafter.
3. Level 3 Asbestos Worker Training: All employees engaged in asbestos removal must be provided with a 16-hour asbestos work practices course. The course must be provided in person and must include the following information:
   1. History of asbestos use,
   2. Routes of exposure to asbestos,
   3. Health hazards associated with asbestos,
   4. Buildings that may have ACM,
   5. Typical building components that may contain asbestos,
   6. Types of asbestos work permitted by University employees,
   7. Exposure control during asbestos work,
   8. Personal protective equipment (PPE) mandated during asbestos work,
   9. Exposure monitoring conducted by EHS, and
   10. ACM disposal.

   All University employees eligible for Level 3 Training must complete the training upon initial hire/assignment and at least annually thereafter.

   *In lieu of the internal level 3 training course, employees may be sent to an asbestos supervisor course provided by another company as long as the course is accredited by the North Carolina Department of Health & Human Services Health Hazards Control Unit.

Medical Surveillance Program

• All University employees trained at Level 3 and that conduct asbestos removal must be included in a medical surveillance program administered by the UNC-Chapel Hill University Employee Occupational Health Clinic (UEOHC). The program must include initial medical screening for all University employees trained at Level 3. The initial medical screen must consist of the following:
  • Review of medical and work history, with emphasis on the pulmonary, cardiovascular, and gastrointestinal systems.
  • Physical examination with emphasis on pulmonary and gastrointestinal systems.
  • Pulmonary function testing for forced vital capacity and forced expiratory volume at one second.
  • Posterior and anterior chest x-ray.
  • Any other procedure the examining physician says is necessary.
• All University employees trained at Level 3 must receive additional examinations at least annually or in greater frequency if the examining physician says it is necessary.
• The UEOHC must keep copies of the physician’s written opinion for the University employees' most recent exam.

Housekeeping Policies & Procedures

• Housekeeping employees may burnish vinyl tile floors that contain asbestos if the wax finish over the floor is in good condition. Housekeeping employees must report damaged vinyl floor tiles that contain asbestos to their supervisor.
• If Housekeeping employees are going to strip vinyl floor tiles containing asbestos of their wax finish, the Housekeeping employees must strip the vinyl floor tiles using a wet processes with low abrasion pads operating below speeds of 300 revolutions per minute.
• Sanding or grinding of asbestos containing vinyl floor tile is prohibited.

Maintenance Policies & Procedures

• University employees and/or external contractors may conduct asbestos abatement. However, University employees are only permitted to conduct limited removal of materials containing friable asbestos. University employees should contact the EHS Asbestos Industrial Hygienist for guidance on specific projects. University employees and/or external contractors that are removing materials that contain asbestos must use the following controls:
  • Non-friable methods whenever possible,
  • Mini-enclosures or glove bags,
  • Local exhaust ventilation and
  • PPE.
• University maintenance employees must not use tools likely to release a large number of asbestos fibers into the workplace during abatement activities. Tools that may release a large number of asbestos fibers include power drills, power saws, sanders, and grinders.
• Asbestos must be removed following asbestos safe work practices, which are outlined by job task in Appendix C.
• Properly dispose of all asbestos debris at the Giles Horney complex shed.
• University employees and/or external contractors vacuuming ACM debris must use a HEPA vacuum.

Roles and Responsibilities

Various University employees/departments have differing responsibilities for implementation of the asbestos control program. These employees include:

EHS Asbestos Industrial Hygienist

• Conduct online and in person training for university employees.
• Document ACM in University buildings
• Conduct inspections of University facilities to determine condition of ACM.
• Retrieve bulk samples of ACM or PACM and send samples to a lab for testing.
• Conduct air monitoring for asbestos removal work conducted by University employees.
• Conduct periodic inspections of work conducted by University employees.
• Respond to inquiries regarding the UNC-Chapel Hill asbestos control program and ACM on campus.
• Review data provided by consultants that are retained by outside contractors for asbestos abatement.
• Review the asbestos control program annually.
• Conduct annual inspections of focus buildings. Inspections must include:
  • A visual assessment of any damaged ACM.
  • Air monitoring to measure asbestos fibers in the atmosphere.
• Conduct inspections of containment for asbestos remediation work conducted by outside contractors. Conduct an additional inspection when work is completed to ensure adequate clean-up.
• Conduct inspections of housekeeping equipment to ensure buffers used on asbestos containing floor tile do not exceed 300 RPM.
• Review NC HHCU permits submitted by maintenance supervisors.

Training Coordinators

• Ensure all University employees have completed their required training upon initial assignment and at least annually thereafter.

Housekeeping & General Maintenance Employees

• Follow the housekeeping and general maintenance asbestos policies.
• Tell EHS and close off the area if a housekeeping and/or general maintenance employee encounters deteriorating asbestos.

Asbestos Removal Maintenance Employees

• Follow the asbestos removal policies.
• Tell EHS if an asbestos removal maintenance employee encounters deteriorating asbestos.

Asbestos Maintenance Supervisors

• Provide University employees with all equipment needed for proper asbestos abatement at no cost to the employees.
• Coordinate with the EHS Asbestos Industrial Hygienist to have air monitoring conducted during abatement work.
• Maintain all equipment needed to conduct proper asbestos abatement.
• Package, label, and transport all waste to the Giles Horney Complex.
• Submit an application for the annual asbestos removal permit to the NC HHCU no later than December 16th. Supply EHS with a copy of the permit. A blank copy of the permit to be obtained from the NC HHCU is contained in Appendix B.
• Document asbestos removal using the Asbestos O&M Activity Checklist found in Appendix A.
• Tell the EHS Asbestos Industrial Hygienist about all abatement activities.

Construction and Project Managers

• Hire environmental consultants for all construction projects involving asbestos removal.
• Ensure the asbestos abatement contractor is approved to work in NC.
• Ensure an asbestos inspection is conducted for all construction, demolition, and renovation projects to assess the presence of ACM and potential for disturbance during the work phase of the project.
• Provide EHS with copies of the following before starting a project:
  • the asbestos inspection report,
  • the project design specification, and
  • the air monitoring plan.
• Make worksites available for inspection by EHS employees.

Contractors

• Follow all OSHA and EPA standards related to asbestos removal including:
  • Conduct all air monitoring as required by OSHA and EPA standards.
  • Place required warning signs to advise occupants in the area of asbestos remediation work.

Employee Exposure Assessment

The EHS Asbestos Industrial Hygienist must conduct exposure assessments for asbestos removal employees. The exposure assessment must document the following information:

• the type of work performed,
• the length of time the work took, and
• who performed the work.

The exposure assessment must be made using air monitoring data. Asbestos maintenance supervisors must inform the EHS Asbestos Industrial Hygienist of when asbestos work will be conducted so that monitoring can occur.

Employee Complaints

• Complaints relating to potential asbestos exposure filed by building occupants must be reported to EHS.
• EHS must inspect the work area and evaluate the potential for exposure.
• The evaluation may require the EHS representative to collect a bulk sample to determine if the material contains asbestos.
• The EHS representative may perform air monitoring if there is any disturbance of ACM that could result in personnel exposure to airborne asbestos.
• EHS must maintain a written report of the investigation and must provide the employee with a copy of the report.

Appendices

Appendix A: Asbestos O&M Activity Checklist

Please see the attached fillable PDF.

Appendix B: Asbestos Removal Permit

Please download and use the current version of NC DHHS Form # 3768 that is posted on the NC DHHS Asbestos Forms, Applications, & Notifications website.

Appendix C: Asbestos Work Practices

A. Removal of Thermal System Insulation Utilizing a Glovebag

The following work practice procedures must be followed during the removal of pipe insulation under Class I, II, or III work activities. (This method should be performed after normal business hours in occupied areas.) Please note that Class III workers (ASBESTOS O&M Trained) cannot remove more than one standard glovebag (60″ x 60″) of TSI.

1. Check the temperature of the pipe to ensure that it does not exceed 150° Fahrenheit. Note: High temperature glovebags may be required for steam lines exceeding 150° Fahrenheit.
2. Install critical barriers on all HVAC ductwork, floor drains, and other openings. Place danger signs and barrier tape around the regulated work area.
3. Put on a respirator and disposable suit. Perform negative and positive pressure fit check.
4. Place a layer of 6-mil polyethylene sheeting under the work area.
5. If necessary, cut approximately a foot down the sides of the glovebag and place the tools in the pouch.
6. Wrap tape around the pipe where you will attach the bag. Tape the bag closed.
7. Cut two small holes in the bag and insert the nozzles of the HEPA vac and the sprayer. Seal the openings with duct tape.
8. Smoke test the glovebag to insure that it is sealed airtight.
9. Spray the insulation with amended water, being sure to soak the area to be cut.
10. Cut the insulation with a saw or knife at each end of the section to be removed. Cut it lengthwise along the bottom with a knife.
11. Break the insulation away from the pipe and lower it to the bottom of the bag.
12. Spray the insulation with amended water to wash any asbestos to the bottom of the bag.
13. Spray, scrub, and wipe the exposed pipe to remove any asbestos on the pipe. Use a brush with nylon or fiber bristles. Spray lockdown on the pipe.
14. Grab the tools in your hands and pull the gloves inside out. Remove the rest of the air in the bag by briefly turning on the HEPA vac. Twist the sleeve and tie it off with two pieces of duct tape. Cut the sleeve between the tape at the twist. Put the sleeve containing the tools in the next glovebag to be used or open it in a pail of water for cleaning.
15. Turn the HEPA vacuum on again. Twist the bag below the pipe and tape it closed.
16. Slip a large plastic asbestos disposal bag around the glovebag. Remove the glovebag from the pipe and fold it into the disposal bag. Seal and label the bag.
17. Apply encapsulant paint on the cut edges of the asbestos pipe and apply a canvas cloth to seal the open ends.
18. Vacuum the work area, move to the decontamination area, and vacuum your clothing.
19. Remove and wipe your respirator with a damp cloth. Remove your disposable suit inside out and place it in an asbestos disposal bag with contaminated rags, used filters, and decontamination plastic sheeting. Seal and label the bag for disposal.
20. Contact EHS to conduct monitoring and a visual inspection if the scope of work includes the removal of more than three linear feet.
21. Remove barrier tape and signage from the work area.
22. Transport waste to the storage facility (through the Asbestos Supervisor for Facilities).

B. Drilling into ACM

1. If possible, shut off the HVAC system serving the work area and install critical barriers.
2. Mark the drilling location.
3. Put on a respirator, disposable gloves, and disposable suit. Perform negative and positive pressure fit check. (Once a NEA is established, the PPE with the exception of the non-porous disposable gloves can be omitted from the requirements.)
4. Pre-clean work area if visible dust or debris is present with amended water and/or HEPA vacuum.
5. Place a drop cloth of 6-mil polyethylene sheeting under the work area.
6. Fill a paper cup with shaving cream and apply the shaving cream side down to the substrate.
7. Drill through the surface and remove the drill bit being sure to clean with a wet wipe or water.
8. Wipe the shaving cream off the surface with a wet wipe and place it in disposal bag.
9. If debris falls to the ground, either wet wipe, HEPA vacuum, and/or dispose in an asbestos disposal bag.
10. Dispose of gloves in the asbestos waste bag.
11. Transport waste to the storage facility (through the Asbestos Supervisor for Facilities).

C. Mini Enclosure (Plastic Closet)

The mini enclosure should be sized to house a maximum of two workers.

1. If possible, shut off the HVAC system serving the work area.
2. Install critical barriers on all HVAC ductwork, floor drains, and other openings. Place the danger signs and barrier tape around the regulated work area.
3. Construct the mini enclosure from polyvinylchloride (PVC) piping and line with two layers of 6-mil poly. Place a small layer of poly on the ground outside of the containment as decontamination area.
4. Smoke test the enclosure.
5. Create an opening in the enclosure and add protective flaps over the opening.
6. Install a HEPA vacuum to the enclosure placing the vacuum on the opposite side of the entrance opening. The HEPA vacuum functions as the negative air machine.
7. Install tools needed to perform the abatement.
8. Put on a respirator, disposable gloves (optional), and two disposable suits.
9. Apply the amended water to the ACM using a garden sprayer. Remove no more than the amount held by one waste bag.
10. Place the material in an asbestos disposable bag (double bagged) and remove from the mini enclosure after wiping down.
11. HEPA vacuum and wet wipe the interior surfaces of the mini enclosure.
12. Apply lockdown to all of the surfaces within the mini enclosure.
13. When finished, clean off the outside suit with a HEPA vacuum.
14. Remove the outside suit by rolling the suit inside out and place it in a disposable bag. Move to the decontamination area outside the mini containment and remove the remaining suit while wearing the respirator.
15. Thoroughly wash the respirator and hands after exiting.
16. Contact EHS to conduct monitoring and/or visual inspection of the work area.
17. Once the lockdown has dried, tear down the mini enclosure and place the polyethylene sheeting in waste bags.
18. Transport waste to the storage facility (through the Asbestos Supervisor for Facilities).

D. Removal of Flooring Material and Mastic Utilizing Non-Friable Removal Techniques (Class II)

1. If possible, shut off the HVAC system serving the work area.
2. Install critical barriers on all HVAC ductwork, floor drains, and other openings. Place the danger signs and barrier tape around the regulated work area.
3. Install negative pressure differential machines equipped with a HEPA filter in the work area and exhaust (when possible) to the outside via window, doorway, etc.
4. Put on respiratory protection and PPE.
5. If the mastic is scheduled to be removed, remove the baseboards and tape a two foot wide layer of 4-6 mil poly along the base of the walls as a splashguard while removing the mastic.
6. Using a heat gun or an infrared heat machine, heat the tiles and remove using a mason’s trowel. Exception: If the flooring material was identified as being damaged and brittle, do not use heat and gently remove the tiles and place them in a sealed bag.
7. Class III Workers (ASBESTOS O&M Trained) can only abate the amount of material that will fit in one waste bag if the flooring material is friable.
8. Place the tiles in cardboard boxes and then place into the disposable bag in order to prevent puncturing the disposal bags. Seal the bags with the goose neck seal.
9. Contact EHS to determine if air monitoring and/or visual inspection is necessary if removing more than 160 square feet of non-friable flooring material, .
10. Transport the waste to the temporary storage facility maintained by the Asbestos Supervisor for Facilities.

E. Principles of Containment and Personal Protection

The following containment and personal protection practices must be followed when performing asbestos abatement activities:

1. Personnel must wear a minimum of a half face cartridge respirator equipped with a HEPA (P100) filter. Use a glove bag for removal of TSI.
2. Plastic sheeting must be used as a drop cloth on the floor below any TSI and surfacing material that is to be removed.
3. A step-off drop cloth of polyethylene sheeting must be placed beside all work areas as a decontamination area.
4. Wet methods of ACM removal must be used to minimize airborne asbestos.
   • Exception: If dry removal has been approved due to electrical or other safety hazard.
5. The room or area must be isolated from the building ventilation system.
6. Enclosures under negative pressure must be constructed to isolate the ACM removal from other areas of the building.
7. Warning signs must be posted outside the room or enclosure with the following information: “Danger, Asbestos, May Cause Cancer, Causes Damage to Lungs, Authorized Personnel Only.”
8. Surfaces potentially contaminated with ACM must be cleaned using wet methods or a HEPA vacuum.
9. Contaminated waste is to be placed in sealed, doubled 6-mil bags or other approved leak-tight containers and transported to the temporary storage area at Facilities Services.

Related Requirements

External Regulations

• 29 CFR 1910.1001: Asbestos Standard for General Industry
• 29 CFR 1926.1101: Asbestos Standard for Construction Industry
• 40 CFR 61.145: Asbestos Standard for Demolition & Renovation
• 40 CFR 61.148: Asbestos Standard for Insulating Materials
• 40 CFR 61.150: Asbestos Standard for Demolition & Renovation Operations
• 40 CFR 763, Appendix C: Asbestos Model Accreditation Program for States
• NC Administrative Code: Title 10A, Chapter 41, Subchapter C .0601-.0611
• NC Department of Administration, State Construction Office: Asbestos Abatement Guidelines and Policies

University Policies, Standards, and Procedures

• Design and Construction Guidelines - A-20.1: Hazardous Materials Guidelines
• Design and Construction Guidelines - A-32: Environmental Demolition and Remediation

Contact Information

Policy Contact

Environment, Health and Safety
1120 Estes Drive
Campus Box #1650
Chapel Hill, NC 27599-1650
Phone: 919-962-5507

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