Environmental Health & Safety

University of Colorado Boulder

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Asbestos Operations and Maintenance Program

This Environmental Health & Safety guideline documentation is intended for Operations and Maintenance.

Revised as of March 12, 2014

General Description

The objective of this program is to outline the work practices, training requirements and processes put in place by the University’s Environmental Health and Safety Department to protect building occupants and University Employees during Operation and Maintenance (O&M) activities. This O&M program is intended for University of Colorado Boulder employees who have been trained for O&M work under the CU EHS O&M training. This program is not intended or designed for Contractors conducting asbestos abatement on the Boulder Campus.

I. Definitions

Amended Water: water to which surfactant (wetting agent) has been added to increase the ability of the liquid to penetrate

Asbestos: includes chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos, actinolite asbestos, and any of these minerals that has been chemically treated or altered.

Asbestos-Containing Material (ACM): any material containing more than one percent (1%) asbestos.

Authorized Activity: Small scale short duration job task, specific to the University of Colorado’s Boulder Campus, which will impact asbestos containing material, has been approved and documented by CU EHS, has a current Negative Exposure Assessment and is included in this Operations and Maintenance Program.

Class I Asbestos Work: the removal of thermal system insulation and/or surfacing material (ACM or PACM).

Class II Asbestos Work: removal of any ACM which is not Class I, such as wallboard, floor tile, ceiling tile, linoleum, transite board, roofing materials and mastics.

Class III Asbestos Work (O&M): repair and maintenance operations where ACM is likely to be disturbed.

Class IV Asbestos Work: maintenance and custodial activities during which employees contact but do not disturb ACM, and activities to clean up dust and debris which may be generated by Class I, II, or III work.

Clearance Air Monitoring: Air monitoring conducted by an Asbestos Project Monitor at the conclusion of an asbestos project. Clearance air monitoring includes the successful completion of a final visual inspection for work area debris and the collection and analysis of air samples in accordance with AHERA protocols.

Competent person: in addition to the definition in 29 CFR 1926.32 (f), one who is capable of identifying existing asbestos hazards in the workplace and selecting the appropriate control strategy for asbestos exposure, who has the authority to take prompt corrective measures to eliminate them, as specified in 29 CFR 1926.32(f): in addition, for Class I and Class II work who is specially trained in a training course which meets the criteria of EPA’s Model Accreditation Plan (40 CFR 763) for supervisor, or its equivalent and, for Class III and Class IV work, who is trained in a manner consistent with EPA requirements for training of local education agency maintenance and custodial staff as set forth at 40 CFR 763.92 (a)(2).

CU-EHS: University of Colorado Environmental Health and Safety Department

Friable Asbestos Containing Material: any material containing more than one percent asbestos, which when dry, may be crumbled, pulverized or reduced to powder by hand pressure.

GAC: General Abatement Contractor

High Efficiency Particulate Air (HEPA) Filter: a filter capable of trapping and retaining at least 99.97 percent of all mono-dispersed particles of 0.3 micrometers in diameter.

Threshold Quantity: Maximum amount of specific types of ACM that can be removed or disturbed by CU personnel under this program. Quantities greater than threshold must be conducted by a GAC or with direct approval from CU EHS.

MMS: Material Management System maintained by CU EHS

Negative Exposure Assessment (NEA): a demonstration by the employer, which complies with the criteria in OSHA 29 (CFR) 1926.1101 paragraph (f) (2) (iii), that the employee exposure during the monitored operation is expected to be consistently below the PELs.

Non-Friable Asbestos Containing Material: materials in which asbestos is bound in a matrix which cannot, when dry, be crumbled, pulverized or reduced to powder by hand pressure (such as floor tile and asphaltic building materials).

Permissible Exposure Limits (PELs):
(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 fiber per cubic centimeter as an eight (8) hour time weighted average.
(2) Excursion Limit (EL): the employer shall ensure that no employee is exposed to an airborne concentration of asbestos in excess of 1.0 fiber per cubic centimeter of air as averaged over a sampling period of thirty (30) minutes.

PPE: Personal Protective Equipment

Presumed Asbestos Containing Material (PACM): thermal system insulation and surfacing material in buildings constructed no later than 1980 are assumed to contain asbestos until it has been analyzed to verify or negate its asbestos content.

Regulated Area: means an area established by the employer to distinguish areas where airborne concentrations of asbestos exceed or there is a reasonable possibility that they may exceed the permissible exposure limits. The regulated area shall be demarcated in any manner that minimizes the number of persons within the area and protects persons outside the area from exposure to airborne asbestos.

Small Scale Short Duration (SSSD): removal or disturbance of small quantities of ACM only if required in the performance of another maintenance activity not intended as asbestos abatement.

Vinyl Asbestos Floor Tile (VAT): vinyl floor tile and in some cases its mastic which contain more than one percent asbestos and must be handled as ACM.

II. Purpose and Introduction

This document contains the University of Colorado’s Asbestos Operations and Maintenance (O&M) program for the Boulder Campus. The objective of this program is to outline the work practices, training requirements and processes put in place by the University’s Environmental Health and Safety Department (CU-EHS) to protect building occupants and University Employees during Operation and Maintenance (O&M) activities. O&M activities or Class III asbestos work means repair and maintenance operations, where “ACM”, including TSI and surfacing ACM and PACM, is likely to be disturbed. This O&M program is intended for University of Colorado Boulder employees who have been trained for O&M work under the CU EHS O&M training. This program is not intended or designed for Contractors conducting asbestos abatement on the Boulder Campus.

A. Asbestos History and Use on Campus

Asbestos is a class of naturally occurring fibrous minerals. Due to its heat and chemical resistance and its strength and flexibility, asbestos has been used in different building and non-building related materials. While most uses of asbestos have been banned, some asbestos containing products remain on the market today. The most commonly encountered types of asbestos containing materials at UCB include floor tile and mastic, ceiling tiles, pipe insulation, fireproofing, window glazing, asbestos cement products and roofing. All building materials in structures built prior to 1989 must be presumed to contain asbestos unless laboratory analytical sample data is available to prove a material is not asbestos containing. EPA regulations require that all buildings, regardless of age, be surveyed for asbestos prior to demolition or renovation.

B. Asbestos Exposure and Health Concerns

When materials containing asbestos are left intact and undisturbed they do not pose a health risk to building occupants or workers. There is a potential for exposure only when the material becomes damaged to the extent that asbestos fibers become airborne and are inhaled. Asbestos is more likely to release fibers when it is friable. The term friable means the material can be easily reduced to a dust or powder with hand pressure only. If friable forms of asbestos are disturbed and become airborne, an inhalation hazard may result. In non-friable materials like floor tile and laboratory bench tops, the asbestos fibers are tightly bound in a matrix which limits the potential for a fiber release unless the material is rendered friable through mechanical means (i.e. abraded, sanded or sawed).

Generally, adverse health effects from asbestos are the result of long-term exposure to high concentrations of airborne fibers. According to the EPA, airborne asbestos levels in buildings are typically much lower than those identified in industrial work places where asbestos related health effects have been observed.

If exposed to asbestos, several factors may influence whether harmful health effects will occur. These factors include:

  • Dose – how much asbestos one is exposed to
  • Duration – how long one is exposed to asbestos fibers
  • Whether or not you smoke

C. Health Effects of Asbestos

Asbestos has been determined to be a cancer and lung disease hazard. There are no warning signs that asbestos is causing problems in your body since there are no acute or short-term symptoms. Asbestos related diseases have a latency period of 20-40 years before seeing any symptoms. The three most common asbestos related diseases are:

  1. Asbestosis – Asbestosis is a serious, progressive, long term non-cancer disease of the lungs.
  2. Lung Cancer – Lung cancer causes the largest number of deaths related to asbestos exposure.
  3. Mesothelioma – Mesothelioma is a rare form of cancer that is found in the thin lining (membrane) of the lung, chest, abdomen, and heart and almost all cases are linked to exposure to asbestos.

Exposure to asbestos increases your risk of developing lung disease. That risk is made worse by smoking. Smoking increases the risk of lung cancer 90 times more than exposure to asbestos alone.

III. Administrative Procedures

The asbestos content of every building material on campus is not accounted for in the management system. The Material Management System (MMS) is updated with laboratory data regarding asbestos content from previous projects and sampling events. Prior to impacting building materials for a project, O&M trained staff is responsible for determining if the building materials to be impacted are asbestos containing. O&M staff will be trained on the use of the MMS and how to search for specific building materials. If the building material to be impacted during the course of a project is not represented in the MMS, O&M trained staff have two options.

  1. Assume the building material(s) to be impacted are asbestos containing and follow all procedures set forth in this O&M program. CU EHS is available as a resource to help determine the appropriate course of action on a case by case basis.
  2. Submit a project through the Operations and Maintenance Portal on the CU EHS MMS to request asbestos sampling. CU EHS will conduct sampling for laboratory analysis and provide an Asbestos Hazard Communication report outlining the sample results and any necessary follow up actions.

EH&S will be responsible for coordinating disposal, manifesting and billing each speedtype for the asbestos waste generated on a bi-monthly basis.

A. Building Surveillance

The CU EHS Asbestos and Lead Group have a constant presence in campus buildings during inspections and other day to day activities. Asbestos and Lead staff are certified as EPA Asbestos Building Inspectors and are trained to recognize, document and mitigate asbestos hazards. However, it is important to note, Facilities Management and Housing Maintenance staff who have been trained as a part of this O&M Program have a responsibility and are expected to report any ACM (or suspect ACM) which has been damaged or has the potential of becoming damaged to the Asbestos and Lead Group. All sampling and inspection data is managed by the Asbestos and Lead group and housed in the asbestos MMS. Additional inspection and sampling is conducted in house by the Asbestos and Lead Group on an as needed basis.

B. Authorized O&M Activities

To minimize potential asbestos exposure to maintenance personnel and building occupants, CU EHS has developed Authorized O&M Activities for procedures which will disturb ACM.

Authorized Activities must:

  • be specific to small scale short duration tasks which will impact asbestos
  • be approved by CU EHS
  • have a Negative Exposure Assessment
  • be included in this O&M Program

All Authorized Activities have written procedures outlining approved work methods, type of ACM, required engineering controls and appropriate PPE. CU EHS has developed maximum quantities of particular types of ACM that can be removed or disturbed under this program. Any asbestos work scheduled to be conducted by CU personnel who will exceed these limits must be conducted by a GAC or with direct approval from CU EHS.

Material Type Maximum Quantity
Floor tile and mastic ≤ 25 ft2
Caulking 10 ft
Window glazing 10 ft
CMU sealant ≤ 3 ft2
Transite (disturbance)* < 25 ft2
Drywall/plaster (disturbance)* ≤ 25 ft2
Roofing < 25 ft2
Ceiling tile ≤ 8 ft2
Fire doors 1 each
Adhesives ≤ 25 ft2
* Disturbance, not removal.

A list of Authorized O&M Activities and corresponding work procedures can be found in Appendix D.

A review of the current Authorized Activities will be conducted at the initial O&M training and at the annual refresher training thereafter. The review will include discussion about work procedures (i.e. pros, cons, feasibility etc.) and any proposed changes or updates. O&M trained staff are responsible for informing CU EHS of new work procedures (not currently addressed as an Authorized Activity) which will impact asbestos containing materials. CU EHS will determine whether the task is authorized under this O&M program and be responsible for developing a written work procedure.

C. O&M Workflow

  1. O&M trained employees are assigned a work order which may potentially disturb asbestos containing materials.
  2. Employee is responsible for checking the CU EHS MMS to determine if building material(s) to be impacted contain asbestos.
    1. If materials do not contain asbestos, project can be conducted using safe work practices and appropriate dust control measures.
    2. If materials do contain asbestos and the quantity to be disturbed is less than material specific O&M limit, trained staff can conduct the work following the Authorized Activity requirements outlined in this O&M program
    3. If asbestos data is not available in the MMS, O&M trained staff have two options:
      1. Assume the material contains asbestos, ensure the quantity to be disturbed is less than material specific O&M limit and proceed following the Authorized Activity requirements outlined in this O&M program.
      2. Submit a Work Request through the Operations and Maintenance Portal on the CU EHS MMS to request asbestos sampling. CU EHS will conduct sampling for laboratory analysis and provide an Asbestos Hazard Communication report outlining the sample results and any necessary follow up actions.

D. Prohibited Places

The following work practices shall not be used for any work that disturbs asbestos containing materials, regardless of measured levels of asbestos exposure or the results of initial exposure assessments:

  • Dry sanding
  • High-speed abrasive disc saws that are not equipped with point of cut ventilator or enclosures with HEPA filtered exhaust air
  • Compressed air used to remove or clean dust and debris from materials containing asbestos
  • Dry sweeping, shoveling or other dry clean-up of dust and debris containing ACM and PACM
  • Employee rotation as a means of reducing employee exposure to asbestos
  • Removal of thermal system insulation or surfacing material will not be performed by University of Colorado employees.

E. Routine Maintenance and Cleaning

It is important to minimize the disturbance of asbestos-containing materials and the subsequent release of asbestos fibers. This can be accomplished by staying out of physical contact with materials that contain, or are presumed to contain, asbestos.

Dust and debris in an area containing visibly deteriorated ACM shall not be dusted or swept dry, or vacuumed without using .a HEPA vacuum filter. This cleaning shall only be carried out by certified asbestos workers.

The manufacturer’s instructions will provide directions on how and when to change the bag and filters of HEPA vacuum used in O&M activities.

Workers cleaning HEPA vacuums used in O&M activities should follow manufacturer’s instructions including:

  • Conduct cleaning activities outdoors away from high use areas
  • Workers conducting cleaning activities should wear PPE
  • When removing  bag and filter,  lightly mist with water to suppress dust
  • If feasible, use another HEPA vacuum to clean the interior surfaces
  • At a minimum, wet wipe all interior surfaces

F. Waste Storage and Disposal

O&M trained staff are responsible for collecting all asbestos waste and asbestos contaminated materials (i.e. clothing, PPE, etc.) in sealed, labeled, impermeable bags or other closed, labeled, impermeable containers. Asbestos waste generated from O&M activities must be delivered to the site specific storage facility according to where the work was conducted. Waste generated from buildings on Main Campus must be brought to room 21 in the Economics building and waste generated from East Campus must be brought to the Marine Street Asbestos Waste storage facility. All waste must be delivered to the specified storage area immediately following the scheduled O&M work or at the end of the work shift, whichever comes first. Asbestos waste must not be stored in vehicles, offices or any other areas not intended for asbestos waste storage. O&M trained staff are responsible for accurately documenting the work that was completed in the O&M Asbestos Waste Log at the waste storage facility. Employees must provide the following information regarding the O&M waste:

  • Date work was completed
  • Name of O&M trained staff responsible for work
  • Building
  • Room #’s
  • Work Order #
  • Speedtype
  • Material(s) Removed
  • Quantity of Material Removed

G. Documentation of Abated ACM

O&M trained employees are responsible for providing CU EHS documentation for projects which have removed an entire material type from a functional space. For example, the floor tile and mastic from and entire room have been abated and no longer exist in that room. CU EHS will then be responsible for updating the MMS to reflect the abatement information.

IV. Employee Training

There are various levels of required training for personnel who will work with or around asbestos containing building materials. The level and extent of training is dependent upon the type of work employees will be responsible for conducting with asbestos containing materials. CU EHS can guide and assist in training types and the subsequent requirements. Documentation of training activities must be provided to the CU EHS Asbestos and Lead office and to the employee’s supervisor.

A. Awareness Training

The OSHA asbestos standards for General Industry (29 CFR 1910.1001) and the Construction Industry (29 CFR 1926.1101) require employers to provide asbestos awareness training to employees who may encounter or potentially disturb ACM or PACM. The general industry standard applies to manufacturing, brake or clutch servicing, and building custodial or housekeeping work. The construction standard applies to building maintenance and construction work and also to housekeeping activities performed after maintenance or construction work. Asbestos awareness training is required within 30 days of initial assignment and on an annual basis thereafter. The training is provided by CU EHS. The Asbestos Awareness training covers:

  • Types of asbestos and characteristics
  • Health effects associated with asbestos exposure
  • Relationship between smoking and asbestos in producing lung cancer
  • Information on smoking cessation programs
  • University’s Policy regarding asbestos management
  • Locations where asbestos materials are commonly found
  • How to recognize signs of damage and deterioration of ACM and PACM
  • Proper response to fiber release episodes
  • Standard requirements related to housekeeping

B. Operation and Maintenance (Class III) Training

The OSHA asbestos standard for the Construction Industry (29 CFR 1926.1101(k)(9)) requires employers to provide Class III asbestos training to employees who are likely to be exposed to asbestos in excess of the PEL. CU EHS has developed a Class III asbestos training curriculum, in compliance with the OSHA asbestos standards, specific to the University’s O&M program. The training curriculum is developed around the pre-approved work procedures and type of work conducted by personnel on the Boulder Campus. CU employees entered into this O&M program must complete the O&M training at the time of assignment and prior to disturbing any ACM or PACM. All employees enrolled in the CU O&M program must have an annual refresher thereafter. The O&M training is in addition to the initial Asbestos Awareness training.

The Asbestos O&M training provided by EH&S covers general Asbestos Awareness and:

  • Methods of recognizing asbestos
  • The proper methods of handling ACM or PACM
  • The use of respiratory protection and CU EHS Respiratory Protection program.
  • Additional personal protection measures and good work practices.
  • Guidelines, requirements and frequency of the medical surveillance program
  • CU specific O&M work practices and procedures, including hands on demonstration
  • Access to and use of the CU EHS Asbestos MMS
  • Overview of the CU EHS Negative Exposure Assessment Policy
  • Review of authorized work procedures and necessary changes or updates
  • Waste storage and disposal procedures

V. Medical Surveillance

Medical examinations and consultations are required for all employees who are engaged in asbestos work for a combined total of 30 or more days per year or; are exposed at or above the permissible exposure limit or excursion limit; and for employees who wear negative pressure respirators. Days when fewer than sixty minutes of O&M asbestos work are completed are not included in the 30-day count.

The medical examination must be conducted under the supervision of a licensed physician prior to disturbance of any ACM or PACM and repeated at least annually thereafter. The examination must be provided at no cost to the employee. The medical examination must be scheduled with one of the University’s approved occupational health providers. If the examining physician determines that any of the examinations should be provided more frequently than specified, affected employees will be examined at the frequencies specified by the physician.

Medical examinations include a medical and work history, with special emphasis directed to the pulmonary, cardiovascular, and gastrointestinal systems. Along with a pulmonary function test, any examinations or tests deemed necessary by the examining physician will be included.

EH&S must have a copy of the physician’s clearance for asbestos work and respirator use. The employee’s supervisor must also maintain a copy of both reports.

A. Information Provided to the Physician

The following information must be provided to the physician by the employee’s supervisor prior to the physical.

  • A description of the affected employee’s duties as they relate to the employee’s exposure.
  • The employee’s representative exposure level or anticipated exposure level.
  • A description of any personal protection equipment to be used by the employee.
  • Any information from previous medical examinations of the affected employee that is not otherwise available to the examining physician.

Each new CU employee enrolled in the O&M program must complete the OSHA Initial Medical Questionnaire prior to scheduling a medical examination and before disturbance of any ACM or PACM. The Initial Medical Questionnaire can be found in Appendix A. CU employees enrolled in the O&M program must complete a Periodic Medical Questionnaire prior to their annual medical re-examination.

B. Physician’s Written Opinion

The examining physician provides a written statement consisting of the physician’s opinion whether the employee has any detected medical conditions that would place the employee at an increased risk of material health impairment from exposure to asbestos. The physicians report will also include:

  • Any recommended limitations on the employee, or on the use of personal protective equipment such as respirators
  • A statement that the employee has been informed by the physician of the results of the medical examination, and any medical conditions that may result from asbestos exposure.
  • A statement that the employee has been informed by the physician of the increased risk of lung cancer attributable to the combined effect of smoking and asbestos exposure.

The physician will not reveal in the written opinion given to the employer, specific findings or diagnoses unrelated to occupational exposure to asbestos. The affected employee will provide a copy of the physician’s written opinion to the supervisor within 30 days from its receipt. The employee is responsible for providing a copy of the Physician’s written opinion to the supervisor and to CU EHS.

C. Record Keeping

CU EHS is responsible for maintaining Employee O&M training documentation and fit testing records. Supervisors are responsible for maintaining medical surveillance documentation and the Physician’s written opinion. The employee is responsible for providing CU EHS with a copy of the Physician’s written opinion at the time of Fit Testing.

VI. Negative Exposure Assessments (NEA)

CU EHS has developed a NEA protocol for O&M trained employees who will perform tasks which will disturb ACM. The purpose of the NEA is to demonstrate that employee exposures for specific tasks will be consistently below the PELs. Each NEA is specific to employees enrolled in the O&M program and whose training and experience are no more extensive than that of employees performing the Authorized Activity.

A NEA determination will be based on:

  • Objective data demonstrating that the specific job task cannot release airborne asbestos fibers in concentrations exceeding the TWA and excursion limit under those work conditions having the greatest potential for releasing asbestos fibers.
  • Air sample data, collected for comparison to the PEL and EL within 12 months of the Authorized Activity and show that under the conditions prevailing and which will prevail in the current workplace there is a high degree of certainty that employee exposures will not exceed the TWA and excursion limit. Sample data must be obtained under workplace conditions “closely resembling” the processes, type of material, control methods, work practices, and environmental conditions outlined in the work procedure.

CU EHS will conduct negative exposure assessment monitoring for Authorized Activities on an annual basis and managing the data associated with this sampling. Analytical results and data regarding air monitoring will be managed by CU EHS and provided in writing to all O&M trained staff.

VII. Personal Protective Equipment (PPE)

A. Respiratory Protection

Respiratory protection must be worn for all work involving disturbance of ACM or PACM unless a NEA has been performed and demonstrates that employee exposure during the specific operation is expected to be consistently below the PEL and EL. The NEA must be performed by CU EHS and be specific to the work practices outlined in this O&M program. Before respirators can be worn, employees must be enrolled in the University of Colorado Respiratory Protection program. Enrollment in the Respiratory Protection Program includes:

  • Completion of an initial and annual respirator medical questionnaire
  • Initial and annual respirator medical evaluation by a licensed physician
  • Initial and annual respiratory Protection Training
  • Fit testing (prior to respirator use, as needed and at a minimum annually)

All CU employees enrolled in the University’s O&M Program and Respiratory Protection Program must have a fit test conducted by CU EHS prior to respirator use. Additional fit tests are required annually at a minimum and on an as needed basis if required. CU EHS provides respiratory protection training and fit testing at no cost to the employee or department. Additional information regarding the CU EHS Respiratory Protection Program, fit testing and training can be found in the Training section of this website.

B. Protective Clothing

Employees must wear protective clothing when conducting O&M activities which are likely to create exposures at or above the OSHA PEL or EL. Protective clothing is considered a disposable coverall (e.g. Tyvek) made from a synthetic fabric which will not allow asbestos fibers to pass through. This type clothing prevents a worker’s regular clothing from being contaminated with asbestos fibers. Protective clothing is not required if an NEA has been performed and demonstrates that employee exposure during the specific operation is expected to be consistently below the PEL and EL. The NEA must be performed by CU EHS and be specific to the work practices outlined in this O&M program.