asbestos management program carnegie mellon university · 2020. 6. 17. · september 3, 2015...

Asbestos Management Program Carnegie Mellon University

Revision 007

January 31, 2012 (reviewed, no changes) September 6, 2013 (reviewed with minor changes, noted in RED)

September 4, 2014 (reviewed, no changes) September 3, 2015 (reviewed, no changes) September 2, 2016 (reviewed, no changes) September 1, 2017 (reviewed, no changes)

September 18, 2018 (reviewed with changes, noted in RED) December 4, 2019

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Asbestos Management Program Carnegie Mellon University

Procedure #AM-0: Program Overview

Contents This document presents the procedures related to the management of asbestos containing materials at Carnegie Mellon University. The Department of Environmental Health and Safety (EH&S) coordinates the work of the Carnegie Mellon Asbestos Management Plan. Included in this Program are procedures for:

#AM-1 #AM-2

#AM-3 #AM-4 #AM-5 #AM-6 #AM-7 #AM-8 #AM-9

#AM-10 #AM-11

Attachment 1

Identification of asbestos-containing materials Assessment of risk of asbestos-containing materials and

Determining Appropriate Response Actions for ACM Routine Surveillance and Operations/Maintenance of ACM Repair, Encapsulation, Enclosure and Removal of ACM Training requirements for asbestos-related activities Approved asbestos consultants/contractors/laboratories Recordkeeping for Asbestos Activities Periodic Review and Audit of Program Database of Locations, of Abatement and Sampling Activities Expousre Monitoring Accidental Fiber Release Checklist of activities for Campus Design and Facility

Development (CDFD)

Applicable Regulations

A number of regulations are applicable to activities associated with the asbestos-containing materials at Carnegie Mellon. These include but are not limited to the following: • OSHA Worker Protection, 29 CFR 1910.1001 • OSHA Construction Industry Standard, 29 CFR 1926.1101 • OSHA Respiratory Protection 29 CFR 1910.134 • EPA NESHAPS 40 CFR Part 61, Subchapter C • EPA Asbestos in Schools Rule, 40 CFR 763 • Commonwealth of Pennsylvania Dept. of Labor and Industry Asbestos

Certification • County of Allegheny, Title 20

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Policy These overall policies address all asbestos-related activity at Carnegie Mellon University: • At no time shall any university employee be exposed to asbestos fibers at an

amount greater than the OSHA PEL currently in effect. • At no time shall unlicensed persons perform any asbestos activity that is

addressed by the Commonwealth of Pennsylvania Dept. of Labor and Industry Asbestos Certification regulations. This includes asbestos inspections/sampling, project design, and abatement supervisor or worker.

• The university shall use the Allegheny County clearance air standard (0.01 f/cc) as its maximum allowable asbestos airborne level.

• There are currently no campus areas subject to the AHERA Asbestos-In-Schools regulation. Previously, that portion of Margaret Morrison Carnegie Hall occupied by the Children’s School, where kindergarten instruction occurs was formerly addressed by AHERA. All asbestos from this area has been removed; completed in 2005.

• Environmental Health & Safety (EH&S) is responsible for oversight for the university’s compliance with asbestos regulations, as well as these policies and procedures.

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Procedure AM-1: Identification of asbestos-containing materials

Current inventory of asbestos

There has been no comprehensive process for the identification of all ACM in campus buildings, although a great deal of formal and informal inspection, sampling and analysis has been performed. Several buildings have been completely surveyed while others have been partially surveyed. A good deal of additional identification work has been undertaken during building renovation projects. EH&S maintains all records and reports for asbestos identification activities. They also maintain and periodically update a database of the locations of known asbestos materials on campus. The campus community and other interested parties may contact EH&S via [email protected] for this information.

Sampling, Inspection and

Analysis

Confirmation of the presence or absence of asbestos containing materials is a critical activity when there is concern expressed by building occupants and as required prior to all renovation and demolotion activities. If there is not current information confirming the presence or absence of asbestos materials at a given location, an asbestos inspection will need to be performed, generally also involving sampling of suspect materials. Typically there are two ways to perform this function:

1. Licesnsd EH&S personnel will collect bulk material samples in accordance with 40 CFR Part 763.86 to determine the asbestos status of an area or material. The sample(s) shall be collected in a manner that minimizes any asbestos fiber release. Inspection and/or sampling for projects must be requested at leaset 2 weeks in advance of project initiion. Please email [email protected] to request an EH&S inspection.

2. An approved (see procedure AM-6 for details) asbestos consultant may

perform sampling and or inspection of the particular area(s) or material(s). This work will be coordinated either by the appropriate Campus Design & Facility Development (CDFD) Project Manager (typically) by an FMS project manager (for smaller projects) OR by EH&S (for selected projects).

NOTE: Only persons holding a current Asbestos Inspector license from the Commonwealth of Pennsylvania Department of Labor & Industry may collect bulk samples, regardless of whether university personnel or contractors perform the activity. NOTE: Laboratories performing bulk sample analyses for asbestos content must be approved by EH&S for this activity. 3. A copy of all laboratory test results or inspection reports with test results

shall be provided to EH&S for retention and inclusion in the asbestos database. (See procedure AM-7)

mailto:[email protected]


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4. The location databases referenced above can be requested via [email protected]. (See procedure AM-9)

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Procedure AM-2: Assessment of Risk & Determining Appropriate Response Actions for ACM

Risk Assessment Assessing the risk associated with asbestos containing materials and determining the appropriate response actions are based on the condition and type of material in question, and its potential for damage and/or exposure. These factors shall be determined by the licensed Asbetsos Management Planner. The following Table outlines the appropriate response actions for the material and its condition and represents suitable reactions to the risk expected by the situation. The inspector or EH&S may choose a more stringent response if this is deemed appropriate.

Table 1: Determining Response Action for ACM

Surfacing Material (i.e., plaster, acoustical plaster, fireproofing)

Repair damage and remove debris

Enclose, encapsulate or remove material, if repair is not practical or appropriate.

Place in O&M program

Damaged (<10% total, <25%localized) X X X Significantly damaged (>10% total, >25% localized)* X X Undamaged, with potential for damage X** X Undamaged, with potential for significant damage X** X Undamaged, inaccessible X

*also isolate area and restrict access **if preventive measures will not prevent damage

Thermal System Insulation (i.e., pipe, tank or boiler insulation)




Damaged (<10% total, <25%localized) X X X Significantly damaged (>10% total, >25% localized) X X X Undamaged, with potential for damage X** X Undamaged, with potential for significant damage X** X Undamaged, inaccessible X

**if preventive measures will not prevent damage

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Miscellaneous Material (i.e., floor tile, ceiling tile, transite)




Damaged (<10% total, <25%localized) X X X Significantly damaged (>10% total, >25% localized)* X X Undamaged, with potential for damage X** X Undamaged, with potential for significant damage X** X Undamaged, inaccessible X

*also isolate area and restrict access **if preventive measures will not prevent damage

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Procedure AM-3: Routine Surveillance and Operations/Maintenance of ACM

O&M Program An Operations and Maintenance (O&M) Program is a process by which asbestos-containing material not appropriate for active abatement (i.e., removal, enclosure or encapsulation) is managed. This management is designed to protect the health and safety of people in areas of ACM by monitoring the condition of asbestos materials and controlling the release of asbestos fibers. O&M activities will be performed by appropriately licensed personnel, either in-house or from outside contractors, depending on the level of work and the timeliness required. 1. Periodic inspection and surveillance of asbestos materials will occur on a

schedule appropriate for the material location, type and previous assessments.1 This process consists of viewing the areas of asbestos containing materials and identifying any areas of damage, potential fiber release or change in condition from the previous assessment. Records of this activity will be retained by EH&S.

2. If the periodic inspection and assessment identifies areas of ACM damage or

potential fiber release, corrective actions will be initiated to address these conditions, following the process presented in the previous procedure. EH&S will coordinate through FMCS any abatement or repair activity.

1 In general, most friable asbestos areas will be assessed on an annual basis.

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Procedure 4: Repair, Encapsulation, Enclosure and Removal of ACM

General Information

Asbestos abatement includes any repair, enclosure, encapsulation or removal of asbestos containing materials. All asbestos abatement work must be performed by properly licensed and accredited contractors using accredited and licensed supervisors and workers. It is the responsibility of the Carnegie Mellon staff person coordinating this work to ensure that all contractor special conditions clauses are met (e.g Completion of 2-hr Asbestos Awarenss Training by all contract workers, etc.). It is critical to understand that most asbestos abatement activity at the university requires a permit from the Allegheny County Health Department (ACHD) and that a minimum of 10 days is generally needed to obtain this permit. It is alos important to understand that the Univesity must also complete a Notification for Facility Demomoltion and Renovation for The abatement activities must be performed following the requirements set out in the ACHD permit, or, in the absence of a permit, by EH&S.

Repair, Encapsulation, Enclosure and

Facility Removal

All repairs, encapsulation, enclosure and removal performed on ACM at Carnegie Mellon will be performed by outside contracted workers. All such workers will be appropriately accredited and licensed by applicable agencies, such as Commonwealth of Pennsylvania Department of Labor and Industry, and the Allegheny County Health Department (ACHD). Additionally, all work will be performed under permits obtained from the ACHD, where applicable. All contracted asbestos abatement activity will be coordinated by the CDFD Project Manager or FMCS Project Manager assigned to asbestos-related projects. It is their responsibility to develop the scope of work, facilitate its proper completion, and to ensure compliance with regulatory and Carnegie Mellon asbestos requirements. Due to sometimes confusing compliance requirements, EH&S needs to be informed of all asbestos activity prior to its planning and implementation, and be updated as the project progresses. Nearly all Most abatement projects will require clearance air monitoring to establish safe airborne levels in the work site prior to re-occupancy. The following table outlines the requirements:

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Table 2-Air Monitoring Requirments, Post-Abatement

Size Friable Non-friable <160 ft 2 or <260 lin ft (non-permitted)

At least three clearance tests if area is more than 20 linear or 20 ft2, otherwise, use contractor’s personals as clearance. Project monitoring may be required if the work will be in a sensitive area (as determined by EH&S).

Use contractor’s personals as clearance test

>160 ft2 or >260 lin ft (permitted)

Five clearance tests mandatory (additional samples will be required if the work area is greater than 5000 ft²). Five project monitoring samples mandatory.

Five clearance tests mandatory (additional samples will be required if the work area is greater than 5000 ft²). On-site project monitor if sensitive area (as determined by EH&S) or if abatement quantity is more than 500 ft2.

For projects of moderate or large size, abatement oversight by an independent consultant may be required2 during the work activity. This oversight typically includes independent air sampling, project specification monitoring and regulatory coordination. The oversight consultant will be independent of the abatement contractor and will be hired by the CMU CDFD or FMCS prject manager . Clearance air monitoring and project monitoring must be performed by an approved consultant. All abatement activity must be performed by an approved abatement contractor. Contact [email protected] for more information. Project monitoring samples must be taken 10 feet away from the containment area and one of the required project monitoring samples must be taken duing clearance testing if aggressive air sampling is performed.

2 Project monitoring is required if the project requires a permit AND involves the abatement of friable asbestos. EH&S may require more stringent use of project monitoring when the situation merits.


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Procedure AM-5: Training Requirements for Asbestos-related Activities

Asbestos Awareness Training

For university employees who may work near asbestos materials or whose activities (such as building renovation) may affect asbestos materials, OSHA 2 hour Asbestos Awareness training is required. Workers meeting this definition are considered Class IV workers by OSHA regulations. These workers are required to have training, plus annual refresher training, as described below: Work that does not disturb asbestos is permitted at any time. An employee may work near asbestos containing materials, such as pipe insulation, floor tiles or even sprayed on asbestos insulation, as long as the material is not disturbed. This may include the following activities: • Replacing or repairing electrical or other wiring • Repairing plumbing or other facility items • Cleaning or buffing floor tiles that have sufficient finish to not contact the floor

tile • Any work done NEAR asbestos materials but not disturbing them Work that disturbs or may disturb asbestos materials is NOT permitted. Some examples of activities that are not permitted are: • Sanding or drilling through floor tiles or asbestos cement board • Lifting or replacing ceiling tiles in areas where asbestos fireproofing is above

the tiles • Drilling holes in ANY asbestos material • Moving furniture or other items that may disturb asbestos materials • Renovating any space where asbestos materials are present • Removing asbestos insulation or floor tiles for any reason • Buffing asbestots-containg floor tiles that does not have sufficient finish to

avoid contacting the floor tile • Strpiing of asbestos-containg floor tiles Performing renovations in areas where ACM is present Environmental Health and Safety (EH&S) offers Asbestos Awareness training annually in several different sessions and dates, and targets specific areas and personnel as follows (this list is not enclusive):

FMS CDFD Housing/Dining Business managers Building managers Telecom

EH&S maintains records of the training and the attendees. It is the responsibility of the managers and supervisors to ensure that necessary employees att this required training.

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In-house asbestos inspectors

Staff performing asbestos inspections, assessments or evaluations, preparing specifications, etc., must obtain training and Pennsylvania Department of Labor and Industry Licenses (L&I) appropriate for that activity. Such training must be updated, and licenses renewed, on an annual basis.

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Procedure AM-6: Approved asbestos consultants/contractors/laboratories

Approval Process Just as for any hazardous material operation, performance is of the utmost importance and cost of service is only one factor in the decision to select an outside contractor. Therefore, the monitor for all hazardous materials operations (including lead and asbestos removal) must meet prequalification requirements and submit a performance based proposal. EH&S has reviewed the qualifications of a number of consultants and approved several for work at the university. For more information, email EH&S at [email protected]. Items for submission should prove or provide evidence of the following: a) Contractor must submit resumes for all employees, stating certifications,

licenses, training, and experience. b) The generation of accurate and precise testing results is essential for a

contractor providing analytical services to the university. There are a number of proficiency registries and accreditations available to help ensure quality analytical results. At a minimum, the laboratory must demonstrate the following:

a. For asbestos fiber counts performed in the field, all analysts must be registered by and perform successfully in the Asbestos Analysis Registry of the American Industrial Hygiene Association (AIHA).

b. For asbestos fiber counts performed in the laboratory, and for industrial hygiene analyses (metals, organics, silica), all laboratories must be accredited by the AIHA Industrial Hygiene Laboratory Accreditation Program for these analytes as applicable.

c. For environmental lead analyses (paint chip, soil and wipe), all laboratories must be accredited by the AIHA in the Environmental Lead Laboratory Accreditation Program (if lead is part of the project, as it ofen is).

d. For asbestos bulk analyses, all laboratories must be accredited by the AIHA for this analysis or by the National Institute of Science and Technology (NIST) National Voluntary Laboratory Accreditation Program (NVLAP) for bulk asbestos analyses.

e. For asbestos analyses by Transmission Electron Microscopy, the laboratory must be accredited in the NIST/NVLAP for this analysis.

Demonstration of the above accreditation/registrations shall consist of supplying a copy of the current accreditation or registration AND the submittal of any applicable proficiency or round robin testing activity associated with the applicable analyte(s), for the past year.

List any citations by any regulatory body issued either to the oversight contractor or abatement contractor whom they were charged with to keep in compliance


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during abatement operations. This is applicable to asbestos and/or lead abatement activities.

Current list of approved

contractors

A current listing of approved asbestos abatement contractors and asbestos consultants can be obtained via [email protected] .

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Procedure AM-7: Recordkeeping for asbestos activities

Recordkeeping Thorough documentation of all asbestos management activities is a requirement of the university. All inspection, O&M surveillance, corrective actions and abatement work must be thoroughly documented. This documentation shall include, where applicable, the written reports of inspection, surveillance and testing performed, copies of all applicable certifications, accreditations and licenses, copies of all correspondence with regulatory authorities (including notifications and permits). This information shall be retained in the EH&S offices and in the BRM archives. All asbestos-related training performed and received by Carnegie Mellon staff shall be retained in compliance with regulatory specifications and Carnegie Mellon requirements. EH&S shall maintain all training documentation.

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Procedure AM-8: Periodic Review of the Management Program

Program Review At least annually, EH&S shall review this program to ensure that its specifications reflect the performance of asbestos management activities at Carnegie Mellon and also ensure regulatory compliance at all levels. Where applicable, changes in the procedures and/or policies shall be made. The date of the review and any updates shall appear on the written documents.

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Procedure AM-9: Database of Locations, of Abatement and Sampling Activities

Asbestos Location Database

EH&S maintains a database of the locations of known asbestos (and confirmed non-asbestos) materials on campus. The database may only be accessed by EH&S personnel. For records requests, please email [email protected] This database is reviewed and updated at least annually. The database identifies the type of material, whether it is asbestos containing, its location, and any abatement history of note.

Asbestos Activity Database

EH&S also maintains records of asbestos activity, designed to supplement the location records. For records requests, please email [email protected]

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Procedure AM-10: Exposure Monitoring

Exposure Assesment

CMU employlees are not permitted to engage engages in any activity with the potential to disturb known or suspected asbestos containing material. Any CMU employee who engages in any activity with the potential to disturb known or suspected asbestos containing material shall be monitored by breathing zone air sampling to ensure exposures are kept below the 8-hour time-weighted average Permissible Exposure Limit (PEL) of 0.1 fibers/cubic centimeter of air (f/cc) and the 30-minute Excursion Limit of 1.0 f/cc. Sampling and analysis shall be performed in accordance with OSHA-specified methodology. Prior to engaging in these activities, the employee must contact EH&S via [email protected].

Asbestos Exposure Records

Employees who were potentially exposed to known or suspected asbestos containg materials must complete a Supervisors’ Injury Ilness Report via: https://www.cmu.edu/hr/work-life/life-experiences/work-injury.html. EH&S will maintain all asbestos air sampling records and other relevant records as required by the Occupational Safety and Health Adminstration. For records access, email EH&S via [email protected].

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Procedure AM-11: Accidental Fiber Release The potential for accidental asbestos fiber release exists in all areas where asbestos is present at the

University, particularly in areas with easily accessible or friable asbestos containing materials (ACM).

Through the CMU Asbestos Management Program, the risk of fiber release is minimized by means of

periodic inspections and employee training to recognize and not disturb any suspect or known ACM.

Potential ACM may include, but is not limited to, the following:

• Pipe insulation

• Spray-on Fireproofing

• Acoustical Plaster

• 9-inch x 9-inch floor tiling and associated mastic (adhesive)

• Ceiling tiles and associated mastic

Despite periodic inspections and employee training, ACM may be accidentally disturbed during

routine maintenance, construction, or renovation. It may also deteriorate through water damage, air

erosion, vibrations, or by other physical means. In the event that damage occurs, it is crucial to be

familiar with this emergency response procedure so that exposure to University students, faculty, staff

and visitors is reduced to the greatest extent possible.

Each instance of accidental fiber release will vary in size and scope and must be handled on a case-by-

case basis. Releases will be considered either minor or major based on the amount of disturbed ACM.

Each release episode, regardless of size and scope, must be reported to EHS as soon as possible. Only

approved asbestos abatement contractors may perform cleanup activities.

• Minor fiber releases constitute less than 3 square or linear feet of impacted ACM. Only

approved asbestos abatement contractors may conduct cleanup. Minor fiber releases may

require only minimal containment and evacuation.

• Major fiber releases constitute greater than 3 square or linear feet of impacted ACM or those

that involve the HVAC system. Major fiber releases must be cleaned up by an approved

asbestos abatement contractor. The abatement contractor should also be able to assist in

developing a strategy for conducting the cleanup operations. Major fiber releases may require

larger containment areas, departmental/building evacuation, and HVAC system shutdowns.

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The following procedure should be followed by any person causing or knowledgeable of ACM

damage:

1. Stop any and all work in the release area.

2. Evacuate the release area immediately. If it is safe to do so on your way out, close all windows

within the space and doors that lead to other areas. Never re-enter the release area or attempt to

clean up the impacted ACM unless you have been instructed to do so by EHS and have been

properly trained to respond to asbestos fiber releases and have the appropriate respiratory

protection.

3. Notify your immediate supervisor and, where applicable, the CMU Project Manager.

4. Report the release to EHS at 412-268-8182. This number is monitored 24/7 to receive emergency

EHS phone calls. EHS will assess and coordinate additional evacuation of the building (if

warranted), further isolation of the release area, cleanup activities, and re-entry approval. Be

prepared to provide the following information (additional details may be requested at a later

time):

a. Location of release [building and room number(s)]

b. Date and time of release

c. Type and amount of ACM disturbed

d. Is the material known or appear to be friable (i.e. can it be reduced to a powder via

crushing by hand)?

e. Has the immediate release area been evacuated?

f. Were doors and windows closed upon evacuating the release area?

EHS responsibilities upon receiving an accidental fiber release notification are generally as follows:

1. Gather information regarding the release from the messenger and any other applicable

personnel.

2. Immediately notify EHS personnel overseeing the Asbestos Management Program. Those

personnel will complete and/or direct the remaining steps.

3. Based on if the release is minor or major conduct the following:

a. Minor: Engage FMCS to remotely modify and/or restrict air flow from the affected area

into the air handler/HVAC system. All doors and windows in the immediate vicinity of

the area should be closed. Contact FMCS, or other responsible party, to engage asbestos

abatement contractor for additional containment and cleanup.

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b. Major: Engage FMCS to shut down the HVAC system in the affected area. All doors and

windows in the immediate vicinity of the release should be closed. Contact FMCS, or

other responsible party, to engage asbestos abatement contractor for additional

containment and cleanup.

4. Notify EHS Director.

5. With assistance from the EHS Director, notify and evacuate, if needed, any occupied areas

immediately adjacent to the release area and/or areas that could be reasonably expected to be

impacted by the fiber release. Evacuation decisions should be based on:

a. The amount of ACM impacted;

b. The location of disturbed ACM with respect to the air handling system and overall air

plenum;

c. Accessibility to the area by building occupants; and,

d. The amount of fibers potentially released (e.g. friable versus non-friable).

Notification should also be made to the occupants of evacuated spaces. See Figure 1 below for an

example e-mail notification that can be sent to department managers for distribution to their personnel.

Figure 1. Building Occupant Notification E-mail Example Subject Line: [Location of Area(s) Impacted by Fiber Release] Asbestos Disturbance Dear___________: Test results have confirmed that asbestos was present in floors XX of XXX Hall. However, preliminary air quality test results throughout XXX Hall have revealed that no asbestos particles were released within the air space of the building. Please note that asbestos is not considered to be harmful unless it is disturbed and that the preliminary air quality results have determined that there was no disturbance. The final report from PSI (the company that performed the testing) is expected to be released late next week. Until this final report is issued declaring Warner Hall safe to re-enter, the building will remain closed. If laptop computers are needed by staff in order to be able to perform work responsibilities during this time, please let me know. Environmental Health and Safety will be contacted to retrieve only essential computer equipment. Additionally, the Unified Communications Team is currently working to address off-site provisioning of phone capabilities to enable Undergraduate Admission staff to field calls during the holiday break. XXX will be making arrangements for the asbestos to be abated. Please be assured that the process to abate the asbestos from floors XX-XX will be performed using the highest standards of safety and care. Additional third parties will be brought in to perform air monitoring, cleaning of spaces and replacement of air filters. If you should have any discomfort or would like to make any alternate work arrangements once the abatement process begins, please let me know and we will coordinate accordingly. Thank you for your continued patience, professionalism and resiliency throughout this process. [Include your signature here.]

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6. Post signage immediately surrounding the release area to restrict access and prevent

unintended entry by those not involved in response efforts. University Police should be

contacted for assistance with heightened security as necessary. Example signage may be seen in

Figures 2 and 3.

7. Update evacuated personnel with information regarding the status of response efforts and

when they can expect to be allowed to re-enter their spaces.

a. During cleanup activities, if building occupants need to obtain critical work materials,

coordination may be made with Environmental Risk Management, Disaster Recovery

and Business Continuity so items can be safely obtained and alternate work locations

can be organized. Depending on the severity of the asbestos disturbance, it may not be

appropriate or possible for personal item retrieval until clean-up is completed.

8. Clearance air sampling should be completed in accordance with state and federal regulations

relevant to the abatement performed and additionally throughout the building as deemed

necessary by EHS to confirm satisfactory cleanup. Tape-lift or micro-vacuum samples of dust

may be required if it is suspected that a major release of fibers was circulated throughout the

building to ensure asbestos fibers have not settled in remote locations, thus prompting further

cleanup.

Figure 3. Access Control Signage

Figure 2. Access Control Signage

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9. After clean-up and applicable air sampling confirms satisfactory clean-up, communicate to

evacuated building occupants that it is safe to re-enter. All posted signage should be removed.

10. Document activities regarding the event. The following should be included, as applicable:

a. Date and time of the event

b. Date and time of the report

c. Name, e-mail, and phone number of person reporting the incident

d. Location (building name and room number(s))

e. Type of material disturbed

f. Identify if the material is friable or non-friable

g. Reason for the incident

h. Actions taken to prevent the spread of fibers

i. Areas of building evacuated

j. Name of abatement contractor used for cleanup and all supporting disposal

documentation

k. Date of clean-up

l. Air sampling results

m. Names and contact information of persons who are concerned about possible exposure

to asbestos fibers as related to the accidental release.

i. CMU employees must fill out a Supervisor’s Injury and Illness form and submit

to Human Resources.

ii. CMU students must fill out applicable sections of the Supervisor’s Injury and

Illness form and submit to EHS at [email protected] for record keeping.


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Attachment 1 Asbestos Abatement Project Activity Checklist

Applicability Persons coordinating asbestos abatement work as part of a project, renovation or demolition activity on campus. This includes (but is not limited to):

FMS personnel CDFD personnel

Facility Coordinators Housing

***Environmental Health and Safety must be alerted in advance of ANY planned asbestos abatement to be performed on campus. Contact Enviromental Health and Safety at [email protected] .

Action There is a three step process to ensure that all renovations that occur on campus address asbestos materials in a way that complies with all applicable regulations and with University Policy. Please perform ALL of the asbestos management steps listed below:

Step #1

SURVEY – Perform comprehensive testing and identification of materials that will be impacted by all renovation and demoltion activities.

a) Contact EH&S to see if there is currently information for the area(s) in question b) EH&S will assist with sampling or request that arrangments be made with an

approved consultant to survey, sample and identify possible asbestos containing material1. Requests must be made to [email protected] at least 2 weeks prior to project initiation; additional time may be necessary based on scope of project.

Ensure that a copy of any inspection or testing is forwarded to EH&S for including in the campus asbestos database.

Step #2

REMOVAL - Contact an approved asbestos contactor2 to perform all necessary abatement work. Note that all asbestos to be impacted by the activity will need to be abated. Also note that University practice does not permit the covering of asbestos containing floor tile with new floor coverings of any type. a) Permits from Allegheny County - Projects involving more than 160 ft2 of abatement

will require a permit from Allegheny County. They require a 10 working day wait time prior to the start of abatement.

b) Notifcations to Allegeny County- c) Notifcation to NESHAP d) Air sampling – Please see Table 2 below for air sampling requirments e) Project monitoring - If a permit is required for a project and if the asbestos to be

removed is FRIABLE3, additional project monitoring and air testing will be required. This activity can also be performed by the approved consultant. The work here entails having a consultant’s technician remain on site during the abatement, to ensure that proper work is performed and also to collect air samples outside the

3 “Able to be crushed or reduced to powder with hand pressure”


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work area, to ensure that there is no asbestos contamination outside the enclosed work zone. EH&S may require a daily report from the monitor.

Step #3

REPORTING – Both the Abatement Contractor and the Asbestos Consultant must submit a final report. A copy of each report must be sent to EH&S. The reports shall include:

Abatement Contractor’s Report

must include:

a) A copy of the clearance inspection form from Allegheny County,

b) A copy of the signed landfill receipt of the waste from the project,

c) A copy of the permit under which the work occurred, d) A copy of all contractor air monitoring results, plus

log in sheets and work progress forms used during the project.

e) Discussion of any unusual issues or problems related to the project

Asbestos

Consultant’s Report must

include:

a) All air monitoring results (including finals) collected by the consultant.

b) Copies of any log forms or checklists used by the consultant during the project.

c) Discussion of any unusual issues or problems related to the project.

Table 2-Air Monitoring Requirments, Post-Abatement

Size Friable Non-friable <160 ft 2 or <260 lin ft (non-permitted)

At least three clearance tests if area is more than 20 linear or 20 ft2, otherwise, use contractor’s personals as clearance. Project monitoring may be required if the work will be in a sensitive area (as determined by EH&S).

Use contractor’s personals as clearance test

>160 ft2 or >260 lin ft (permitted)

Five clearance tests mandatory (additional samples will be required if the work area is greater than 5000 ft²). Five project monitoring samples mandatory.

Five clearance tests mandatory (additional samples will be required if the work area is greater than 5000 ft²). On-site project monitor if sensitive area (as determined by EH&S) or if abatement quantity is more than 500 ft2.

Clearance air monitoring and project monitoring must be performed by an approved consultant. All abatement activity must be performed by an approved abatement contractor. Contact [email protected] for more information. Project monitoring samples must be taken 10 feet away from the containment area and one of the required project monitoring samples must be taken duing clearance testing if aggressive air sampling is performed. 1List of approved consultants may be obtained from EH&S 2List of approved asbestos contractors may be obtained from EH&S 3 “Able to be crushed or reduced to powder with hand pressure”


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Prepared and updated by Andrew J. Lawson, MPM, MSIH, CIH Biological and Radiation Safety Manager Environmental Health and Safety Carnegie Mellon University December 4, 2019

asbestos management program carnegie mellon university · 2020. 6. 17. · september 3, 2015...

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